Privacy Policy for Pacific Games LLC

Last Updated: March 12, 2025

Introduction and Scope
Pacific Games LLC (“Pacific Games”, “we”, “our”, or “us”) is committed to protecting your privacy. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you use any of our mobile applications or services. It applies to all current and future apps published by Pacific Games LLC, including but not limited to our wellness app Tappy: Self Care Fidgeter (“Tappy”) and our social app Link (collectively, the “Services”). By downloading or using any of our apps, you agree to the collection and use of information in accordance with this Privacy Policy.
We comply with applicable data protection laws, including the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the California Online Privacy Protection Act (CalOPPA), the Children's Online Privacy Protection Act (COPPA), and other relevant privacy laws. If you do not agree with our practices, please do not install or use our applications.

Information We Collect
Types of Data Collected: The information we collect depends on which app you use and how you interact with it. Generally, we may collect the following categories of data:

• Personal Information: Information that identifies you as an individual, such as your name, email address, username, or other account registration details. (For example, apps like Link that require an account may ask for your email and a username or display name.) In contrast, apps like Tappy do not require you to provide personal identifiers to use the core features.

• User-Provided Content: Any content or information you voluntarily enter into our apps. This might include journal entries, mood logs, or other wellness data in Tappy, or profile information and in-app communications in Link. Important: In apps like Tappy, this personal wellness content is stored locally on your device or in your private iCloud account and is not transmitted to Pacific Games servers. We do not have access to your individual journal or mood entries; they remain under your control.

• Device and Technical Data: Information about the device and app you use, such as your device model, operating system version, unique device identifiers (e.g., Device ID or Advertising ID), browser type (if using a web interface), language, region, and app version. We may also collect information about how your device interacts with our Services, including crash reports, performance data, and debug information.

• Usage Data: Data about your use of our apps, such as feature usage patterns, time spent, interaction events, and other statistical information. This information is generally collected in aggregate form and does not directly identify you. For example, we might track which features of Tappy are most used to help improve the user experience, or how often users play certain game levels in Link.

• Location Information: Our apps currently do not collect precise location data, unless explicitly stated and permitted by you. Some technical data like IP address may indirectly indicate a general location (e.g., city or country), which is used for analytics and fraud prevention. If any future app or feature intends to use precise location, we will ask for your permission first and explain what it will be used for.

• Contacts or Social Information: If an app has social features (such as adding friends or sharing content) and you choose to grant access to your contacts or link to a social media account, we will collect information necessary to provide that feature (e.g., friend list or social media username). At present, our apps do not integrate with your contacts or social media, but if we introduce such features, we will update this Policy and seek your consent where required.

App-Specific Data Practices: We strive to collect only the minimum data needed for each app's functionality.

• Link (Higher Data Collection): Link may require user registration or account creation for full functionality. This means Link could collect personal identifiers (like email, username, or profile avatar) and user-generated content (such as game progress, scores, or communications with other players). Link might also utilize online services for gameplay, so it can collect usage data and device identifiers to synchronize accounts, enable multiplayer features, or save your progress on our servers. If Link offers in-app social features (e.g., chat or friend lists), any information you share via those features will also be collected and stored to operate that service.

• Tappy (Minimal Data Collection): Tappy is designed to collect as little personal data as possible. You can use Tappy without creating an account or providing personal details. The wellness and journaling data you input in Tappy stays on your device and in your personal iCloud (if you use iCloud backup/sync). Pacific Games LLC does not have access to your personal notes, mood entries, or any health data you record in Tappy. The only data we may receive from Tappy are non-identifiable analytics (such as how often the app is opened, or error reports if the app crashes) to help us improve performance. Tappy does not send us your content or sensitive information.

How Information is Collected: We collect information in several ways:

• Directly from You: You may provide us information when you register an account, fill out a form, enter information into the app, request customer support, or communicate with us (for example, via email or in-app feedback forms).

• Automatically: Our apps may automatically collect certain technical and usage data as described above through analytics tools or built-in application frameworks. For instance, we might use Apple’s or Google's developer tools that automatically gather anonymized usage stats or crash reports.

• From Third Parties: If you choose to connect via a third-party account (for example, sign in with Apple or Google in Link), we receive information from that third party such as your name and email associated with that account. We treat this information as described in this Policy. Additionally, if we ever partner with third-party analytics or advertising providers, they may collect data subject to their own privacy policies (as explained in the Third-Party Advertising and Analytics section below).

We do not knowingly collect any sensitive personal information such as government ID numbers or financial information (purchases are handled by the app stores), or health/medical data beyond what you optionally input into our wellness apps for your personal use. We do not ask you to disclose any special categories of personal data (e.g., racial or ethnic origin, political opinions, religious beliefs) and request that you not share such data in our apps.

How We Use Your Information
We use the information we collect for the following purposes:

• To Provide and Maintain Services: We process your data to enable core app functionality. For example, personal info in Link is used to create and manage your account, while usage data in Tappy helps ensure the app features work correctly across different devices.

• To Improve and Personalize Our Apps: We analyze usage data and feedback to understand how our apps are used and to improve their design, content, and user experience. This helps us fix bugs, optimize performance, and develop new features. If an app offers personalized content (such as suggested exercises in Tappy or customized game experiences in Link), data is used to tailor those features to you.

• To Communicate with You: If you contact us or provide your contact information, we may use your email or other info to respond to inquiries, provide support, and send important administrative messages (like changes to our terms or this policy, security alerts, or app updates). We may also send you newsletters or marketing communications about new features or products if you have opted in to such messages. You can opt out of marketing emails at any time (see Your Rights and Choices below).

• To Facilitate In-App Features: For apps with social interaction or wellness tracking (e.g., saving progress, sharing achievements, or mood tracking in Tappy), the data you input is used to provide those features to you. For instance, Tappy may use your mood entries to display charts or progress to you, but this data remains private unless you choose to share it.

• For Analytics and Research: We may use aggregated, anonymized data about how users interact with our apps to conduct research on improving wellness outcomes (in the case of Tappy) or enhancing game design (in the case of Link). This data helps us understand trends and user needs on a broad scale without identifying individuals.

• To Ensure Security and Prevent Fraud: Information (especially technical and device data) is used to maintain the security of our applications, such as detecting and preventing malicious activity, cheating in games, or unauthorized access. We may also use data to verify user identity where necessary and to enforce our Terms & Conditions.

• To Comply with Legal Obligations: In certain cases, we may need to process and/or retain your information to comply with laws, regulations, or legal process (such as a court order or subpoena), or to respond to lawful requests by authorities. For example, keeping records of purchases or consents may be required by financial or privacy laws.

• With Your Consent: If we ever need to use your information for a purpose that is not compatible with the purposes listed above, we will ask for your consent. You have the right to withdraw your consent at any time (see Your Rights and Choices).

Legal Bases for Processing (GDPR)
If you are located in the European Economic Area (EEA) or United Kingdom, we rely on the following legal grounds under the GDPR for processing your personal data:

• Performance of a Contract: We process data to provide the services you have requested under our Terms & Conditions. For example, when you use our apps, we must process your data to deliver the app’s functionality (this is necessary for the performance of the contract between you and us).

• Consent: In cases where we ask for your consent to collect or use data (such as for sending marketing communications or enabling certain optional features), we will only process your data for those purposes if you have given consent. You can withdraw your consent at any time.

• Legitimate Interests: We may process your data for our legitimate business interests, such as improving our products, securing our systems, analyzing usage patterns, or communicating important updates. We will only rely on this ground after considering your rights and ensuring that our legitimate interests do not override your data protection interests or fundamental rights and freedoms.

• Legal Obligation: Where we have a legal duty to collect, use, or retain your information (for example, complying with tax, accounting, or reporting obligations), we will process data as necessary to fulfill those obligations.

• Protecting Vital Interests: In the unlikely event that processing is necessary to protect someone’s life or prevent serious harm, we could process personal data on this basis (though this is rare and would typically relate to emergency situations).
   

Data Sharing and Disclosure
We value your privacy and handle your data with care. We do not sell your personal information to third parties. However, we may share your information in the following situations, to the extent necessary for the purposes described:

• Service Providers: We may share data with third-party companies and individuals that provide services on our behalf (our “processors”). This includes services like cloud hosting (to store data or allow sync across devices), analytics providers (to help us understand app usage), crash reporting services, customer support tools, or similar operational services. These service providers are contractually obligated to handle data securely and only use it for the specific services we request.

