Privacy Policy

Last updated: May 10, 2026

At a glance

• We collect only what we need to make our apps and website work.
• We do not sell your personal information, and we do not share it for cross-context behavioral advertising.
• Apps we publish for children — including any app listed in Apple's Kids category or Google Play's Designed for Families program — are subject to additional safeguards described in Section 9.
• We do not show behavioral or interest-based advertising to children, and our child-directed apps do not use third-party SDKs unless those SDKs have self-certified compliance with COPPA and the relevant families program.
• You can email info@trelven.com at any time to access, correct, or delete your information — or, if you're a parent, to act on your child's behalf.

1. Introduction

Trelven LLC ("Trelven," "we," "us," or "our") operates the website trelven.com and the mobile and web applications we publish (collectively, the "Services"). This Privacy Policy explains what information we collect, how we use it, when we share it, and the choices you have. It applies to all of our Services unless a specific Service has its own published privacy notice that supplements or replaces parts of this one.

Each app we publish also includes a data-safety disclosure on its App Store and Google Play listing (see Section 16) that summarizes the specific data that app collects. Read those alongside this policy.

2. Information We Collect

2.1 Information you provide

• Account information — if a Service requires an account, we collect identifiers you provide such as name, email address, and authentication credentials.
• Communications — when you email us, use a contact form, or otherwise contact us, we receive what you send.
• User content — content you create or upload inside a Service, where applicable to that Service's features.
• Payment information — purchases are processed by the App Store, Google Play, or another payment processor. We do not receive your full card number; we receive transaction confirmations and limited metadata needed to honor the purchase (see Section 11).

2.2 Information we collect automatically

• Device and usage data — device type, operating system version, app version, language, time zone, the date and time of activity, and pseudonymous app-event metrics used to operate and improve the Services.
• Crash and diagnostic reports — if a Service crashes or hits an error, we receive diagnostic information (e.g., stack trace, OS version, the device model). Crash reports are limited to information needed to diagnose the issue.
• Approximate location — your IP-based approximate location (typically city/country) may be inferred to provide region-appropriate content, currency, or compliance with local law. We do not collect precise (GPS) location unless a Service feature requires it and you opt in via your device's permission prompt.
• Identifiers — subject to your platform-level permissions, we may use a per-device identifier (e.g., Apple's IDFV, Android's Advertising ID) only as needed to run the Services. In apps directed to children, we do not use device identifiers for advertising or cross-app tracking. On Apple platforms we comply with App Tracking Transparency ("ATT") and will not access the IDFA for tracking unless you grant permission via the system ATT prompt (see Section 10).
• Cookies and local storage (website) — our website may use a small amount of local storage for essential functionality. We do not set cross-site tracking cookies (see Section 14).

2.3 Information from third parties

If you sign in through a third-party identity provider (such as Apple or Google), we receive the limited profile information that provider shares with us, in accordance with the permissions you grant them.

3. How We Use Information

We use information to:

• Provide, maintain, and improve the Services.
• Respond to your requests, questions, and support inquiries.
• Monitor and analyze usage, performance, and security.
• Detect, investigate, and prevent fraud, abuse, and unauthorized activity.
• Process payments, subscriptions, and refunds (through the relevant store).
• Comply with legal obligations and enforce our Terms of Use.

We do not sell your personal information, and we do not "share" it for cross-context behavioral advertising (as those terms are defined under U.S. state privacy laws).

4. Legal Bases for Processing (EEA / UK)

If you are in the EEA, UK, or another jurisdiction where data-protection law requires a legal basis, we rely on the following:

• Performance of a contract — to provide the Services you request.
• Legitimate interests — to improve the Services, keep them secure, and prevent abuse, balanced against your rights and freedoms.
• Consent — where required (e.g., for certain analytics, the ATT identifier on iOS, marketing communications, or sensitive data).
• Legal obligation — to comply with applicable laws.

You may withdraw consent at any time where processing is based on consent. Withdrawing consent does not affect the lawfulness of processing already carried out.

5. How We Share Information

We share information only in the limited circumstances below:

• Service providers (subprocessors) — vendors that process data on our behalf (for example, cloud hosting, crash reporting, analytics, customer support, and email delivery) under written contracts that require them to use the data only to provide services to us, to keep it confidential, and to protect it consistent with this policy. For apps directed to children, we restrict service providers to those that have self-certified compliance with COPPA and the relevant families program.
• Legal and safety — when required by law, valid legal process, or to protect the rights, property, or safety of Trelven, our users, or others.
• Business transfers — in connection with a merger, acquisition, financing, or sale of assets. Any successor will be bound by this policy or one that provides equivalent protections.
• With your consent — for any other purpose disclosed at the time and with your permission.

