Privacy Policy
Effective Date: August 11, 2026
This Privacy Policy (the "Policy") applies to the collection, use, storage, and sharing of personal information by Shearwater Data LLC ("we," "us," or the "Company") through its official website (https://www.shearwatergames.com) and related services. This Policy strictly complies with the requirements of the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), and the California Online Privacy Protection Act (CalOPPA), and is intended to protect the privacy rights of California residents ("you").
I. Scope and Purposes of Information Collection
1. Information Actively Collected
Device and Behavioral Data: IP address, browser type, device model, operating system, browsing history, clickstream data, page dwell time, and geographic location (with your authorization).
App Information and Performance:
Crash Logs – We collect application crash log data, such as the number of app crashes, stack traces, memory status, thread information, crash rate statistics, and high-frequency crash scenarios.
Diagnostic Information – We collect performance metrics related to user experience (such as smoothness, responsiveness, and resource consumption), for example, battery life, loading time, latency, frame rate, or technical diagnostic information.
Other App Performance Data – We collect macro-level data such as long-term trends and user behavior correlations (e.g., daily crash rate changes, weekly lag counts), which may be correlated with multi-dimensional data such as user behavior, device characteristics, and system environment.
App Activity – Installed applications.
2. Information Passively Collected
Technical data is automatically collected through local storage (such as browser cache), including session IDs, advertising identifiers (such as IDFA), and device advertising IDs.
3. Purposes of Information Collection
To provide, maintain, and optimize website services (such as user registration and content access);
To send marketing communications (subject to prior consent or compliance with the CCPA "opt-out" rules);
To ensure website security, prevent fraud, and reduce abuse;
To fulfill legal obligations (such as tax reporting and court subpoenas);
To conduct internal research for product and service improvement (the use of anonymous data requires separate authorization).
II. Information Sharing and Disclosure
1. Data Sales and the Right to Opt Out
Under the CCPA, you have the right to opt out of the sale of your personal information at any time through the "Do Not Sell My Personal Information" link. We are committed to not discriminating against you for exercising this right, including refusing service or raising prices. "Sale" includes the exchange of personal information for monetary or other consideration, including targeted advertising partnerships.
2. Processing of Sensitive Personal Information
The collection, use, or sharing of sensitive personal information requires your explicit consent. Unless explicitly authorized, we will not use sensitive information for advertising purposes.
III. Consumer Rights and How to Exercise Them
1. Right to Access
You have the right to request, free of charge, up to twice per year, the categories of personal information collected in the past 12 months, the specific pieces of information, the sources, the business purposes, and the list of third parties with whom it was shared. Responses will be provided within 45 days, extendable to 90 days upon written notice.
2. Right to Delete
You may request deletion of the personal information collected. We will complete the deletion within 15 business days (excluding statutory retention periods) and notify third parties to cease using the information.
3. Right to Correct
If you find that the information is inaccurate or incomplete, you may submit a correction request, and we will verify and update it.
4. Right to Restrict Processing
Under certain circumstances (for example, during an abuse complaint), you may request that the processing of your personal information be suspended.
5. Right to Data Portability
You have the right to obtain a copy of your personal information in a structured, commonly used, and machine-readable format so that it can be transferred to another service provider.
6. How to Exercise These Rights
Submit a request through the "Privacy Center" on the website, send an email to [email protected], or write to:
Shearwater Data LLC
Attn: Privacy Officer
4407 Yardarm Ct, Soquel, CA 95073 US
Requests must include your name, contact information, the specific right you are asserting, and details. Identity verification may require proof of identity (notarization required for sensitive requests).
IV. Data Security Measures
1. Technical and Organizational Safeguards
Sensitive data is stored using AES-256 encryption and transmitted using TLS 1.3;
Access controls (role-based permissions), multi-factor authentication, regular security audits, and penetration testing are implemented;
Employees receive annual privacy and security training and sign confidentiality agreements;
An incident response plan is maintained, with notification to affected users of data breaches within 72 hours.
2. Data Minimization and Retention
We collect only the minimum data necessary to achieve the purposes of collection and regularly purge outdated information. Personal information will not be retained longer than necessary to fulfill the purposes of collection, unless required by law (for example, tax records are retained for 7 years).
V. Children's Privacy Protection
We do not knowingly collect personal information from children under the age of 13. If we discover information about a user under 13, it will be deleted immediately, and the account will be terminated. Parents or guardians in California may contact us to request deletion of a minor's information.
VII. Policy Updates and Notifications
This Policy is reviewed at least every 12 months. Material changes (such as an expansion of the scope of information use or new third-party sharing) will be announced at least 30 days in advance through website notifications, email, or prominent pop-up announcements.
VIII. Contact Us
If you have any questions about this Policy or our privacy practices, please contact:
Email: [email protected]
Phone: 1-971-363-5655 (Monday to Friday, 9:00 AM to 5:00 PM Pacific Standard Time)
This Policy is governed by the laws of the State of California, and all interpretations are reserved by Shearwater Data LLC.
