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Privacy Policy

Last updated 29 September 2026 · Commercium Limited

This Privacy Notice explains how Commercium Limited (“we”, “us”, “our”) collects, uses, shares and protects information when you use the mobile game Three Seals: Dojo Duel (the “App”) and its support pages at threeseal.com. We are the data controller of the information described here. If you do not agree with this notice, please do not use the App. Questions: support@threeseal.com.

Summary of key points

  • No account, no ads, no tracking. The App does not ask for your e-mail, password, phone number, payment details, contacts, camera, microphone or location permission. It shows no advertising and does not use Apple’s advertising identifier.
  • Your progress stays with you. Your avatar, the name you type, belt, points and wins are stored on your device and, if iCloud is on, in your own iCloud storage. We never receive them.
  • Anonymous gameplay statistics. To improve the game, the App sends usage events to our analytics provider Amplitude, Inc. They are linked only to a random installation ID, never to your name or Apple account. You can turn them off at any time in Menu › Anonymous stats.
  • We do not sell your data or share it for advertising.
  • You are in control. Menu › Delete my data erases everything on your device and in iCloud and renews the installation ID. Your rights are explained in section 10.

Apple and Android versions

The App is available on Apple devices through the App Store and on Android devices through Google Play. Everything in this notice applies to both versions, with the following differences.

  • iCloud and Game Center are Apple features and do not exist in the Android version. On Android your progress is stored on your device only: there is no cloud copy and there are no leaderboards. If the device is reset or the App is uninstalled, the progress cannot be recovered. Wherever this notice mentions iCloud or Game Center, it describes the Apple version only.
  • Operating system version. Where section 1 says that each event contains the iOS version, the Android version of the App sends the Android version instead.
  • No advertising identifier on either platform. The App uses neither Apple’s advertising identifier (IDFA) nor Android’s Advertising ID. Only the random installation ID described in section 1 is used, and Menu › Delete my data replaces it.
  • Google. If you obtained the App from Google Play, Google handles the download, updates and any payments as an independent controller under Google’s own privacy policy. We do not receive that information from Google.
  • Purchases. The App has no in-app purchases. If they are added in future, they will be handled by the store you installed the App from (the App Store or Google Play) under that store’s terms.
  • Age rating. The App is rated 4+ on the App Store. On Google Play it carries the age rating and target age group shown on its Google Play listing.

1. What information do we collect?

Stored only on your device and in your iCloud

Your avatar, the name you choose, belt, points, wins and losses, streaks, collected seals and stamps, and your settings (sound, haptics, language) are stored on your device. If iCloud is enabled, a copy is kept in your Apple account’s iCloud key-value storage so your progress returns if you reinstall the App. This storage is provided by Apple under Apple’s privacy policy. We do not receive this data.

Anonymous gameplay statistics

Unless you turn statistics off, the App automatically records these events:

  • the App was opened (whether it is the first launch, and whether the tutorial had been completed);
  • the tutorial was finished or skipped, and at which step;
  • an avatar was chosen (the animal type and whether a custom name was entered, but never the name itself);
  • a duel was started, finished or left: game mode, master and level, result, number of rounds, duration, points gained and win streak;
  • a run in a game mode such as the Temple Path, Daily Seed or Weekly Sensei was started or finished: steps cleared and points;
  • a new master was unlocked, a new belt was reached, the language was changed, or the upcoming multiplayer mode was tapped;
  • your total active play time passed a threshold (for example 10, 30 or 60 minutes).

Each event also contains a random installation ID, a session number, the time of the event, the App version, the iOS version, the platform, the App’s language and a summary of your progress (belt, points, number of wins and losses, unlocked masters, number of runs, and whether Game Center and iCloud are connected, as yes/no only).

Installation ID. This is a random number the App creates on first launch. It is not your device’s advertising identifier (IDFA) or vendor identifier, and it is not linked to your name, avatar, Game Center alias, Apple ID or any other information that identifies you. Menu › Delete my data replaces it with a new one.

Approximate location. When events arrive, Amplitude uses the IP address of the request to derive an approximate location (country, region and city). We use this only in aggregate, for example to see which countries and languages play the game. The App never requests access to your device’s location.

Events wait on your device and are sent in batches when you return to a menu screen or leave the App, over an encrypted (HTTPS) connection. Nothing is sent while you are playing a duel.

Game Center

If you choose to sign in to Game Center, your scores and achievements are sent to Apple’s Game Center. Apple processes this data as an independent controller under its own privacy policy. You can manage the connection and your visibility in iOS Settings › Game Center.

