Blood & Bytes: Kagura - Privacy Policy

1. Introduction

Genoma Games ("we," "us," or "our"), a game development studio based in Madrid, Spain, develops and operates Blood & Bytes: Kagura. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you interact with our game, website, testing programs, or related services.

We are committed to protecting your privacy and complying with applicable data protection regulations, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and Spain's Ley Organica de Proteccion de Datos Personales (LOPDGDD).

Data Controller: Genoma Games Madrid, Spain Email: info@genomagames.com Physical address available upon request.

2. Applicable Regulations

Based on the global nature of our services, we comply with the following privacy regulations:

As a Spanish company processing personal data of EU residents, we are directly subject to the General Data Protection Regulation (GDPR). This regulation requires lawful, fair, and transparent data processing with valid legal bases such as consent.

Spain - LOPDGDD

Spain's Fundamental Law on Data Protection (Ley Organica de Proteccion de Datos Personales y Garantia de los Derechos Digitales) implements and refines GDPR requirements for Spanish territory.

California - CCPA/CPRA

For California residents, we comply with the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), which grants specific privacy rights including the right to know, delete, correct, and opt-out.

United States - CAN-SPAM Act

All email communications comply with the CAN-SPAM Act, which establishes rules for commercial email including clear unsubscribe mechanisms.

Other US States

We monitor and comply with comprehensive privacy laws in other US states as applicable, including Colorado, Connecticut, Virginia, and others.

3. Personal Data We Collect

We collect the following categories of personal information:

3.1 Contact Information

Data	Purpose	Legal Basis (GDPR)
Name	Identification and communication	Consent
Email Address	Primary communication channel, sending game keys and updates	Consent

3.2 Demographic Information

Data	Purpose	Legal Basis (GDPR)
Country	Regional segmentation and localization	Consent
Preferred Language	Communication and game localization	Consent
Year of Birth	Age verification and demographic analysis	Consent

3.3 Gaming Profile Information

Data	Purpose	Legal Basis (GDPR)
Gaming Frequency	Player segmentation and testing group assignment	Consent
Average Session Duration	Understanding player habits	Consent
Gaming Platforms Used	Technical compatibility assessment	Consent
Preferred Platform	Primary testing focus	Consent
Alpha/Beta Experience	Tester experience assessment	Consent
Feedback Experience	Identifying proactive testers	Consent

3.4 Preference Information

Data	Purpose	Legal Basis (GDPR)
Liked Game Genres	Player affinity analysis	Consent
Disliked Game Genres	Understanding player preferences	Consent
Games of Interest	Reference comparison	Consent
Gaming Motivations	Player type classification	Consent
Related Interests	Broader interest profiling	Consent

Data	Purpose	Legal Basis (GDPR)
Opt-in for Updates	Permission to send game news and announcements	Consent
Opt-in for Surveys	Permission to send feedback requests	Consent

3.6 Game Access Data

Data	Purpose	Legal Basis (GDPR)
Game Key	Linking access to your contact record	Contract performance
Registration Date	Program administration	Legitimate interest
Key Activation Status	Tracking program participation	Legitimate interest

4. How We Use Your Information

We use your personal data for the following purposes:

4.1 Service Delivery

Registering you as a player or tester
Assigning and distributing game keys
Tracking your participation status
Segmenting players into appropriate groups

Sending game updates and development news (if opted-in)
Sending feedback surveys and questionnaires (if opted-in)
Important announcements related to your game access

4.3 Product Improvement

Analyzing player demographics to understand our audience
Understanding gaming preferences to inform development decisions
Evaluating player feedback for quality assessment

5. Third-Party Services and Data Processors

We use the following third-party services to process your data:

5.1 Brevo (formerly Sendinblue)

Purpose: Email marketing and contact management Data Shared: Email address, name, game key assignment, consent preferences Location: European Union (with appropriate safeguards for any transfers) Role: Data Processor DPA: We maintain a Data Processing Agreement with Brevo in compliance with GDPR Article 28.

Brevo is used to:

Store and manage contact information
Send email communications (updates, surveys)
Track email delivery and engagement metrics
Link game keys to contact records

5.2 Notion

Purpose: Internal database for program management Data Shared: Registration form responses Location: United States (EU-US Data Privacy Framework participant) Role: Data Processor

5.3 Steam

Purpose: Game distribution platform Data Shared: No personal data shared directly; game keys are redeemed by users Note: When you redeem a game key on Steam, Steam's own privacy policy applies to that relationship.

