Privacy Policy

Privacy Policy

Frostfall: Pip's Polar Quest (the "App")

Effective date: 2 August 2026 · Version 1.0

---

1. Who is responsible for this App

The App is published by Hiroki Igarashi (the "Developer", "we", "us"), an individual developer.

Contact for any privacy question, request or complaint: 50@storms.jp

We aim to respond within 30 days.

2. Summary

The App does not collect, transmit, sell, share, or disclose any personal information 

whatsoever.

The App contains no networking code of any kind. It cannot send data anywhere, and it does not 

attempt to. There is no account, no sign-in, no advertising, no analytics, no tracking, no in-app 

purchase, and no third-party software of any kind inside the App.

A small amount of gameplay preference data is written to your device's own local storage so the App 

can remember your settings between sessions. That data never leaves your device, is never readable 

by us, and is deleted when you delete the App.

3. Scope

This policy applies to the Frostfall iOS application distributed through the Apple App Store. It 

does not apply to Apple's own services (see section 9), nor to any other product.

4. Personal information we do not collect

We do not collect, and the App has no technical capability to collect or transmit, any of the 

following:

• Name, email address, postal address, telephone number, or any other contact information

• Account credentials, usernames or passwords

• Payment or financial information

• Precise or coarse location data

• Contacts, calendars, reminders, photos, media, or files

• Camera or microphone input

• Health, fitness, or biometric data

• Device identifiers used for tracking, including IDFA, IDFV, or any advertising identifier

• IP address, user agent, or any other network-derived identifier

• Browsing, search, or purchase history

• Usage analytics, event telemetry, session recordings, or heat maps

• Any data about children, or any data at all from any user

The App requests no system permissions. Its Info.plist declares no permission usage 

descriptions, which means iOS will never present a permission prompt for location, camera, 

microphone, photos, contacts, notifications, tracking, or any other protected resource. If you are 

ever asked for such a permission while the App is open, it did not come from this App.

5. Information stored locally on your device

The App writes the following values, and only the following values, to the standard iOS 

per-application preference store (UserDefaults) inside the App's own sandbox. None of it is 

personal information, none of it identifies you, and none of it is transmitted:

Stored value

What it holds

Why

frostfall.bestScore

Your highest score, as a number

To show "Best" on the title screen

frostfall.difficulty

Easy / Normal / Hard, as a number

To remember your chosen difficulty

frostfall.musicOn

On or off

To remember your music setting

frostfall.sfxOn

On or off

To remember your sound-effects setting

frostfall.lang

The language you chose, as a code such as ja

To remember your chosen language

frostfall.seenTutorial

Whether HOW TO PLAY has been opened

So the tutorial is not re-offered

frostfall.qaMode

On or off

Selects the length of the idle attract demo

Retention. These values persist on your device until you change them in the App or delete the 

App. Deleting the App removes all of them. Nothing is stored on any server, so there is nothing for 

us to retain, back up, or erase on your behalf.

Access. This data lives in the App's sandbox on your device. We have no access to it. The App 

does not synchronise it to iCloud.

6. Device functions the App uses

For completeness, and to match the App's declared privacy manifest (PrivacyInfo.xcprivacy), the 

App uses exactly two of Apple's "required reason" APIs:

• User defaults (Apple reason code CA92.1) — to read and write the seven values listed in 

• section 5, which are accessible only to the App itself.

• System boot time (Apple reason code 35F9.1) — to measure how much time elapses between 

• taps, so gestures such as flicking the language wheel behave correctly. The value is used 

• momentarily in memory and is never stored or transmitted.

That manifest declares NSPrivacyTracking = false and an empty collected-data list, consistent 

with this policy.

7. No network connections

The App makes no network requests. It contains no HTTP client, no web view, no socket code, and no 

remote endpoint of any kind. All artwork is drawn by the App as it runs, and all music and sound is 

either synthesised at run time or played from files bundled inside the App. The App is fully 

functional with the device in Airplane Mode.

8. No third parties

The App integrates no third-party software development kits, libraries, services, advertising 

networks, analytics providers, attribution services, social networks, or crash reporters. No 

personal information is shared with anyone, because none is collected. We do not sell or share 

personal information, as those terms are defined under the California Consumer Privacy Act, and we 

have never done so.