• Affiliates: If Pacific Games LLC has affiliate companies (under common ownership or control), we may share information with them, but only in compliance with this Privacy Policy. Any affiliates would be required to honor the same privacy commitments.

• Legal Compliance and Protection: We may disclose information if required to do so by law or in response to valid legal requests (e.g., subpoenas, court orders, or government demands). We may also share information when we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to anyone’s safety, or violations of our terms and policies.

• Business Transfers: In the event Pacific Games LLC is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, user information may be transferred or disclosed as part of that transaction. We would transfer your data as an asset to the potential or actual successor organization. In such cases, we will ensure the receiving party agrees to respect your personal data in a manner consistent with this Privacy Policy. We will also notify you (for example, via email or a prominent notice on our website or in-app) of any change in ownership or use of your personal information, as well as any choices you may have regarding your personal data.

• With Your Consent: Apart from the cases above, we will share your personal information with companies, organizations, or individuals outside of Pacific Games LLC only when we have your explicit consent to do so. For instance, if you opt in to share your progress on a social media platform or send data to an integrated third-party app, we will do so only with your direction and consent.
   

Third-Party Advertising and Analytics
Currently, our apps do not display third-party ads and we keep user tracking to a minimum. However, we want to outline how we will handle advertising and analytics should we integrate them in the future, to remain transparent:

• Analytics Tools: We may use third-party analytics services (such as Google Analytics for Firebase, Apple Analytics, or similar tools) to collect and analyze usage information. These services may use tracking technologies (like app instance identifiers or cookies in a web context) to help us understand how you use our apps, so we can improve them. Any analytics data shared with third parties will be anonymized or aggregated whenever possible, and these analytics providers are not permitted to use the data for any purpose other than providing services to us.

• Advertising Partners: In the event we decide to offer a free ad-supported version of our apps or integrate ads for monetization, we may partner with advertising networks or partners (for example, Google AdMob or other ad networks). If we do so, those partners may collect device information and identifiers (such as your Advertising ID on Android or IDFA on iOS), IP address, and certain app usage information to provide you with relevant ads. They may employ cookies or similar tracking technologies to measure ad effectiveness or limit how many times you see an ad.

• User Consent for Ads: We will comply with privacy laws regarding advertising. For example, on iOS devices we will honor Apple’s App Tracking Transparency (ATT) framework by requesting your permission before enabling tracking for advertising purposes. If you decline, we will not share your data for targeted advertising on those devices. Similarly, if required (such as under GDPR in the EU), we will obtain your consent before using personal data for personalized ads. You will have the ability to withdraw consent or opt out of targeted advertising at any time through in-app settings or system settings.

• Opt-Out of Personalized Ads: Even if you initially consent, you can opt out of personalized advertising. You can typically do this by adjusting your device settings to limit ad tracking (such as selecting “Limit Ad Tracking” on iOS or “Opt out of Ads Personalization” on Android). You can also reset your mobile advertising identifier, which will disassociate past data from your device. If our apps provide an internal setting to disable personalized ads, we will provide instructions in the app or in an updated Privacy Policy.

• Third-Party Advertising Content: Please note that if ads are provided, they may contain links or content from third-party websites or services. Pacific Games LLC does not control the privacy practices of third-party advertisers. We encourage you to review the privacy policies of any third-party sites or services that you visit or interact with from within our apps.
   

External Links and Third-Party Services
Our apps or website may occasionally contain links to third-party websites, products, or services (for example, a link to an article, a social media page, or an external resource). This Privacy Policy does not apply to information collected on any third-party site or service that you access through those links. We are not responsible for the privacy practices or content of third-party services.
If you leave our app via an external link or engage with a third-party service (including using a third-party login method for our app), the third party's terms and privacy policy will apply to any data processed by that third party. We recommend you review the privacy policies of those services before providing any personal information or using their features.
Data Security
We take reasonable and appropriate measures to protect your personal information from unauthorized access, loss, misuse, or alteration. These measures include:

• Encryption & Secure Transmission: We use modern security protocols (such as HTTPS/TLS) to encrypt data in transit between your device and our servers. For apps that store data in the cloud (like Tappy using Apple's iCloud), we rely on those platforms' encryption and security features. Any sensitive operations are transmitted securely.

• Secure Storage: Personal data that we do store is kept on servers with strong security protections. For example, databases are encrypted at rest where applicable and housed in secure facilities. Access to these systems is limited to authorized personnel with security credentials.

