Privacy Policy for Copper Coin B.V.

Last Updated: 06 November 2025

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:

  1. Your registration as a playtester for our video games.

  2. Your use of the Serenity Sketch Demo (the "App" or "Software").

  3. 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 two main categories of information, depending on whether you are using the app or signing up for the playtester list/newsletter.

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

Information Collected and Purpose:

  • 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 (Non-Personal Usage Data)

When you use the Serenity Sketch Demo App, we automatically collect the following anonymized usage and technical data (Non-Personal Information) to facilitate beta testing, support, and game improvement. This data is collected in a form that does not directly identify you.

Information Collected and Purpose:

  • Gameplay Information: Collected for understanding play duration, levels played, frequency of sessions, and game progression rates.

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

  • Non-Persistent IDs: Anonymized identifiers assigned to your device solely for analytics and performance tracking.

Purpose of Use: This data is used solely for product improvement (refining game design, adjusting difficulty, enhancing performance) and beta testing/support (monitoring for technical issues, analyzing crashes).

C. 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 (email address) when we have a lawful basis to do so under GDPR.

Processing Basis for Personal Data (Email Address):

  • Data Type: Email Address

  • Legal Basis: Consent (Art. 6(1)(a))

  • Rationale: 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.

Processing Basis for Non-Personal Data (Anonymized Usage Data):

  • Data Type: Anonymized Usage Data

  • Legal Basis: Legitimate Interest (Art. 6(1)(f))

  • Rationale: We have a legitimate interest in monitoring the technical performance and optimizing the game for the benefit of all users and the final product, provided the data is fully anonymized and non-identifiable.

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 may share data with third-party service providers (such as Google Firebase for analytics, and email management platforms) who 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. 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.

6. Data Retention

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

  • Usage Data: We retain collected usage and technical data only for as long as is necessary for the purposes set out in this Policy (typically the duration of the beta test and a reasonable period thereafter). This data is then deleted or permanently anonymized.

7. 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.

8. Contact Us

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

Copper Coin B.V.

  • Email: josh@coppercoin.nl

  • KvK number: 93096615