We respect your privacy and aim to collect and store only the information necessary to provide FAZAN, manage user accounts and subscriptions, enable online gameplay, maintain game progress and statistics, and provide account recovery and notifications.

This Privacy Policy explains what information FAZAN processes, why it is used, where it is stored, and what happens when you delete your account.

FAZAN is designed to require minimal personal information.

We do not require you to provide:

Your username:

• must be unique;
• is visible to other FAZAN users during online features; and
• does not need to be your real name.

Please avoid choosing a username containing personal information that you do not wish to make public.

When an account is registered, FAZAN also creates a random Account ID. The Account ID is used to identify and recover your FAZAN account and to authenticate your account on another device.

You should keep your Account ID secure.

2. Account and game information stored by FAZAN

FAZAN may store the following information in connection with your account:

• username;
• Account ID;
• subscription authenticator or purchase credential;
• subscription duration;
• subscription expiry information;
• subscription renewal status;
• highest game level unlocked;
• number of offline games played and won;
• number of online games played and won; and
• registered device information used for app functionality and notifications.

Registered device information may include:

• device/platform type;
• platform;
• Firebase Installation ID, Firebase Cloud Messaging registration token, or similar device identifier; and
• the date or time when the device registration was updated.

This information is used only as necessary to operate FAZAN and its account, subscription, gameplay, recovery and notification features.

3. Subscription and payment information

Subscriptions are processed through the payment service appropriate to the platform on which the subscription is purchased, including:

• Apple App Store / StoreKit on iOS;
• Google Play Billing on Android; and
• PayPal for supported desktop versions.

FAZAN may receive and store a purchase token, receipt, subscription identifier, authenticator or similar credential required to validate and manage the subscription.

FAZAN does not require users to provide payment-card details directly to FAZAN. Payment information such as card or bank details is handled by the relevant payment provider according to that provider’s own terms and privacy practices.

4. Gameplay words and word history

Valid words used during gameplay are stored locally on participating users’ devices for FAZAN’s word-history functionality.

A user’s own words are stored locally on that user’s device so that the user can view their previously played words.

Valid words played by other participants in an online game are also stored locally on participating users’ devices. These words are stored without being linked to the username or identity of the player who submitted them.

For example, another participant’s device may retain a word that was used during a game, but the local word-history record does not identify which player entered that word.

During online games, words are transmitted through the FAZAN server as necessary to operate the multiplayer game. FAZAN does not permanently store users’ played-word histories on its server.

5. Other information stored locally on your device

FAZAN stores some information locally on your device to provide game functionality and preferences.

This may include:

• offline played-word history;
• online played-word history;
• words encountered from other online players;
• level word history;
• FAZAN friends identified by their usernames;
• blocked users;
• game timers;
• invitation timer;
• game mode;
• theme settings; and
• colour palette settings.

Friends and blocked-user information is maintained locally on the user’s device and is not stored as a persistent social relationship on the FAZAN server.

FAZAN also includes encrypted game lexicons required for gameplay. These lexicons are application resources and are not user account data.

6. Online gameplay and temporary session information

When you use online multiplayer features, FAZAN temporarily processes information required to operate the current session, including your username, language, connection state, invitations, game participation and game events.

Online invitations and active game-session information are used for the current session and are not maintained by FAZAN as permanent account records after they are no longer required for the session.

FAZAN does not maintain a permanent server-side database of friendships or blocked-user relationships.

Abuse reports

If you use FAZAN’s reporting functionality, FAZAN may process and retain information contained in the report, including the reported username, the reason for the report and any optional information submitted with it.

Reports may be retained where reasonably necessary to investigate abuse, identify patterns of repeated or serious complaints, protect users and the service, and enforce the FAZAN Terms of Use.

Because FAZAN does not permanently retain complete game-session or played-word histories on its server, we may not always be able to independently verify every event described in a report.

7. Push notifications and device registration

If notification functionality is enabled, FAZAN may process device identifiers required to send notifications.

FAZAN uses Firebase-related device registration information for this purpose, which may include a Firebase Installation ID, Firebase Cloud Messaging registration token, or similar identifier required to address notifications to an app installation. Firebase uses such identifiers to identify app instances for message delivery.

Device registration information associated with your FAZAN account is removed when your account is deleted.

Your device operating system may also provide controls allowing you to enable or disable notifications.

8. How we use information

Information processed by FAZAN is used for purposes including:

• creating and maintaining your FAZAN account;
• identifying your account;
• validating subscriptions;
• restoring or recovering account access;
• authenticating your account on another device;
• operating online multiplayer games;
• displaying users participating in online functionality;
• maintaining game progress and statistics;
• providing local word-history features;
• maintaining friends and blocked-user preferences locally;
• sending relevant app/game notifications;
• preventing misuse and maintaining the reliability and security of the service; and
• providing customer support where necessary.
• reviewing abuse reports and enforcing the FAZAN Terms of Use where reasonably necessary;

FAZAN does not use your information to build advertising profiles.

FAZAN does not require your real name, email address or password in order to create a FAZAN account.

