Privacy Policy for ACT: Action Control Tower

Effective date: January 8, 2026
Game: Action Control Tower
Company: Kahler Development (Denmark)
Contact: ACT@kahlerdevelopment.com
Address: Skæring skolevej 121
Website: kahlerdevelopment.com

This Privacy Policy explains how Kahler Development (“we”, “us”, “our”) collects, uses, shares, and protects personal data when you use Action Control Tower on iOS, Android, and any web version we may provide.


1) What we collect
We collect the following categories of information, depending on what you use in the game:

	A. Information you provide
	Account details (if you create an account): email address, username/display name, password (stored in hashed form), and optional profile details.
	Leaderboard/community info (if enabled): display name, scores, ranks, match results, and other performance statistics you choose to submit.
	Support messages: email address, your message, and any files you attach.

	B. Information collected automatically
	Device and app info: device model, operating system version, language, country/region, time zone, app version, and basic identifiers.
	Usage and gameplay data: session duration, game progression, settings, interactions, and feature usage.
	Diagnostics: crash reports, error logs, and performance metrics.
	Network info: IP address and approximate location derived from IP (for example, country or city level).

	C. Purchases
	If you buy something in the game, the App Store or Google Play processes the payment. We receive information needed to confirm and support your purchase (for example, the product purchased and a transaction/order identifier), but we do not receive your full payment card details. 

	D. Advertising data (if the game shows ads)
	If we use ads, we and/or our ad partners may collect:
	Advertising identifiers (where permitted)
	Ad impressions, clicks, and basic ad performance metrics
	Device and general location (approximate)
	On iOS, if you choose “Ask App Not to Track”, we cannot access the device advertising identifier (IDFA) and cannot track you in the ways Apple defines as “tracking”. 

	E. Web version data (if you play on the web)
	If we provide a web version, we may use cookies or similar technologies for login/session management, preferences, analytics, and (if applicable) advertising. Where required, we will request your consent.


2) How we use your information

We use personal data to:
Provide and operate the game (including saving progress and enabling features)
Create and manage accounts (if enabled)
Run leaderboards and comparisons (if enabled)
Process purchases, verify transactions, and restore purchases
Provide customer support and communicate with you
Improve game balance, features, and user experience
Monitor performance and fix bugs and crashes
Prevent fraud, abuse, and cheating, and enforce our terms
Show ads (if enabled), measure ad performance, and (where permitted) personalize ads


3) Legal bases for processing (EEA/UK, including Denmark)
We process personal data under one or more of the following legal bases:
Contract: to deliver the game and features you request (for example, accounts, purchases, leaderboards).
Legitimate interests: to secure and improve the game, prevent fraud/cheating, and understand performance (balanced against your rights).
Consent: for certain analytics, cookies (web), and personalized advertising where required.
Legal obligation: where we must comply with law.


4) How we share information
We do not sell your personal data in the ordinary sense. We may share data:

	A. With service providers (processors)
	We use trusted vendors to help operate the game, such as:
	Hosting and infrastructure providers
	Analytics and crash reporting providers
	Customer support tools
	Ad networks and mediation providers (if ads are enabled)
	Anti-fraud and security services (if used)
	They may process data only on our instructions to provide services to us.

	B. With platform providers
	Apple and Google (and any web platform providers) may process data under their own privacy policies when you download, install, or use platform services (for example, payments, app distribution, device services).

	C. For legal and safety reasons
	We may disclose information if required by law, or to protect players, the public, or our rights and services.

	D. Business transfers
	If Kahler Development is involved in a merger, acquisition, or asset sale, data may be transferred as part of that transaction subject to safeguards.


5) Advertising and analytics choices
In-game settings (if available)
If we provide a privacy settings screen, you can:
Opt in or out of analytics (where offered)
Control ad personalization preferences (where offered)
iOS tracking permission
If we request permission to track, iOS will show Apple’s tracking prompt. If you do not allow tracking, we will not access IDFA and will not track you as defined by Apple’s rules. 
Android advertising controls
On Android, you can limit ad personalization and reset advertising identifiers via device settings (availability varies by Android version and device).
Web cookies (if applicable)
On the web version, you can manage cookies through your browser settings and any cookie banner/preferences tool we provide.


6) International transfers
We may use service providers that process data outside Denmark and the EEA. Where required, we rely on appropriate safeguards (for example, the EU Commission’s Standard Contractual Clauses).


7) Data retention
We keep personal data only as long as necessary:
Account data: while your account is active, and for a reasonable period after deletion as needed for security, legal compliance, and dispute handling.
Leaderboard data: while the leaderboard feature is active, or until you delete your account (subject to technical and integrity constraints, for example preserving historical rankings).
Diagnostics and logs: typically for a limited time, unless needed to investigate security issues or serious bugs.
Support communications: as long as needed to resolve your request and maintain records.


8) Security
We use reasonable technical and organizational measures to protect your information (for example, access controls, encryption in transit where appropriate, and least-privilege access). No system is 100% secure.


9) Children
Action Control Tower is not intended for children under 13. We do not knowingly collect personal data from children under 13.
Under Danish rules implementing GDPR Article 8, consent-based processing for information society services offered directly to children is lawful if the child is at least 13, otherwise parental authorization is required. 
datatilsynet.dk
If you believe a child under 13 has provided personal data, contact us and we will take steps to delete it.


10) Your rights (EEA/UK)
Depending on your location and the circumstances, you may have rights to:
Access your personal data
Correct inaccurate data
Delete your data
Restrict or object to certain processing
Data portability
Withdraw consent (where processing is based on consent)
Lodge a complaint with a supervisory authority
In Denmark, the supervisory authority is Datatilsynet (Danish Data Protection Agency).
To exercise your rights, contact us at ACT@kahlerdevelopment.com We may need to verify your request.


11) Third-party links and services
The game may link to or integrate with third-party services (for example, ad partners or platform services). Their privacy practices are governed by their own policies.


12) Changes to this policy
We may update this Privacy Policy from time to time. We will post the updated version and change the effective date. If changes are material, we will provide an additional notice in-game or on our website.