A current list of significant subprocessors is available on request at info@trelven.com.

6. Data Security

We use administrative, technical, and physical safeguards designed to protect information, including encryption in transit (HTTPS/TLS), access controls on production systems, security review of code changes, and periodic review of our practices. No method of transmission or storage is perfectly secure, however, and we cannot guarantee absolute security.

7. Data Retention

We retain personal information only as long as we need it. Specific windows:

• Account data — retained while your account is active, and deleted within 30 days of an account-deletion request, except where retention is required by law.
• Children's account data (where any exists) — same 30-day deletion window on parental request; see Section 9.
• Crash and diagnostic logs — up to 90 days.
• Support emails — up to 2 years, then deleted.
• Anonymous or aggregated data — may be retained indefinitely, as it no longer identifies you.

8. Children's Privacy

This section is the most important part of this policy for parents and for users of our children's apps. We design our products with the recognition that some users are children, and for our forthcoming kids gaming apps the primary users will be children. We comply with the U.S. Children's Online Privacy Protection Act ("COPPA"), Article 8 of the EU GDPR (and the equivalent UK-GDPR provisions for children under the digital age of consent), Apple's App Store Review Guidelines for the Kids category, and Google Play's Designed for Families and Families Ads & Monetization policies.

8.1 Apps directed to children

Each Trelven app's App Store and Google Play listing — and its in-app first-run notice — clearly indicate whether the app is directed to children. An app is "directed to children" if it is published in Apple's Kids category, listed in Google Play's Designed for Families program, or otherwise principally intended for users under the relevant age threshold (under 13 in the U.S., or the equivalent local age elsewhere). The safeguards in this section apply to all such apps.

8.2 What we collect from children

For apps directed to children, we strictly limit data collection to what is necessary to support the internal operation of the app (within the meaning of the COPPA Rule's "support for the internal operations" exception):

• Pseudonymous device-level identifiers used only for internal operations such as crash reporting, frequency-capping of in-app messages, and maintaining session continuity.
• Game-state data (progress, scores, settings) stored on the device by default. Server-side backup or cross-device sync is only enabled where a verifiable parental consent flow has been completed.
• Aggregate usage counts that do not identify the user (e.g., total sessions, average level reached).

We do not knowingly collect any of the following from a child without verifiable parental consent: real name, email address, phone number, postal address, contact list, photos, videos, microphone audio, camera input, precise location, persistent identifiers used for behavioral advertising, social-network identifiers, or any other personal information beyond what's permitted by COPPA's internal-operations exception.

8.3 No behavioral advertising to children

Apps directed to children do not show behavioral, interest-based, or remarketing advertising. If an app directed to children displays advertising at all, it will be limited to contextual ads served by ad networks that have self-certified compliance with COPPA, Apple's Kids category rules, and Google Play's Families Ads & Monetization policy, and that do not collect or use persistent identifiers from children for advertising or cross-app tracking.

8.4 Third-party SDKs in children's apps

We restrict third-party SDKs in apps directed to children to those that have self-certified compliance with COPPA and the relevant families program, and that operate in a child-safe configuration. We disclose all such SDKs in each app's App Store data-safety / app privacy disclosure and Google Play data-safety form.

8.5 Verifiable parental consent

Where a feature in a children's app would otherwise require us to collect personal information beyond what COPPA's internal-operations exception allows, we either (a) do not enable that feature, or (b) gate it behind a verifiable parental-consent flow at the point of collection. Where we use a neutral age-screen, users under the applicable age threshold are routed to a children's experience that complies with this section.

8.6 Parental rights

As a parent or legal guardian, you have the right to:

• Review the personal information (if any) we have collected from your child.
• Direct us to delete that information.
• Refuse further collection or use of your child's information.
• Withdraw consent you previously gave.

To exercise any of these rights, email info@trelven.com with the subject line "Parental request" and include the app name, your child's in-app username or account identifier (if any), and what you'd like us to do. We respond within 30 days. To verify the request, we may ask you to confirm information only a parent would reasonably know.

8.7 Communication and social features

Our children's apps do not include open chat, user-to-user messaging, or unmoderated user-generated-content features. Any social features present (e.g., leaderboards) are limited and use pseudonymous identifiers chosen from a pre-approved word list.

8.8 In-app purchases in children's apps

Where in-app purchases exist in a children's app, they are placed behind a parental gate consistent with App Store and Google Play requirements, so a child cannot complete a purchase without an adult's interaction.

8.9 Reports about a child

If you believe a child under 13 (or under the applicable local age) has provided us with personal information in a Service not directed to children, please email info@trelven.com and we will promptly investigate and delete it.

