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Privacy Policy for Fig and Totems

Holm Studio SASU (“we”, “our”, or “us”), a French Société par Actions Simplifiée Unipersonnelle registered in France, respects your privacy. This Privacy Policy explains what information is processed when you use Fig and Totems (the “Game”).

Data Controller: Holm Studio SASU — SIREN: 995 293 586 — 200 rue de la Croix Nivert, 75015 Paris, France. Email: rim@holmgamestudio.com

1. Information We Process

We have designed Fig and Totems to minimise the personal data we process. However, some data is unavoidably processed to operate the Game’s multiplayer functionality and to allow players to share feedback with us.

a) Anonymous device identifier

When you launch the Game for the first time, an anonymous identifier is generated and stored locally on your device (via Unity PlayerPrefs). This identifier is used to allow you to rejoin a multiplayer room after a temporary disconnection. It is not linked to your real identity, but under GDPR it is considered an “online identifier” and therefore personal data.

b) Multiplayer connection data

When you play in multiplayer mode, the following data is processed through our multiplayer service provider Photon (see Section 2):

  • Your IP address
  • Your region
  • Connection metadata (session ID, timestamps, latency)
  • The anonymous identifier described above
  • In-game state synchronised between players (positions, actions, game events)

c) Voluntary feedback

If you choose to use the in-game “Rate the demo” form, we collect:

  • Your star ratings for gameplay and multiplayer experience
  • Your yes/no recommendation answer
  • Any optional free-text comments you choose to submit

You are not required to submit this form, and we ask that you do not include personal information (such as your name, email address, age, or the names of other people) in the free-text field.

What we do NOT collect:

  • We do not create user accounts
  • We do not use analytics or advertising SDKs
  • We do not track your location beyond the regional information needed for multiplayer routing
  • We do not sell your data or share it for marketing purposes

2. Third-Party Services

Photon (Exit Games GmbH)

We use Photon PUN 2 to provide multiplayer functionality. Photon acts as a data processor on our behalf, meaning we (Holm Studio SASU) remain the data controller for data processed through Photon in connection with the Game. Photon processes your IP address, region, anonymous identifier, and in-game session data to enable multiplayer sessions. Photon is headquartered in Germany; multiplayer traffic is generally routed through regional servers (EU traffic stays on EU servers), but Photon may transfer data internationally under Standard Contractual Clauses where required. Photon’s privacy policy is available at photonengine.com/legal/privacy.

If you wish to exercise your data protection rights regarding multiplayer connection data, please contact us first (see Section 7) — Photon will redirect such requests back to us as the controller.

Google Forms / Google Sheets (Google LLC)

The in-game “Rate the demo” form transmits your submission to a Google Form, with responses stored in Google Sheets. Google acts as a data processor for this submission. Data may be transferred to Google servers located outside the European Economic Area; Google relies on Standard Contractual Clauses and, where applicable, the EU-U.S. Data Privacy Framework for such transfers. Google’s privacy policy: policies.google.com/privacy.

Distribution platforms (Steam, Apple, Google)

If you obtain the Game through a distribution platform, that platform may collect data independently in accordance with its own privacy policy. We have no access to or control over that data.

3. Legal Basis for Processing (GDPR)

We rely on the following legal bases under Article 6 of the GDPR:

  • Performance of a contract / legitimate interest (Article 6(1)(b) and (f)): for the anonymous identifier and multiplayer connection data, which are necessary to provide the Game’s multiplayer functionality you have chosen to use.
  • Consent (Article 6(1)(a)): for the optional feedback form. Your consent is given by the act of voluntarily submitting the form, and you may withdraw consent at any time by contacting us (see Section 7).

Providing this data is not a statutory requirement. However, providing the data described in Section 1(a) and 1(b) is necessary to use the Game’s multiplayer functionality; without it, multiplayer cannot function. Providing feedback under Section 1(c) is entirely voluntary.

We do not use your data for automated decision-making, including profiling, within the meaning of Article 22 of the GDPR.

4. Data Retention

  • Anonymous identifier (on your device): stored on your device until you uninstall the Game or clear its data.
  • Photon connection data: retained by Photon for as long as necessary to operate the service and ensure security, in accordance with Photon’s own privacy policy.
  • Feedback form submissions: retained for the duration of the Game’s development and post-release support, up to a maximum of three (3) years, after which they are deleted.

5. Children’s Privacy

Fig and Totems is not directed at children under the age of 13 (or under 15 in France, per Article 8 of the French Data Protection Act). We do not knowingly collect personal data from children below these ages.

If you are a parent or guardian and believe that your child has submitted personal information through our feedback form, you have the right to:

  1. Request a description of the categories of personal information we have collected from your child;
  2. Review the specific information we hold about your child;
  3. Refuse to permit further collection or use of your child’s information;
  4. Have your child’s information deleted.

To exercise these rights, contact us at rim@holmgamestudio.com. We will verify that you are the parent or guardian before responding, and will act on valid requests promptly.

6. Data Security

We take reasonable technical and organisational measures to protect data. The anonymous identifier is stored only on your device. Multiplayer data is transmitted to Photon over the connection security mechanisms Photon provides. Feedback submissions are protected by Google’s security infrastructure.

7. Your Rights

If you are located in the European Economic Area, the United Kingdom, or another jurisdiction granting equivalent rights, you have the right to:

  • Access the personal data we hold about you
  • Request rectification or erasure
  • Restrict or object to processing
  • Data portability
  • Withdraw consent at any time (for processing based on consent)
  • Lodge a complaint with a supervisory authority. In France, this is the CNIL (cnil.fr)

To exercise these rights, contact us at rim@holmgamestudio.com. Note that for the anonymous identifier, you can also clear it yourself by deleting the Game’s local data or uninstalling the Game.

🇬🇧 Request Data Deletion

8. Changes to This Privacy Policy

This Privacy Policy may be updated as the Game evolves. Any updates will be reflected on this page with a revised “Last updated” date.

9. Contact

Holm Studio SASU — SIREN: 995 293 586 — 200 rue de la Croix Nivert, 75015 Paris, France. Email: rim@holmgamestudio.com