Privacy policy

Scope and layered notices

This privacy policy explains how ORT Blue Studio handles personal information in connection with its mobile applications, games, websites, support channels, and related services (collectively, the “Services”).

Data practices differ between Services. A store listing, in-application notice, permission prompt, or feature-specific notice may provide more specific information. That specific notice supplements this policy and controls for that feature if it describes a narrower practice. If a Service works entirely offline and keeps progress only on the device, ORT Blue Studio does not receive that local-only information.

This policy does not turn an optional category into a collection practice. ORT Blue Studio processes a category described below only when the relevant Service or feature actually uses it.

Who is responsible

ORT Blue Studio, an independent game studio based in the United Kingdom, is the controller or business responsible for the personal information covered by this policy, unless a feature-specific notice says otherwise.

Privacy enquiries may be sent to ortbluestudio@proton.me. This address also reaches the person responsible for privacy matters at ORT Blue Studio.

Registered office: 19 Ollerton Road, Birmingham, England B26 1PP.

Information we may process

Depending on the Service and the features a user chooses, ORT Blue Studio may process the following categories:

• Information provided directly: a name, email address, support message, feedback, attachments, and any other information a user chooses to send.
• Technical and usage information: IP address, device type, operating system, language, app version, session timing, feature interactions, diagnostics, and crash or performance information, but only where an online, diagnostic, or analytics feature is enabled.
• Account or transaction information: an account identifier, entitlement, purchase status, or marketplace receipt where a Service offers accounts or purchases. Payment card details are handled by the relevant marketplace or payment provider and are not received by ORT Blue Studio unless a specific notice expressly says so.
• Device permissions: information from a device feature only after the Service requests the permission and the user grants it. The permission screen or feature notice explains the purpose.

ORT Blue Studio does not intentionally request sensitive personal information unless it is necessary for a clearly explained feature and lawful safeguards are in place. Users should not include sensitive information in general support messages.

Sources of information

Information may come directly from the user, from the device or Service when an online feature is enabled, or from a platform or service provider such as an application marketplace, hosting provider, diagnostics provider, or payment provider. ORT Blue Studio does not obtain information from data brokers.

Local save data that never leaves the device is controlled by the user through the Service, device settings, application storage controls, or uninstallation.

Purposes and legal bases

Where applicable, information is processed to:

• provide, maintain, and support the requested Service;
• respond to messages, feedback, and privacy requests;
• authenticate users, confirm entitlements, or process a transaction where those features exist;
• diagnose faults, protect security, prevent misuse, and improve reliability;
• comply with law and establish or defend legal claims; and
• analyse or improve a Service only when the relevant notice, settings, and consent requirements permit it.

For people in the UK, European Economic Area, and other regions that require a legal basis, ORT Blue Studio relies as appropriate on performance of a contract, compliance with a legal obligation, consent, or legitimate interests such as providing support, maintaining security, and improving reliability. Legitimate interests are used only after considering the user’s rights and reasonable expectations. Consent may be withdrawn at any time, without affecting earlier lawful processing.

Website, cookies, and local storage

ORT Blue Studio does not currently use advertising or behavioural analytics cookies on this website. Essential request information may be processed by the hosting provider to deliver pages, prevent abuse, and maintain security. The website is hosted by Vercel; its handling of information is described in the Vercel Privacy Notice.

A Service may use device-local storage for progress, preferences, or settings. Local-only storage is not transmitted to ORT Blue Studio unless an identified online or synchronisation feature does so.

Sharing and service providers

ORT Blue Studio may disclose information only as needed to:

• vendors that host, distribute, secure, diagnose, support, or process transactions for a Service;
• application marketplaces and platform providers used by the user;
• professional advisers who are subject to confidentiality duties;
• authorities or other parties where required by law, valid legal process, safety, fraud prevention, or the protection of legal rights;
• a successor in a merger, financing, reorganisation, or sale, subject to applicable law and continued protection; or
• another party when the user directs or consents to it.

Providers are authorised to process information only for the relevant service or another lawful purpose and are expected to protect it appropriately. A feature-specific notice identifies material providers where required.

No sale, targeted advertising, or significant profiling

ORT Blue Studio does not sell or rent personal information. As of the effective date, it does not share personal information for cross-context behavioural advertising, use personal information for targeted advertising, or profile users to make decisions that produce legal or similarly significant effects.

Because these activities are not performed, there is currently no separate “Do Not Sell or Share” mechanism and browser-based opt-out signals such as Global Privacy Control do not change the Services’ behaviour. If these practices change, this policy and the relevant Service will be updated with any legally required notice, consent, and opt-out controls before the change takes effect.

Retention, deletion, and security

Personal information is kept only as long as reasonably needed for the purpose described at collection. Retention is determined by the nature and sensitivity of the information, the duration of the user relationship or support request, security needs, legal limitation periods, and applicable record-keeping duties. When information is no longer needed, it is deleted or anonymised where reasonably practicable.

ORT Blue Studio uses reasonable administrative, technical, and organisational measures designed to protect information against accidental loss and unauthorised access, alteration, disclosure, or destruction. No electronic system is completely secure. If a personal data breach occurs, ORT Blue Studio will investigate and notify affected people and regulators where required by law.

