Privacy Policy

MEDIA EMPIRE

• Version: 1.0
• Effective Date: 2026-09-17
• Operator: MEDIA EMPIRE Project Team
• Contact: [email protected]

This Privacy Policy explains how the MEDIA EMPIRE Project Team ("we," "us," "the Team") handles information in connection with MEDIA EMPIRE, a fictional-world broadcasting-station management simulation game available as a web application and, in the future, as a Windows/Unity application.

1. Purpose of This Policy

We built MEDIA EMPIRE to be playable without creating an account or handing over personal information. This Policy describes what limited data the game and its supporting infrastructure process, why, for how long, and what choices you have. It applies to the web version hosted on Cloudflare Pages, the backend API and database hosted on Railway, and the optional AI-assisted features that call the OpenAI API.

2. Personal Data We Process

MEDIA EMPIRE does not require registration and does not ask for your name, e-mail address, or other identity information to play. In the ordinary course of play we process:

• An anonymous owner key and save/game IDs — randomly generated identifiers used to associate a save file with the browser or device that created it. These identifiers are not linked to your real identity by us.
• Game commands and simulation telemetry — the in-game actions you take (scheduling programs, hiring staff, budget decisions, etc.) and derived simulation state, needed to run and persist your game.
• Technical logs — our hosting providers (Cloudflare and Railway) automatically record standard web/server logs, including IP address, user agent, request timestamps, and similar metadata, for security and operational purposes.
• Browser local storage — the web client uses your browser's localStorage for convenience features, such as remembering recently opened games, UI preferences, and similar client-side settings. This data stays on your device.
• Aggregate traffic counts — to know which pages get opened and how often, we store the page path, language, referring domain, a coarse device type, the country code our hosting provider supplies, and a hash used to tell visitors apart. That hash is computed with a salt that is replaced at random every day, so the same visitor is recognised only within a single day and following anyone across days is not technically possible. No IP address, no raw user agent string and no cookie is stored.
• Ad impression and click counts — aggregate numbers for how often an advertisement shown in the service was displayed or clicked. They contain nothing that identifies a person.

We do not collect your e-mail address or other contact details unless you voluntarily send them to us, for example by writing to our contact address.

3. How We Collect Personal Data

Data is collected automatically as a technical consequence of operating the game: your browser or client sends requests to our API, and our hosting providers log connection metadata as part of normal operation. We do not use third-party trackers, analytics pixels, or advertising SDKs to collect data about you.

4. Purpose of Processing and Legal Basis

We process the data described above to: operate and maintain the game and your saved progress; secure our systems against abuse, fraud, and technical failure; diagnose and fix bugs; and, where you opt in, provide AI-assisted suggestions. Where the GDPR applies, our legal bases are: performance of a contract (providing the game you requested), our legitimate interest (service security, debugging, anti-abuse), and consent (where you actively invoke optional AI features or contact us).

5. Retention Period

• Save data is retained until you delete it, or automatically after 12 months of inactivity on that save.
• Technical logs held by our hosting providers are retained according to each provider's default retention schedule, and in no case longer than 90 days, after which they are deleted or anonymized.
• Correspondence you send to our contact address is kept only as long as needed to handle your request.

6. Provision to Third Parties

We do not sell, rent, or trade your data. We do not share data with third parties for their own marketing purposes. Limited data is shared only with the sub-processors described in Section 7, strictly to operate the service.

7. Sub-processors and Hosting Providers

We use the following processors to operate MEDIA EMPIRE:

• Cloudflare — content delivery network and hosting for the web client (Cloudflare Pages). Cloudflare may process connection and request metadata as part of delivering the site.
• Railway — hosts our backend API and PostgreSQL database, in the region as configured on our Railway project. Save data, game commands, and technical logs pass through and are stored on Railway's infrastructure.
• OpenAI — used only when you actively use a ChatGPT-powered feature (program-concept suggestions or balance-analysis reports). In that case, the text of your request or an aggregated, anonymized balance report is sent to OpenAI's API to generate a response. We do not intentionally include personal data in these requests. Use of OpenAI's API is governed by OpenAI's own data-handling policies for API usage, which at the time of writing do not use API inputs to train OpenAI's models by default.

8. International Data Transfers

Because our providers operate global infrastructure, your data may be processed in countries other than your own, including the United States and other jurisdictions where Cloudflare, Railway, or OpenAI operate servers. Where required, we rely on the safeguards these providers offer for international transfers, such as standard contractual clauses or equivalent mechanisms.

9. Your Rights

Subject to applicable law (including the GDPR for users in the European Economic Area), you may have the right to: access the data we hold about your save/session; request correction of inaccurate data; request deletion of your save data or logs; request a portable copy of your data; object to certain processing; and withdraw consent for optional features at any time. To exercise any of these rights, contact us at [email protected] with enough detail (such as your save/owner key) for us to locate your data. You also have the right to lodge a complaint with your local data protection supervisory authority.

10. Children's Privacy

MEDIA EMPIRE is not directed at children under 14 in Korea, under 13 in the United States, or under 16 in the European Economic Area (or the applicable local age of digital consent). We do not knowingly collect personal data from children below these ages. If you believe a child has provided us with personal data, please contact us so we can delete it.

11. Destruction Procedure and Method

When a save is deleted by the user or expires after 12 months of inactivity, it is permanently removed from our production database. Technical logs are deleted or irreversibly anonymized automatically once their retention period expires. We use secure deletion methods appropriate to the storage medium used by our hosting providers.

12. Security Measures

We apply reasonable technical and organizational measures to protect your data, including: encryption in transit via TLS for all client-server communication; access controls and least-privilege principles for administrative access to our database and hosting dashboards; and reliance on the security infrastructure of reputable providers (Cloudflare, Railway). No system is perfectly secure, and we cannot guarantee absolute security.

13. Cookies and Local Storage

We do not use advertising cookies or third-party tracking cookies. The web client may use strictly necessary cookies or localStorage for session continuity and convenience (for example, remembering recently opened games). You can clear this data at any time through your browser settings; doing so may reset these conveniences but will not delete server-side save data tied to your owner key.

14. Privacy Officer and Contact

For any question, request, or complaint regarding this Policy or your data, please contact the MEDIA EMPIRE Project Team at [email protected]. This address also serves as our privacy contact point.

15. Changes to This Policy

We may update this Policy as the game and its infrastructure evolve. Material changes will be reflected by a new version number and effective date at the top of this document. Continued use of MEDIA EMPIRE after a change takes effect constitutes acceptance of the revised Policy.