Last updated: August 30, 2026
1. Introduction
SnowCloud Entertainment ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and safeguard information when you use Halo and Horns(the "App").
2. Data Controller
The data controller responsible for personal data processed in connection with this App is:
Dwight Gijzen, trading as SnowCloud Entertainment
Kastanjelaan 17, 6431 GL Hoensbroek, Netherlands
Email: info@snowcloud-entertainment.com
KvK: 42141785
3. Information We Collect
Information you provide: We do not require you to create an account or provide personal information to use the core features of Halo and Horns.
Automatically collected data: The App may collect anonymised analytics data such as crash reports, device type, operating system version, and general usage patterns to help us improve the App. This data cannot be used to identify you personally.
Game data:Progress, scores, and preferences may be stored locally on your device or, if enabled, synced via Apple's iCloud service. We do not have access to iCloud data.
4. Legal Basis for Processing (GDPR Article 6)
Where the GDPR applies, we process data on the following legal bases:
- Anonymised analytics and crash reporting: Legitimate interests (Article 6(1)(f)). We have a legitimate interest in understanding how the App performs and is used, in order to improve it. Because the data is anonymised and cannot identify you, this interest is not outweighed by your privacy rights.
- Responding to support requests: Legitimate interests (Article 6(1)(f)) or, where you have explicitly contacted us, performance of a contract or your consent.
- Local game data: This is stored solely on your device. We do not process it and no legal basis is required on our part.
5. How We Use Your Information
- To operate, maintain, and improve the App
- To diagnose and fix technical issues
- To understand how players use the App (anonymised)
- To respond to your support requests
6. Third-Party Services and International Transfers
The App may use third-party services such as Apple GameCenter for leaderboards and Apple's analytics framework. Apple Inc. is based in the United States. Where Apple processes data on our behalf outside the European Economic Area (EEA), Apple relies on Standard Contractual Clauses or other appropriate safeguards recognised under GDPR Chapter V. We encourage you to review Apple's Privacy Policy at apple.com/privacy.
We do not sell your data to third parties and we do not use your data for targeted advertising.
7. Children's Privacy
Our App is not directed to children under 16. We do not knowingly collect personal information from children under 16. If you believe your child has provided us with personal information, please contact us and we will promptly delete such information.
8. Data Retention
Anonymised analytics data is retained for up to 24 months for analysis purposes. Local game data remains on your device until you delete the App.
9. Your Rights
Under the GDPR and applicable national law, you have the right to access, rectify, erase, restrict, or object to the processing of your personal data, and the right to data portability where technically feasible. Because we collect minimal data and most of it is anonymised, most requests can be fulfilled by simply uninstalling the App. For other requests, contact us at the address in section 2.
10. Right to Lodge a Complaint
If you believe we are processing your personal data in violation of the GDPR, you have the right to lodge a complaint with the Dutch supervisory authority:
Autoriteit Persoonsgegevens
Postbus 93374, 2509 AJ Den Haag, Netherlands
autoriteitpersoonsgegevens.nl
11. Changes to This Policy
We may update this Privacy Policy from time to time. The updated version will be indicated by a new "Last updated" date at the top of this page. We encourage you to review this page periodically.
12. Contact Us
If you have any questions or concerns about this Privacy Policy, please contact the data controller at the address listed in section 2.