Privacy Policy

Frostfall 2 (the "App")

Effective date: 21 September 2026 · Policy version 1.1

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.

There is no account, sign-in, advertising, analytics, tracking, or in-app purchase. The game, music and bundled music video work offline. An optional How to Play link opens the support website in your default browser; that website is separate from the App, as explained in section 7.

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 describes the Frostfall 2 iOS application distributed through the Apple App Store. Apple's services (section 9), the support website, your browser and email services operate separately. Section 7 explains what happens when you choose to open the support website or send a support email. Statements about the App collecting no data refer to the App itself.

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 declares a motion usage description for the device-tilt parallax effect on its title and storybook scenes. It reads device orientation locally to move the artwork; it does not record or transmit motion data. The App does not request access to location, camera, microphone, photos, contacts, notifications, or advertising tracking.

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:

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.

Device motion. Core Motion supplies the device orientation for the title and storybook parallax effect. Readings are used only in memory on your device and are not stored or transmitted. Sampling stops when the App is inactive or Reduce Motion is enabled.

Music Hall playback. Music Hall can continue playing bundled music when the screen is locked or the App is in the background. The App provides the current track title, artwork, duration, playback position, and play/pause state to the iOS system player so its controls stay in sync. This uses local iOS playback services and does not send data to the Developer.

7. Offline play and optional external links

The game, music and bundled music video do not require network access. Their content is included in the App and can be used in Airplane Mode. The App has no developer-operated backend, embedded web view, advertising SDK, analytics SDK or remote content download.

The optional How to Play link opens the support website in your default browser. The browser then connects to that website under the website and browser providers' privacy policies. The App does not attach gameplay preferences, scores or motion readings to the link. If you choose to contact support by email outside the App, you voluntarily provide your email address and message so that we can respond. These external website and email interactions are separate from the App's data collection practices.

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

Refer to the App Store age rating for age suitability.   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, in-app purchases, embedded web content, chat or communication between players. Its optional How to Play link opens the support website in the default browser, as described in section 7. Shops use clams and fish collected while playing; there is no real-money purchase inside 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

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