• Access Controls: Pacific Games LLC restricts internal access to personal data. Only employees, contractors, and agents who need the information to operate, develop, or improve our Services are granted access, and they are subject to strict confidentiality obligations.

• Testing and Safeguards: We regularly update and maintain our applications with security in mind. We use industry best practices for coding and testing to reduce vulnerabilities. Security features (like Face ID/Touch ID locking in Tappy for your journal entries) are offered to help you keep your data safe on your device.

• No Guarantee: Despite our efforts, please understand that no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to protect your personal data, we cannot guarantee absolute security. In the event of a security breach that affects your personal information, we will notify you and the appropriate authorities as required by law.
   

Data Retention
We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Policy, and as required or permitted by law:

• If you create an account in one of our apps (e.g., Link), we will retain your account information and data for as long as your account is active or as needed to provide you services. If you decide to delete your account or request deletion of your data, we will delete or anonymize your personal information within a reasonable timeframe, except to the extent we need to retain it for legal obligations or dispute resolution.

• For apps that do not require accounts (e.g., Tappy), the personal content you create is stored on your own device/iCloud and not on our servers. Pacific Games LLC does not retain this personal content. Any incidental analytical or technical data that we collect (e.g., crash logs or anonymous usage stats) may be retained in our analytics records for internal analysis. We generally keep such data in aggregate form without personal identifiers.

• We will also retain and use your information as necessary to comply with our legal obligations (for example, we may keep records of purchases or transactions as required by tax laws), resolve disputes, and enforce our agreements. When we have no ongoing legitimate business need or legal requirement to retain your personal information, we will delete it or anonymize it from our systems.
   

Your Rights and Choices
You have rights and choices regarding your personal data. Pacific Games LLC is committed to honoring your rights under applicable privacy laws:

• Access and Portability: You have the right to request a copy of the personal information we hold about you, and to receive it in a common portable format. This allows you to verify the information and to move it to another service if you wish.

• Correction (Rectification): If any of your personal information that we have is inaccurate or incomplete, you have the right to request that we correct or update it. You can also correct certain information yourself within the app if that feature is available (for example, you may edit your profile details in Link).

• Deletion (Right to be Forgotten): You have the right to request that we delete the personal data we have collected from you. For example, you can ask us to delete your account and associated data. Do note that we may retain some information as required by law or for legitimate purposes (as described in Data Retention above), but we will inform you if that is the case. In apps like Tappy, you can delete your own content at any time (and because we don't store it on our servers, deleting the app or your entries effectively removes it from our control).

• Restriction of Processing: You can ask us to restrict or suspend the processing of your personal information in certain circumstances, such as if you contest the accuracy of the data or object to us processing it. When processing is restricted, your data will only be stored but not actively used until the restriction is resolved.

• Objection to Processing: You have the right to object to our processing of your personal information in certain cases. In particular, you can object to processing that is based on our legitimate interests, and we will cease processing your information unless we have compelling legitimate grounds or it is needed for legal reasons. You also have the right to object at any time if we were to process your data for direct marketing purposes (currently, we do not use your data for third-party marketing; and if you receive our optional newsletter, you can unsubscribe at any time).

• Withdraw Consent: If we are processing your personal data based on your consent, you have the right to withdraw consent at any time. For instance, if you consented to receive wellness tips via email, you can opt out later. Withdrawal of consent will not affect the lawfulness of any processing we conducted prior to your withdrawal.

• California Privacy Rights: If you are a California resident, you have specific rights under the CCPA (California Consumer Privacy Act) in addition to those listed above. These include the right to know the categories of personal information we have collected about you, the sources of that information, the business purpose for collecting it, and the categories of third parties with whom we share it. You also have the right to know what personal information we have disclosed for a business purpose and to whom. You have the right to request deletion of your personal information and the right to opt out of the sale of your personal information. As stated above, Pacific Games LLC does not sell your personal information. If that ever changes, we will provide a clear method for you to opt out. California residents also have the right not to receive discriminatory treatment for exercising their privacy rights.

• Children’s Privacy Rights: As noted in the Children's Privacy section below, if you are a parent or guardian of a child under 13 (or under 16 in certain jurisdictions) and believe we have inadvertently collected personal information from that child, you have the right to request that the information be deleted. We will promptly remove any such data from our records in compliance with COPPA and similar laws.

