Legal
Privacy Policy
1. Who we are
Game House Club is a game studio brand owned and operated by KKA & Associates LLC ("KKA," "we," "us," or "our"). KKA is the developer and publisher of the Game House Club games and is responsible for the information described in this policy (the "controller" or "business" under applicable law).
2. What this policy covers
This Privacy Policy applies to:
- our mobile games and apps, including Brain Drain, Tic Tac Toe, Memory Tide (a photo memories and slideshow app), and Focus Syllabl (a habit, focus, and study planner), and any updates, beta (TestFlight) builds, or future games that link to this policy (together, the "Games");
- our website at gamehouseclub.com (the "Site"); and
- support and other communications you have with us (together with the Games and Site, the "Services").
Each Game's App Store listing includes an Apple "App Privacy" label. If a specific Game collects information in a way not described here, that Game will tell you in its App Store label and, where required, in the Game itself before the collection happens.
This policy does not cover third-party services we do not control, such as Apple's App Store, Game Center, or iCloud. Those services are governed by their own privacy policies.
3. Information we collect
3.1 Information stored on your device
To make the Games work, they save gameplay information locally on your device, such as game progress, levels, scores, statistics, streaks, and preferences (for example sound, difficulty, and accessibility settings). Some Games may ask for a birth year or age range so they can offer age-appropriate content and difficulty. Unless a Game clearly tells you otherwise, this information stays on your device, is not sent to our servers, and is not used to identify you. Deleting a Game from your device deletes this locally stored information.
Planner and habit content. Focus Syllabl lets you enter your own content, such as identity statements ("who I am" and "who I want to be"), habits, classes, syllabus details, assignments, tasks, schedules, and focus sessions. This content is stored on your device and is used only to run the app's features for you. Insights such as focus predictions, streaks, and progress heat maps are calculated from this content to show back to you, and are not used for advertising or shared with anyone. Please do not enter sensitive personal information (such as health, financial, or government ID information) into free-text fields.
Reminders and notifications. If you allow notifications, an App can send reminders about your habits, tasks, and deadlines. You can turn reminders off in the App's settings or in your device's Settings at any time.
3.2 Photos, faces, and photo locations (Memory Tide)
Memory Tide is built so that your photos never leave your device to reach us. Specifically:
- Photo access. With your permission, Memory Tide reads the photos you allow (your full library or only the photos you select) and any iCloud Shared Albums you choose as sources. It uses them to resurface memories, find related pictures, and build slideshows. You can change this at any time in Settings → Privacy & Security → Photos → Memory Tide, or by tapping "Select More Photos" in the app. Memory Tide does not delete or edit the photos in your library or shared albums.
- Dates, places, and content. To organize memories by day and place and to make your library searchable (for example "beach," "dog," or a city name), Memory Tide uses information already stored in your photos, such as the date taken and the location recorded by your camera, and analyzes image content on your device. Memory Tide does not access your device's live GPS location.
- Faces and People. Face grouping happens only if you tap Find Faces. Memory Tide then analyzes your photos on your device to detect faces and suggest groups of photos that appear to show the same person. You decide which groups to keep and what to name them. Face data and the names you assign are stored only on your device. They are never transmitted to KKA or any third party, are not used to identify anyone to us or to others, and are never sold, leased, traded, or used for advertising. Face data is kept only until you delete the People data or the app, whichever comes first.
- Slideshows and sharing. Slideshows you create are saved on your device. When you tap Share or Save to Photos, you choose where the slideshow goes, using Apple's share sheet. Anything you share with another person or service (such as Messages, YouTube, or Instagram) is handled under that recipient's or service's terms and privacy policy, not ours.
Because this content stays on your device, we cannot see, access, recover, or delete it for you. You control it through the app and your device settings.
3.3 Information you choose to give us
If you email us or contact support, we receive the information you choose to include, such as your email address, name, the content of your message, and any screenshots or attachments. Please do not send us sensitive information, and if you are under 13, please ask a parent or guardian to contact us for you.
3.4 Information provided through Apple
- Purchases. If a Game offers paid downloads or in-app purchases, Apple processes the transaction. We receive confirmation that a purchase was made so we can deliver it, but we do not receive your name, payment card number, or billing address.
- Crash reports and diagnostics. If you have chosen to share analytics with app developers in your device settings, Apple may provide us with crash logs and aggregated usage and performance statistics. Apple de-identifies this information, and we use it only to find and fix problems. You can turn this off at any time in your device's privacy settings.
- Beta testing. If you join a TestFlight beta, Apple may share the feedback, screenshots, crash reports, and contact email you submit through TestFlight so we can improve the Game.
- Optional Apple services. If a Game supports Game Center or iCloud and you choose to use them, Apple handles that information under Apple's privacy policy. For example, Game Center leaderboards may display the nickname you chose in Game Center.
3.5 Information collected when you visit the Site
The Site does not use advertising cookies, analytics cookies, or tracking pixels. Like nearly every website, our hosting and security provider (Cloudflare) automatically processes technical information needed to deliver the Site and protect it from abuse, such as IP address, browser type, device type, referring page, and the date and time of your visit. The Site loads fonts from Google Fonts, which means your browser connects to Google's servers to download them.
3.6 Information we do not collect
We do not collect your precise geolocation, contacts, microphone data, health data, government ID numbers, or biometric identifiers or information (such as face geometry or face templates) through the Games. Any analysis of photos, faces, or photo locations described in Section 3.2 happens on your device, and the results never reach us. If a Game lets you add a document, photo, or camera scan (for example, a class syllabus), it accesses only the item you choose, and uses it only for the feature you requested. Any device permission (such as camera, photos, or notifications) is requested by your device first, and you can say no or change it later in Settings.
4. How we use information
We use information only for the following purposes:
- to provide, operate, and maintain the Games and Site, including saving your progress on your device;
- to deliver purchases and restore them when you ask;
- to respond to your questions, feedback, and support and privacy requests;
- to diagnose crashes, fix bugs, and improve performance, accessibility, and gameplay;
- to keep the Services safe and secure, and to prevent fraud and abuse;
- to comply with law, enforce our terms, and protect the rights, property, and safety of our players, KKA, and others.
We do not use your information for automated decision-making that produces legal or similarly significant effects on you, and we do not build advertising profiles about you.
5. Legal bases (EEA, UK, Switzerland)
If you are in the European Economic Area, the United Kingdom, or Switzerland, we process personal data on these legal bases:
- Contract: to provide the Games and any purchases you request;
- Legitimate interests: to secure, support, and improve the Services, where those interests are not overridden by your rights;
- Consent: where we ask for it (for example, optional analytics sharing you enable on your device), which you can withdraw at any time;
- Legal obligation: where we must process data to comply with law.
7. Children's privacy
We want families to feel good about our Games. We comply with the U.S. Children's Online Privacy Protection Act (COPPA), the EU and UK GDPR, the UK Age Appropriate Design Code, and similar laws that protect children.
- We do not knowingly collect personal information from children under 13 (or the minimum age of digital consent in their country) without verifiable parental consent, except as permitted by law, such as a one-time response to a support request after which the contact information is deleted.
- Any age or birth year a Game asks for is used only to tailor content and difficulty, is not used to identify the child, and is not shared.
- Our Games do not show behavioral (targeted) advertising, do not include public chat or the ability to share personal information with other players, and do not let children make purchases without the protections of Apple's Family Sharing and "Ask to Buy" features.
- Parents and guardians can control purchases, app downloads, and analytics sharing through Apple's Screen Time and Family Sharing settings.
Parents: if you believe your child has given us personal information, email gameadmin@gamehouseclub.com. You can ask to review the information, have it deleted, and refuse further collection. We will verify that you are the parent or guardian and respond promptly.
8. Advertising and tracking
We do not track you across other companies' apps or websites, and we do not use Apple's Identifier for Advertisers (IDFA) for tracking. Our Games do not include behavioral advertising. If we ever introduce advertising or any tracking that requires your permission, we will update this policy and the Game's App Store privacy label first, and we will ask for your permission through Apple's App Tracking Transparency prompt where required.
Do Not Track and Global Privacy Control. Because we do not sell personal information or use it for targeted advertising, there is nothing to opt out of. We nonetheless honor Global Privacy Control (GPC) signals as a valid opt-out request where the law requires.
9. Data retention
We keep personal information only as long as we need it for the purposes in this policy, then delete or de-identify it:
- On-device data (including game progress, planner content, and Memory Tide face groups and names): stays on your device until you delete it in the app, reset the app's data, or delete the app;
- Support emails: kept for up to 24 months after your issue is resolved, unless we need them longer to comply with law or resolve a dispute;
- Information about children received by mistake: deleted as soon as we discover it;
- Website server logs: kept by our hosting provider for a short period for security purposes.
10. Security
We use reasonable administrative, technical, and physical safeguards designed to protect information, including encryption in transit (HTTPS), access controls, and limiting the information we collect in the first place. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If a data breach affecting your personal information occurs, we will notify you and the authorities as the law requires.
11. International transfers
KKA is based in the United States, and our service providers may process information in the United States and other countries. When we transfer personal data from the EEA, UK, or Switzerland, we rely on lawful transfer mechanisms such as the European Commission's Standard Contractual Clauses (and the UK Addendum) or our providers' certifications under the EU–U.S. Data Privacy Framework.
12. Your privacy rights
Depending on where you live, you may have the right to:
- Know and access the personal information we hold about you;
- Correct inaccurate information;
- Delete your information;
- Port your information in a usable format;
- Object to or restrict certain processing;
- Withdraw consent at any time, without affecting earlier processing;
- Opt out of the sale or sharing of personal information, targeted advertising, or profiling (we do none of these);
- Appeal our decision on your request; and
- Complain to your local data protection authority.
We will not discriminate against you for exercising any of these rights. Because most game data lives only on your device, you can also exercise control directly by resetting a Game's data or deleting the Game.
13. Additional U.S. state disclosures
These disclosures apply to residents of California and other U.S. states with comprehensive privacy laws, including Colorado, Connecticut, Virginia, Utah, Texas, Oregon, and others.
- Categories collected in the past 12 months: identifiers (such as the email address you use to contact us, and IP address when you visit the Site); commercial information (confirmation of Apple purchases); and internet or device activity (de-identified diagnostics and website logs). Game progress and settings are stored on your device and are not collected by us.
- Sources: you, your device, and Apple.
- Purposes: the business purposes listed in Section 4.
- Disclosures: to the service-provider categories listed in Section 6, for business purposes only.
- Sale and sharing: we have not sold or shared personal information, including that of consumers under 16, in the past 12 months, and we have no actual knowledge of doing so.
- Sensitive personal information: we do not collect sensitive personal information, including precise geolocation or biometric information, and we do not use any information to infer characteristics about you. Photo, face, and photo-location processing in Memory Tide occurs only on your device and is not collected by us.
- Shine the Light: we do not disclose personal information to third parties for their own direct marketing.
14. How to make a request
Email gameadmin@gamehouseclub.com with the subject line "Privacy Request" and tell us what you would like us to do. To protect you, we may need to verify your identity, usually by confirming details only you would know or by replying to the email address you contact us from. You can use an authorized agent, but we may ask for proof that they are authorized.
We will respond within the time the law requires, generally within 30 days (45 days in some U.S. states, extendable where permitted). If we deny your request, we will explain why, and you may appeal by replying with "Appeal" in the subject line. If your appeal is denied, you may contact your state attorney general or data protection authority.
15. Third-party services and links
The Services may link to or work with services run by others, such as the App Store, Game Center, iCloud, and Google Fonts. We are not responsible for their privacy practices, and we encourage you to read their policies, including Apple's privacy policy at apple.com/legal/privacy.
16. Changes to this policy
We may update this policy from time to time. When we do, we will change the "Last updated" date above, and if the changes are material, we will give you notice through the Site, the Games, or another appropriate method before they take effect. Where the law requires, we will ask for your consent.
17. Contact us
KKA & Associates LLC, d/b/a Game House Club
Email: gameadmin@gamehouseclub.com
Website: gamehouseclub.com