International transfers

ORT Blue Studio is based in the United Kingdom. Service providers may process information in the UK, European Economic Area, United States, Canada, and other countries in which they operate. Privacy protections in those countries may differ from those in the user’s country.

Where law requires a transfer mechanism, ORT Blue Studio uses an applicable safeguard such as an adequacy decision, approved standard contractual clauses, the UK International Data Transfer Agreement or Addendum, or another legally recognised mechanism. Information about an applicable safeguard may be requested using the contact address below.

Children and young people

The intended age group for each Service is stated in its marketplace listing or feature-specific notice. ORT Blue Studio does not knowingly collect personal information from a child where parental consent or another legal basis is required, unless the Service is specifically designed for that audience and provides the required child-appropriate notice, safeguards, and parental consent process.

If a parent or guardian believes a child has provided personal information contrary to this policy, they should contact ORT Blue Studio. The information will be reviewed and deleted or otherwise handled as required by applicable law.

Regional privacy rights

Privacy rights depend on location and the applicable law. Rights may be subject to exceptions and may include the following:

UK, EEA, and Switzerland. Users may have rights to be informed, access, rectification, erasure, restriction, data portability, objection, withdrawal of consent, and safeguards concerning automated decision-making. Users may also complain to the UK Information Commissioner’s Office, their local EEA supervisory authority, or the Swiss Federal Data Protection and Information Commissioner.

Right to object. Where processing is based on legitimate interests, a user may object based on their particular situation. ORT Blue Studio will stop that processing unless there are compelling legitimate grounds to continue or it is needed for legal claims. ORT Blue Studio does not use personal information for direct marketing.

California. Where the California Consumer Privacy Act applies, California residents may request access to categories and specific pieces of personal information, correction, deletion, and information about collection, use, disclosure, sale, and sharing. They may opt out of sale or sharing and limit certain uses of sensitive personal information. ORT Blue Studio does not discriminate against a user for exercising an applicable privacy right.

For the 12 months preceding this policy’s effective date, ORT Blue Studio may have collected only the categories described in Sections 3 and 4 when a relevant Service or feature used them, and may have disclosed them to the provider categories in Section 7 for the business purposes in Section 5. ORT Blue Studio did not sell or share those categories for cross-context behavioural advertising.

Other US states. Residents of states with applicable comprehensive privacy laws may have rights to access, correct, delete, or obtain a portable copy of personal information and to opt out of sale, targeted advertising, or certain significant profiling. Where required, a user may appeal a refused request by replying to the decision.

Canada. Subject to applicable federal or provincial law, users may request access to and correction of their personal information, withdraw consent subject to legal or contractual limits, and challenge ORT Blue Studio’s compliance. Users may also complain to the Office of the Privacy Commissioner of Canada or the applicable provincial regulator.

Brazil. Where Brazil’s LGPD applies, users may request confirmation and access, correction, anonymisation, blocking or deletion, portability, information about sharing, review of certain automated decisions, and withdrawal of consent. They may also contact Brazil’s National Data Protection Authority.

Australia and New Zealand. Where applicable, users may request access and correction and may complain about the handling of personal information. Complaints may also be directed to the Office of the Australian Information Commissioner or the Office of the Privacy Commissioner of New Zealand after ORT Blue Studio has had a reasonable opportunity to respond.

How to exercise rights or make a complaint

Send a request to ortbluestudio@proton.me with the subject “Privacy request”. Describe the Service and the right being exercised. ORT Blue Studio may request information reasonably necessary to verify identity, protect against fraud, and locate the relevant records. Authorised agents may submit a request where applicable law permits it and valid authority can be verified.

Requests are handled without undue delay and within the period required by applicable law. Requests are generally free, though a lawful fee or refusal may apply to manifestly unfounded, excessive, or repetitive requests. If a request is denied, the response will explain the reason and any available appeal or complaint route.

Users may first ask ORT Blue Studio to review a privacy concern. They also retain the right to complain to the competent privacy or data protection authority in their country or state. A directory of European authorities is available from the European Data Protection Board; other users may contact their national, provincial, or state privacy regulator.

Automated decisions

ORT Blue Studio does not currently use personal information to make decisions based solely on automated processing that produce legal or similarly significant effects. If a Service introduces such processing, a specific notice will explain the logic, significance, consequences, and available rights before it is used.

Third-party links and services

A Service may link to a marketplace, operating-system feature, website, or service not controlled by ORT Blue Studio. The third party’s own terms and privacy notice govern its independent processing. ORT Blue Studio is not responsible for an independent third party’s privacy practices.

Changes to this policy

This policy may be updated to reflect changes in the Services, providers, or law. The effective date will be revised when an update is published. Where required, ORT Blue Studio will provide additional notice or request consent before a material change takes effect. Previous versions may be requested using the contact address below.

Contact ORT Blue Studio

For privacy questions, rights requests, or complaints, contact:

ORT Blue Studio
19 Ollerton Road
Birmingham, England B26 1PP
ortbluestudio@proton.me