Document: Privacy Policy · Last updated: 2026-07-31 · Effective: 2026-07-31

Privacy Policy

This Privacy Policy explains how Farouk Fusion (“Farouk Fusion,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal data when you use our websites, mobile applications, games, and AI services, including farouks-fusion.com, the EFURC card-battler game (Unreal Engine 5), the EFER cinematic universe and lore sites, the EFEMM anime and character universe experiences, and the JKPHermex Android AI chat application (together, the “Services”).

We take privacy seriously. We follow the EU General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”), the UK GDPR and Data Protection Act 2018, the California Consumer Privacy Act of 2018 as amended by the CPRA (“CCPA/CPRA”), the Children’s Online Privacy Protection Act (“COPPA”), Apple App Store Review Guideline 5.1.1, and the Google Play User Data Policy.

1. Who we are (Data Controller)

Farouk Fusion is the data controller for personal data processed through the Services. You can reach our Data Protection Officer at osei1sup@gmail.com. Postal mail can be sent to the address listed on farouks-fusion.com/contact.

2. Personal data we collect

2.1 Account & contact data

• Email address (used as your account identifier and for essential transactional messages).
• Display name and optional profile information you choose to provide.
• Account creation date and authentication metadata.

2.2 Device & technical data

• Device model, operating system version, locale, time zone, and app version.
• Push-notification tokens (Apple APNs, Google FCM) when you opt in.
• IP address, rough geolocation derived from IP (country/region), and crash diagnostics.

2.3 Usage & gameplay data (EFURC)

• Match history, deck composition, win/loss records, ranked rating, and tournament participation.
• In-game chat and friend-list interactions.
• Anti-cheat telemetry: input timing, frame-rate samples, and integrity checksums.

2.4 Conversation data (JKPHermex)

• Chat messages you send to the JKPHermex assistant and the assistant’s replies.
• Optional voice or image inputs you choose to share with the assistant.
• Feedback signals (thumbs up/down, bug reports) you submit.

2.5 Creative & lore content (EFER & EFEMM)

• User-generated lore posts, fan-art submissions, character profiles, and comments you publish.
• Optional moderation history (warnings, suspensions) tied to your account.

2.6 Purchase & payment data (IAP)

• App-Store or Play-Store receipts (validated via Apple/Google billing; we never see full card numbers).
• Entitlement records: which virtual items or subscriptions you own.
• If you buy directly from farouks-fusion.com: name, billing address, and last-four card digits handled by Stripe or RevenueCat.

3. Why we use your data (purposes & legal bases under GDPR Art. 6)

You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

4. Cookies and similar technologies

See our full Cookie Policy. In short: we set strictly-necessary cookies for authentication and session, a single functional cookie that remembers your theme preference, and no advertising or cross-site analytics cookies. We honor the Global Privacy Control and Do Not Track signals.

5. Children

The Services are not directed to children under 13. We do not knowingly collect personal data from children under 13 (COPPA) or under 16 where the higher age applies under local GDPR guidance. If you believe a child under 13 has provided us data, contact osei1sup@gmail.com and we will delete it within 7 days. JKPHermex, EFURC ranked play, EFEMM community posting, and EFER lore submissions are gated by an age screen that blocks under-13 users from creating accounts.

6. Child-safety-by-design for UGC (EFURC, EFER, EFEMM)

User-generated content in our games and lore sites is filtered and reviewed as follows:

• Hash-matching: Incoming images and text are compared against known CSAM hashes using industry-standard tooling; matches are reported to NCMEC as required by U.S. law (19 USC 2258A).
• Automated classifiers: Pre-publication screening for nudity, sexual content involving minors, and graphic violence.
• Human moderation: A trained moderation team reviews flagged content within 24 hours.
• Reporting: Any user can report content via the in-app “Report” button or by emailing osei1sup@gmail.com.
• No public profile data for under-13: Profile data is not exposed to other players for users flagged as under-age.

7. How we share data (third-party processors)

We do not sell personal data. We share data only with vetted processors who act on our documented instructions:

8. International data transfers

Farouk Fusion is operated from the United States. Where personal data of EU/UK residents is transferred outside the EEA/UK, we rely on the European Commission’s Standard Contractual Clauses (Commission Decision 2021/914) and the UK International Data Transfer Addendum, supplemented by encryption in transit (TLS 1.3) and at rest, strict access controls, and periodic transfer-impact assessments. A copy of the relevant safeguards is available on request to osei1sup@gmail.com.

9. Data retention

We retain personal data for as long as your account is active and for up to 3 years after the last interaction to honor legal obligations (tax, fraud-prevention), resolve disputes, and enforce our terms. After that period, data is either deleted or anonymized for statistical purposes. Specific retention windows:

• Account profile: 3 years after last activity.
• EFURC gameplay telemetry: 18 months.
• IAP receipts: 7 years (tax/audit).
• JKPHermex chat logs: 30 days, unless you opt into longer history.
• Support tickets: 2 years.
• Server logs (IP, request metadata): 90 days.

