Privacy
Policy

Depending on how you use FISHY, we may process information such as:

• your Meta account or app-specific identifier;
• your Meta age category;
• your username or display name where provided through Meta or used in FISHY;
• information about your device and internet connection;
• IP address;
• general country or regional information derived from your device, platform or IP address;
• gameplay information;
• game progress;
• inventory and Virtual Items;
• purchase and entitlement information;
• multiplayer and lobby information;
• game settings and preferences;
• head, hand and controller movement required to operate the VR game;
• voice data where voice chat is available;
• diagnostic, crash and analytics information;
• information you provide when contacting support;
• information you provide when joining a mailing list, promotion or other optional service; and
• website usage information.

We use this information primarily to operate FISHY, provide multiplayer gameplay, maintain player progression and purchases, provide age-appropriate experiences, keep the game secure, enforce our Terms and Conditions, understand how FISHY performs, improve the game and comply with our legal obligations.

We do not sell personal information.

We do not use personal information collected through FISHY for targeted or behavioural advertising.

FISHY does not contain third-party advertising.

Additional protections apply to players using Meta parent-managed accounts and other users who are treated as children under applicable privacy laws.

FISHY is intended for a mixed-age audience.

On supported Meta Quest devices, eligible children aged 10 to 12, or the equivalent child age category in their region, may access FISHY using a Meta parent-managed account where permitted by Meta.

FISHY is not intended for children under the age of 10.

Meta operates and administers parent-managed Meta accounts. Enver does not administer Meta accounts.

Age categories

For a mixed-age Meta Quest application, we may use Meta's Get Age Category API to receive an age category associated with the user's Meta account.

The age categories provided by Meta may identify the user as:

• Child;
• Teen;
• Adult; or
• Unknown where age-category information is temporarily unavailable.

We use age-category information to provide age-appropriate features, comply with child-safety and privacy obligations and determine whether particular social or other functionality should be available.

We do not need a user's exact date of birth simply to use the Meta age-category system unless another feature or legal requirement separately requires it.

Child accounts

Users identified as children may receive a more restricted version of FISHY.

Depending on applicable law, Meta's requirements, parental settings and the functionality implemented in FISHY, restrictions may apply to features such as:

• voice communication;
• public communications;
• custom usernames;
• friend-related functionality;
• private rooms or room codes;
• invitations;
• purchases;
• social discovery; and
• other features through which a child could disclose personal information or communicate with other users.

We may automatically restrict these features for child accounts unless the feature is permitted by applicable law and any required parental permission has been obtained.

Information from children

We seek to collect only information reasonably necessary to provide and support FISHY.

For child users, persistent identifiers such as an app-specific account ID, device-related identifier or IP address may be processed where necessary for internal operations such as:

• authenticating the user;
• operating network communications;
• saving game progress;
• maintaining an inventory;
• providing multiplayer functionality;
• providing game settings;
• preventing fraud or abuse;
• maintaining security;
• debugging;
• analytics necessary to understand and maintain the operation of the game; and
• complying with legal or platform requirements.

We do not use information from child users for targeted advertising.

We do not sell personal information belonging to child users.

Where applicable law requires verified parental consent before we collect, use or disclose particular information from a child, we will obtain that consent or restrict the relevant feature.

Voice data and children

A person's voice can constitute personal information, particularly when the speaker is a child.

Where voice chat is available, audio may need to be transmitted between users in order to provide the feature.

For users identified as children, voice functionality may therefore be disabled, restricted or subject to parental permission or additional safeguards.

We do not create voiceprints for the purpose of identifying players.

Unless we provide a separate notice stating otherwise, Enver does not intentionally retain permanent recordings of ordinary voice-chat conversations.

If FISHY later introduces voice recording for moderation, safety, reporting or another purpose, we will update this Privacy Policy and implement any additional notices, parental permissions or other safeguards required by law before applying that functionality to child users.

Parents' rights

A parent or legal guardian may contact us to:

• ask what personal information we hold about their child;
• request correction of their child's information;
• request deletion of their child's information;
• request deletion of their child's FISHY profile where applicable; or
• ask us to stop further collection or use of their child's personal information where applicable.

Contact:

hi@enverstudio.com

We may need to verify that the person making the request is the child's parent or legal guardian before disclosing information or acting on the request.

We may also need information sufficient to identify the child's FISHY or Meta-linked profile.

The precise information processed may depend on your device, account type, age category, game version and features you use.

A. Account and platform information

We may receive or process information associated with your Meta account where made available through authorised Meta Platform functionality.