Information you send us

If you contact support by e-mail, we receive your e-mail address and the content of your message.

Sensitive information and payments

We do not process sensitive personal information. The App currently has no in-app purchases. If purchases are added in future, payments will be handled entirely by Apple’s App Store (Apple’s App Store privacy notice) and we will update this notice.

2. How do we use your information?

  • To provide the game and keep your progress on your device and in your iCloud.
  • To understand how the game is played and improve its difficulty, balance, tutorial and features (anonymous statistics).
  • To find and fix problems.
  • To answer your support requests.
  • To comply with legal obligations.

We do not use your information for advertising, for profiling that has legal or similarly significant effects, or for automated decision-making.

3. What legal bases do we rely on?

If you are located in the UK or the EEA, the UK GDPR and the GDPR require us to explain our legal bases:

  • Legitimate interests for anonymous gameplay statistics: improving the game. We have balanced this against your interests: the data is minimal, linked only to a random installation ID, never used for advertising, and you can switch it off at any time.
  • Performance of a contract for providing the game and answering your support requests.
  • Legal obligations where we must keep or disclose information by law.

If you are located in Canada, we rely on your implied consent to collect anonymous statistics when you use the App. You can withdraw it at any time in Menu › Anonymous stats.

4. When and with whom do we share information?

  • Amplitude, Inc. (United States), our data analytics service provider, stores and analyses the gameplay statistics on our behalf under a data processing agreement and may not use them for its own purposes.
  • Apple, for Game Center and iCloud, only if you use them, under Apple’s own privacy policy.
  • Business transfers. We may transfer information in connection with a merger, sale of company assets, financing or acquisition of all or part of our business.
  • Legal requirements. We may disclose information where required by law or to protect the rights, property or safety of our users, us or others.

We do not sell personal information and do not share it for cross-context behavioural advertising.

5. International transfers

Amplitude processes data in the United States. Where information is transferred from the UK or the EEA, it is protected by the safeguards required by UK and EU law, such as standard contractual clauses and the UK International Data Transfer Addendum.

6. Cookies, tracking and Do-Not-Track

The App uses no cookies and no advertising identifier, and does not track you across apps or websites owned by other companies, so Apple’s App Tracking Transparency prompt is not shown. Storage on your device is used only for your progress, settings and statistics waiting to be sent. There is no agreed standard for Do-Not-Track signals, so we do not respond to them. Because we do not track you, there is nothing for such a signal to switch off in the App. The thecommercium.co.uk website has its own cookie notice.

This website

threeseal.com counts visits in one of three ways, and you choose in the banner. Basic statistics run until you choose and after Basic only: the pages you view, the buttons you press, the links you follow, the domain of the site that sent you, your language and page errors, grouped by a visit entry that is deleted when you close the tab and sent to our analytics provider Amplitude, Inc. with no identifier kept and no IP address or location attached. For these we rely on our legitimate interest in improving the site; UK law allows them without prior consent as long as you are told and can switch them off. If you choose Accept, the site also stores a random identifier in your browser and sends Amplitude information about your visit: the pages you view, the buttons you press (for example Play now), your language, the website that sent you, your browser and device type, and your approximate location derived from your IP address. The legal basis for that is your consent. We use all of it only to understand how the site and the game are found and used. If you choose Decline, only your choice is stored and nothing is sent. You can change your choice at any time with Cookie settings at the bottom of every page. If your browser sends a Global Privacy Control signal, we do not measure at all and do not ask.

The browser version of the game at play.sealduel.com saves your progress in your browser’s local storage and, if you accept measurement there, sends the same anonymous gameplay statistics as the app (for example a duel started, a round result, a duel finished). If you decline, it sends nothing. Like any web server, ours keeps standard access logs (IP address, browser type, page requested and time) to keep the site secure and working. See our Cookie Policy.

7. How long do we keep your information?

  • Progress on your device and in iCloud: until you delete it with Menu › Delete my data, or delete the App and its iCloud data.
  • Statistics waiting on your device: deleted as soon as they are sent, or immediately when you turn statistics off.
  • Statistics held by Amplitude: only as long as needed to analyse how the game is played. When no longer needed, we delete or anonymise them.
  • Support e-mails: as long as needed to handle your request and any follow-up, unless the law requires us to keep them longer.

8. How do we keep your information safe?

Statistics are sent over encrypted connections, contain no directly identifying information, and access to them is restricted. We use appropriate technical and organisational measures, but no transmission over the internet or storage technology can be guaranteed to be 100% secure.

