Privacy Policy
Effective 30 April 2026
Contents
1. Introduction
This Privacy Policy explains how Matthysen Holding BV ("we", "us") handles information when you use Orion: A Word Puzzle Game (the "App") on iOS. We have designed the App to collect no directly identifying information about you — no name, email, phone number, or password. The minimal data we do process is described below.
Matthysen Holding BV is the data controller for the purposes of the EU General Data Protection Regulation (GDPR) and the Dutch Implementation Act (UAVG).
2. Information we collect
What we don't collect
We do not ask for or store your name, email address, phone number, password, photo, contacts, or location. There is no sign-up form.
Anonymous account & gameplay progress
When you first open the App, an anonymous account identifier is generated and stored on your device. This identifier is used to save your gameplay progress to our database — level completions, achievements, in-game currency balances (Star Dust, Dream Dust), and purchase entitlements (e.g. Remove Ads). The identifier is a random string and is not linked to your real identity. Under GDPR, online identifiers can still constitute personal data, so we treat it as such.
Purchase information
In-app purchases are processed entirely by Apple. We never see your payment card, Apple ID, or billing address. We receive only a product identifier and a receipt indicator (via RevenueCat) so we can grant the purchased item to your anonymous account.
Advertising
The App displays ads via Google AdMob. If you grant App Tracking Transparency (ATT) permission, AdMob may receive your Identifier for Advertisers (IDFA) to serve personalised ads. If you decline, ads are non-personalised. We never receive your IDFA — it stays between your device and Google.
3. How we use information & legal basis
We process the limited data described above for the following purposes, on the following legal bases under Article 6 GDPR:
- Provide the App and save your progress — Art. 6(1)(b), performance of the contract between you and us.
- Deliver in-app purchases — Art. 6(1)(b), performance of the contract.
- Serve non-personalised advertising — Art. 6(1)(f), legitimate interest in funding the App.
- Serve personalised advertising (only if you opt in via ATT) — Art. 6(1)(a), your consent. You can withdraw consent at any time in iOS Settings → Privacy & Security → Tracking.
We do not use your data for profiling, scoring, or any decision with legal effect. We do not sell your data.
4. Third parties, processors & international transfers
We use the following processors, each contractually bound to protect data:
| Provider | Purpose | Data |
|---|---|---|
| Apple (Apple Distribution International, Ireland) | App distribution & in-app purchase | Handled entirely by Apple — we receive only the receipt |
| Supabase Inc. (United States) | Anonymous gameplay storage | Anonymous account ID, gameplay progress |
| RevenueCat Inc. (United States) | Purchase entitlements | Anonymous user ID, product ID, receipt |
| Google Ireland Ltd / Google LLC (AdMob) | Advertising | IDFA (only if you grant ATT), device info |
Some of these providers process data outside the EEA, including in the United States. Where this happens, transfers are protected by the European Commission's Standard Contractual Clauses and, for Google and other certified entities, the EU–U.S. Data Privacy Framework.
We do not sell or share data with any party not listed above.
5. Children's privacy
The App is rated 4+ and is suitable for general audiences. We do not knowingly collect personal information from children. If you believe a child has somehow provided us personal information, contact us and we will investigate and erase it.
6. Your rights & deleting your account
You can delete your account and all associated gameplay data at any time, directly from within the App: Profile → Delete Account. Deletion is immediate and permanent.
Under the GDPR you also have the right to: access the data we hold about you, request correction or erasure, restrict or object to processing, request data portability, and withdraw consent (where processing is based on consent). To exercise any of these rights, contact help@orionwordgame.com.
7. Data retention
Anonymous gameplay data is retained while your account exists. When you delete your account from the Profile screen, all associated data is erased immediately, except where retention is required by law (e.g. Apple's purchase records for tax compliance, which Apple — not we — control).
8. Security
We use industry-standard safeguards including TLS encryption in transit, encryption at rest, and row-level access controls so each anonymous account can only access its own row. No system is perfectly secure, but we work to protect data continuously.
9. Changes to this policy
We may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated effective date. Continued use of the App after the effective date constitutes acceptance.
10. Contact
Questions about this policy or your data? Contact us at:
DREAMPRISM
A Game Studio
Email: help@orionwordgame.com
Web: dreamprism.games