1. Scope and controller
This policy applies to bloomlight.nawaeurope.com, related Bloomlight support communications, and the Bloomlight app when released.
The intended data controller is Thoth Group LLC, a Delaware limited liability company operating the NAWA Europe brand and nawaeurope.com. NAWA Europe is not a separate legal entity and is not established in Romania. Bloomlight is created by Adel Ramzy. The controller’s registered address, Delaware file number and applicable tax details must be completed in the Legal Notice before commercial publication. Privacy questions can be sent to privacy@nawaeurope.com.
2. Plain-language summary
- The public website has no advertising, behavioral analytics, tracking pixels or non-essential cookies.
- The optional Early Light newsletter form does not transmit data through the website; it prepares a subscription request in the visitor’s own email application.
- The planned game does not require a NAWA Europe account and does not include third-party advertising.
- Core progress and settings are designed to remain on the device, with optional Apple iCloud synchronization where enabled.
- Game Center, iCloud and purchases are Apple services controlled through the player’s Apple Account and device settings.
- NAWA Europe does not sell personal information or share it for cross-context behavioral advertising.
- If you email support, we receive the information you choose to include so we can answer you.
3. Information that may be handled
| Category | Examples | Source | Purpose |
|---|---|---|---|
| Hosting security data | IP address, requested URL, time, browser or device type, response code | Automatically generated by the web server | Deliver the site, prevent abuse and diagnose faults |
| Support correspondence | Email address, message, attachments and device details you provide | Directly from you | Answer requests and resolve problems |
| Newsletter correspondence | Email address, subscription request, consent and later unsubscribe request | Directly from you when you send the prepared email | Send requested Bloomlight development, TestFlight and release news |
| Local game data | Progress, settings, unlocked content and accessibility preferences | Created through gameplay | Save progress and provide the game |
| Game Center data | Player identifier, display name, achievements and leaderboard scores | Apple Game Center, if enabled | Provide achievements, challenges and rankings |
| Purchase status | Product, transaction identifier and entitlement status; never full card details | Apple StoreKit | Complete or restore the full-game unlock |
| Diagnostics | Crash details, app version, OS and device model | Apple diagnostics when a user chooses to share them | Find bugs and improve reliability |
The planned app does not need precise location, contacts, photographs, camera, microphone, health data or advertising identifiers for its core experience. If the final build changes, this policy and the App Store privacy disclosures will be updated before release.
4. Website data
The website is a static presentation. It does not create a profile, run advertising, embed social-media trackers, store preferences in local storage or set first-party marketing cookies. The hosting service may create short-lived server logs containing network and request information to operate and secure the site.
Early Light newsletter requests
The newsletter form does not submit an email address to a website database. When a visitor completes the form, the site opens the visitor’s default email application with a prepared subscription request addressed to NAWA Europe. No subscription request is received unless the visitor chooses to send that email. The sent request is then handled as email correspondence and used only for the requested Bloomlight updates.
Subscribers can withdraw consent at any time by replying with “unsubscribe” or emailing privacy@nawaeurope.com. Withdrawal does not affect processing already carried out with valid consent.
When you follow a link to the App Store or another external site, that destination processes information under its own terms. We do not receive your full payment details from Apple.
For current details about browser storage, see the Cookie Policy.
5. The game and Apple services
On-device progress
Gameplay progress and preferences are designed to be stored locally. Deleting the app may remove local data. If iCloud synchronization is enabled, a copy may remain in the player’s iCloud storage until removed through Apple’s settings.
Game Center
If the player enables Game Center, the app may access the Game Center player identifier, display name, achievements and scores needed for those features. NAWA Europe does not plan to create a separate player-profile database. Game Center can be managed through Apple device settings.
StoreKit purchases
Purchases and restorations are processed by Apple. The app receives transaction and entitlement information needed to unlock content, but not the player’s complete card or bank information.
Apple diagnostics
Apple may provide crash or performance reports when users have enabled sharing with developers. Reports are used to investigate technical issues and are not used for advertising.
6. Purposes and legal bases
Where the EU GDPR or UK GDPR applies, NAWA Europe relies on:
- Contract: to provide the game, recognize purchases, save requested progress and respond to service requests.
- Legitimate interests: to secure the website, prevent abuse, diagnose faults and improve stability, balanced against user rights.
- Consent: to send the optional Early Light newsletter and where a device or service presents another optional choice, such as sharing diagnostics or enabling an optional Apple service.
- Legal obligation: to keep records or respond where applicable law requires it.
NAWA Europe does not use support messages or gameplay information for unrelated advertising.
8. International transfers
Apple, the hosting provider or the email provider may process data in countries outside the user’s country. Where European data-transfer rules apply, NAWA Europe will use an adequacy decision, approved contractual safeguards or another lawful transfer mechanism as appropriate. Provider locations and safeguards must be verified during deployment.
9. Retention and deletion
- Web security logs: intended to be retained for no more than 30 days unless a security investigation or legal requirement justifies longer retention.
- Support messages: normally up to 24 months after the issue closes, then deleted or anonymized unless required for a dispute or law.
- Newsletter contact: until consent is withdrawn or the newsletter is discontinued. A minimal suppression record may be retained where necessary to respect an unsubscribe request.
- Local game data: until the player resets progress or removes the app and associated local data.
- iCloud and Game Center: according to the player’s Apple settings and Apple’s retention practices.
- Purchase records: as long as needed to provide the entitlement and meet accounting, fraud-prevention or legal obligations.
- Developer diagnostics: normally up to 24 months, then deleted or aggregated.
More practical deletion instructions appear on the Privacy Choices page.
10. Your privacy rights
Depending on location, users may have rights to know or access personal data, correct it, delete it, restrict or object to processing, receive a portable copy, withdraw consent, and complain to a regulator. California residents may also have rights to know, correct, delete, opt out of sale or sharing, limit certain sensitive-data uses, and receive equal service when exercising their rights.
Because NAWA Europe does not sell or share personal information for behavioral advertising, there is no sale or targeted-advertising opt-out to apply. A Global Privacy Control signal is consistent with the site’s default no-sale/no-tracking configuration.
To make a request, unsubscribe from news, or withdraw consent, email privacy@nawaeurope.com. We may request limited information to verify the request and will not use that information for another purpose. Authorized agents may act where applicable law permits.
EU and EEA users may complain to the supervisory authority available under applicable law, including the authority in their country of residence. Users elsewhere may contact the privacy or consumer authority available in their jurisdiction.
11. Children
Bloomlight is intended as a broad-audience game, not a service designed to collect information from children. The website has no account, public chat, advertising or user-content upload. Children should not send personal information to support without a parent or guardian.
If NAWA Europe learns that personal information from a child was collected contrary to applicable law, it will take reasonable steps to delete it. A parent or guardian can contact privacy@nawaeurope.com.
12. Security and policy changes
NAWA Europe will use measures appropriate to the information involved, including HTTPS, access controls, data minimization, software updates and limited retention. No internet or storage system can be guaranteed completely secure.
Material changes will be posted on this page with a new effective date. Where required, users will receive additional notice or be asked for consent.
13. Contact
Privacy: privacy@nawaeurope.com
Support: support@nawaeurope.com
Website: bloomlight.nawaeurope.com
The controller’s postal address, country and any applicable registration or tax details will be published in the Legal Notice before commercial launch.