1. Scope and Controller
This Privacy Policy describes how the operator of Sanwan Archive ("Sanwan Archive," "we," "us," or "our") collects, uses, discloses, stores, and protects personal information when you use the app or contact us.
Sanwan Archive is currently designed as a local-first app. Most gameplay and preference data is stored on your device. If you contact us by email, enable a future cloud feature, or use platform services such as app distribution, additional information may be processed as described below.
For privacy questions, rights requests, withdrawals of consent, access or correction requests, and complaints, contact us at sanwancyl@163.com.
2. Quick Summary
3. Information We Handle
The categories below reflect the current app design and disclosures required or commonly expected under privacy laws in California, Canada, Singapore, and Australia.
| Category | Examples | Source | Retention |
|---|---|---|---|
| Save and profile data | Save-slot names, active slot, completed cases, collected evidence IDs, solved relationships, timeline order, achievements, ratings, streak days, play time, current case ID. | Created by your app use and stored locally. | Until you delete or reset saves, delete the app, or remove local files. |
| Preferences | Language choice, text size, music volume, sound volume, animation setting, auto-save setting. | Provided by you through settings or generated by app defaults. | Until you change settings, reset preferences, or delete the app. |
| Photos and photo metadata | Imported images, original file name, local file path, case assignment, location hint, import timestamp. | Provided by you when you import or assign photos. | Until you delete photos, reset relevant records, delete the app, or remove local files. |
| Exported and imported files | Save-slot JSON that may include progress, settings, ratings, collections, and photo references. Exported JSON is not intended to include photo binary files. | Generated or provided by you when you export or import saves. | Under your control once exported; local imported data remains until deleted or overwritten. |
| Support communications | Email address, message content, attachments you choose to send, and related troubleshooting details. | Provided by you when you contact us. | As long as reasonably needed to respond, maintain records, resolve disputes, and comply with law. |
| Platform and diagnostic data | App distribution, crash, device, or payment information handled by Apple or other app platforms under their own policies. The current app code does not intentionally collect device identifiers through our own server. | App platform or operating system, where applicable. | Handled by the relevant platform or retained by us only if we receive it for support or compliance. |
4. How We Use Information
We use personal information for purposes that are reasonable and appropriate for the app, including:
- Providing game features such as save slots, case progress, clue boards, memory replay, achievements, collections, and settings.
- Using imported photos as local scene or memory replay backgrounds when you choose to import them.
- Letting you export, import, duplicate, rename, switch, or delete save slots.
- Responding to support, privacy, access, correction, deletion, complaint, and consent withdrawal requests.
- Maintaining security, preventing misuse, debugging issues, and improving app reliability.
- Complying with legal obligations, regulatory requests, and enforceable rights.
Depending on your location, our legal bases or permitted grounds may include your consent, performance of the app relationship, compliance with law, legitimate or reasonable purposes, and protection of rights and safety. We seek to limit collection, use, and disclosure to what is necessary or reasonable for the identified purposes.
6. Regional Privacy Notices
California Notice at Collection and CCPA/CPRA Rights
If the California Consumer Privacy Act, as amended by the California Privacy Rights Act, applies to us and to your personal information, you may have rights to know, access, receive portability, delete, correct, opt out of sale or sharing, limit certain uses of sensitive personal information, and be free from discrimination for exercising your rights.
The categories of personal information we may collect are listed in Section 3. The purposes are listed in Section 4. The categories of third parties are listed in Section 5. We do not sell personal information and do not share personal information for cross-context behavioral advertising in the current version. We do not use sensitive personal information for purposes that require a right to limit under California law in the current version.
Canada: PIPEDA and Substantially Similar Laws
We aim to follow fair information practices, including accountability, identifying purposes, consent, limiting collection, limiting use, disclosure and retention, accuracy, safeguards, openness, individual access, and complaint handling. You may request access to or correction of your personal information and may withdraw consent subject to legal and contractual limits.
Singapore: PDPA
We aim to process personal data for notified purposes with appropriate consent or another lawful basis, to provide access and correction rights, to protect personal data, to retain it only as needed, and to use appropriate safeguards for overseas transfers where applicable. You may withdraw consent by contacting us, subject to legal or operational consequences that we will explain where required.
Australia: Privacy Act and Australian Privacy Principles
We aim to handle personal information openly and transparently, collect only what is reasonably necessary, use and disclose it for appropriate purposes, avoid direct marketing unless lawful, take reasonable steps to protect information, and provide access and correction rights where required. If you are not satisfied with our response to a privacy complaint, you may contact the Office of the Australian Information Commissioner.
7. How to Exercise Your Rights
To exercise privacy rights, contact us at sanwancyl@163.com. Please describe your request and the region whose law you believe applies. We may need to verify your identity or authority before fulfilling a request.
- Access and portability. You may request information about personal information we hold about you, where applicable.
- Correction. You may ask us to correct inaccurate information we hold, where applicable.
- Deletion. You may request deletion of information we hold, subject to legal exceptions. For local-only data, you can usually delete or reset it through the app, device, or file controls.
- Consent withdrawal. You may withdraw consent where processing is based on consent, subject to legal or practical consequences.
- Objection, opt-out, or limitation. Where applicable, you may object to certain processing or opt out of sale, sharing, direct marketing, or targeted advertising. The current version does not sell or share personal information for targeted advertising.
- Authorized agents. If applicable law allows an authorized agent to act for you, we may require proof of authorization and identity verification.
- Appeals and complaints. You may complain to us, and you may also contact your local privacy regulator where you have that right.
We will respond within the time required by applicable law. For California requests, this is generally within 45 days unless an extension is permitted. For Canada, Singapore, and Australia, we will respond within the period required by applicable law or within a reasonable time.
8. Retention and Deletion
Local save data, preferences, photo records, and imported photos are retained on your device until you delete or reset them, overwrite them, delete the app, or remove the relevant files. We cannot delete files that remain solely on your device unless the app provides a local deletion function you choose to use.
Support emails and related records may be retained for as long as reasonably necessary to respond, keep business records, resolve disputes, protect rights, and comply with law. Exported save files and shared photos are under your control once you send or store them outside the app.
9. International Transfers
Local app data is generally stored on your device. If you contact us by email, use a future cloud feature, or interact with an app platform, your information may be processed in countries or regions other than where you live. Where required, we use reasonable safeguards and require service providers to protect personal information in line with applicable law.
10. Security
We use reasonable administrative, technical, and organizational measures appropriate to a local-first app. You can help protect your information by securing your device, limiting who can access exported saves and photos, avoiding unnecessary sensitive information in support emails, and keeping your operating system up to date.
No method of storage or transmission is completely secure. If we become aware of a data breach that requires notification under applicable law, we will take steps required by that law.
11. Children and Young People
The app is not intended for children under 13. We do not knowingly collect personal information from children under 13. If you believe a child has provided personal information to us, contact us and we will take appropriate steps. If your local law requires parental or guardian consent for users above age 13, the user must have that consent before using the app.
13. Policy Updates
We may update this Privacy Policy from time to time. The updated version will be shown with an updated effective date or similar notice. If a change materially affects how we handle personal information, we will provide notice or seek consent where required by law.
14. Contact, Requests, and Complaints
Contact us at sanwancyl@163.com for privacy questions, requests, withdrawals of consent, access or correction requests, deletion requests, opt-out requests, and complaints.
Please avoid sending sensitive photos, government IDs, passwords, or unrelated personal information unless we specifically request it for verification or support and you agree to send it.