HOLY TOWER GAMES — PRIVACY POLICY

Last Updated: June 2026

Welcome to Holy Tower Games! This Privacy Policy explains how Holy Tower Games ("we," "us," or "our") collects, uses, discloses, and safeguards your personal data when you visit our website (the "Site"), purchase or play our premium games on Steam or other PC platforms (the "Games"), or otherwise interact with us (collectively, the "Services").

We are committed to respecting your privacy and protecting your personal data in accordance with applicable data protection laws, including the UK Data Protection Act, the EU General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA).

1. INTRODUCTION & CONTACT DETAILS

Who We Are

Holy Tower Games is an independent game development studio specializing in premium PC games.

• Company Name: Holy Tower Games
• Mailing Address: Ds. Dersalam 06/01, Kec. Bae, Kab. Kudus, Jawa Tengah, Indonesia 59321
• Contact Email: [email protected]

For the purposes of applicable data protection legislation, Holy Tower Games is the Data Controller of your personal data collected directly through our website, future newsletters, and direct support interactions.

Please note: When you purchase or play our Games on Steam, Valve Corporation (operator of the Steam platform) acts as an independent data controller for your purchase transaction data and Steam account data. We encourage you to review Steam’s Privacy Policy to understand how they handle your data. All in-game progress, cloud saves, and achievements are managed entirely through Steam's native systems.

2. AGE REQUIREMENTS & CHILDREN'S PRIVACY

Our Services are not designed for or intentionally targeted at children under the age of 13 (or under 16 in certain jurisdictions within the EU/EEA). We do not knowingly collect, solicit, or market to children.

If we learn that we have inadvertently collected personal data from a child under the minimum age threshold without verifiable parental consent, we will take immediate steps to delete that information from our systems. If you believe we have accidentally collected data from a child, please contact us at [email protected].

3. THE DATA WE COLLECT AND HOW WE USE IT

Because we develop premium, pay-to-play Games, we do not display third-party behavioral ads, sell your game-play data, or use invasive ad-tracking networks within our Games. We limit our data collection to the absolute minimum required to provide, support, and improve our Games and Site.

The table below outlines the categories of data we collect, our sources, and how we use them:

4. COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small text files stored on your device when you visit websites.

We use cookies to:

1. Ensure Basic Site Functionality: Essential cookies that keep the website secure or remember user-selected configurations.
2. Basic Analytical Insights: Non-essential cookies managed via Google Analytics to analyze anonymous user behavior (such as pages visited).

You can control your cookie preferences or disable them entirely through your web browser's settings. Since we do not run third-party advertising on our website, we do not place tracking cookies for targeted advertisement profiles.

5. DATA RETENTION

We will retain your personal data only for as long as is strictly necessary for the purposes set out in this Privacy Policy:

• Game/Steam Data: Retained as long as you maintain your Steam account and keep our game in your library.
• Enquiry Data: Retained for as long as needed to fully resolve your query and to refer to for future support trends.
• Newsletter Data: Retained until you opt-out or unsubscribe by clicking the link in any marketing email we send in the future.
• Website Server Logs: Automatically deleted or anonymized in accordance with Google Analytics' default retention policies.

6. DATA TRANSFERS & DISCLOSURE

Where is your data stored?

Because Holy Tower Games operates globally through platforms like Steam, your data may be transferred to and processed in countries outside of your home region (including the USA, EU, and Indonesia).

Whenever we transfer personal data out of the European Economic Area (EEA) or the UK to a country not recognized as providing an adequate level of data protection, we implement appropriate safeguards, such as Standard Contractual Clauses (SCCs) approved by the European Commission, to ensure your data remains secure.

Disclosure of Your Data

We do not sell your personal data. We may disclose your personal data only in the following limited circumstances:

• To Service Providers: Trusted third-party vendors who assist us with hosting, analytics (Google Analytics), and customer support. These processors are contractually bound to process your data only on our instructions and to maintain confidentiality.
• Compliance with Law: Where required by law, government authorities, or courts to defend our legal rights, investigate fraud, or prevent crime.
• Business Transfers: If Holy Tower Games is involved in a merger, acquisition, or sale of assets, your data may be transferred as part of that transaction, subject to standard confidentiality agreements.

7. YOUR RIGHTS UNDER GDPR (UK & EU RESIDENTS)

If you reside in the United Kingdom or the European Economic Area, you hold the following rights:

• Right of Access: Request a copy of the personal data we hold about you.
• Right to Rectification: Request that we correct any inaccurate or incomplete personal data.
• Right to Erasure ("Right to be Forgotten"): Request the deletion of your personal data under certain conditions.
• Right to Restriction of Processing: Request that we restrict how we process your data.
• Right to Data Portability: Request that we transmit your data to another organization in a structured, machine-readable format.
• Right to Object: Object to our processing of your personal data based on legitimate interests or direct marketing.
• Right to Withdraw Consent: Where our processing is based on your consent (such as future newsletters), you have the right to withdraw consent at any time.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days. If we cannot resolve your concern, you have the right to lodge a complaint with your local Data Protection Authority (for example, the ICO in the UK).

8. CALIFORNIA RESIDENTS' PRIVACY RIGHTS (CCPA/CPRA)

If you are a resident of California, the California Consumer Privacy Act (CCPA) provides you with specific rights.

Categories of Personal Information Collected (Last 12 Months):

We may collect, and have collected over the preceding 12 months, the following categories of personal information:

• Category A (Identifiers): Such as IP address, email address, Steam ID, or support contact details.
• Category F (Internet/Network Activity): Such as navigation paths, device operating system, and basic analytics of Site usage.
• Category G (Geolocation Data): Approximate physical location derived from IP address (typically limited to country/region).

We Do Not "Sell" or "Share" Your Data

Holy Tower Games has not sold or shared (for cross-contextual behavioral advertising) any personal information to third parties in the preceding 12 months.

Your Rights Under CCPA:

• Right to Know & Access: Request to know what categories of personal information we have collected, the sources, the business purpose, and the specific pieces of data we hold.
• Right to Delete: Request the deletion of your personal information, subject to legal exceptions.
• Right to Correct: Request corrections to inaccurate personal information.
• Right to Opt-Out: Because we do not sell or share personal information, you are already opted out.
• Right to Non-Discrimination: We will never discriminate against you for exercising your privacy rights.

To exercise your CCPA rights, email us at [email protected] with the subject line "CCPA Request" and details allowing us to verify your identity.

9. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our Games, business practices, or legal obligations. We will notify you of any material changes by updating the "Last Updated" date at the top of this policy and, if applicable, posting a notice on our Site or within Steam announcement forums.