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Privacy Policy

Effective date: May 12, 2026

1. Introduction

This Privacy Policy describes how Banshee Technologies S.L. ("we", "us", or "our"), a company registered in Spain, handles information in connection with the Paperclip Empire mobile application ("the App"), available on the Apple App Store.

We are committed to protecting your privacy. The App has been designed with a privacy-first approach: all game data is processed and stored locally on your device. We do not operate backend servers that receive your gameplay data.

2. Nature of the Application

Paperclip Empire is an incremental / idle game designed solely for entertainment purposes. Players progress by producing virtual paperclips, unlocking upgrades, automations, and expanding their virtual empire.

• The in-game currency, paperclips, and any virtual items have no real-world monetary value whatsoever
• Virtual items cannot be redeemed, exchanged, transferred, or withdrawn for real money, cryptocurrency, goods, or services
• In-app purchases allow players to acquire additional virtual currency or boosters for extended gameplay, but these items retain no cash value
• The App does not offer gambling, wagering, or any opportunity to win real money or prizes

3. Information We Collect

We do not collect any personal information. Specifically:

• No user accounts or registration are required
• No names, email addresses, or contact information are collected
• No analytics or tracking tools are actively integrated
• No cookies or similar tracking technologies are used
• No advertising SDKs or ad-tracking are present in the App
• No gameplay data, statistics, or preferences leave your device
• No crash reporting or telemetry data is collected by us
• No location data is collected or used
• No camera or photo library access is requested
• The App does not request or access the IDFA (Identifier for Advertisers)

4. Data Stored on Your Device

The App stores game-related data locally on your device using standard device storage. This data never leaves your device and includes:

• Game progress: Paperclip count, resources, current production rate, prestige level, and progression milestones
• Upgrades & automations: Purchased upgrades, auto-clickers, factories, and other production-related items
• Gameplay statistics: Total paperclips produced, time played, achievements, and similar metrics
• Daily bonus data: Bonus claim history and streak tracking
• Preferences: Sound, music, vibration, notification, theme, and language settings
• Purchase entitlements: Status of any in-app purchases or boosters acquired

This data is stored in standard application storage and will be removed if you uninstall the App. We have no access to, and no ability to retrieve, any data stored on your device.

5. Third-Party Services

The App integrates one third-party service:

RevenueCat (In-App Purchase Management)

We use RevenueCat to manage optional in-app purchases. RevenueCat processes transactions through Apple's StoreKit framework. When you make a purchase, RevenueCat may receive:

• An anonymous vendor identifier (IDFV) used solely for purchase validation and entitlement management
• Transaction data provided by Apple's StoreKit (purchase receipts, subscription status)

RevenueCat does not receive your name, email address, or any other personally identifiable information from us. No data is shared with RevenueCat beyond what Apple provides through the standard StoreKit purchase flow.

RevenueCat's privacy policy: https://www.revenuecat.com/privacy

6. In-App Purchases

Paperclip Empire offers optional in-app purchases that allow you to acquire additional virtual currency, boosters, or cosmetic items. Please understand:

• All purchases are entirely optional — the App is fully playable without any purchases
• Purchased virtual items have no real-world monetary value and are non-refundable except as required by applicable law or Apple's refund policies
• Virtual items cannot be transferred, traded, or exchanged between users or outside the App
• Purchases are processed entirely through Apple's App Store and are subject to Apple's terms and conditions
• We do not directly process, store, or have access to your payment information (credit card numbers, billing address, etc.) — all payment processing is handled by Apple
• If a minor uses the App on a shared device, we encourage parents and guardians to enable Apple's Ask to Buy and Screen Time restrictions to prevent unintended purchases

7. Device Permissions

The App uses the following device capabilities:

• Audio playback: The App plays background music and sound effects. No microphone recording is performed by the App.
• Haptic feedback: The App uses device vibration for tactile feedback during gameplay. This does not access or collect any data.
• Network access: Required solely for processing in-app purchases through RevenueCat and Apple's StoreKit. No gameplay data is transmitted over the network.

The App does not request or use permissions for: camera, photos, contacts, calendar, location, health data, or Bluetooth.

8. Advertising & Tracking

The App does not contain any advertising. There are no banner ads, interstitial ads, video ads, or rewarded ads. No advertising SDKs or ad networks are integrated. The App does not participate in any advertising tracking or data sharing with advertisers. The App's privacy manifest declares NSPrivacyTracking: false.

9. Data Sharing

We do not sell, trade, rent, license, or otherwise share any user data with third parties, because we do not collect any user data. The only data exchange that occurs is between the App and Apple's StoreKit / RevenueCat during optional in-app purchases, as described in Section 5.

10. Data Retention

Since we do not collect personal data, there is no personal data retained on our servers. All game data is stored exclusively on your device and persists until you delete the App or clear the App's data. You are in full control of your data at all times.

11. Your Rights Under GDPR

As a company based in the European Union (Spain), we comply with the General Data Protection Regulation (GDPR). Although we do not collect personal data, you retain all rights granted under the GDPR, including the right to:

• Access — Request confirmation of whether personal data is being processed
• Rectification — Request correction of inaccurate data
• Erasure — Request deletion of personal data
• Restriction — Request restriction of data processing
• Portability — Request transfer of data in a machine-readable format
• Objection — Object to data processing

Since no personal data is collected or processed by us, these rights are inherently satisfied. If you have any questions or wish to exercise these rights, please contact us at the address below.

You also have the right to lodge a complaint with a supervisory authority. In Spain, this is the Agencia Española de Protección de Datos (AEPD) — www.aepd.es.

12. Children's Privacy

Paperclip Empire carries an App Store age rating of 9+. The App does not collect any personal information from users of any age. Because the App contains optional in-app purchases, we strongly recommend that parents and guardians supervise younger players and make use of Apple's parental controls (Family Sharing, Ask to Buy, and Screen Time) to manage in-app purchases on devices used by minors.

We do not knowingly collect personal information from children. If you believe we have inadvertently received personal data from a child, please contact us so we can address the issue promptly.

13. Data Security

Because all game data is stored locally on your device, your data benefits from the security protections built into your device's operating system, including device passcode, Face ID, and Touch ID protections. We have no remote access to any of your data, and no data is transmitted to our servers.

14. International Users

Paperclip Empire is operated by Banshee Technologies S.L., based in Spain (European Union). The App does not transmit data to servers in any jurisdiction. All data remains on your local device. In-app purchase processing is handled by Apple in accordance with Apple's own privacy policy and applicable regional laws.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time, including when new gameplay features are introduced. Any changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically. Your continued use of the App after any changes constitutes acceptance of the updated policy.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the App, please contact us: