Privacy
Policy

1.Who We Are

Data controller

[legal entity name and company form], trading as Naughty Reels Studios

Business ID

[Business ID (Y-tunnus)]

Registered address

Karjalankatu 5, [postcode and city], Finland

Contact email

hello@naughtyreelsstudios.com

Data Protection Officer

Not applicable

If you are located in the European Economic Area (EEA), the United Kingdom or Switzerland, the company named above is the controller responsible for your personal data under the General Data Protection Regulation (GDPR).

2.Information We Collect

2.1 Information you provide directly

• Account information: username, email address, password (stored in hashed form).
• Payment information: billing details processed through our third-party payment processors (we do not store full card numbers).
• Communications: messages you send us via support, contact forms, email, or the feedback and bug-report tool inside the Studio — including any screenshots or other images you attach. A screenshot captures whatever was on your screen at the time, so please avoid sending one that shows information you would rather not share with us.
• User content: any content you upload, create or submit through the Services — for example game specifications, prompts, uploaded artwork and the games you build.

2.2 Information collected automatically

• Device and usage data: IP address, browser type, operating system, device identifiers, referring URLs, pages visited and timestamps.
• Cookies and similar technologies: see Section 7 (Cookies) below.
• Log data: server logs generated in the ordinary course of operating the Services.
• Diagnostic context attached to a report: when you send a report through the feedback tool we also record the page you were on, your browser and window size, your interface language and time zone, and which studio and account the report came from, so that we can reproduce what you saw.

2.3 Information from third parties

• Payment processors (transaction status, fraud-check signals).
• Analytics providers — Google Analytics (see Sections 5 and 7).

3.How We Use Your Information

We use the information we collect to:

1. Provide, operate and maintain the Services;
2. Process payments and prevent fraud;
3. Create and manage your account;
4. Respond to inquiries and provide customer support;
5. Read, classify and act on the feedback and bug reports you send us, which includes having an AI service summarise the report and any screenshots so we can route and fix the problem;
6. Send administrative communications (for example policy updates, security notices);
7. Send marketing communications, where you have consented or as otherwise permitted by law (you may opt out at any time);
8. Monitor, analyse and improve the Services;
9. Detect, investigate and prevent fraud, abuse and security incidents;
10. Comply with legal obligations and enforce our Terms and Conditions.

4.Legal Bases for Processing (EEA/UK Users)

Where the GDPR applies, we rely on the following legal bases:

• Performance of a contract — to provide the Services you request (for example account creation, game building and preview features).
• Legitimate interests — to secure and improve the Services, prevent fraud, and for analytics, provided these interests are not overridden by your rights.
• Consent — for marketing communications and non-essential cookies, which you may withdraw at any time.
• Legal obligation — where processing is required to comply with applicable law (for example anti-fraud, financial record-keeping).

5.Sharing of Information

We do not sell your personal data. We may share information with:

• Service providers who perform functions on our behalf (hosting, payment processing, AI generation and support triage, web analytics — Google Analytics, provided by Google — and customer support), bound by contractual confidentiality and data protection obligations.
• Legal and regulatory authorities, where required to comply with law, respond to lawful requests, or protect our rights, users or the public.
• Business transfers, if we undergo a merger, acquisition or sale of assets, subject to standard confidentiality arrangements.
• Affiliates, for the purposes described in this policy.

A current list of key third-party processors can be requested at hello@naughtyreelsstudios.com.

6.International Data Transfers

If we transfer personal data outside the EEA/UK, we use appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, to ensure your data remains protected in accordance with this policy and applicable law. This applies in particular to analytics data processed by Google (Section 7), which may be processed on servers outside the EEA.

7.Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Keep you logged in and remember preferences (essential cookies);
• Understand how the Services are used and improve them (analytics cookies).

For analytics we use Google Analytics, a service provided by Google. It sets its own cookies and collects usage data such as the pages you visit, how you arrived, your device and browser type, and an approximate location. Analytics cookies are set only with your consent, which you give or refuse in our cookie banner and can change at any time in its settings. We do not use advertising or marketing cookies.

You can also manage cookies through your browser settings. Disabling essential cookies may affect the functionality of the Services.

8.Data Retention

We retain personal data only as long as necessary to fulfil the purposes described in this policy, including to satisfy legal, accounting or reporting obligations. Account data is generally retained for the life of your account plus [X] years thereafter, unless a longer retention period is required by law.

Feedback and bug reports, including any screenshots attached to them, are kept while the issue is open and for a reasonable period afterwards as a record of what was reported and what was done about it. You can ask us to delete a report you sent at any time — see Section 9.

9.Your Rights

Depending on your location, you may have the right to:

• Access the personal data we hold about you;
• Request correction of inaccurate data;
• Request deletion of your data;
• Object to or restrict certain processing;
• Request data portability;
• Withdraw consent at any time (without affecting prior lawful processing);
• Lodge a complaint with a supervisory authority (in the EEA, your local Data Protection Authority; in Finland, the Office of the Data Protection Ombudsman).

To exercise these rights, contact us at hello@naughtyreelsstudios.com. We may need to verify your identity before fulfilling a request.

10.Data Security

We implement technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse or alteration. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11.Children’s Privacy

The Services are not directed at, and are not intended for use by, children. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so we can delete it.

12.Third-Party Links

The Services may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties, and we encourage you to review their privacy policies separately.

13.Changes to This Policy

We may update this Privacy Policy from time to time. We will post the revised version with an updated “Last updated” date and, where required by law, provide additional notice (for example via email or an in-app notice).

14.Contact Us

If you have questions about this Privacy Policy or our data practices, contact us at:

Company

[legal entity name and company form], trading as Naughty Reels Studios

Address

Karjalankatu 5, [postcode and city], Finland

Email

hello@naughtyreelsstudios.com