Privacy Policy

How When Light Fades collects, uses, and protects your child's personal data — written for parents, aligned with Singapore's Personal Data Protection Act (PDPA).

Last updated: 11 May 2026

On this page

  1. Who we are
  2. A note for parents
  3. What we collect
  4. How we use it
  5. Who we share it with
  6. Where we store it
  7. How long we keep it
  8. Your child's and your rights
  9. Cookies and similar technology
  10. Children's data — extra safeguards
  11. Security
  12. International transfers
  13. Changes to this policy
  14. Contact & complaints

1. Who we are

When Light Fades is an educational role-playing game built for primary-school children in Singapore. The service is operated by heta, the team behind the game. Where this policy uses "we", "us", or "our", we mean heta operating When Light Fades.

For any question about your child's personal data — including a request to access, correct, or delete it — write to contact@whenlightfades.com. This address also reaches our Data Protection Officer (DPO).

2. A note for parents

When Light Fades is designed for children under 13. We take that seriously. The headline things you should know up front:

What "personal data" means here. Under Singapore's Personal Data Protection Act (PDPA), personal data is any data about an individual who can be identified from that data, or from that data combined with other information we have. A username on its own usually isn't personal data; combined with a parent's email and gameplay history, it is. We treat all of it as personal data and protect it as such.

3. What we collect

We collect only what the game needs to run, to keep your child's progress safe, and to communicate with you. The full list:

CategoryWhat this isSource
Account data A username your child chooses (filtered for inappropriate words); a password (which we never see — Firebase Authentication stores it as an irreversible hash); or, if you sign in with Google, the Google account identifier and the email address Google shares with us. Provided by you / your child at sign-up.
Parent email The email address you give us so we can verify parental consent, send password-reset links, and send the optional weekly progress report (you can unsubscribe at any time). Provided by you at sign-up or in Settings.
Character profile The character name, gender selection (boy / girl), class (Knight, Mage, etc.), and Singapore primary level (P1–P6) your child picks during character creation. These shape the gameplay and difficulty. Provided by your child in-game.
Gameplay record Level, XP, currencies (Lumen 🪙 and Gems 💎), inventory, equipped items, cosmetics, zone progression, quest state, achievement state. Generated as your child plays.
Learning record How many questions your child has answered in each subject, how many were correct, which topics they have practised, the difficulty level they are working at, and per-day roll-ups (kept for 90 days on the device and mirrored in our cloud database). Generated as your child plays.
AI-generated portraits and sprites If your child uses the optional in-game portrait generator, the short text prompt your child writes (describing their character — e.g. "a knight with red hair") is sent to Google's Vertex AI and the resulting image is stored in our cloud storage. Default portraits in every style are pre-generated by us and ship with the game — they are not personalised. Created by your child explicitly via the Profile screen.
Technical data A reCAPTCHA Enterprise token (used by Firebase App Check to confirm the game is running in a real browser, not a bot); the standard request metadata Google's services log on our behalf (rough IP, browser type, request timestamps). We use this only to keep the service running and to prevent abuse. Generated automatically by your browser.

What we deliberately do not collect

4. How we use it

Under the PDPA we may use personal data only for purposes we have told you about and that a reasonable person would consider appropriate in the circumstances. These are ours:

We do not use your child's learning record to build advertising profiles or to sell to a third party. We do not use it to train Google's general-purpose AI models — when we call Google's Vertex AI to generate a question or a portrait, our project is configured so that the prompt is not used to train Google's foundation models.

5. Who we share it with

We share personal data only with the small number of service providers we rely on to run the game. They act on our instructions, are bound by their own data-protection terms, and cannot use your child's data for their own purposes.

ProviderWhat they do for us
Google / Firebase (Google Cloud)Hosts the game, runs sign-in (Firebase Authentication), stores save data (Cloud Firestore), stores AI-generated images (Cloud Storage), runs our server-side code (Cloud Functions), and powers the AI portrait and question generator (Vertex AI).
Google reCAPTCHA EnterpriseVerifies that requests come from a real browser. This is part of Firebase App Check.
Twilio SendGridDelivers the parent verification email and (if you subscribe) the weekly progress report.

We do not share personal data with marketers, data brokers, advertisers, or social networks. If we ever need to add another provider, we will update this policy and tell you before the change takes effect.

6. Where we store it

Personal data is stored on Google Cloud infrastructure. Our Firestore database, Cloud Storage bucket, and Cloud Functions all run in Google's regions. Vertex AI requests run in Google's global region because the image models we use are only available there. Some technical logs (for example, the App Check token verification) are processed wherever Google's edge network handles your request.

Two pieces of data stay only on your child's device and are never sent to our servers:

7. How long we keep it

8. Your child's and your rights

Under the PDPA you (as parent) and your child have the right to:

  1. Access the personal data we hold about your child and ask how we have used it in the past year.
  2. Correct anything that is inaccurate or out of date.
  3. Withdraw consent to our continued use of the data. Note that withdrawing consent for the core gameplay data will mean your child can no longer play.
  4. Delete the account and all associated personal data. (We are completing this self-serve deletion flow; in the meantime, email us at contact@whenlightfades.com and we will action it within 30 days.)
  5. Port the data — we will provide your child's save and learning record as a structured JSON file on request.
  6. Unsubscribe from non-essential email (the weekly progress report) at any time via the link at the foot of every report.

To exercise any of these, write to contact@whenlightfades.com from the parent email registered on the account. We will respond within 30 days as required by the PDPA, or sooner where we can.

9. Cookies and similar technology

When Light Fades does not use third-party advertising or tracking cookies. The browser-storage we rely on is:

You can clear all of this at any time using your browser's "Clear site data" function.

10. Children's data — extra safeguards

Because our audience is primary-school children, we go beyond the PDPA minimums:

11. Security

We use industry-standard controls:

No internet service can promise that data will never be breached. If we ever experience a security incident that puts your child's data at material risk, we will notify you (and, where required, Singapore's Personal Data Protection Commission) without undue delay.

12. International transfers

Google operates a global network. Your child's personal data may be processed in countries outside Singapore — most commonly the United States, where some Google services are headquartered, and in other regions where Google Cloud has edge infrastructure. Google Cloud is bound by Standard Contractual Clauses and equivalent transfer mechanisms recognised by Singapore's PDPC. When you use our service you are consenting to your child's data being transferred in this way.

13. Changes to this policy

We may change this policy as the game evolves. When we make a meaningful change (such as adding a new service provider or a new type of data collection), we will update the "Last updated" date at the top and — where the change is material to your child's data — email the parent address registered on the account before the change takes effect.

14. Contact & complaints

For anything to do with your child's personal data, please write to:

Data Protection Officer
heta — When Light Fades
contact@whenlightfades.com

If you believe we have not handled your child's personal data in accordance with the PDPA, you can lodge a complaint with Singapore's Personal Data Protection Commission at pdpc.gov.sg. We would always prefer the chance to resolve the issue directly with you first.