9. Apple's role

Apple operates the App Store and the iOS platform. Anything Apple collects when you browse, 

download, or use apps is governed by Apple's Privacy Policy, not by this one.

Two points of transparency:

• If you have enabled Settings → Privacy & Security → Analytics & Improvements → Share iPhone 

• Analytics and Share with App Developers, Apple may make crash reports and aggregated 

• usage statistics available to us through App Store Connect. That is collected and aggregated by 

• Apple, not by the App; what we can see is aggregate figures and anonymised diagnostic 

• information, not information that identifies you. You can switch this off at any time in iOS 

• Settings.

• Apple provides us with aggregate, anonymised App Store download and sales reports. These do not 

• identify individual users.

We do not combine this Apple-provided aggregate information with anything else, because we hold 

nothing else.

10. Children's privacy

The App is suitable for children. Because it collects no personal information from anyone, it 

collects none from children, and it therefore does not knowingly collect personal information from 

children under 13 — or the equivalent age of digital consent in your jurisdiction — within the 

meaning of the United States Children's Online Privacy Protection Act (COPPA), Article 8 of the EU 

General Data Protection Regulation, or comparable laws.

The App contains no advertising, no in-app purchases, no external links, no web content, no chat, 

and no way for users to communicate with one another or with us from inside the App. The shops 

inside the game spend an imaginary in-game currency ("clams") earned by playing; no real money is 

involved anywhere in the App.

11. Your rights

Data protection laws — including the EU and UK General Data Protection Regulation, the California 

Consumer Privacy Act as amended by the CPRA, and Japan's Act on the Protection of Personal 

Information — grant rights over personal information, such as rights of access, correction, 

deletion, portability, and objection.

Where those laws use the concept of a "controller" or "business", that role would fall to the 

Developer named in section 1. In practice there is nothing to control: we hold no personal 

information about you, so there is nothing for us to disclose, correct, delete, port, or restrict, 

and there is no profiling or automated decision-making of any kind. The locally stored preferences 

described in section 5 are entirely under your control — change them in the App, or delete the App 

to erase them.

For the same reason we have not appointed a representative in the European Union or the United 

Kingdom: Article 27 of the EU and UK GDPR requires one only where a controller outside those 

territories processes personal data of people within them, and this App processes none.

If you nevertheless wish to make a request or raise a concern, write to 50@storms.jp. You also 

have the right to lodge a complaint with your local supervisory authority.

12. International transfers

None. The App transmits no data from your device, so no personal information is transferred to any 

country.

13. Security

The preference values in section 5 are held inside the App's sandbox, protected by iOS application 

sandboxing and device encryption. Because the App holds no personal information and we operate no 

servers, there is no server-side store to breach and no credential for an attacker to obtain from 

us.

14. Changes to this policy

If a future version of the App changes what it stores, or begins to use the network, this policy 

will be updated before that version is released, and the effective date and version number at 

the top of this document will change. Material changes will also be summarised in the App Store 

"What's New" notes for the release that introduces them.

15. Governing law and jurisdiction

This policy, and any dispute or claim arising out of or in connection with it — including 

non-contractual disputes or claims — are governed by and construed in accordance with the laws of 

Japan. The parties agree that the Tokyo District Court shall have exclusive jurisdiction as 

the court of first instance.

This does not take away rights you have where you live. In particular:

• Nothing in this section deprives you of the protection afforded by provisions of the law of your 

• country of habitual residence that cannot be derogated from by agreement. Consumer protection 

• law in many countries, including throughout the EU and the UK, is of this kind.

• If you are a consumer resident in the European Union, the European Economic Area or the United 

• Kingdom, you may bring proceedings in the courts of the country in which you are resident, and 

• the mandatory consumer protections of that country continue to apply to you.

• Your right to lodge a complaint with the data protection supervisory authority of your country 

• (section 11) is unaffected, and you do not have to go to court to exercise it.

• Where the EU or UK GDPR, the California Consumer Privacy Act, Japan's Act on the Protection of 

• Personal Information, or any other data protection law applies to you by its own terms, it 

• applies regardless of this section. A choice of governing law cannot switch that off, and this 

• section does not attempt to.

Your licence to use the App itself is separate from this policy and is governed by Apple's standard 

Licensed Application End User License Agreement, or by any custom licence agreement presented to 

you at download.

16. Contact

Questions, requests, or complaints about this policy or about privacy in the App:

50@storms.jp