9. Legal bases for processing

Where applicable under data-protection law, we process personal data on one or more of the following legal bases:

• performance of a contract, where processing is necessary to create and operate your FAZAN account, provide gameplay functionality, manage subscriptions or provide other features you request;
• legitimate interests, where processing is reasonably necessary to maintain the security, reliability and integrity of FAZAN, prevent misuse or fraud, and improve or support operation of the service;
• compliance with legal obligations, where we are required to retain or process information under applicable law; and
• consent, where applicable and where consent is required by law, for example for certain optional device or notification functionality.

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

10. Sharing and service providers

FAZAN uses third-party services where necessary to provide subscriptions, device services and notifications.

These may include:

• Apple;
• Google;
• Firebase; and
• PayPal.

Information is transmitted to these providers only as necessary for the relevant service, such as processing or validating a subscription, restoring a purchase, operating platform services or delivering notifications.

These third-party services process information according to their own privacy policies and applicable contractual and legal requirements.

FAZAN does not sell users’ personal information to advertisers or data brokers.

11. International data transfers

FAZAN’s primary server infrastructure is hosted in an AWS region within the European Economic Area. Some third-party service providers used by FAZAN may nevertheless process information outside the European Economic Area or outside the country in which you live.

Some service providers used by FAZAN may process information in countries outside the European Economic Area or outside the country in which you live.

Where personal data is transferred internationally, we rely on safeguards required or recognised under applicable data-protection law, where relevant. These may include adequacy decisions, approved contractual safeguards or other legally permitted transfer mechanisms.

Information processed directly by Apple, Google, Firebase or PayPal may also be subject to the international-transfer arrangements described in those providers’ respective privacy policies.

12. Data retention

Account information is retained while the FAZAN account exists and as necessary to provide the service.

Temporary online-game and invitation information is retained only as necessary to operate the relevant session.

Words transmitted during online gameplay are not retained by FAZAN as permanent server-side player-word histories.

Local game-history and account-related information remains on the user’s device until it is cleared by the app, the account is deleted, the app’s local data is removed, or the application is uninstalled, subject to the behaviour of the operating system.

Information that must be retained to comply with applicable legal, accounting, payment, fraud-prevention or dispute-resolution obligations may be retained for the period required by law or reasonably necessary for those purposes.

13. Account deletion

You can initiate permanent deletion of your FAZAN account directly from the Account screen in the application by selecting Delete account and confirming the deletion.

You may also request deletion of your FAZAN account through the FAZAN Delete Account page on the KAIROS DIGITAL website. This web option allows you to request deletion even if you no longer have access to the application.

Deleting your account removes the account and its associated server-side FAZAN information, including:

• username;
• Account ID;
• subscription/account information stored by FAZAN;
• game statistics;
• game progress; and
• registered device information associated with the account.

FAZAN also clears account-related local information on the device from which the deletion is performed, including locally stored user game-history, friends and blocked-user information.

Words previously encountered during multiplayer games may remain in another participant’s local word-history file. Such words are stored without being linked to the username or identity of the player who originally submitted them.

Account deletion is permanent and the deleted FAZAN account cannot subsequently be recovered.

Deleting your FAZAN account does not necessarily cancel an active subscription managed through Apple, Google or PayPal. Subscription cancellation is handled through the applicable payment provider. FAZAN provides access to the relevant subscription-management mechanism from the Account screen.

Certain information may be retained after account deletion where retention is required by applicable law or reasonably necessary for purposes such as legal compliance, accounting, payment records, fraud prevention or dispute resolution. Where applicable, such information will be retained only for as long as necessary for those purposes.

14. Account recovery and authentication on another device

FAZAN provides an Account ID when an account is created.

The Account ID can be used for account recovery and for authentication on another device.

Because FAZAN does not require an email address or password, you should keep your Account ID secure. Losing access to information required for account recovery may prevent FAZAN from restoring an account in some circumstances.

15. Security

We take reasonable technical and organisational measures intended to protect information processed by FAZAN against unauthorised access, alteration, loss or disclosure.

No electronic transmission or storage method can provide absolute security, but FAZAN is designed to minimise the amount of account information required from users.

16. Your privacy rights

Depending on where you live, applicable privacy law may give you rights relating to your personal data, including rights to:

• obtain information about how your data is processed;
• request access to personal data associated with you;
• request correction of inaccurate data;
• request deletion of your data;
• object to or restrict certain processing where applicable;
• receive personal data in a portable format where the right to data portability applies;
• withdraw consent where processing is based on consent; and
• lodge a complaint with an applicable data-protection supervisory authority.

FAZAN provides an in-app mechanism for deleting your account and its associated account data, as well as an external FAZAN Delete Account page.

For other privacy requests, you may contact us using the details below.

17. Automated decision-making

FAZAN does not use your personal information for solely automated decision-making that produces legal effects or similarly significant effects concerning you.

18. Children’s privacy

FAZAN is a general-audience word game and is not specifically directed at children.

FAZAN does not require users to provide their real name, email address or password when creating an account.

Users should not include unnecessary personal information in their public username.

Parents and guardians should supervise younger users’ use of online services and purchases where appropriate.

19. Changes to this Privacy Policy