Privacy Policy

Effective Date: December 1, 2025

Excerion Sun LLC ("we", "us", "our") respects your privacy. This Privacy Policy describes how we collect, use, and protect your information when you play Hi Stakes Markets Game ("the Game", "the Service").

By using the Service, you agree to the collection and use of information in accordance with this policy.

1. Information We Collect

We collect data to operate the Game, prevent fraud, and provide customer support.

1.1. Information You Provide

  • Email Address: Collected for account authentication, recovery, and critical service notifications.
  • Customer Support Inquiries: Any information you voluntarily provide when contacting help@excsn.com.

1.2. Information Generated by the Game

  • Display Name: The Game assigns a randomized display name (e.g., "TraderX92") to your account. This name is public within the game but does not identify you personally.
  • Simulation Data: We record all in-game actions, including trades, portfolio holdings, contract interactions, and narrative choices. This data is integral to the game's economy.

1.3. Technical Information (Automatic)

  • IP Address: Collected to maintain session security and prevent fraud/abuse (e.g., botnets).
  • Device Information: Basic device model and operating system version to ensure app compatibility.

1.4. Payment Information

We do not collect or store your credit card or bank account numbers.

  • Apple & Google: All payments are processed by the Apple App Store or Google Play Store. Their privacy policies govern the collection of your financial data.
  • Receipts: We store transaction receipts (transaction IDs) provided by Apple/Google to validate purchases, enable content delivery, and resolve support issues.

2. Sweepstakes Information

If you win a prize in a sweepstakes or giveaway:

  1. Collection: We may require your legal name, mailing address, and tax identification number (if required by law) to fulfill the prize.
  2. Security: This sensitive information is stored in secure offline storage separate from the Game infrastructure. It is encrypted at rest and strictly access-controlled.
  3. Retention: We retain this information only for the duration required by applicable tax and audit laws (e.g., IRS regulations). Once the legal retention period expires, this data is permanently destroyed.

3. How We Use Your Information & Lawful Basis

We process your data for the following purposes:

  • Service Delivery: Managing your account, processing game logic, and saving your progress. (Lawful Basis: Performance of Contract)
  • Security & Integrity: Using IP addresses to detect multi-accounting, botting, or unauthorized access. (Lawful Basis: Legitimate Interest)
  • Communication: Sending system emails (e.g., password reset, major TOS updates). (Lawful Basis: Performance of Contract/Legal Obligation)
  • Analytics: We use aggregated, anonymized Simulation Data to balance the game economy. We do not currently use third-party marketing analytics trackers. (Lawful Basis: Legitimate Interest)

4. Data Sharing and Disclosure

We do not sell your personal data. We share data only in the following limited circumstances:

  • Service Providers: We use trusted third-party companies (e.g., cloud hosting, email delivery) to operate the Game. These providers are bound by Data Processing Agreements (DPAs) and are only permitted to use your data on our instructions.
  • Legal Requirements: We may disclose your data if required to do so by law or in response to valid requests by public authorities (e.g., a court order or subpoena).
  • Merger or Sale: If Excerion Sun LLC is involved in a merger, acquisition, or asset sale, your personal data may be transferred.

5. International Data Transfers

Our servers are located in the United States. If you access the Service from outside the United States, please be aware that your information may be transferred to, stored, and processed in the US. Where required, we use appropriate safeguards such as Standard Contractual Clauses (SCCs) to protect data transferred outside the EEA/UK.

6. Data Retention and Deletion

We retain personal data only as long as necessary. Typical retention periods include:

  • Account Data: Retained while your account is active and for up to 12 months after deletion for fraud prevention.
  • IP & Security Logs: Retained for 90 days for security and abuse detection.
  • Sweepstakes & Tax Records: Retained for 7 years to comply with tax and audit laws.
  • Simulation Data: Upon account deletion, identifiers (email, account ID) are removed, and the gameplay history is retained in an anonymized form for the ongoing integrity of the simulation.

7. Your Rights (GDPR / CCPA)

7.1. How to Exercise Your Rights

Depending on your location, you may have rights to access, correct, or delete your personal data. To exercise these rights, please submit a request to legal@excsn.com. We will verify your identity before responding to protect your privacy. We aim to respond to requests within 30 days.

7.2. California Privacy Rights (CCPA)

We do not sell your personal information. California residents have the right to request disclosure of the categories of personal information we collect, the source of the information, the purpose for collection, and the categories of third parties with whom we share it.

8. Security

We use industry-standard technical and organizational measures to protect your information, including TLS for data in transit, encryption at rest for sensitive records, access controls, and periodic security testing. In the event of a data breach, we will notify affected individuals and relevant authorities as required by applicable law.

9. Children's Privacy

Our Service is not intended for children under 13. Users aged 13 to 17 may use the Service only with parental permission. If we become aware that we have collected personal data from a child under 13 without verifiable parental consent, we will delete that data promptly.

10. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top.

11. Contact Us

If you have any questions about this Privacy Policy, please contact us: