Privacy Policy

1. Who we are

Hedge Fund Manager (HFM) and hfmgame.com are provided by Venetia Oriens Pte. Ltd., a Singapore company with UEN 202555559N. In this policy, “we”, “us” and “our” mean Venetia Oriens Pte. Ltd. We are responsible for the personal data processing described here, including as controller where that term applies.

Our registered office is 160 Robinson Road, #14-04, Singapore Business Federation Center, Singapore 068914.

Contact the person responsible for privacy and data protection at [email protected], using “HFM privacy request” as the subject. You may also write to the registered office, addressed to the Data Protection Officer.

This policy covers the HFM mobile app, this website and support communications. App stores, sign-in providers and external services also have their own privacy notices.

2. Information we handle

Information you provide or generate

• Manager profile: your manager nickname, generated manager identifier, manager presentation (character), birth year and profile timestamps. The character choice, which may be labelled “gender” in the game, selects the manager’s art and cinematic. It does not ask for your own gender identity and is not used by HFM for advertising. Use a nickname rather than your legal name. Birth year supports age eligibility and age-related advertising restrictions; we ask for a year, not a full date of birth.
• Account and sign-in information: an HFM account identifier and session information, including for guest accounts. If you link Apple or Google sign-in, we also handle the provider identifier and information supplied through that sign-in, which may include an email address and profile name. Apple may provide a private relay address through Hide My Email. We do not receive your Apple or Google password.
• Game records: saved progress, simulated holdings and trades, career outcomes, scores, achievements, preferences, timestamps and records used for rankings and result checks. These are game records, not information about your real brokerage account or actual investment holdings.
• Support requests: your email address, message, account details and attachments you choose to provide. Please do not send passwords, verification codes, payment-card details or unrelated sensitive information.
• Privacy settings: age eligibility indicators and applicable advertising or tracking choices. These settings may be held by the app, Google’s consent services or your device operating system, depending on the choice.

HFM does not collect nationality in the current release. The game is free to download and play, with interstitial ads and no in-app purchases or subscriptions.

Information handled during Google sign-in

HFM does not ask you to enter a phone number and does not request access to your phone number from Google. However, Google may collect a phone number within its own sign-in or account-creation pages, for example for account security or verification. This does not mean that Google passes the number to HFM or that it becomes part of your HFM manager profile.

Google’s sign-in service also handles account and device identifiers, IP-derived approximate location, usage information and other technical or account information for authentication and service analytics. Information handled by Google during its sign-in experience is governed by Google’s Privacy Policy. HFM uses the name, email and provider identifier supplied to it for account functionality, not to send marketing messages.

Technical and advertising information

Services used by HFM process technical information such as IP address, request time, app or browser version, device and operating-system information, session and security information, and error records to deliver and protect their services.

Google AdMob’s advertising software can collect IP addresses and approximate location inferred from them, device or advertising identifiers, ad impressions and interactions, app interactions, and crash, diagnostic and performance information. Collection and use vary with platform, settings, permissions and the advertising features in use. These data support advertising, measurement, analytics, troubleshooting and fraud prevention.

HFM does not request GPS access for gameplay. Approximate location inferred from an IP address is different from GPS location.

The app also loads fonts from Google Fonts. Requests to Google’s font servers disclose the requesting IP address and technical request information needed to deliver the fonts.

3. Guest play and cloud saves

HFM stores manager information, game progress and settings on your device. It also creates a guest account with a unique identifier in Supabase when you play without linking Apple or Google. Manager profiles, cloud saves, achievements and qualifying leaderboard results can therefore be stored on our servers for guest players too.

A guest account does not require a sign-in email, but its records remain linked to its account identifier. “Guest” does not mean the records are anonymous or stored only on your device. Linking Apple or Google adds sign-in details to support account access and restoration.

HFM maintains one current cloud save per account. A later save can replace an earlier save; cloud saving is not a version history or a guarantee that overwritten progress can be recovered.

Uninstalling the app does not delete cloud data. Losing a guest session may also make it difficult to recover access or prove ownership. Use Delete account or the email request route to request removal of server records. Device backups are controlled separately through your device or backup provider.

4. Why we use information

We use relevant information to run the game; maintain profiles and accounts; authenticate sessions; save and restore progress; operate achievements and leaderboards; respond to support and privacy requests; apply age-related settings; display ads; detect cheating, misuse and fraud; protect the service; and meet applicable legal obligations.

Where a legal basis is required, objectively necessary account and game processing is used to provide the service you request. Security, abuse prevention and service administration may rely on legitimate interests, subject to your rights. Consent is the basis for optional tracking, advertising personalization or non-essential storage where required by law. Legal obligations provide the basis for processing required by law. Agreeing to game terms does not itself give consent to optional tracking.

Information required for a feature is needed to provide that feature. For example, cloud saving requires account-linked game records. Device tracking permission is not a condition of playing HFM.

5. What other players can see

When your results appear on a leaderboard, other players can see your manager nickname, a short public tag derived from your identifier, rank, board or season, and relevant game performance figures such as Alpha, Calmar, years played, CAGR and difficulty. Use a nickname you are comfortable displaying publicly. Other people may view or copy public rankings.

Global leaderboards do not display nationality, email addresses, birth year, sign-in tokens or private support messages. Account deletion covers associated leaderboard entries and caches, including founding-season records.

6. Providers and other disclosures

We use the following providers for the purposes described in this policy:

Authorized personnel and contractors may access information as needed to operate, secure or support HFM. Access should be limited to the work required and subject to appropriate confidentiality and data-protection obligations.

We may disclose relevant information when required by law or valid legal process, or where lawfully necessary to protect rights, investigate fraud or respond to a security incident. If HFM or its business is transferred, relevant data may be included subject to applicable safeguards and required notice.

We do not sell lists of player email addresses. Advertising-related disclosures may nevertheless count as “sharing”, a “sale” or targeted advertising under some privacy laws, even without payment for the data. You can contact us about the rights and choices that apply to you.

7. Advertising and your choices

HFM uses interstitial ads through Google AdMob. The app uses birth-year eligibility to request non-personalized ads for users known to be under 18 and for users whose age is unknown. Because only a year is collected, uncertain birthday boundaries are treated conservatively; an adult may continue to receive non-personalized ads until the year information establishes eligibility.

For eligible adults, advertising personalization depends on applicable consent, permissions and restrictions. Where permitted, advertising providers may link advertising information with information from other apps or websites for targeted advertising or measurement. Non-personalized ads can still involve technical data and identifiers for delivery, measurement, frequency control and fraud prevention.

HFM does not send your manager nickname, raw birth year, character choice, sign-in email, HFM account identifier, saved game or scores to AdMob as custom advertising data. AdMob’s own collection of device, interaction and advertising information is separate from these HFM profile fields.

Google’s User Messaging Platform supplies privacy messages according to region and the consent configuration. A form may not appear in every region. On iOS, the Apple tracking prompt and device tracking settings provide a separate permission control. Android offers advertising and privacy controls in device settings; options vary by system version.

To revisit available advertising choices: open HFM’s main menu and select Privacy choices, below the version information. This option appears when Google’s consent service requires a privacy-options entry point; it may be absent in your region. When available, use it to review or change your choices. HFM requests ads only when Google’s consent service permits an ad request; this does not by itself mean that you have agreed to personalized advertising or Apple tracking.

On iOS, you can also review HFM’s tracking permission in Settings → Privacy & Security → Tracking, where available. Declining tracking does not prevent you from playing. Changing advertising consent and changing Apple’s tracking permission are separate actions.

For help with advertising choices, or to request withdrawal of consent or an applicable opt-out, email [email protected]. Tell us which platform you use and describe the request. Changing a device setting does not itself delete previously collected account or advertising records. Independent providers may also offer controls through their own services.

8. Website technologies

hfmgame.com consists of static information pages and email links. We do not add advertising scripts, optional analytics, social-media embeds, video embeds, external fonts, a website sign-in system or a contact form to these pages.

Cloudflare processes technical requests, including IP addresses and request or security information, to deliver and protect the website. Hosting security features may use necessary cookies or similar protections. This is separate from the mobile app’s advertising and storage.

Selecting an email link opens your email application; you must send the message to submit a request. External links take you to services with their own privacy practices. If we introduce non-essential website technologies, we will update this notice and provide any choices required before their use.

9. Retention and account deletion

Retention depends on the purpose and type of information. We use the following criteria for records under our control:

• Accounts and game records: kept while maintaining the account, including a guest account, unless deletion is requested or the records are no longer needed. Uninstalling or ceasing to play does not itself trigger server deletion.
• Deletion requests: after verifying ownership, we remove the account and associated profile, cloud-save, achievement and leaderboard records from the active service. We provide any necessary verification steps and expected processing time, and confirm completion, subject to applicable legal deadlines.
• Support correspondence and request records: kept for handling the request, related follow-up, complaints or disputes, and any applicable legal or accountability requirement. The need to retain this information is separate from keeping the full game account.
• Security and diagnostic information: retention depends on the troubleshooting, security or fraud-prevention purpose, including whether a specific incident or legal obligation remains unresolved.
• Project logs: the current retention setting for our Supabase API and database logs is one day. This does not describe every provider’s internal, security, advertising or support record, which may follow separate retention rules.
• Backups: automated project backups and point-in-time recovery are not enabled for our current Supabase project. This is not a promise that independent providers hold no operational copies or that device backups are erased. Device backups are managed through your device or backup provider.

Any exception to deletion must be limited to the information needed for the relevant legal, security or other lawful purpose. We will explain any such retention, including the reason and applicable period, when handling your request. Independently operated advertising and sign-in services apply their own retention rules to data they control.

You can use Delete account in HFM for a guest account or an account linked to Apple or Google. You can also request deletion by email without reinstalling the app. See the account-deletion page for instructions, verification and the data covered.

A successful in-game deletion removes the account and associated records from our active cloud service and clears the manager profile and game data on the device used for deletion. You do not need to link a guest account to Apple or Google first. For an Apple-linked account, HFM revokes its Sign in with Apple authorization as part of deletion.

Other devices still using the deleted account are signed out when the app next checks the account with our service. An email request cannot immediately erase offline device files; reconnect and reopen the app so it can detect the deletion. Device backups remain subject to the device provider’s controls. Deleting your HFM account does not delete your Apple or Google account.

10. Your privacy rights

Depending on the law that applies, you may request access, a copy, correction, deletion, restriction or portability of your information; object to certain processing; withdraw consent; or opt out of applicable sale, sharing or targeted advertising. Withdrawal does not undo lawful processing before withdrawal. Some rights have exceptions.

Email [email protected] with your request and enough information to identify the relevant account. Manager name, manager identifier or tag, and the linked sign-in email, if any, can help. If you use Apple Hide My Email, mention it and include the relay address if known. We may need proportionate verification; do not send passwords, sign-in codes or identity documents in your initial message.

The game does not offer routine self-service manager renaming or birth-year editing. This does not remove applicable correction rights: contact us if your personal information, especially your birth year, is inaccurate. After an authorized birth-year correction, the updated year and related age and advertising settings take effect on the device’s next successful sync; reinstalling the app is not required.

We respond within applicable legal time limits and explain any refusal or limitation. Where permitted, you may use an authorized agent and request a review or appeal. You will not be penalized for exercising applicable privacy rights.

You may complain to the relevant data-protection authority, including Singapore’s Personal Data Protection Commission or the authority in your country, where applicable. Contacting us first is not a condition of your regulatory rights.

11. Children and younger users

HFM is intended for users aged 13 and above, subject to higher local age requirements and any legally required parental authorization. It is not directed to children under 13. A store age rating does not replace legal age or consent requirements.

We use birth year to apply eligibility and age-related advertising settings. A conservative year-only check may keep a restriction in place after a birthday. Where required authorization is unavailable, the affected processing or feature should not be used until eligibility requirements are met.

If we learn that personal data was obtained from an ineligible child or without legally required authorization, we take appropriate steps to restrict processing and delete the information, except where retention is legally necessary. A parent or guardian can contact [email protected] about a child’s information.

12. International processing

Venetia Oriens is based in Singapore. Our infrastructure, advertising, sign-in and email providers operate internationally, and authorized administration and support may also take place in Indonesia. Your information may therefore be processed in countries other than your own; it is not necessarily stored only in Singapore.

Our primary Supabase project for HFM account and game records is hosted in Sydney, Australia. This project location does not mean that all provider support, security, email or advertising processing takes place in Australia.

Applicable international-transfer requirements govern these transfers. Where required, appropriate safeguards must apply, such as contractual protections or recognized transfer mechanisms. Contact us for information about the processing locations and safeguards relevant to your data, including a copy of applicable safeguards where you are entitled to one.

13. Security

We use reasonable technical and organizational safeguards appropriate to the information and risks, including protected transmission and limiting access to those who need it. No service can guarantee absolute security. If a data incident requires notification, we notify affected people and authorities as required by applicable law.

14. Changes and contact

We update this policy when our practices change and show the current revision date above. For material changes, we provide appropriate notice through the app, website or another suitable channel and obtain fresh consent where required. Updating this policy alone does not authorize a new use that requires consent.

For questions or requests, contact Venetia Oriens Pte. Ltd. at [email protected] or write to the registered office in section 1.