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Luftskip Privacy Policy

This policy is effective as of the 29th of Januar, 2026.

IF YOU ARE UNDER THE AGE OF 18 (OR THE AGE OF MAJORITY REGULATED BY APPLICABLE LAWS WHERE YOU LIVE), YOU AND YOUR PARENT OR GUARDIAN MUST REVIEW THIS AGREEMENT TOGETHER. YOUR PARENTS OR GUARDIANS SHALL READ AND ACCEPT THIS AGREEMENT BEFORE YOU USE ANY SERVICES FROM LUFTSKIP.

PLEASE READ THIS AGREEMENT CAREFULLY, INCLUDING ANY RELEVANT PRODUCT OR SERVICE END USER LICENSE AGREEMENT OR TERMS OF SERVICES, BEFORE INSTALLING ANY GAME OR USING LUFTSKIP’S SERVICES. IF YOU DO NOT AGREE TO THIS AGREEMENT OR THE PRIVACY POLICY, PLEASE DO NOT INSTALL OR USE ANY OF LUFTSKIP’S SERVICES.

Introduction

Luftskip AS (and its affiliates, agents, representatives, consultants, employees, officers, and directors – collectively, “Luftskip”, “we”, or “us”) is an independent game development studio. We make games, and offer services and digital product development for our customers and clients. We are a company based in Oslo, Norway.

This Privacy Policy outlines how Luftskip collects, uses, processes, and shares your personal data in connection with your use of one of our games or services, including participation in beta testing of our games (collectively called the “Services”). Personal data means any information that can identify you, directly or indirectly, such as, for example, your name, location data, or online identifiers. We are committed to protecting your privacy and handling your data transparently in compliance with the EU General Data Protection Regulation (GDPR) and Norwegian Company Law.

By using a Service offered by Luftskip, you are acknowledging that you have read and understood this Privacy Policy. If you do not agree with this policy, do not access or use our Services, play our games.

Data Controller

Luftskip, registered in Norway, is the controller of your personal data. Contact details are provided at the end of this document.

What Personal Data We Collect and Why

We collect specific categories of personal data for designated purposes:

Data retention

Personal information you voluntarily shared with us

Personal information (like your name, age, and email address) you share with us through email or contact forms (i.e. test registration forms), is retained indefinitely or until erasure is requested by you. This is because you share this information with us voluntarily to participate in our tests or receive communications from us, and we will comply with this request until you tell us to stop. In some cases, signing up or voluntarily sharing personal information with us, makes you eligible for a reward. In order to verify and process that reward, we need to retain your information. By requesting erasure of said information, you also revoke your right to any pending rewards, as we will have no way of verifying your eligibility.

Third Party Platform Account Information

Account Information obtained through your use of the game is retained indefinitely since it is used to facilitate your access to and use of the related game, or until erasure is requested or consent manually revoked through the applicable platform.

We utilize this information primarily to allow you access to the game, and connect players in multiplayer matches. Player activity data and country are used for monitoring game engagement, but are not stored beyond this purpose.

When you participate in a beta test run, the ID or email associated with your account is collected. We will retain this information as long as the test period lasts, or until erasure is requested by you. We will delete this information when the beta test period is complete.

Third Party Communication Servers Account name and posts

Posts to any of our third party servers may be used and retained indefinitely unless erasure is requested or manually deleted by the user who submitted a post. We do not indiscriminately store messages and account names from our third party communication servers. If you submit feeback or a support request to us, we may store the message and your account name to be able to serve your request and reply. Posts that convey useful information for us to improve or market our games and services may be stored and used anonymized. We may contact users to ask to share their testimonials with accreditation. We will never post or share users identifiable information without explicitly obtaining consent on a case by case basis.

Third party services may allow people to create accounts, post information and send messages to each other. Users are often pseudonymous, but users can state any information they like about themselves in discussions. Information you enter into the Luftskip’s third party servers should be considered public and can remain even after you terminate your account unless you delete it yourself or request us to delete it for you. Consider the sensitivity of any information you post on third party servers.

Game session related data

All data processed when you are accessing one of our games distributed via platforms and game stores is processed in accordance with the agreements you have entered into with the platforms and game stores, and is not directly under our control. The data is or may be shared via the platforms and game stores to other players when you host or join a multiplayer session. Thus, platforms and game stores process and store your data in accordance with their policies. Please refer to the section on our sub-processors for the relevant links.

With the exception of players’ country of origin when accessing one of our games through any platforms and game stores, we do not process this data directly. We store players’ country information without connection to other account information indefinitely for analytical purposes.

Data Erasure

Requests for data erasure are processed as soon as possible, and no later than 30 days from the time we were made aware of the request.

Sub-processors and Data Transfer

To facilitate gameplay and operational effectiveness, we use various sub-processors.

Your data may be transferred to the countries listed in each of our sub-processors respective policies.

Epic Games Inc.

All data you provide when accessing one of our games through the Epic Games Store, is processed in accordance with the agreement we have entered into with Epic Games Inc. Data retrieved in-game or through the Epic Games Store is processed by Epic Games to facilitate game sessions and account usage. The data is shared via the Epic Online Subsystem to other players when you host or join a multiplayer session.

When you sign up for closed beta tests of any of our games distributed through the Epic Games Store, your Epic Games account ID is stored within our Epic Games Developer Organization account, processed by Epic Games Inc.

Data controller information

Data processing location

USA/Internationally

Policies

Infomaniak Network SA

Data submitted to us via sign-up forms or emails, as well as data we obtain from our third party communication servers, is stored on our Infomaniak KSuite Cloud Service (KDrive), with Infomaniak Network SA as a sub-processor. Storage is limited to Switzerland. For information regarding the Data Processing Agreement between Luftskip AS and Infomaniak Network SA, refer to the contact email at the bottom of this document.

Data processing location

Switzerland

Policies

Infomaniak's terms: https://www.infomaniak.com/en/legal/confidentiality-policy

Links to other websites and services

Other users may share, or on our Services there may be, advertisements or links to other websites or services whose privacy practices may differ from Luftskip’s. When you use a link to an external site or service, the privacy policy and data processing disclosures for that site or service governs. We at Luftskip cannot control or be held liable for these third parties’ privacy practices and content. If you click on any link or advertisement provided by another company or user, please understand that you are then leaving our Services and any personal data you provide will not be covered by this Policy.

Your Rights Under GDPR

You have the right to:

To exercise these rights, please contact us on support@luftskip.com.

Depending on your country of residence, you may also have the right to file a complaint with the supervisory authority in your country.

Data Security

We strive to adhere to the principles of privacy by default - privacy by design, and to protect any data we handle. Our most important data security measure, is to not collect any data we do not need. We collect as little information as necessary to provide our Services, anonymize any information possible, and avoid sharing data with third parties whenever possible. All our staff sign confidentiality agreements alongside their employee contracts, and receive relevant training regarding privacy regulations and our handling of data. We use well established sub-processors, and always prioritize processors that are best in class with regards to privacy. Luftskip complies with Norwegian and European laws and regulations in all aspects of our operations.

However, there is no such thing as perfect security and complete online or offline security can never be guaranteed, so you should always be careful when sharing your information online. In the case of data breaches, leaks or cyber attacks, we are well aware of our obligations to protect all our users’ data by taking precautionary measures as well as fulfill our obligations to our users and authorities.

Sharing of Information

We do not share your information with any third parties, with the following exceptions:

  1. As disclosed in this policy with Epic Games, Inc. and Infomaniak Network SA, our designated sub-processors.
  2. In order to comply with the law or law enforcement, i.e. to prevent fraud or abuse, or to protect Luftskip’s legal rights, property, or the safety of Luftskip, its employees, users or others.

As stated above, we transfer and share your information to third parties (including service providers operating on our behalf) which are located in countries outside the European Union (“EU”) and/or the European Economic Area (“EEA”) which may not have the same level of data protection laws as those in the country where you are located. When your data is sent to a country outside the EU/EEA that is not subject to an adequacy decision by the EU Commission, the transfers will only occur if we (or an applicable processor) have implemented what we believe to be appropriate safeguards in accordance with the GDPR, such as EU Commission approved standard contractual clauses, which are deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals. We only work with actors who we truly believe respect the security of your personal data and treat it in accordance with the GDPR or the relevant applicable law.

Third-party data sales

We do not, and will never, sell any of your data to third parties.

Children

We do not knowingly and directly collect personal information from children under the age of 18. If we become aware that a child under 18 has directly provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please send us an email at support@luftskip.com.

Parents and guardians are responsible for the acts of children under 18 years of age (or the age of majority regulated by applicable laws where you live ) when using Luftskip’s Services, including but not limited to any payments, damages, and/or liabilities related to the acts of their children. Luftskip recommends that parents and guardians familiarize themselves with parental controls on devices they provide to their children.

When selling our products through third party retailers, like the Epic Games Store, the registering and verification of age and consent is managed by them. When children under the age of 18 are allowed to access a game made by us through third party retailers, the personal information gathered through the acquisition or use of said game will be processed on the basis of the agreement entered with the relevant third party retailer. Epic Games Store limits accounts held by children under the age of 13 (or the age of digital consent in their region), and requires parental consent to allow certain features. Please review Epic Games Inc.’s Parental Consent (https://www.epicgames.com/site/en-US/parental-consent) for details regarding this.

Changes to This Policy

We may update this policy periodically to reflect changes in our practices or regulatory requirements. Any changes will be posted at https://luftskip.com/privacy with an updated revision date. Therefore, please review the privacy policy frequently to ensure you are aware of any changes. If we make a substantial change to the privacy policy, we will provide you with a notice through our Services or by email.

Contact Us

For questions or concerns about our privacy practices, please contact us at:

Email: support@luftskip.com

Address: Oslo, Norway (Physical address can be provided on valid request)