6. International Data Transfers

As our players may be located worldwide, your data may be transferred outside your country of residence.

For EU Residents

Transfers outside the European Economic Area (EEA) are protected by:

EU-US Data Privacy Framework (for US recipients certified under this framework)
Standard Contractual Clauses (SCCs) approved by the European Commission
Adequacy decisions where applicable

Your Rights

You have the right to request information about the safeguards in place for any international transfers of your data.

7. Data Retention

We retain your personal data only as long as necessary for the purposes described in this policy:

Data Category	Retention Period
Contact Information	While you use our services + 2 years
Demographic Information	While you use our services + 2 years
Gaming Profile & Preferences	While you use our services + 2 years
Consent Records	Duration of consent + 3 years (legal compliance)
Game Key Assignment	While you use our services + 2 years
Transaction Records	7 years (tax and financial compliance)

"While you use our services" means the period during which you actively interact with our game, website, or communications. We consider your relationship inactive after 24 months without any interaction (login, email open, or other engagement).

Why we retain data after inactivity: The additional 2-year retention period allows us to: (1) enable account reactivation if you return to our services, (2) respond to any disputes or support requests related to your previous participation, and (3) comply with potential legal obligations.

After the retention period, your data will be:

Deleted, or
Anonymized for aggregate statistical purposes

8. Your Rights

Depending on your location, you have the following rights regarding your personal data:

Right of Access: Request a copy of all personal data we hold about you
Right to Rectification: Request correction of inaccurate or incomplete data
Right to Erasure: Request deletion of your data ("right to be forgotten")
Right to Restriction: Request limitation of how we process your data
Right to Data Portability: Receive your data in a machine-readable format
Right to Object: Object to processing based on legitimate interests
Right to Withdraw Consent: Withdraw your consent at any time
Right to Complain: Lodge a complaint with your local data protection authority

8.2 Rights Under CCPA/CPRA (California Residents)

Right to Know: Request disclosure of data collected and its purposes
Right to Delete: Request deletion of your personal information
Right to Correct: Request correction of inaccurate information
Right to Opt-Out: Opt-out of sale or sharing of personal information
Right to Non-Discrimination: Not be penalized for exercising your rights

Note: We do not sell your personal information.

8.3 How to Exercise Your Rights

To exercise any of these rights, including withdrawing your consent, contact us at:

Email: info@genomagames.com Subject Line: Privacy Request - [Your Right]

To withdraw consent: Send an email to info@genomagames.com with the subject "Withdraw Consent" specifying which consent(s) you wish to withdraw. You can also use the unsubscribe link in any marketing email to withdraw consent for that specific communication type.

We will respond to your request within the timeframes required by applicable law.

9. Email Marketing and Unsubscribe

9.1 Opt-In Communications

We only send marketing emails (updates, surveys) if you have explicitly opted-in. Each type of communication has a separate opt-in.

9.2 Unsubscribe

Every marketing email includes an unsubscribe link. You can:

Click the unsubscribe link in any email
Contact us at info@genomagames.com
Update your preferences through Brevo's preference center

9.3 Transactional Communications

Essential communications (game key delivery, critical updates) are not subject to marketing opt-in and will be sent to all active users.

10. Children's Privacy

Our game and services are not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16.

If we discover that we have collected personal data from a child under 16, we will delete that information promptly.

If you believe a child under 16 has provided us with personal information, please contact us at info@genomagames.com.

11. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

Encryption: Data transmitted via HTTPS; data at rest protected by service provider encryption
Access Controls: Limited access to personal data on a need-to-know basis
Service Provider Security: We only use service providers with appropriate security certifications
Breach Response: Procedures in place to detect, investigate, and report data breaches

In the event of a data breach that poses a risk to your rights, we will notify the relevant authorities and affected individuals as required by applicable law.

12. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements.

Notification of Changes:

Material changes will be communicated via email to registered users
The "Last Updated" date at the top will be revised
Previous versions will be archived and available upon request

13. Contact Information

For any questions, concerns, or requests regarding this Privacy Policy or your personal data:

Genoma Games Madrid, Spain Physical address available upon request.

Email: info@genomagames.com

Website: https://genomagames.com

This Privacy Policy is provided in English. A Spanish version may be made available upon request.