This may include:

• an app-scoped or platform user identifier;
• Meta age category;
• username or display name;
• account entitlement information;
• information necessary to verify that you are entitled to access FISHY;
• information relating to in-app purchases or entitlements;
• account language, locale or similar settings; and
• other Meta Platform information required for a feature you choose to use.

Not every item of information available through the Meta Platform SDK is necessarily stored by Enver.

We aim to access only the platform data required for the FISHY features we operate.

B. Gameplay information

We may process information about how you play FISHY, including:

• player progression;
• fish caught;
• collections;
• achievements or challenges;
• rods;
• bait;
• equipment;
• clothing and cosmetics;
• inventory;
• Virtual Items;
• virtual currency balances;
• rewards;
• game settings;
• preferences;
• tutorial progress;
• game sessions;
• session duration;
• game mode;
• multiplayer sessions;
• lobby or room information;
• interactions with game systems;
• event participation; and
• other gameplay events.

We use this information to operate the game, preserve progression, maintain inventories, provide multiplayer functionality, balance and improve gameplay and troubleshoot problems.

C. Purchase information

FISHY may offer purchases such as Virtual Items, currency, cosmetics, equipment or bundles.

Purchases made through Meta are processed through Meta's payment systems.

Enver does not ordinarily receive your full payment card details from Meta.

We may receive information such as:

• confirmation that a purchase occurred;
• transaction or purchase identifier;
• the item or bundle purchased;
• entitlement information;
• price or currency information where provided;
• transaction status; and
• information necessary to restore or verify purchases.

We use this information to provide purchased content, maintain player inventories, prevent fraud, provide customer support and keep appropriate financial or transaction records.

D. Device, technical and network information

When you use FISHY, we or our service providers may automatically process technical information such as:

• IP address;
• device type;
• headset model;
• operating system or firmware information;
• app version;
• software or SDK version;
• hardware information;
• network information;
• language or locale;
• general country or regional information;
• session identifiers;
• app-instance or similar technical identifiers;
• timestamps;
• connection information;
• crash information;
• error reports;
• diagnostic information; and
• performance data.

We use this information to establish network connections, operate multiplayer services, maintain security, diagnose problems, prevent abuse and improve game performance.

E. VR movement information

FISHY is a virtual reality game and necessarily responds to movement information generated by the headset and controllers.

We may process information reflecting:

• head position and movement;
• hand or controller position and movement;
• orientation;
• gestures;
• player movement through the virtual environment; and
• similar spatial gameplay information.

This information is used to render and operate FISHY, determine how your virtual character moves and interacts with the game world and, where relevant, transmit appropriate gameplay information to other users in multiplayer sessions.

We do not use ordinary VR movement information to identify you through biometric analysis.

We do not use this information for targeted advertising.

F. Voice information

Where voice chat or other voice functionality is available, voice data may be processed to transmit communications between players.

Voice data may be processed by Enver's communications or multiplayer service providers as necessary to operate the feature.

Unless we separately notify users otherwise, we do not use voice data to create voiceprints or identify a player by their voice.

Unless separately disclosed, Enver does not intentionally maintain permanent recordings of ordinary player voice-chat conversations.

Voice-chat availability may vary according to age category, parental settings and other safety requirements.

G. Multiplayer and safety information

If you interact with other users, we may process information associated with those interactions where necessary to provide multiplayer functionality or maintain safety.

This may include:

• lobby or room membership;
• player IDs;
• report information;
• block or mute information;
• information about alleged violations;
• relevant gameplay records;
• enforcement history;
• ban or suspension records;
• appeal correspondence; and
• information reasonably necessary to investigate cheating, abuse, threats, fraud or other violations of our Terms and Conditions.

We may retain certain enforcement information even after other account information is deleted where reasonably necessary to prevent ban evasion, protect users, establish or defend legal claims or maintain the integrity of the Services.

We collect information that you choose to provide to us.

Support and communications

If you contact us, we may collect:

• your email address;
• your name if you provide it;
• your username or player identifier;
• your Meta identifier where needed to locate your account;
• the contents of your message;
• attachments or screenshots you send;
• information about a problem you are experiencing; and
• records of our correspondence with you.

Reports and appeals

If you report another player or appeal a moderation decision, we may collect:

• your contact information;
• relevant player identifiers;
• information concerning the report or enforcement action;
• evidence you choose to provide;
• relevant game or moderation records; and
• correspondence relating to the investigation or appeal.

Ban appeals may be sent to:

hi@enverstudio.com

Mailing lists

If you choose to join an official FISHY mailing list, we may collect your email address and information concerning your subscription preferences.

