Privacy Notice

1. Who is responsible for your data

EMPIRE is operated by Lacey Rochelle, who acts as the data controller for the personal data described in this notice. That means the seller determines how and why your personal data is processed.

2. What we collect and why

We collect the following categories of personal data:

• Operational player identifier: a random ID stored in your browser, used to link your premium subscription to your device and to keep your game progress.
• Gameplay and usage data: decisions, scenario progress, achievements, are stored as needed to provide requested gameplay. For every visitor, Empire keeps anonymous daily totals: page views, fresh visits, the kind of site you came from (for example Google or ChatGPT), device type (mobile, tablet or desktop), country, approximate city, and how far games get (for example game started or month 3 reached). These totals use no cookies or stored identifiers and contain nothing that identifies you or links one visit to another. A more detailed Empire visit record, and ad measurement by Meta and OpenAI, run only if you tap Allow. Decline, withdrawal and browser privacy signals block them. Mixpanel and Ghaze are no longer used.
• Typed custom answers: if you use "Make your own decision", the text you type is sent to OpenAI, through Lovable's AI gateway, solely to interpret it within the game, together with the question, choices and a summary of game numbers. The request disables response storage, and the gateway currently labels this model’s Responses endpoint as zero-retention. This does not establish that every gateway log, infrastructure copy or backup is immediately erased. New operational records retain only the identifiers and outcome fields needed to enforce answer allowances and recover requested decisions, not the typed answer or optional visit attribution. Historical saved answers may still contain the answer, player identifier, game, question and outcome, and may link to earlier browser or account activity; they are not anonymous. New analytics permissions do not authorise historical account linkage. OpenAI and Lovable process the request; authorised hosting and database providers may also process stored data. The application restricts historical saved-answer review to authorised administrators. Please don't include personal details. An automated daily job is intended to remove records older than 90 days; removal can take until the next successful daily run. It removes the typed text and every identifying field (player, session and account identifiers, referral and campaign data), leaving only the game, question, outcome and date. You can ask us to delete your answers sooner using “Request deletion of my custom answers” in the feedback form from the same browser you used to submit them, or see Your rights below.
• Support messages: if you contact us, the content of those messages, used to help you.
• Consent preferences: a separate random browser credential and its server-side hash remember your current notice version, analytics choice, separate advertising choice and revision. These preference records are not used to identify you in gameplay or measure refused visits. Withdrawal stops optional browser delivery immediately; server confirmation blocks old permissions from collecting further analytics. If offline, the preference remains pending and is retried before analytics can resume.
• Technical data: IP address, device and browser identifiers and similar telemetry, used for security, fraud prevention and product improvement.
• Approximate location: the country and city your connection appears to come from, worked out by our hosting provider at the time of each visit. We store only the country and city, never your full IP address, and use them to understand where consenting browsers come from. Optional visit location collection requires current analytics permission. The anonymous daily totals include only a country and approximate city count for each fresh visit. City is often approximate or missing.
• Traffic source data: sanitized referral domains and campaign (UTM) parameters, collected with analytics permission, used to understand how players find EMPIRE.

Payment details (card numbers, billing address, purchase tax data) are collected and processed directly by Stripe, our payment provider. We never see or store your full card details.

3. Legal bases

We process personal data on the following bases: performance of our contract with you (providing the game and your subscription), our legitimate interests (security, fraud prevention, analytics and product improvement), your consent where required (optional marketing or non-essential cookies), and compliance with legal obligations (tax and accounting records).

4. Who we share data with

• Stripe (payment provider): for the sale of the product, subscription management, payments, tax compliance and invoicing.
• Service providers and subprocessors: hosting, database and analytics providers that process data on our behalf to operate the service.
• AI service provider (OpenAI): your typed custom answers are sent to OpenAI, through Lovable's AI gateway, to interpret them during play; the gateway is configured with response storage disabled; its model listing labels this endpoint zero-retention. We have not independently verified every intermediary’s log retention or processing location.
• Advertising measurement (Meta and OpenAI): only after you separately allow advertising measurement, advertising pixels may use browser storage and connection information to attribute visits to advertisements. Global Privacy Control and Do Not Track block optional analytics and advertising. We do not supply names, emails, player identifiers or typed answers to the OpenAI advertising pixel, and do not send gameplay events to it. After Stripe confirms a paid new subscription, we report a plan-enrollment event for advertising measurement, only with Accept and no applicable opt-out. No subscription identifier or payment amount is included. Decline or withdrawal disables its measurement consent.
• Professional advisers: legal and accounting advisers where necessary.
• Authorities: where we are required to disclose data by law.

5. International transfers

Some of our service providers (including Stripe and our hosting infrastructure) process data outside Australia. Where personal data is transferred internationally, we rely on appropriate safeguards such as standard contractual clauses or adequacy decisions.

6. Retention

We keep personal data only for as long as needed for the purposes above: generally while your player record is active, plus any period required for legal, tax or accounting obligations. Game progress stored locally in your browser stays there until you clear your browser storage. Data that is no longer needed is deleted or anonymised.

Custom-answer removal applies to the active application database, including stored derived details on those custom-answer records. Game history on your device, related gameplay records, restricted service logs, backups and any copies previously exported may have separate retention. We cannot promise immediate erasure from those systems; their applicable retention periods and any additional deletion required must be checked when handling a request.

7. Your rights

Depending on where you live, you may have the right to access, correct, delete, restrict or port your personal data, to object to processing, and to withdraw consent at any time. Australian users may complain to the Office of the Australian Information Commissioner (OAIC); users in the UK/EEA may complain to their local supervisory authority. We respond to verified requests within one month. To exercise any right (including deleting typed custom answers sooner than the automatic 90-day removal), use the feedback link at the bottom of the home page, or the support link in your payment receipt if you're a paying customer.

The deletion-request action verifies this browser’s private player key without requiring payment, a sign-in or an email. An administrator can remove this browser’s custom-answer records’ text and linking fields from the active database and mark the request completed. If you no longer have that browser, provide the approximate game, question and submission date in your message; do not paste the original answer or private key. We may need proportionate verification before acting. An optional email lets us confirm completion. The request itself is retained as support correspondence.

8. Security

We apply appropriate technical and organisational measures, including encryption in transit, access controls and least-privilege access to production systems.

9. Cookies and local storage

EMPIRE uses essential browser storage to save your game progress, your operational player ID and your subscription status. These are required for the service to work. We use optional analytics storage only with current permission. Meta and OpenAI advertising measurement may use non-essential cookies only with separate advertising permission; you can withdraw consent using the preferences above. You can clear this storage at any time through your browser settings, which will reset your local progress.

10. Changes and contact

We may update this notice from time to time; the "last updated" date above shows the current version. Questions about privacy: contact the seller, Lacey Rochelle, via the feedback link on the home page, or the support link in your payment receipt if you're a paying customer.