10. Your rights

Depending on where you live, you have some or all of these rights. We extend them to all users worldwide:

• Access — request a copy of the personal data we hold about you.
• Rectification — correct inaccurate or incomplete data.
• Erasure (“right to be forgotten”) — ask us to delete your data.
• Restriction — pause processing while a complaint is investigated.
• Portability — receive your data in a machine-readable format (JSON).
• Objection — object to processing based on legitimate interests or for direct marketing.
• Withdraw consent — for any processing based on consent.
• Opt out of sale / sharing (CCPA/CPRA) — we do not sell data, but you can still confirm this in writing.
• Lodge a complaint with your supervisory authority (e.g., the Irish DPC, the UK ICO, or the California AG).

To exercise any of these rights, email osei1sup@gmail.com from the address on your account. We respond within 30 days (45 days under CCPA, extendable by 45 days with notice). For UK and EU users, we extend the same 30-day target.

10. Regional rights addenda

10.1 EU and UK residents (GDPR / UK-GDPR)

You have the rights described in Section 10 of this Policy. In addition, you have the right to lodge a complaint with your supervisory authority. A list of EU supervisory authorities is available at edpb.europa.eu; the UK Information Commissioner’s Office can be contacted at ico.org.uk.

10.2 California residents (CCPA / CPRA)

Categories of personal information we have collected about California residents in the past 12 months, as required by Cal. Civ. Code § 1798.110:

• Identifiers: email, IP address, account name.
• Commercial information: IAP purchase history, Virtual Goods owned.
• Internet/Network activity: gameplay telemetry, app crash logs.
• Inferences: skill rating (EFURC), language preference.

We do not collect sensitive personal information (Cal. Civ. Code § 1798.140(ae)). You have the right to know, delete, correct, and limit, and to non-discrimination. We do not sell or share personal information for cross-context behavioral advertising. To exercise your rights, see Section 10 of this Policy.

10.3 Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and other US-state residents

If you live in one of the US states that has enacted comprehensive privacy legislation, we extend the rights described in this Policy to you on the same terms.

11. Security

We protect personal data with administrative, technical, and physical safeguards appropriate to the risk, including TLS 1.3 in transit, AES-256 at rest, role-based access controls, audit logging, multi-factor authentication for staff, and incident-response procedures. If a breach is likely to result in a high risk to your rights and freedoms, we will notify you and the relevant supervisory authority within 72 hours as required by GDPR Art. 33–34.

13. Automated decision-making

EFURC matchmaking pairs you with opponents using an automated algorithm; this is not “solely automated decision-making with legal effects” under Art. 22 GDPR. JKPHermex AI outputs may inform, but do not determine, any decision that produces legal or similarly significant effects on you. You can always request human review by emailing osei1sup@gmail.com.

14. Specific product disclosures

14.1 EFURC (Unreal Engine 5 card-battler)

EFURC collects gameplay telemetry (matches, decks, ratings), anti-cheat telemetry, and in-game chat. On supported platforms we use kernel-level anti-cheat (similar to BattlEye/EAC) which reads process memory while EFURC is running; this data is deleted after each session and is never shared with third parties. You can opt out of telemetry by setting Settings → Privacy → Telemetry = Off in the game; this does not disable anti-cheat, which is necessary to protect the integrity of ranked play.

14.2 JKPHermex (AI assistant on Android)

JKPHermex sends your chat messages to a hosted large-language-model provider (under contract with us) to generate a reply. We retain the messages for 30 days unless you enable long-term memory in Settings → Memory. Image and voice inputs you provide are processed by the same model provider; we do not use them for training. You can export or delete your JKPHermex data at any time from the in-app Privacy & Data panel.

14.3 EFER and EFEMM

EFER and EFEMM user-generated content (lore posts, fan-art, character profiles) is public by default. You can set individual posts to “Friends-only” or “Private.” We never use your EFER/EFEMM content to train JKPHermex or any other model.

14.4 farouks-fusion.com

The website logs standard HTTP request metadata (IP, User-Agent, referer, status code) for 90 days for security and debugging. Marketing email signups require double opt-in, and you can unsubscribe from any email via the “Unsubscribe” link in the message footer.

15. Changes to this Policy

We will post material changes on this page and, where required, notify you by in-app message or email at least 14 days before they take effect. The “Last updated” date at the top of the page records the most recent revision.

16. Contact

Questions, comments, or complaints about this Policy or our handling of your data can be sent to osei1sup@gmail.com. EU and UK users may also contact their supervisory authority; we will cooperate with any inquiry.

This Privacy Policy is published under the operator name “Farouk Fusion” and applies to farouks-fusion.com, the EFURC game, the EFER and EFEMM universe sites, and the JKPHermex AI assistant. Public privacy and legal requests currently route to osei1sup@gmail.com and the site contact form.