9. Advertising, Analytics, and Tracking

9.1 In our adult Services and on the website

We use a limited set of analytics tools (e.g., aggregated event counts and crash reports) to understand how features are used and to fix bugs. If an adult Service shows advertising, the app's privacy notice will identify the ad networks involved. We do not engage in cross-context behavioral advertising.

9.2 App Tracking Transparency (Apple platforms)

On Apple platforms we comply with App Tracking Transparency: we do not access the IDFA for cross-app or cross-website tracking unless you grant permission via the system ATT prompt. Declining the prompt does not affect your ability to use the Service.

9.3 In our children's apps

See Section 8 — no behavioral advertising; analytics is limited to non-personal aggregate measures used only for internal operations.

9.4 Do Not Track and Global Privacy Control

Our website recognizes the Global Privacy Control ("GPC") browser signal as an opt-out request where applicable state laws require it. Because we do not sell personal information or share it for cross-context behavioral advertising, the practical effect of GPC is a recorded opt-out for those purposes. We do not respond to the legacy "Do Not Track" header, which has no agreed standard interpretation.

10. Push Notifications

If you grant permission, a Service may send you push notifications. You can revoke this at any time in your device or browser settings. Children's apps do not send marketing push notifications.

11. In-App Purchases and Subscriptions

Purchases are processed by the platform store (Apple App Store or Google Play), and refund and subscription management is handled by the relevant store. We receive transaction confirmations and limited associated metadata. In apps directed to children, all in-app purchases are gated behind a parental confirmation step as required by the App Store / Google Play.

12. Your Privacy Rights

Depending on where you live, you may have the right to:

• Access the personal information we hold about you.
• Correct inaccurate information.
• Delete your personal information.
• Receive a copy of your information in a portable format.
• Object to or restrict certain processing.
• Withdraw consent where processing is based on consent.
• Opt out of "sale" or "sharing" of personal information as those terms are defined by U.S. state privacy laws (we do not engage in either).
• Not be discriminated against for exercising your rights.

12.1 California residents (CCPA / CPRA)

California residents have the rights listed above and the right to know what categories of personal information we have collected, the sources of that information, the purposes for collecting it, and the categories of third parties with whom we share it. We do not sell personal information and we do not share it for cross-context behavioral advertising. To exercise these rights, email info@trelven.com. We will not discriminate against you for exercising any right.

12.2 Other U.S. states

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Montana (MCDPA), and other states with comprehensive privacy laws have rights similar to those listed above. To exercise them, email info@trelven.com. Where state law provides a right to appeal a denied request, you may appeal by replying to our decision; we will respond within the time required by that state's law.

12.3 EU / EEA / UK residents (GDPR / UK-GDPR)

You have the rights listed above plus the right to lodge a complaint with your local data-protection authority. Our point of contact for privacy matters, and our representative where one is required, can be reached at info@trelven.com.

12.4 Verifying requests

We need to confirm your identity before honoring most requests. For an account holder we typically verify via the email address on the account. For parental requests on a child's behalf, see Section 8.6.

13. International Data Transfers

We are based in the United States. If you access the Services from outside the U.S., your information may be transferred to, stored, and processed in the U.S. or other countries where our service providers operate. Where required, we use appropriate safeguards for international transfers (such as the European Commission's Standard Contractual Clauses with the UK Addendum where applicable).

14. Cookies and Web Storage

Our website may use cookies and similar technologies for essential functionality and a small amount of aggregate usage measurement. You can disable cookies in your browser settings; some site features may be affected. We do not set cross-site tracking cookies, and we do not use cookies on pages aimed at children.

15. Account Deletion

You can request account deletion at any time. The simplest way is to use the in-app Settings → Account → Delete Account control in any Service that has an account, or to email support@trelven.com from the address tied to the account with the subject line "Delete my account." Step-by-step instructions are also on our Support page. We complete deletion within 30 days.

16. App Store and Google Play Disclosures

Each app we publish includes:

• An App Privacy disclosure on its App Store page describing the data the app collects, the purposes, and whether it is linked to you or used to track you.
• A Data Safety disclosure on its Google Play page describing data collection, sharing, security practices, and whether data is encrypted in transit and at rest.
• Where the app is in Apple's Kids category or Google Play's Designed for Families program, the additional disclosures required by those programs.

Those listings should be read alongside this Privacy Policy. Where an app-specific in-app notice conflicts with this policy, the in-app notice controls for that app.

17. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date above. For material changes we will provide additional notice through the Services or by email where appropriate. Continued use of the Services after an update constitutes acceptance of the revised policy.

18. Contact Us

Questions about this policy, privacy rights requests, or parental requests:

Trelven LLC
General & privacy: info@trelven.com
Account / support: support@trelven.com

For parental requests regarding a child's information, please use the subject line "Parental request" so we can route the message promptly.