Privacy Policy

Effective date: 21 January 2026

Game/Service: This is BATTLE! (the “Service”)

Platforms: web (battle.anespiem.com), iOS and Android apps, Telegram (@this_is_battle_bot)

1) Who we are

Data Controller: Anespiem Private Limited

UEN: 202512394Z

D-U-N-S: 599597004

Registered office: 2 Venture Drive, #19-21 Vision Exchange, Singapore 608526

If you have any privacy questions or want to delete your character, contact us at mail@anespiem.com.

2) The short version (key points)

• No accounts, no registration. We do not ask for your real name, email, phone number, age, or address to use the Service.
• You create a character with a Nickname and an About (character story/bio). Please avoid putting real-world personal information there.
• Chat is real-time and not stored by us. We do not keep chat history on our application side.
• We do not run analytics, ads, profiling, or tracking.
• Payments are handled by third-party providers. We do not receive your card number. We may receive and store a limited purchase confirmation to deliver your purchase and handle refunds/support.
• If you email us (for example, to delete a character), we will process your email address and message to handle your request.

3) What information we collect (and what we do not)

We design the Service to collect as little data as possible.

A) Information you choose to provide

1. Character Nickname A nickname can become “personal data” if it identifies you (for example, if you use your real name or a unique handle tied to you). We recommend using a non-identifying nickname.

2. Character About (story/bio) You can optionally write a character story/bio. Please do not include real-world personal information.

3. Chat messages (content you send) If the Service has chat, messages are transmitted to other players in real time. We do not store chat history on our application side. Important: other players (or platform providers) may still be able to keep copies (for example, screenshots, device caches, or Telegram’s own systems). We do not control that.

4. Emails you send us (support / deletion requests) If you contact us at mail@anespiem.com, we receive your email address and the contents of your message (and any attachments). We use this only to respond and to process your request (including character deletion).

B) Payments (purchase-related information)

The Service offers optional paid features/content. Payments are processed by third-party providers:

• Web: Xsolla
• iOS: Apple App Store in-app purchases
• Android: Google Play in-app purchases
• Telegram: Telegram Stars

We do not collect or store your payment card details. Payment providers process payment information under their own privacy policies.

To deliver purchases and provide support (including refunds where applicable), we may receive and store limited purchase confirmation information, such as:

• the purchased item/content and its delivery status
• date/time of purchase
• amount and currency (or equivalent purchase value)
• a transaction/receipt identifier or purchase token provided by the platform/provider
• the platform used (web/Telegram/iOS/Android)
• the character identifier used inside the Service (to attach the purchase to the right character)

This purchase confirmation may be personal data if it can be linked to an individual (directly or indirectly). We use it only for purchase delivery, support, and compliance.

C) Technical data (minimized)

To deliver any online service, devices and networks must exchange technical information (for example, IP addresses at the network level). Our application is configured not to keep logs that record user IP addresses, user agents, request history, or endpoint trails. We keep only server-side error logs about our code behavior, without user-identifying details.

However:

• Our hosting provider may process network and security logs as part of providing hosting and protecting infrastructure (this is typical for hosting). These logs are controlled by the provider under their own policies and operational needs.

D) What we do not do

We do not:

• create user accounts or require registration
• collect real names, phone numbers, or ages
• collect advertising identifiers (IDFA/GAID)
• use Apple Game Center or Google Play Games
• run analytics/metrics
• collect crash reports
• do profiling, targeted advertising, or sell personal data

4) Why we use information (purposes)

We use the limited information described above only to:

• Provide the Service (showing Nickname and About, running game sessions)
• Deliver purchases (granting paid content to the correct character)
• Operate and secure the Service (basic reliability and security)
• Respond to you and process deletion requests when you email us

We do not use your information for marketing or advertising.

5) Legal bases (GDPR)

Where the GDPR applies, we rely on these legal bases:

• Performance of a contract (Article 6(1)(b)) To provide the Service features you request (including delivering purchases).

• Legitimate interests (Article 6(1)(f)) To keep the Service secure and working (e.g., limited operational error logging without user-identifying details), and to prevent or resolve payment/support issues.

• Legal obligation (Article 6(1)(c)) If we must retain certain records for tax, accounting, or legal compliance (especially purchase-related records).

• Consent (Article 6(1)(a)) Only where required. Currently, we do not run tracking or marketing that would typically require consent.

6) Who we share information with

We share personal data only when necessary:

• Payment providers (to process payments). Payments are processed by:

  • Xsolla (web)
  • Apple (App Store)
  • Google (Google Play)
  • Telegram (Telegram Stars)

These providers process payment-related information under their own privacy policies. We typically receive only purchase confirmations/receipts needed to deliver content and handle support.

• Email provider (Gmail/Google). Our support email is hosted on Gmail. Emails you send are processed and stored there so we can respond and handle requests.

• Hosting provider (Switzerland). We host the Service on a server located in Switzerland. The hosting provider may process limited technical data as part of providing hosting and infrastructure security.

• Platform providers (independent services). Telegram / Apple / Google may process technical and service data as platform providers. We do not control their internal retention.

We do not sell personal data and do not share it for advertising.

7) International transfers

We are a Singapore company. Your information may be processed in:

• Singapore (our company operations)
• Switzerland (hosting)
• Other countries where our service providers operate (for example, email or payment infrastructure)

When required, we use appropriate safeguards for international transfers, such as contractual protections provided by our service providers.

8) How long we keep information (retention)

• Nickname + About: stored while your character exists. If you ask us to delete your character, we will delete these character fields and associated character data (unless we must keep something for legal reasons—see below).

• Chat: not stored by us as chat history.

• Purchase confirmations/records: kept as long as needed to:

  • deliver and maintain your purchase/entitlements,
  • provide support/refunds where applicable,
  • and meet tax/accounting/legal obligations.

If you delete a character, we may keep purchase records that we must retain for legal or audit reasons, and we will aim to minimize linkage to in-game identity where feasible.

• Emails to support (mail@anespiem.com): stored in our Gmail inbox until we delete them. We keep them as long as needed to handle your request and for basic record-keeping. You can ask us to delete the email thread as well.

9) Your rights (GDPR)

If you are in the EEA/UK (and in other places with similar laws), you may have the right to:

• access your personal data
• request correction
• request deletion
• object to processing or request restriction
• request portability (where applicable)
• lodge a complaint with your local data protection authority

To exercise your rights, email mail@anespiem.com. Because we do not run accounts and do not store persistent identifiers, we may ask for minimal information to locate the right character or purchase (for example, your character nickname, platform, approximate time of last play, and—if relevant—purchase receipt/transaction ID).

10) Security

We use reasonable technical and organizational measures designed to protect the Service. No online service can be 100% secure, but we aim to minimize data and reduce risk by design.

11) Children

The Service does not ask for age and is not designed to collect personal data from children.

Content suitability: We aim to keep the game content suitable for approximately PEGI 12 (moderate fantasy violence / themes). This is a self-assessment and the Service may not be formally PEGI-certified.

If you are a parent/guardian and believe a child has sent us personal data (for example, by email), please contact us at mail@anespiem.com and we will address it.

12) Changes to this policy

We may update this Privacy Policy from time to time. If we make changes, we will update the “Effective date” at the top.

13) Contact

For privacy questions or deletion requests: mail@anespiem.com

Controller: Anespiem Private Limited (details in Section 1)