Privacy Policy for Copper Coin B.V.

Last Updated: August 11, 2026

1. Introduction and Scope

This Privacy Policy explains how Second Half Holdings B.V. (the "Licensor," "IP Owner," or "we") and its authorized developer, Copper Coin B.V. (the "Developer"), collect, use, and disclose information related to:

Your registration as a playtester for our video games.

Your use of the Serenity Sketch app (the "App" or "Software"), including any in-app purchases.

Your subscription to our newsletter or other marketing communications.

By using the App, signing up as a playtester, or subscribing to the newsletter, you agree to the collection and use of information in accordance with this policy. References to "we," "us," or "our" refer collectively to both the Licensor and the Developer acting on its behalf.

2. Information We Collect and How We Use It

We collect the following categories of information, depending on how you interact with us.

A. Information Collected via Playtester Sign-up/Newsletter (Personal Data)

Email address: Collected to contact you about playtesting opportunities, send invites, schedules, feedback requests, and, if you opt in, communicate news and updates about our games and company.

B. Information Collected via App Use (Technical and Gameplay Data)

When you use the App, we collect the following technical and gameplay data to support the App, provide customer support, and improve game design and performance. This data is collected in anonymized or non-directly-identifying form:

Technical Information: device model, operating system version, App version, crash reports, and error logs.

Gameplay Information: session count and duration, levels/Practices completed, and progression through the App.

This information, along with app-usage events such as level/session start and completion, paywall views, and purchase completions, is collected using TelemetryDeck, a third-party analytics service. TelemetryDeck does not use advertising identifiers, does not use cookies, and does not engage in cross-app tracking. Your device is identified using a randomly generated identifier that is salted and hashed both on your device and again on TelemetryDeck's servers, so that neither TelemetryDeck nor we can reconstruct your original identifier.

C. Purchase and Entitlement Information

When you make an in-app purchase, Apple processes your payment directly; we do not receive or store your payment card details. We use RevenueCat, a third-party entitlement management service, to record which content you are entitled to. This may include a RevenueCat-generated account identifier tied to your purchase and entitlement status. This information is used solely to grant you access to content you have purchased.

D. Future Collection of User Generated Content (UGC)

The App is a painting game, and in the future, it may allow you to create, modify, or submit content (e.g., digital paintings, asset modifications), referred to as "User Generated Content" or "UGC."

Currently: We do not collect any UGC through the App.

Future Collection: If/when UGC features are implemented, the App will collect the UGC you choose to create or submit. This Policy will be updated, and you will be notified of the change before such collection begins. By submitting UGC, you grant us the license outlined in the EULA to use it for promotional and improvement purposes.

3. Legal Basis for Processing (GDPR)

We only process your personal data when we have a lawful basis to do so under GDPR.

Email Address — Legal Basis: Consent (Art. 6(1)(a)). You actively subscribe to the playtester list or newsletter, granting explicit permission for this specific use. You may withdraw consent at any time via the unsubscribe link.

Technical and Gameplay Data — Legal Basis: Legitimate Interest (Art. 6(1)(f)). We have a legitimate interest in monitoring the technical performance and optimizing the game for the benefit of all users, provided the data is fully anonymized and non-identifiable.

Purchase and Entitlement Data — Legal Basis: Performance of a Contract (Art. 6(1)(b)). Processing this data is necessary to deliver the paid content and benefits you have purchased.

4. How We Share Your Information

We will not sell or rent your information to third parties. We may disclose the collected data in the following circumstances:

Internal Sharing: Information is shared between the Licensor (Second Half Holdings B.V.) and the Developer (Copper Coin B.V.) for the necessary purposes of game development, support, and business operations.

Service Providers & International Data Transfers: We share data with Apple (for processing in-app purchases), RevenueCat (for entitlement management), and TelemetryDeck (for anonymized app-usage analytics), and may share data with email management platforms that assist us in operating our business. As these providers may be located outside the European Economic Area (EEA), such as in the United States, your information may be transferred internationally. We ensure these transfers are protected by implementing appropriate safeguards, such as Standard Contractual Clauses (SCCs), to ensure your data receives a level of protection consistent with EU data protection law.

Legal Compliance: We may disclose your information if required by law or in the good faith belief that such action is necessary to comply with a legal obligation, protect our rights or property, or ensure the safety of our users or the public.

5. Children's Privacy

The App has an App Store age rating of 9+ and is intended for a general audience. We do not knowingly collect personal data from children under the age of 13 (or under 16 where a stricter threshold applies under local law). If you believe a child has provided us with personal data, please contact us at josh@coppercoin.nl and we will take steps to delete it.

6. Security and Protection of Information

We take reasonable and industry-standard measures to protect the information we collect from unauthorized access, use, or disclosure. These measures include:

Access Control: Limiting access to your email address and associated personal data to authorized personnel only.

Storage: Storing your data in secure, controlled environments.

Anonymity: Collecting and using gameplay and technical data in an anonymized, non-personally identifiable form.

However, you should be aware that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

7. Data Retention

Playtester Email Address: We retain your email address until you request its deletion or unsubscribe from the mailing list.

Technical and Gameplay Data: We retain this data only for as long as is necessary for the purposes set out in this Policy. This data is then deleted or permanently anonymized.

Purchase and Entitlement Data: Retained for as long as necessary to administer your entitlements, and otherwise in accordance with Apple's and RevenueCat's own retention practices.

8. Your Rights (Email/Personal Data)

You have the following rights regarding your email address under GDPR:

Access: Request access to the email address we hold for you.

Rectification: Request correction of any inaccurate or incomplete information.

Erasure: Request that we delete your email address from our records.

Objection/Unsubscribe: You can object to the processing of your email address for direct marketing purposes and can unsubscribe from our email list at any time by clicking the "unsubscribe" link in any email we send you.

Right to Complain: You have the right to lodge a complaint regarding our data processing with a supervisory authority, specifically the Autoriteit Persoonsgegevens (AP) in the Netherlands.

9. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact the Developer:

Company: Copper Coin B.V.

Email: josh@coppercoin.nl

KvK number: 93096615