We will use this information to send communications you have requested or, where permitted by law, FISHY news and marketing communications.

You may unsubscribe at any time using the unsubscribe mechanism in an email.

We do not knowingly add child users to general marketing lists without any permission required by applicable law.

Surveys, competitions and promotions

If you voluntarily participate in a survey, competition, giveaway, playtest or promotion, we may collect information described at the point of collection.

This may include:

• name;
• email address;
• username;
• player ID;
• survey responses;
• competition entries;
• social-media account details; or
• shipping details where a physical prize must be delivered.

Additional terms or privacy notices may apply to particular promotions.

If you visit an official FISHY website, we or our service providers may process information such as:

• IP address;
• browser type;
• device type;
• operating system;
• pages visited;
• referral source;
• approximate geographic region;
• interactions with the website;
• session information; and
• cookies or similar identifiers.

We may use cookies or similar technologies to operate the site, remember preferences, maintain security and understand how the website is used.

Where required by law, non-essential cookies or analytics technologies will be used only after the required consent has been obtained.

We may use Google Analytics or related Google analytics technologies to understand use and performance of our Services where implemented.

Depending on the implementation, Google Analytics may process information such as:

• an app-instance or client identifier;
• session information;
• interactions or events;
• approximate geographic information;
• device information;
• operating system information; and
• performance or usage statistics.

We use analytics to:

• understand how users interact with FISHY or our website;
• diagnose problems;
• measure performance;
• improve gameplay and user experience;
• understand feature usage; and
• produce aggregate statistics.

We do not use Google Analytics data collected from FISHY for targeted advertising.

Where users are identified as children, analytics processing will be configured and limited as necessary to comply with applicable child-privacy requirements.

We may use technology supplied by Exit Games GmbH or related Photon services ("Photon") to provide networking and multiplayer functionality.

When you participate in online multiplayer gameplay, Photon may process information necessary to establish and maintain multiplayer sessions, such as:

• IP address;
• session or connection information;
• player or application identifiers;
• lobby or room information;
• network traffic necessary for gameplay; and
• technical or diagnostic information.

Where Photon voice or another Photon communications product is used, voice or communications data may also be transmitted as necessary to provide that functionality.

Photon acts according to the contractual arrangements governing its services and its own applicable privacy documentation.

FISHY may use the Meta Platform SDK and related Meta services for functionality including:

• verifying users and entitlements;
• determining age category;
• in-app purchases;
• multiplayer or social functionality;
• account-related features;
• cloud or platform functionality; and
• other Meta Quest features.

Information made available to Enver by Meta is used only for purposes permitted by Meta's developer terms, our Privacy Policy and applicable law.

Meta separately processes information as the operator of its own platform and services.

FISHY may operate an official Discord server or community.

Discord is a separate third-party service.

If you join an official FISHY Discord community, Discord will process information in accordance with its own privacy policy and terms.

Enver may receive or process information visible or supplied within an official FISHY Discord community, including:

• Discord username;
• Discord user ID;
• messages or content posted in the community;
• moderation information;
• reports;
• ban or appeal information; and
• information you voluntarily provide to moderators or Enver.

Joining Discord is not required simply to play FISHY unless we expressly state otherwise for a particular optional feature.

Users must meet Discord's applicable minimum-age requirements.

We may offer FISHY merchandise in the future.

Where merchandise is sold through a third-party store or payment provider, that provider may process information required to complete the purchase.

If Enver receives information relating to a merchandise order, it may include:

• name;
• email address;
• delivery address;
• order information;
• transaction status; and
• customer-support correspondence.

We will use that information to process and support the transaction, prevent fraud and comply with financial and legal obligations.

Full payment-card information may be processed directly by the relevant payment processor rather than Enver.

We use personal information for the following purposes.

Providing FISHY

We use information to:

• authenticate users;
• verify entitlement to use FISHY;
• provide gameplay;
• save progress;
• maintain inventories;
• fulfil purchases;
• connect multiplayer sessions;
• provide social features;
• provide voice functionality where enabled;
• maintain settings and preferences; and
• otherwise provide requested Services.

Providing age-appropriate experiences

We use age-category and related information to:

• identify child, teen and adult account categories;
• provide different functionality where appropriate;
• restrict features for child users where necessary;
• comply with Meta requirements;
• comply with children's privacy and safety laws; and
• apply parental settings.

Safety, moderation and enforcement

We use information to:

• investigate reports;
• respond to abuse;
• enforce our Terms and Conditions;
• prevent cheating;
• prevent ban evasion;
• protect children and other users;
• detect threats to the Services;
• respond to emergencies; and
• cooperate with competent authorities where required or appropriate.