9. Children

The App is rated 4+. It does not ask for or knowingly collect personal information from children: the statistics contain no name, contact details or precise location. If you believe a child has sent us personal information, for example by e-mail, contact us and we will delete it.

10. What are your privacy rights?

In some regions, such as the UK, the EEA, Switzerland and Canada, you have the right (i) to request access to and a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict processing, (iv) to data portability where applicable, and (v) not to be subject to automated decision-making. You may also object to processing based on legitimate interests.

In the App you can exercise the most important rights yourself, at any time:

  • Menu › Anonymous stats stops all statistics (object or withdraw consent). Pending events are deleted.
  • Menu › Delete my data erases your progress on the device and in iCloud and replaces the installation ID.

Because statistics are linked only to a random installation ID that we cannot connect to you, we normally cannot find events that belong to a particular person. If you would like us to act on past statistics, contact us and we will help as far as we are able.

If you are located in the UK and are unhappy with how we have handled your information, you can complain to us by e-mail at support@threeseal.com or by post (see section 14). We will acknowledge your complaint within 30 days, investigate without undue delay, keep you informed and explain the outcome. If you are not happy with our final response, you can complain to the Information Commissioner’s Office (ICO), the UK supervisory authority: ico.org.uk/make-a-complaint, helpline 0303 123 1113, or Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

If you are located in the EEA, you may complain to your national data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

11. Do United States residents have specific privacy rights?

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah or Virginia, you may have the right to know about, access, correct, obtain a copy of and delete the personal information we hold about you, and not to be discriminated against for exercising these rights.

Categories of personal information collected in the past twelve (12) months:

  • A. Identifiers: YES. A random installation ID (online identifier) and the IP address of statistics requests, used to derive approximate location.
  • B. Personal information in the California Customer Records statute: NO
  • C. Protected classification characteristics: NO
  • D. Commercial information: NO
  • E. Biometric information: NO
  • F. Internet or other similar network activity: YES. Interactions with the App (the gameplay events listed in section 1).
  • G. Geolocation data: approximate only (country, region and city derived from the IP address); no precise device location.
  • H. Audio, electronic, sensory or similar information: NO
  • I. Professional or employment-related information: NO
  • J. Education information: NO
  • K. Inferences drawn to create a profile: NO
  • L. Sensitive personal information: NO

We have not sold personal information or shared it for targeted advertising in the preceding twelve (12) months, and we do not profile you. We disclose statistics only to our service provider Amplitude, Inc. for business purposes under a written contract.

To exercise your rights, e-mail support@threeseal.com. You may use an authorised agent; we may ask for proof that the agent is validly authorised and may need to verify your request. If we decline to act on your request, you may appeal by e-mailing us; we will reply in writing with our reasons. If your appeal is denied, you may complain to your state attorney general. California residents may also request, once a year and free of charge, information under California Civil Code Section 1798.83 (“Shine The Light”); we do not disclose personal information to third parties for their direct marketing.

12. Do other regions have specific privacy rights?

Australia and New Zealand. We process personal information in line with Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020. You may request access to or correction of your information using the contact details below, and complain to the Office of the Australian Information Commissioner or the Office of the New Zealand Privacy Commissioner.

Republic of South Africa. You may request access to or correction of your information using the contact details below. If you are unsatisfied with how we handle a complaint, you can contact the Information Regulator (South Africa): enquiries@inforegulator.org.za; complaints (POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za and POPIAComplaints@inforegulator.org.za.

13. Do we make updates to this notice?

We may update this notice from time to time. The “Last updated” date at the top shows the latest version. If we make material changes, for example new kinds of data collection or in-app purchases, we will update this page and, where appropriate, tell you in the App.

14. How can you contact us?

For privacy questions, contact our Data Protection Officer at michael@thecommercium.co.uk, or write to:

Commercium Limited
Data Protection Officer
14/2e Docklands Business Centre
10-16 Tiller Road
London, Tower Hamlets, E14 8PX
United Kingdom

Commercium Limited is registered in the United Kingdom under company registration number 16456125 and is the data controller of your personal information. General enquiries: hq@thecommercium.co.uk · thecommercium.co.uk. App support: support@threeseal.com.

15. How can you review, update or delete your data?

Your progress is under your control in the App: Menu › Delete my data erases it, and Menu › Anonymous stats turns statistics off. For any other request about your personal information, e-mail support@threeseal.com with the subject “Three Seals privacy request”.