To exercise any of your rights above, please contact us at cameron@pacific.dev. We may need to verify your identity (for example, by asking you to provide information associated with your account or usage) before fulfilling your request, to ensure we do not disclose data to the wrong person. We will respond to your request within the timeframe required by the applicable law (for example, within 30 days for GDPR requests and 45 days for CCPA requests, with the possibility of a reasonable extension if needed, of which we will inform you). In certain cases, if your request is complex or if we have many requests, we may extend the response deadline as permitted by law, but we will notify you of the extension and the reason.

Opt-Out Options: In addition to the rights above, you have the following choices to manage your privacy:

• Opt-Out of Marketing Communications: If you have subscribed to any newsletter or promotional communications from us, you can opt out at any time by clicking the "unsubscribe" link in those emails or by contacting us at cameron@pacific.dev with your request. Please note that you will still receive transactional or administrative messages from us (such as support responses or important account updates) even if you opt out of marketing emails.

• Push Notifications: With your consent, some of our apps may send push notifications or alerts to your device (for example, a daily wellness reminder from Tappy or a notification of a friend request in Link). If you no longer wish to receive these notifications, you can disable them at the device level in your settings.

• Device Permissions: Most mobile platforms (iOS, Android, etc.) have permission systems for specific types of device data or features, such as camera access, microphone, contacts, or location. You can choose to grant or deny these permissions. If you initially grant permission and later change your mind, you can revoke permission through your device settings. Note that some features of our apps may not function properly without the relevant permissions (for example, a social feature might not work without camera or contacts access, if such features are introduced).

• Analytics and Tracking Controls: As mentioned in the Third-Party Advertising and Analytics section, you can limit the collection of data for analytics or advertising purposes by adjusting settings on your device (such as resetting your advertising ID or enabling Do-Not-Track features where available). Additionally, if our apps provide an in-app setting to disable certain analytics or tracking, we will honor your choice.

Children's Privacy (COPPA)
Our Services are not intended for children under the age of 13, and we do not knowingly collect or solicit personal information from children under 13. (For users in the European Union or other regions with a different age of consent, we do not knowingly collect personal information from children under 16 without verifiable parental consent.)
In compliance with the U.S. Children’s Online Privacy Protection Act (COPPA), if we learn that we have inadvertently collected personal information from a child under 13 without parental consent, we will take immediate steps to delete that information from our records. If you are a parent or guardian and discover that your child under 13 has provided personal data to us, please contact us at cameron@pacific.dev so we can delete the child’s information.
Some of our apps may have content suitable for a general audience (for example, Tappy is rated 4+ in app stores for its content), but even so, we do not target our Services at children and we do not knowingly collect their personal data. We encourage parents and guardians to supervise their children’s use of our apps and to teach their children never to share personal information without permission.

International Data Transfers
Pacific Games LLC is based in the United States, and the majority of our development and server infrastructure is likely located in the U.S. or other jurisdictions. If you are using our Services from outside the United States, be aware that your information (including personal data) may be transferred to, stored, or processed in the United States or other countries where our servers or our service providers are located. These countries may have data protection laws that are different from those of your country of residence and, in some cases, may not be as protective.
However, we take steps to ensure that adequate safeguards are in place when we transfer personal data internationally. For example, for users in the EEA or UK, if we transfer personal data out of Europe, we will rely on legal transfer mechanisms such as Standard Contractual Clauses (SCCs) or other approved methods to ensure your data is protected according to EU/UK standards. By using our apps or providing us with information, you consent to the transfer of your data to the U.S. and other jurisdictions as described in this Policy.
We will also ensure that any third-party partners receiving your information are bound by privacy obligations consistent with this Policy and applicable laws, regardless of where they are located.
Changes to This Privacy Policy
We may update or modify this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes to this Policy, we will update the "Last Updated" date at the top of the policy. In some cases, we may provide additional notice of significant changes, such as via an in-app notification or by posting a notice on our website or sending an email (if we have your email on file).
We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting the personal information we collect. Your continued use of our apps after any changes to this Policy will signify your acceptance of the updated terms.
Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: cameron@pacific.dev

• Website: www.pacific.dev (you may find contact forms or further information here)

We will do our best to address your inquiry promptly and thoroughly. Your privacy is important to us, and we welcome your feedback.