FATHOMFALL Children's Privacy Notice

Effective date: 2026-10-15

Version: 1.2

FATHOMFALL (the "Game") is operated by Venture Returns LLC, a Missouri limited liability company ("Venture Returns," "we," "us," or "our"). This Children's Privacy Notice explains how we approach the privacy and safety of younger players in the FATHOMFALL game (the "Game"). It supplements our Privacy Policy and reflects our obligations under the U.S. Children's Online Privacy Protection Act (COPPA), the UK Age-Appropriate Design Code (the "Children's Code"), and the EU/UK General Data Protection Regulation as applied to children.

Contact: privacy@fathomfallgame.com, or by mail at Venture Returns LLC, 117 S. Lexington St., Ste. 100, Harrisonville, MO 64701, USA.

1. Age gate and minimum age

The Game presents an age gate the first time you run it. You must meet the minimum age to play:

• In the United States, the Game is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you are under 13, please do not use the Game.
• In the EU/EEA, the minimum age to consent to information-society services without parental authorization varies by country (between 13 and 16). If you are below that age in your country, you should only use the Game with the involvement and consent of a parent or guardian.
• In the UK, the Children's Code applies to users under 18, and we apply age-appropriate design to all younger players as described below.

If you do not meet the applicable minimum age, the age gate should prevent you from proceeding. If a child below the applicable age has used the Game, see Section 5.

2. What we collect, and our data-minimizing approach

We deliberately collect very little, which reduces the privacy risk to younger players. For all players, including younger ones, we collect only:

• A display name you choose (which appears publicly on the leaderboard: see Section 4);
• A random, server-issued session identifier stored in your browser;
• Gameplay statistics we derive on our server (rating, renown, in-game currency, level, progress);
• Only if the player chooses to sign in, a phone number, used to send a one-time code and to link progress across devices. Our sign-in provider, Stytch, processes the number, and we keep only its last two digits (Privacy Policy, Section 3.6). Sign-in is optional and the Game never asks for it to play. Parents can delete the link at any time with Settings → "Manage my data."

We do not collect real names, email addresses, precise location, contacts, photos, or any special-category/sensitive data. We do not use third-party analytics, advertising, or trackers, and we do not sell or share personal information. There is no behavioral advertising or profiling for marketing.

3. Age-appropriate design (UK Children's Code / GDPR)

Consistent with age-appropriate design principles, we:

• Apply high-privacy defaults: minimal data collection, audio off by default, no behavioral advertising, and no unnecessary data sharing;
• Avoid profiling children for advertising or marketing;
• Avoid nudge techniques and dark patterns that would push younger players to share more data or weaken their privacy;
• Provide clear, plain-language notices (this document and the Privacy Policy);
• Use data only to provide and protect the Game (run gameplay, save progress, operate the leaderboard, and keep play fair and safe);
• Make it easy to delete data: any player can remove their profile and local data from Settings → "Manage my data."

4. Public display name: guidance for younger players and parents

A player's chosen display name appears publicly on the leaderboard and to other players. We strongly advise younger players not to use their real name or any personal information as a display name. Our Community Guidelines prohibit display names that reveal personal information or that are hateful, harassing, sexual, or otherwise inappropriate, and we operate a notice-and-action process to report and remove violating names.

5. Parental rights and contact

If you are a parent or guardian and believe your child has provided us personal information, or you want to review or delete information associated with your child, contact us at privacy@fathomfallgame.com. We will:

• Help you access the limited information associated with the child's device profile;
• Delete that information and profile on request; and
• Take steps to prevent further collection where appropriate.

Because guest play is anonymous and keyed to a server-issued session identifier, you can also delete the child's profile and local data directly from the device via Settings → "Manage my data."

6. If we learn we collected a younger child's data

If we learn that we have collected personal information from a child below the applicable minimum age without the required parental consent, we will delete that information promptly.

7. No targeted advertising or sale of children's data

We do not serve targeted advertising, and we do not sell or share the personal information of any player, including children. We do not knowingly create marketing profiles of children.

8. Changes to this Notice

We will update this Notice as the Game evolves (for example, if optional account creation or other features are added). We will revise the version and effective date below and, for material changes, provide more prominent notice in the Game.

9. Contact

Operator / data controller: Venture Returns LLC, 117 S. Lexington St., Ste. 100, Harrisonville, MO 64701, USA

Children's privacy and parental requests: privacy@fathomfallgame.com

© 2026 Venture Returns LLC. All rights reserved.

Changelog

• 2026-10-17, editorial: Punctuation only (each dash became a colon or a comma). No change in meaning, so the version is unchanged and no new acceptance is needed.
• 1.1, 2026-06-23: Named Venture Returns LLC (a Missouri limited liability company) as the operator of the Game and the data controller; added the operator's postal address and the copyright notice.
• 1.0, 2026-06-21: Initial publication.