Privacy Policy
Effective date: [DATE]
This Privacy Policy explains how ISEMI COMPANY LTD, a company registered in Vietnam under business registration number 0318141838, with its registered office at 23 T4A Street, Tay Thanh Ward, Tan Phu District, Ho Chi Minh City, Vietnam ("we", "us"), the controller of your personal data, collects, uses and protects information when you play Queen Below (the "Game") on iOS or Android or visit https://queenbelow.isemi.io. If you have questions, contact us at company@isemi.io.
1. Information we collect
Account information. The Game does not ask for a password, email or real name. When you sign in with Apple Game Center or Google Play Games, we receive the player identifier that Apple or Google provides for this Game, and your public player name (Game Center nickname or Play Games name), which we show in your profile so you can see which account is linked. If you play without signing in, we create a guest account linked to a random identifier stored on your device.
Game data. Your empire name, starting species, nest layout, resources, troops, generals, alliance membership and rank, battle reports and replays, and your position on the shared map. Other players can see your empire name, alliance, queen level, power and ranking. Your nest location is only revealed to players who scout it or to your alliance, as the game rules describe.
Chat. Messages you send in the realm or alliance channels, together with your empire name, alliance tag and queen level at the time. Messages are filtered for offensive words before they are shown.
Safety reports and blocks. When you block a player, we store which empire you blocked. When you report a message, we store a copy of that message (its text, channel and time, and the sender's empire name and player ID), the reason you chose and your player ID, so our team can review it even after the message has left the chat history.
Support requests. When you write to our support address, we receive your email address and what you write.
Activity records. Each day you open the Game, our server notes that your account was active that day. We use this only to count daily players and how many come back after 1, 7 and 30 days.
Technical data. Our servers process your IP address and basic connection data to run the Game, limit abuse and keep the service secure. We do not store IP addresses in our game database; server logs that may contain them are deleted after 30 days.
We do not collect your location, contacts, photos, microphone, or any data from other apps. We do not show advertising and do not track you across other companies' apps or websites.
2. How we use information
- To run the Game: keep your empire, process your actions, resolve battles and show rankings.
- To provide chat, alliances and other multiplayer features.
- To keep the Game safe and fair: filter offensive content, review reports, act against cheating, abuse and attacks on our servers, and suspend accounts that break our Terms of Service.
- To answer support requests and fix bugs.
- To send the notifications you turned on.
- To measure, per player and in aggregate, how players progress (for example how many come back after 1, 7 and 30 days), so we can balance and improve the Game. We aggregate or delete these records after 14 months.
Where the law of your country requires a legal basis (for example, the GDPR in the EU and the UK GDPR), we rely on:
| Purpose | Legal basis |
|---|---|
| Sign-in, running your empire, battles, rankings, chat, alliances, delivering purchases | Performing our contract with you |
| Chat filtering, reviewing reports, anti-cheat, server security, rate limiting | Our legitimate interest in keeping the Game safe and fair |
| Push notifications | Your consent, which you can withdraw in your device settings |
| Balancing and improving the Game (progress statistics) | Our legitimate interest in improving the Game |
| Keeping purchase records, answering lawful requests from authorities | Legal obligation |
Providing account and game data is necessary to play; without it we cannot provide the Game. Our chat filter replaces offensive words automatically. Accounts may be flagged automatically for cheating, but a person reviews every suspension. We do not make decisions with legal or similarly significant effects based solely on automated processing.
3. Who we share information with
- Other players see what the Game shows by design: empire name, alliance, queen level, power, rank, chat messages and battle reports involving them.
- Apple and Google, to sign you in, process purchases and deliver notifications. They act as independent controllers.
- Service providers that help us operate the Game, under contracts that require them to protect your data: our server host ([HOSTING PROVIDER, REGION]) and our email provider, which processes the messages you send to our support address.
- Authorities, when the law requires it, or to protect the safety of players or the public.
- A company that takes over the Game, if the Game is sold or transferred, under this policy.
We do not sell your personal information and do not share it for advertising.
4. How long we keep information
- Chat messages: 7 days.
- Battle reports and game notifications: 14 days.
- Account and game data (empire, items, alliance, block list): until you delete your account.
- Activity records (days you played): 14 months, or until you delete your account if sooner.
- Message reports: 90 days after the report is closed, longer only if needed for an ongoing case.
- Support requests: 1 year after the request is closed.
- Server logs: up to 30 days.
- Purchase records: as long as tax and accounting laws require (currently up to 10 years under Vietnamese accounting law).
- Backups: deleted data disappears from our backups within 35 days.
5. Deleting your account
You can delete your account inside the Game: Settings → Account → Delete account. Your account is locked for 7 days, so you can change your mind by signing in again and choosing to cancel.
After 7 days we permanently delete your account, empire, nest, generals, resources, unused virtual items (including Amber and remaining VIP days, which are not refunded), alliance membership, your activity records, push token, your chat messages, the reports you made, your block list and other players' blocks of your empire. Your empire name may remain in other players' battle reports and chat history until those expire automatically (14 days at most). Backups are overwritten within 35 days. Records we must keep by law (such as purchase records) are kept only as long as required.
If you can no longer open the Game, request deletion at https://queenbelow.isemi.io/delete-account.html or email company@isemi.io with the subject "Delete my account" and your player ID or empire name and realm. We may ask you to confirm from the Game or from the linked Game Center or Google Play Games account.
6. Your rights
Depending on where you live, you may have the right to access, correct, delete or receive a copy of your personal data, to object to or restrict some uses, and to withdraw consent. Write to company@isemi.io with your player ID (Settings → Account). We will answer within one month (this can be extended where the law allows). To protect your account, we may ask you to confirm the request from the Game or from the linked Game Center or Google Play Games account. You can object at any time to processing based on our legitimate interests.
We answer free of charge. You can complain to the data protection authority where you live or work (in the UK, the ICO), or contact our representatives (section 8). California residents: we do not sell or share personal information, and we do not use sensitive personal information, as those terms are defined in the CCPA/CPRA.
7. Children
The Game is not directed to children under 13 (or the higher minimum age in your country), and we do not knowingly collect personal information from them. Players under 18 should have a parent's or guardian's permission. If we learn that we have collected personal data from a child under 13, we delete the account. If you believe a child has given us personal information, contact company@isemi.io.
When you first open the Game we ask for your year of birth. If you are under 13, you cannot play, and nothing is sent to our servers. We keep only your age group (13–15, 16–17, or 18 and over), not your year of birth, and use it to apply age-appropriate settings (for example, fewer notifications for players under 18, and no paid summon wheel spins for players under 16).
8. Security and international transfers
We protect data with encrypted connections (HTTPS and secure WebSockets), access controls on our servers and limited log retention. If a data breach affects you, we will notify you and the authorities as the law requires.
We are based in Vietnam, our game servers are operated by [HOSTING PROVIDER, REGION], and our team accesses data from Vietnam. Your data is therefore processed outside your country, including outside the EU, the UK and South Korea, in places whose data protection laws may differ from yours. Where we use service providers, we require them by contract to protect your data, using the European Commission's standard contractual clauses (and the UK addendum) where the law requires. You can ask us for a copy of these safeguards.
Vietnamese law. We are established in Vietnam and also process your data in accordance with Vietnam's Law on Personal Data Protection (Law No. 91/2025/QH15) and its implementing regulations. Our team accesses your data only as needed to run the Game, keep it safe and provide support.
For users in South Korea: the personal data listed in section 1 is transferred over the network to [HOSTING PROVIDER, REGION] when you play, to host the Game, and kept for the periods in section 4. You can refuse by not using the Game or by deleting your account, but then we cannot provide the Game.
9. Our website
Our website does not use cookies, analytics or third-party content: fonts and images are served from our own site. Our web host processes your IP address to deliver pages and keeps server logs for up to 30 days.
10. Changes
If we change this policy, we will update the effective date above and, for important changes, tell you in the Game and, where the law requires, ask for your consent. Previous versions are available on request.
11. Contact
ISEMI COMPANY LTD, 23 T4A Street, Tay Thanh Ward, Tan Phu District, Ho Chi Minh City, Vietnam · company@isemi.io