Privacy Policy

1. Who is responsible

The Service is operated by [FULL NAME], an individual (natural person) — not yet incorporated as a company (“we”, “us”). [FULL NAME] is the controller of your personal data and the contact for privacy matters, including any request about your data, at [contact email]. If we incorporate as a company in the future, we will update this Policy with the new entity’s details.

2. Data we collect

We collect:

• · Account: email, username, password (stored encrypted), and date of birth;
• · Consent records: the date, time, and IP address at which you accepted these Terms and this Policy;
• · Game use: your progress, heroes, actions, and preferences;
• · Payments: processed by third parties; we receive the transaction confirmation, not your full card data;
• · Technical data: IP address, device/browser identifiers, access logs, and cookies.

3. Why we use it and legal basis

We use your data to create and maintain your account and provide the Service (performance of a contract); to verify the minimum age and record acceptances (compliance with a legal obligation and the regular exercise of rights); for security, fraud prevention, and improving the Service (legitimate interest); and, where you choose, to send communications (consent).

4. Sharing

We do not sell your data. We share only what is necessary with payment providers, with the infrastructure and cloud providers that host the Service, and with authorities when required by law or court order.

5. Cookies

We use cookies and similar technologies to keep your session, remember preferences, and understand how the Service is used. You can manage cookies in your browser; some are essential for the Service to work.

6. Retention

We keep your data while your account exists and for as long as needed to meet legal obligations, resolve disputes, and enforce our agreements. After your account is closed, we delete or anonymize the data, except where the law requires us to keep it.

7. Your rights

Under the LGPD, you may:

• · Confirm that we process your data, and access it;
• · Correct incomplete, inaccurate, or outdated data;
• · Request anonymization, blocking, or deletion of unnecessary data or data handled unlawfully;
• · Request data portability;
• · Learn with whom we share your data;
• · Withdraw consent.

8. Minors and minimum age

The Service is intended for people aged 16 or older. We process the data of 16- and 17-year-olds in their best interest and with the consent and assistance of a legal guardian. We do not knowingly collect data from people under 16; if we learn of such collection, we delete the data.

9. Security

We apply technical and organizational measures to protect your data. No system is completely secure, but we work to reduce risks and to respond to incidents.

10. International transfer

Some providers may process data outside Brazil. In those cases, we adopt safeguards compatible with the LGPD to protect your data.

11. Changes and contact

We may update this Policy; we will announce material changes in the Service, and the date above shows the latest version.

The Portuguese-language version of this Policy is the official one and prevails over any translation. Contact: [contact email].