1. Introduction
This Data Processing Addendum (“Addendum”) forms part of the agreement between You and Creative Instincts Studio (“Processor”) regarding the use of any software, game, application, or digital service (“Product”). This Addendum explains how Creative Instincts Studio processes personal data on Your behalf.
2. Definitions
- “Personal Data” means any information relating to an identified or identifiable individual.
- “Processing” means any operation performed on Personal Data, including collection, storage, use, or deletion.
- “Controller” means the individual or entity that determines the purposes and means of processing Personal Data (You).
- “Processor” means the individual or entity that processes Personal Data on behalf of the Controller (Creative Instincts Studio).
3. Roles and Responsibilities
3.1 Controller Responsibilities
You determine what Personal Data is collected and how it is used. You are responsible for ensuring that Your use of the Product complies with applicable laws.
3.2 Processor Responsibilities
Creative Instincts Studio processes Personal Data only:
- As necessary to operate and improve the Product
- As instructed by You
- As required by law
Creative Instincts Studio does not sell, rent, or share Personal Data with third parties for marketing purposes.
4. Types of Data Processed
Depending on the Product, Creative Instincts Studio may process:
- Device information (model, OS version, crash logs)
- Gameplay or app usage data
- User preferences or settings
- Account or profile information (if applicable)
- IP address or region (for analytics or security)
Creative Instincts Studio does not intentionally collect sensitive data unless explicitly required by the Product.
5. Purpose of Processing
Personal Data may be processed for:
- Operating and maintaining the Product
- Improving performance, stability, and features
- Analytics and usage insights
- Security, fraud prevention, and abuse detection
- Customer support and troubleshooting
All processing is limited to what is necessary for the Product to function.
6. Sub‑Processors
Creative Instincts Studio may use trusted third‑party service providers (“Sub‑Processors”) for:
- Analytics
- Cloud hosting
- Crash reporting
- Payment processing (if applicable)
A list of Sub‑Processors is available upon request. Creative Instincts Studio ensures all Sub‑Processors follow data protection standards consistent with this Addendum.
7. Data Security
Creative Instincts Studio implements reasonable technical and organizational measures to protect Personal Data, including:
- Encryption where appropriate
- Access controls
- Secure data storage
- Regular security reviews
No method of transmission or storage is 100% secure, but Creative Instincts Studio takes appropriate steps to reduce risk.
8. Data Retention
Personal Data is retained only as long as necessary for:
- Operating the Product
- Legal compliance
- Resolving disputes
- Maintaining security
When data is no longer needed, it is securely deleted or anonymized.
9. Data Subject Rights
Depending on Your region, You may have rights to:
- Access Your Personal Data
- Request correction or deletion
- Restrict or object to processing
- Request data portability
Requests can be submitted to: [email protected]
10. International Transfers
If Personal Data is transferred outside Your region, Creative Instincts Studio uses appropriate safeguards such as:
- Standard contractual clauses
- Secure transfer mechanisms
- Compliance with applicable laws
11. Breach Notification
In the event of a data breach affecting Personal Data, Creative Instincts Studio will notify You without undue delay and provide relevant information as required by law.
12. Termination
Upon termination of Your use of the Product, Creative Instincts Studio will:
- Stop processing Personal Data
- Delete or return Personal Data upon request, unless legally required to retain it
13. Changes to This Addendum
Creative Instincts Studio may update this Addendum as needed. Continued use of the Product after changes constitutes acceptance of the updated terms.
14. Contact Information
For questions about this Addendum or data practices, contact: