Privacy policy

Who is responsible

The data controller is Benjamin Caballero, entrepreneur individuel (EI), a micro-enterprise established in France, trading as Midnight Condor. Privacy contact: [email protected]. Professional address: 5 impasses du petit Nice, 16000 Angoulême, France.

Midnight Condor is responsible for multiplayer profiles, support requests and optional statistics and crash reports. Google and its partners also process advertising data according to their roles and the choices presented in the game.

• Legal notice
• Contact

Merge District

Merge District is a free solo game intended for people aged 18 and over. It works offline without a player account, Google sign-in, remote profile, multiplayer, leaderboard or chat. Neighbours are game characters. Progress, saves, preferences and your custom city name stay in the application on your device.

Optional repair and energy reminders are local Android notifications, without a server push service. Local data remain until the corresponding application data are removed; “Erase and restart” archives old saves and does not erase all local copies. Any device or platform backups are separate and depend on their settings.

The game offers only optional rewarded Google AdMob ads, without real-money in-app purchases or subscriptions. Google User Messaging Platform (UMP) updates privacy information at each normal launch and may contact Google before you request a bonus. This alone does not initialize the ad delivery SDK or load an ad. Ads require your voluntary request and permission from UMP; this may allow limited or non-personalized ads and does not necessarily mean consent to personalization. Advertising choices and this policy are available in settings. Refusing ads or playing offline does not block normal gameplay.

To manage privacy choices, UMP may contact Google and process the IP address, the region derived from it, and application and device information. Depending on how Google’s service is configured, technical diagnostics about consent operations may also be transmitted, including their duration and success or error states. These operations help update privacy information, present applicable messages and operate and diagnose this service. They may occur before you make an advertising choice or even if you refuse ads, without loading an ad or initializing the ad delivery SDK. Disabling AdMob crash reporting does not disable these UMP diagnostics. Their retention follows Google’s criteria for this service, security and legal obligations.

For advertising, Google and any applicable partners may process IP addresses and derived approximate location, device and application data, ad interactions, diagnostics and technical identifiers for ad delivery, measurement and fraud prevention. The AdMob SDK may also process the app set ID for fraud prevention. This identifier is excluded from ad personalization and ad measurement. Merge District removes the Android advertising ID and AdServices permissions; Firebase advertising ID collection and AdMob publisher first-party identifiers are disabled. AdMob’s own crash reporting is disabled, separately from Crashlytics. Other technical identifiers and personal data may still be processed. The privacy form and Google’s linked rules identify purposes, partners and legal bases: consent where required, including personalization and device access or storage, and legitimate interests for permitted security or fraud-prevention operations, with withdrawal or objection rights where applicable.

Firebase Analytics and Crashlytics are two independent options, both off by default and separate from advertising choices. Firebase is not initialized when both are off. With your consent, Analytics helps us understand and improve gameplay through screens, sessions, starting a game, producing or merging materials and completing a construction stage, with section/language context. The SDK may process instance or installation identifiers, device/application information and IP-derived approximate location. The application adds no city name, real name, email, free text, complete save or custom player User-ID; these data are not entirely anonymous.

With separate consent, Crashlytics helps diagnose Java/native crashes using traces, crash context, device/system/app information and installation identifiers; application errors use fixed save_failed and save_recovered codes. Crashlytics is initialized only after you consent to that option, even if Analytics is already enabled. Once initialized, it may continue creating local diagnostic files until the game process stops completely, even after you withdraw that consent. Sending pending reports requires permission for both the current and previous launch. Withdrawing Crashlytics consent prevents the game from authorizing further uploads and requests deletion of pending local reports. Withdrawing Analytics consent also resets its local Analytics data. A toggle cannot recall a transfer in progress or erase data already received by Google. If saving a choice fails, follow the settings error and retry before leaving the game.

For Merge District, Google Analytics (including Firebase Analytics) is configured to retain detailed user and event data for 2 months. The retention period is not reset by new user activity. Standard aggregated reports are outside this setting. A retention change takes effect after 24 hours; expired data are removed in Google’s monthly deletion cycle, not immediately. Firebase documents 90 days for Crashlytics traces, extracted minidump data and associated identifiers before starting removal from active and backup systems; this is not a universal 90-day deadline for all Google data. Advertising data follow Google’s and applicable partners’ retention criteria for their purposes, security and legal obligations, separately from Firebase.

Merge District has no remote player profile to delete. Trading Empire Sim’s profile deletion form and code do not apply to this game. Removing local application data or restarting the city does not erase data already sent to Google; the game provides no automatic cloud-data erasure mechanism. For data-rights requests, contact [email protected] under the rights section below. Requests are examined using the information available to locate the data, without promising automatic or immediate deletion of every SDK record.

• Merge District: SDK data and privacy
• Google Analytics retention
• Google AdMob SDK data
• Providers and transfers
• Your rights

Brain Atelier - Classic Games

Brain Atelier - Classic Games offers 12 leisure games for people aged 18 and over. There is no account, sign-in, game server, multiplayer, chat, real-money in-app purchase or subscription. The game does not integrate Firebase Analytics or Crashlytics. Progress, scores, saved games and preferences stay on your device.

Local data remain until you reset progress or remove the corresponding application data. Resetting progress replaces the save and removes its old local backup and temporary copies, while keeping settings. If cleanup fails, the game displays an error and you can retry. Android application backup is disabled for this game.

Google AdMob rewarded ads provide optional hints during a game. An ad is loaded only after you confirm that you want to watch it; you can cancel instead. Normal gameplay remains available without ads and offline. On Android, Google User Messaging Platform (UMP) updates privacy information at normal launch after the interface appears, and may contact Google before any hint request. This startup check alone does not initialize MobileAds or load an ad. Advertising requires your voluntary request and permission from UMP before initialization, loading and display. That permission may allow limited or non-personalized ads and does not necessarily mean consent to personalization.

Independently of any ad request, the automatic UMP consent check may process your IP address and applicable region, form displays and choices (including refusal), and technical consent diagnostics: durations, successes or errors, SDK and application information and versions, device model, operating system and timestamps. These data support the consent service, regulatory compliance and analysis or diagnosis of that service. This processing may occur at launch before you choose to watch an ad; it is not conditional on permission to request advertising. It does not itself initialize MobileAds or load an ad. Retention follows Google’s applicable criteria for these service purposes and legal obligations.

Google and applicable advertising partners collect and share IP addresses and derived approximate location, application and device information, interactions such as app launches, taps and ad views, diagnostics and technical identifiers for advertising, measurement and fraud prevention. The AdMob SDK may also process the app set ID for fraud prevention. This identifier is excluded from ad personalization and ad measurement. Google documents encryption in transit using TLS. The Android advertising ID and AdServices permissions are absent; AdMob publisher first-party identifiers and its own crash reporting are disabled. This does not exclude other diagnostics, technical identifiers or personal data. Disabling AdMob’s own crash reporting does not disable UMP consent diagnostics.

Where required, advertising choices are accessible in settings and in-game options. The privacy form and linked Google rules describe the purposes and applicable partners: consent where required, including personalization and device access or storage, and legitimate interests for permitted security or fraud-prevention operations, with withdrawal or objection rights where applicable. Advertising data follow Google’s and applicable partners’ retention criteria for the data type, purpose, security and legal obligations. The Analytics and Crashlytics periods stated for the other games do not apply to Brain Atelier - Classic Games.

Resetting progress or uninstalling the game does not recall data already received by Google and does not necessarily clear the separate UMP privacy choices. There is no remote player profile to delete; the Trading Empire Sim profile deletion form does not apply. For data-rights requests, contact [email protected] using the rights section below. Requests are examined using reasonable information available to locate the data, without promising automatic or immediate cloud erasure.

• Google AdMob SDK data
• Google advertising and data
• Google data retention
• Providers and transfers
• Your rights

Trading Empire Sim — Solo play and saves on your device

The solo career works offline without a Google account or multiplayer profile. Your save, progress and privacy preferences are stored locally in the application. The telemetry modules do not send your complete save file.

Platform backups, if enabled, depend on your device and Google settings. Once initialized, Google SDKs may store technical identifiers, preferences and pending reports on your device.

Trading Empire Sim — Multiplayer and leaderboards

If you choose to connect to the monthly challenge or online leaderboards, our server processes a random profile identifier (UUID), a fictional nickname assigned automatically to new profiles by the current game version, and an access token. The token is stored in the application and sent over HTTPS to authenticate requests; the server stores only its hash. No real name, email address, Google account or phone number is requested to create the profile. These data are pseudonymous, not anonymous, and your data protection rights apply.

To run the competition, the server also stores participation, fictional orders, positions, portfolios and capital, results, scores, rankings and reward receipts. Each monthly leaderboard is separate for that calendar month, rather than a cumulative score. Nicknames, ranks and fictional performance published in leaderboards are visible to other players. The Practice leaderboard also exposes the random profile identifier, which is not an access token.

These data are necessary to provide the multiplayer service you request (GDPR Article 6(1)(b)). Security and abuse prevention rely on our legitimate interest in protecting the service and its users (Article 6(1)(f)). Without the data necessary for multiplayer, that feature cannot be provided; solo play remains available.

You can delete your online profile from the monthly challenge options in the game. After server confirmation, the profile and its associated game data are removed from the active database. Your solo career and rewards already stored locally remain. Disconnecting or uninstalling the game does not delete the server profile. You can also request deletion through the form using a deletion code, or by email if you have no code, without opening or reinstalling the game, as explained in the deletion section below.

• Delete my Trading Empire Sim profile
• Delete my profile using a code

Delete my Trading Empire Sim profile

You can request deletion without installing, reinstalling or opening Trading Empire Sim. If you previously generated and saved a deletion code from the monthly challenge options, use the form linked below. Generate this code while you still have access to your online profile and keep it outside the application before uninstalling. It is separate from your game access token and authorizes profile deletion only; keep it private. The server stores only its hash.

No code? Email [email protected] with the subject “Trading Empire Sim — profile deletion”, using the email link below or your usual email service.

For an email request, give your nickname, profile identifier if you already know it, and approximate participation period, as available. We review requests manually and may ask for limited non-public details you already know about your activity, such as a fictional order, to check against records still held. A public nickname or identifier alone is not proof of ownership. Never send your secret access token, password or complete save. If the available information cannot establish the link to the profile, we explain the difficulty and any further information needed; we do not delete another player’s profile on an unverified request.

After a code is validated or the support team verifies your request, deletion removes the profile and its associated participation, fictional orders, positions and capital, results, scores, leaderboard entries and reward receipts from the active database. It does not erase your solo career or rewards already stored on your device.

Deletions made from the game or through the form with a valid code also queue erasure from managed local application backups. This erasure is processed automatically at a later time; it is not instantaneous and an incident may delay completion. After verifying an email request, support applies an administrative procedure that also covers these backups. The daily full-server OVHcloud backup remains separate and may retain data for its one-day retention period. Earlier deletions must be reapplied before the server resumes service from an older backup.

We process verified deletion requests without undue delay and reply within one month of receipt. For a complex request or many requests, the response period may be extended by up to two further months, with the reason explained during the first month.

• Delete my profile using a code
• Email a Trading Empire Sim profile deletion request
• Retention and backup copies

Trading Empire Sim — Optional AdMob advertising

Trading Empire Sim offers optional Google AdMob rewarded ads. Initializing the MobileAds ad delivery SDK, requesting an ad and showing it require your voluntary choice of an advertising bonus offer and permission from Google’s privacy system. Rewards are fictional benefits usable only in the game, with no monetary value or conversion into money.

On Android, Google User Messaging Platform (UMP) attempts to update privacy information at each normal launch, after the game interface appears, and shows a form only if Google requires it. UMP may therefore contact Google before you choose a bonus. You can still manage those choices in settings without requesting an ad. The startup privacy check alone does not initialize MobileAds or request or show an ad, and offline gameplay remains available. UMP permission to request an ad can allow limited or non-personalized ads; it does not mean you consented to personalization. Declining advertising does not block normal gameplay.

When you request advertising, Google and the relevant advertising partners may process your IP address (and derived approximate location), device and application information, ad interactions, diagnostics and technical SDK or device identifiers. These data support ad delivery and measurement, reward attribution and fraud prevention. The AdMob SDK may also process the app set ID for fraud prevention. This identifier is excluded from ad personalization and ad measurement. SDKs may access or store information on your device, including identifiers and privacy choices; the form presents the applicable purposes and partners.

The Android advertising ID permission is enabled for AdMob. When you request an ad, Google may use this identifier for advertising, measurement and fraud prevention, depending on your privacy choices, Android settings and the type of ad served. AdMob publisher first-party identifiers remain disabled. Firebase Analytics does not collect the Android advertising ID; its optional collection choice and the separate Crashlytics choice remain disabled by default.

You can manage advertising choices in the game settings without requesting an ad, including after restarting the game. The entry remains available until UMP confirms that it is not required. Selecting it updates the privacy information and opens the options form if required. A connection or form error is reported and you can retry. The form identifies the applicable purposes, partners and bases: consent where required, including personalization and device access or storage; legitimate interest for certain permitted operations such as security and fraud prevention, with a right to object where applicable. Withdrawing consent does not affect earlier lawful processing.

• Google AdMob SDK data
• Google advertising and data
• Google technologies and storage
• Advertising technology partners

Trading Empire Sim — Optional Firebase statistics

Firebase / Google Analytics is disabled by default. You can enable it in the game settings to help us understand screen usage and improve the game. Declining these statistics does not prevent gameplay, multiplayer or choosing an ad.

The game sends screen-visit events with predefined screen names. The SDK may also process session events, an app-instance identifier, app version, operating system and device characteristics. Google may derive approximate location from the IP address; Analytics does not retain individual IP addresses. These data are pseudonymous, rather than entirely anonymous.

• Analytics data collection
• IP addresses in Analytics

Trading Empire Sim — Optional Firebase crash reports

Firebase Crashlytics is a separate choice, also disabled by default. If enabled, Google may receive crash traces, device, operating system and game-version information, together with technical installation identifiers, to diagnose failures. The game may also send fixed save_failed and market_load_failed codes for non-fatal errors.

The telemetry bridge adds no player name, email address, free text, custom user identifier or complete save file. Once Firebase has been initialized, local diagnostic files may exist even when sending reports is disabled. Enabling reports later may transmit reports still pending on the device.

• Firebase data and privacy

Trading Empire Sim — Your telemetry choices

Optional statistics and crash reports rely on your consent (GDPR Article 6(1)(a)). The two choices are independent in the game settings. Firebase is not initialized if neither is enabled.

Disabling Analytics stops its future collection. Disabling Crashlytics stops future permitted uploads and requests deletion of unsent reports when the SDK is initialized. These actions do not recall data already sent or a transfer in progress; some local files may remain. Withdrawing consent does not affect earlier lawful processing.

When you contact us

If you email us, we receive your email address, message and any attachments you send. Messages are received and stored in Gmail (Google). The publisher, the email service and technical message-delivery providers process these data to handle your request. Gmail uses Google’s consumer privacy rules; Google Ireland Limited is the provider for users established in the European Economic Area.

Ordinary support and general enquiries rely on our legitimate interest in responding to people who contact the studio (GDPR Article 6(1)(f)); you can object where applicable. Handling statutory data-rights requests relies on our legal obligations (Article 6(1)(c)). Sending a message is optional, but we cannot answer without contact details and information about your request.

• Google / Gmail

Recipients and international transfers

Midnight Condor and authorized administrators access data needed for multiplayer and support. OVHcloud hosts the multiplayer server in Canada and processes the hosted data on our behalf; Cloudflare relays and protects traffic. IP addresses are processed to establish and secure connections, even though the multiplayer API is configured without HTTP access logs. Data published in leaderboards are visible to other users.

Google Analytics and Firebase Crashlytics receive data from the options you enable in Trading Empire Sim and Merge District. Under their processing terms, Google acts as a processor for customer data in these services and separately processes some operational data under its own rules. Google AdMob acts as a separate data controller for its advertising services. The relevant advertising partners and their rules are presented in Google’s privacy form. Emails are received and stored in Google / Gmail and routed by technical email-delivery providers.

For the relevant services and users in the European Economic Area, Google’s terms name Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Google and Cloudflare use global infrastructure: data may be processed outside the EEA, including in the United States. Their safeguards include the EU–US Data Privacy Framework for transfers covered by the relevant certifications and standard contractual clauses where applicable. The links below explain these safeguards; you can also request a copy at [email protected].

Hosting the multiplayer server in Canada involves processing outside the EEA. OVHcloud publishes data-processing commitments and standard contractual clauses for the relevant transfers outside the EEA. The applicable safeguards can be requested at [email protected].

• OVHcloud — data protection
• Google / AdMob
• AdMob: separate controller terms
• Analytics processing terms
• Firebase processing terms
• Google transfer safeguards
• Cloudflare processing and transfers

Retention — Trading Empire Sim and the studio

The game-specific retention periods below concern Trading Empire Sim. Merge District and Brain Atelier - Classic Games have their own retention information in their dedicated sections. The studio support and website-log periods apply to all three games where relevant.

Local saves and preferences remain until you remove the corresponding application data, subject to platform backups. The website language choice stays in your browser until cleared.

The multiplayer profile remains until explicitly deleted. Detailed monthly trading accounts, orders and positions are removed when the calendar month closes; final monthly results and reward receipts are retained for 12 months, with purging by calendar month. Practice scores are retained for the current UTC week and eight preceding weeks. Practice purging runs on server startup or certain writes, rather than at a guaranteed expiry time. Monthly retention is checked periodically while the service is running.

Application backups on the multiplayer VPS are retained for seven days. The daily task removes archives more than seven days old after a new backup has been successfully validated; older copies may remain if the task does not complete. According to the publisher’s confirmation, OVHcloud also backs up the entire server once a day, with a retention period of one day. Deleting data from the active database does not immediately erase all backup copies. A restoration must reapply earlier deletions before the service resumes.

To track erasure and prevent data from being reintroduced after a restoration, we keep a restricted minimal record of deletion requests: the random profile identifier, the request date and, once processing is complete, the processing date. These records are kept while older copies can still be restored. Removing a record requires an administrative check that those copies have expired or been erased; there is no automatic deletion after a fixed period.

For Trading Empire Sim, Google Analytics (including Firebase Analytics) is configured to retain detailed user and event data for 2 months. The retention period is not reset by new user activity. Standard aggregated reports are outside this setting. A retention change takes effect after 24 hours; expired data are removed in Google’s monthly deletion cycle, not immediately.

Firebase documents 90 days for Crashlytics traces, extracted minidump data and associated identifiers before starting deletion from active and backup systems. This is not immediate deletion at day 90 or on consent withdrawal.

Google / AdMob advertising data follow Google’s retention periods and criteria, depending on data type, purpose, fraud prevention and legal obligations. The Firebase periods above do not apply to AdMob. Advertising partners listed in the form describe their own retention.

Support emails and attachments are retained for 36 months after the last exchange. Showcase website HTTP logs are retained for 12 months after the recorded event. Relevant records may be kept separately for longer for an incident, legal proceedings or an applicable legal obligation.

• Analytics retention
• Crashlytics retention
• Google / AdMob data retention

Trading Empire Sim — Game audience

Trading Empire Sim is designed for an audience other than children. It has no parental consent mechanism. If you believe a child’s data have been transmitted, contact [email protected] so we can examine the request and appropriate measures.

Your rights

Where the GDPR applies, you can request access, correction, erasure or restriction of your personal data, and portability or objection where applicable. Erasure is subject to applicable legal obligations and the establishment, exercise or defence of legal claims (GDPR Article 17(3)). You can withdraw consent at any time. Send privacy requests to [email protected].

For Brain Atelier - Classic Games, published by Midnight Condor, request data deletion by emailing [email protected] with the subject “Brain Atelier - Classic Games — data deletion” and a description of your request. There is no player account or remote game profile. Progress, scores and saves are local: resetting progress removes them and old local copies while keeping settings; removing application data also removes local settings. A local reset cannot erase advertising data already received by Google. We examine what SDK data can be located using reasonable information; an email address alone may not identify those data. If we cannot establish that link, we explain the limitation. Advertising retention follows Google’s and applicable partners’ criteria; support messages are kept for 36 months after the last exchange.

We will normally respond within one month. If a request is complex or numerous, the period can be extended by up to two further months, with an explanation within the first month. We may ask only for information reasonably needed to locate data or verify the request; please do not send passwords or a complete game save.

You can complain to the CNIL in France or to the supervisory authority in your country.

• Brain Atelier - Classic Games — request data deletion by email
• [email protected]
• Contact
• Contact the CNIL

Technical website logs

This showcase website is hosted by OVHcloud in France and has no cookies, contact form, user accounts or audience analytics. Your language preference is saved only in your browser.

HTTP logs record technical information such as IP addresses, timestamps and requested resources. They are used to operate and secure the website, based on our legitimate interest in its security (GDPR Article 6(1)(f)). Access is limited to the publisher, the hosting provider and authorized administrators. Relevant records may be preserved for an incident, legal proceedings or a lawful authority request.

Updates

The date above will change when this policy is revised. Significant changes to data use must be explained in the affected game before the new collection begins.