Security and fraud prevention

We use information to:

• secure accounts and systems;
• detect suspicious activity;
• prevent unauthorised access;
• prevent fraudulent transactions;
• protect our infrastructure; and
• diagnose security incidents.

Analytics and improvement

We use information to:

• understand game performance;
• understand feature use;
• identify bugs;
• improve reliability;
• balance gameplay;
• improve progression systems;
• understand broad usage patterns; and
• develop and test improvements to FISHY.

Customer support

We use information to:

• respond to questions;
• investigate technical problems;
• resolve purchase issues;
• process privacy requests;
• handle reports; and
• process enforcement appeals.

Legal compliance

We may process information to:

• comply with applicable laws;
• comply with legal process;
• comply with Meta platform requirements;
• maintain tax and financial records;
• protect legal rights;
• establish, exercise or defend legal claims; and
• respond to regulators or law enforcement.

Marketing

Where permitted by law, we may use information you voluntarily provide for marketing purposes, such as sending FISHY news to mailing-list subscribers.

We do not use information collected from gameplay for targeted behavioural advertising.

Where applicable law requires us to identify a legal basis for processing, we rely on one or more of the following.

Contract

We process information where necessary to provide FISHY and perform our agreement with you.

Examples include maintaining player progress, providing purchased Virtual Items and connecting multiplayer sessions.

Legitimate interests

We may process information where necessary for our legitimate interests or those of another party, provided those interests are not overridden by your rights.

These interests may include:

• securing FISHY;
• preventing fraud;
• enforcing our Terms;
• protecting users;
• improving FISHY;
• maintaining reliable systems;
• understanding service performance; and
• handling legal claims.

Consent

We rely on consent where applicable law requires it.

Examples may include:

• certain cookies;
• optional marketing communications;
• certain child-data processing; or
• other optional features requiring consent.

Where processing depends on consent, you may withdraw that consent subject to applicable law.

Legal obligation

We may process information where necessary to comply with a legal obligation.

Vital interests

In rare situations, we may process information where necessary to protect the vital interests of a user or another person, such as responding to an immediate safety threat.

We may disclose personal information to the following categories of recipients.

Platform provider

Meta may receive or process information in connection with the operation of Meta Quest, Meta accounts, purchases, platform functionality and other Meta services.

Multiplayer and communications providers

We may disclose or permit processing of information by providers such as Photon where necessary to operate online multiplayer or communication functionality.

Analytics providers

We may use providers such as Google to provide analytics and performance measurement.

Hosting, infrastructure and technical providers

We may use third parties to provide services such as:

• hosting;
• databases;
• cloud infrastructure;
• content delivery;
• email;
• customer support;
• monitoring;
• error reporting;
• security; and
• other technical operations.

These providers may process personal information where reasonably necessary to provide their services to us.

Professional advisers

We may disclose information to lawyers, accountants, auditors, insurers and other professional advisers where reasonably necessary.

Law enforcement and authorities

We may disclose information where we reasonably believe disclosure is necessary to:

• comply with law or legal process;
• respond to a valid governmental request;
• investigate unlawful conduct;
• protect a child or other person;
• protect the rights or safety of users;
• protect Enver or our Services; or
• prevent serious harm.

Corporate transactions

If Enver is involved in a merger, acquisition, financing, reorganisation, bankruptcy, sale of assets or similar corporate transaction, information may be disclosed or transferred as part of that transaction subject to applicable law.

Enver does not sell personal information for money.

Enver does not use personal information collected through FISHY for targeted or behavioural advertising.

We do not knowingly sell or share the personal information of children for cross-context behavioural advertising.

If our practices change in a way that creates additional opt-out rights under applicable law, we will update this Privacy Policy and provide the required choices before applying the changed practice.

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer period is required or permitted by law.

Retention periods depend on the type of information and why we process it.

For example:

• gameplay and account information may be retained while the relevant FISHY profile remains active;
• inventory and purchase information may be retained to maintain purchased entitlements and transaction history;
• financial records may be retained as required by tax, accounting or other laws;
• support correspondence may be retained for a reasonable period after a matter is resolved;
• moderation, ban and security records may be retained where necessary to protect users, prevent repeated abuse or ban evasion and defend legal claims;
• analytics information may be retained according to the settings applied to the relevant analytics service; and
• backup copies may remain temporarily after deletion until overwritten through our normal backup cycle.

When information is no longer reasonably required, we will delete, anonymise or otherwise dispose of it in accordance with applicable law and our technical processes.

You may request deletion of personal information associated with FISHY by contacting:

hi@enverstudio.com

Please state that you are making a FISHY data-deletion request.

