Legal

Privacy Policy

Current version, published 31 October 2026

1. Who we are

SPiGAME is operated by Fulcrum Group Ltd, a company registered in England and Wales. We are the controller of your personal data. ICO registration number: ZC267475. Contact: privacy@spigame.com.

2. Who can play

  • You must be 13 or over to play. We do not knowingly collect data from children under 13. If we learn an under-13 has an account, we delete it.
  • Players aged 13 to 17 ("Cadets") get a protected experience, set on our servers:
    • adults cannot target, track or message Cadets;
    • Cadets play PvP only with other Cadets, in daylight, at public places;
    • Cadets' positions on the map are never shown precisely;
    • there is a monthly spending cap.

3. What we collect, why, and our lawful basis

DataWhyLawful basis (UK GDPR Art. 6)How long
Email, password (stored hashed by our authentication provider), player ID, agent nameYour account, sign-in, supportContractWhile your account exists
Date of birth / age band, Cadet status, consent statusAge-appropriate design; meeting our legal duties to childrenLegal obligation; legitimate interestsWhile your account exists
Parent or guardian's name and email (Cadets)Asking for and recording consentLegal obligation; legitimate interestsWhile the Cadet account exists. If a parent refuses, or a request expires unanswered: deleted 30 days later
Precise location, while you use the app onlyMissions at real places, nearby players, keeping restricted areas out of play, cheat preventionContract; legitimate interests (fraud prevention)Live map position: replaced on each update and deleted after 24 hours. Location history samples: 30 days. Mission results keep no coordinates
Gameplay data (missions, items, credits, rank, organisations)Running the gameContractWhile your account exists
Chat messages and content you createCommunication between players; safety and moderationContract; legitimate interests (safety)12 months from sending. Reported messages and moderation records: 2 years after the case closes. Messages are not end-to-end encrypted.
Push notification tokenSending notifications you allowedConsent (device prompt)Until you sign out, turn notifications off, or 270 days without use
Purchase records (store transaction IDs, product, amount; never card details)Delivering purchases, refunds, fraud prevention, Cadet spending capContract; legal obligation (tax)6 years after the purchase (UK tax rules)
Crash and performance dataFixing bugsLegitimate interests90 days at most
Gameplay analytics (first-party)Improving the gameLegitimate interests. Not used to profile Cadets.13 months, then kept only as totals with no identifiers
Advertising identifiers and ad interaction data (Google AdMob)Showing ads, including optional rewarded adsConsent for personalised ads (UK/EEA consent form). Cadets, unverified-age players and all iOS players get non-personalised ads only.As set by Google
Camera feedThe optional AR viewContractProcessed on your device. Not stored or uploaded.
Support emailsAnswering youLegitimate interests2 years after your request is closed
Security and audit logs (sign-ins, admin actions)Keeping accounts and the service secureLegitimate interests12 months

Backups roll over within 7 days.

We do not sell your personal data. We do not use it for cross-app tracking, and we don't ask iOS for tracking permission.

4. Who we share data with

These service providers process data for us under contract:

  • Supabase (database, authentication, server functions), hosted in the EU (Ireland, AWS eu-west-1).
  • Expo / EAS (app delivery and push notifications).
  • Apple and Google (app stores, payments, push).
  • RevenueCat (purchase validation).
  • Sentry (crash reports).
  • Google AdMob (ads). For personalised ads, AdMob may act as an independent controller under Google's terms.
  • AI image tools used by our studio to make card art before release. No player data is sent to them, and players cannot generate AI content in the app.

We may disclose data where the law requires it, or to protect players' safety.

International transfers: some providers process data outside the UK (for example, in the US). We rely on UK adequacy regulations, the UK International Data Transfer Agreement or Addendum, or EU Standard Contractual Clauses.

5. Children's privacy (UK Age Appropriate Design Code)

We follow the ICO's Children's Code for players under 18:

  • high-privacy settings by default;
  • no profiling for advertising;
  • location used only while playing and never shown precisely to others;
  • no nudges to share more data;
  • parental controls that can only make settings stricter.

6. Your rights

You can ask to access, correct, delete, restrict or move your data, or object to how we use it. Parents can exercise these rights for Cadets. Email privacy@spigame.com. We reply within one month. You can complain to the Information Commissioner's Office: ico.org.uk, 0303 123 1113.

7. Deleting your account

8. Security

  • Data is encrypted in transit (TLS) and at rest by our hosting provider.
  • Access is restricted by row-level security and least-privilege server functions.
  • We do not claim end-to-end encryption.

9. Changes

We'll tell you in the app before material changes take effect.

10. Contact

Fulcrum Group Ltd. privacy@spigame.com. ICO registration number ZC267475.