We may ask for information reasonably necessary to:

• locate the relevant account or game profile;
• verify your identity;
• verify a parent's authority where the request concerns a child; and
• prevent fraudulent deletion requests.

Once a valid request has been verified, we will delete applicable personal information within the period required by law, subject to legal exceptions.

Deletion may result in the permanent loss of:

• progression;
• inventory;
• collected fish;
• game settings;
• rewards;
• Virtual Items;
• virtual currency; and
• other information associated with the deleted profile.

Some information may be retained where necessary to:

• comply with law;
• maintain transaction or financial records;
• exercise or defend legal claims;
• prevent fraud;
• protect users;
• maintain security;
• enforce bans; or
• document that a privacy request was completed.

Information controlled independently by Meta or another third party must be deleted through that third party's applicable privacy controls.

Your rights depend on where you live.

Subject to applicable law, you may have the right to:

• know whether we process your personal information;
• obtain access to personal information we hold about you;
• receive information about the categories and sources of personal information we collect;
• obtain a copy of certain personal information;
• correct inaccurate personal information;
• request deletion of personal information;
• restrict certain processing;
• object to certain processing;
• withdraw consent;
• obtain portable copies of certain information;
• opt out of certain sales, sharing, profiling or targeted advertising;
• appeal certain decisions concerning a privacy request; and
• complain to an applicable privacy or data-protection authority.

You may exercise applicable rights by contacting:

hi@enverstudio.com

We will not unlawfully discriminate against you for exercising a privacy right.

We may need to verify your identity before responding to certain requests.

Where permitted by law, an authorised agent may make a request on your behalf, although we may require evidence of the agent's authority.

Residents of California and certain other U.S. states may have additional privacy rights.

During the preceding 12 months, depending on the features a user accessed, we may have collected the following general categories of personal information:

• identifiers;
• internet and network activity;
• commercial or transaction information;
• approximate geolocation;
• audio information;
• electronic or sensory information associated with VR movement;
• account and gameplay information; and
• inferences or analytics derived from gameplay or service usage.

The sources, purposes and recipient categories for this information are described throughout this Privacy Policy.

We may disclose these categories of information to service providers, contractors, platform providers and other recipients described in Section 13 for business and operational purposes.

We do not sell personal information for money.

We do not use personal information collected through FISHY for cross-context behavioural or targeted advertising.

Where applicable state law gives you a right to appeal our response to a privacy request, you may submit an appeal to:

hi@enverstudio.com

Please state that the message is a privacy-request appeal.

Enver Studio LLC is based in the United States.

If you access FISHY from outside the United States, your information may be transferred to, stored in or processed in the United States or other countries where Enver or our service providers operate.

Those countries may have data-protection laws that differ from the laws where you live.

Where applicable law requires safeguards for international data transfers, we will use an appropriate transfer mechanism, such as contractual protections or another legally recognised mechanism.

We use reasonable administrative, technical and organisational measures designed to protect personal information against:

• unauthorised access;
• unauthorised disclosure;
• loss;
• misuse;
• alteration; and
• destruction.

No online service or data-storage system can be guaranteed to be completely secure.

You are responsible for protecting access to your Meta account and should notify Meta or Enver as appropriate if you believe your account or FISHY profile has been compromised.

We may use automated systems to support routine game functionality, analytics, security or enforcement.

We do not currently make decisions based solely on automated processing that produce legal or similarly significant effects on ordinary FISHY users, except where permitted by applicable law and accompanied by required safeguards.

Moderation or enforcement decisions may use technical information to assist investigation, but users may appeal FISHY bans as described in our Terms and Conditions.

Our Services may link to third-party websites or services.

Examples may include:

• Meta;
• Discord;
• merchandise providers;
• social-media services; and
• creator or community platforms.

We do not control the privacy practices of third parties when they act independently from Enver.

You should review the privacy policies of those services before providing information to them.

We may update this Privacy Policy from time to time.

We may make changes to reflect:

• new FISHY features;
• changes to our technology;
• new service providers;
• changes to our data practices;
• changes to Meta requirements;
• legal or regulatory developments; or
• safety and security requirements.

When we update this Privacy Policy, we will revise the Effective Date at the top.

Where a change is material, we may provide additional notice through FISHY, our website, email or another appropriate channel.

If a change affecting child users requires new parental consent under applicable law, we will obtain that consent or restrict the affected functionality before applying the change to those users.

For questions about this Privacy Policy, privacy requests, deletion requests or child privacy enquiries, contact:

Email:

hi@enverstudio.com