PRIVACY POLICY¶

Tryll Engine, Inc.

Last updated: November 6, 2026

1. INTRODUCTION¶

1.1 This Privacy Policy describes how Tryll Engine, Inc. (“Tryll,” “we,” “us,” or “our”), a Delaware corporation with registered offices at 1201 N. Orange Street, Suite 7587, Wilmington, DE 19801-1186, USA, processes personal data of visitors to https://tryllengine.com (the “Website”), users of the software development kit and AI runtime distributed under the title Tryll Engine, including its plugin, server, AI models, documentation, and any upgrades, patches, and updates (the “Software”), and members of our community channels. In this Policy, “you” means any individual whose personal data we process, including Website visitors, community members, and individuals who use the Software or act on behalf of a studio. A “studio” means a company or individual developer that has accepted the Tryll Engine License Agreement.

1.2 This Policy does not cover games and other products that studios build with the Software. The Software does not collect any data about players or other end users of those products. Each studio is responsible for its own privacy notices to its players and other end users.

1.3 We act as a data controller within the meaning of the EU General Data Protection Regulation 2016/679 (“GDPR”), the UK General Data Protection Regulation (“UK GDPR”), and equivalent laws. If we process personal data on behalf of a customer under a separate agreement, that agreement and the customer’s privacy notice govern that processing.

1.4 Our representative in the European Union under Article 27 GDPR is Tryll Engine Europe BV, [address], Belgium.

1.5 We respect your privacy and aim to handle personal data in line with applicable law and reasonable expectations.

2. PERSONAL DATA WE COLLECT¶

2.1 We process the following categories of personal data, only to the extent you provide them or they are generated when you use the Website or the Software:

Contact information: email address, first and/or last name.
Professional information: company or studio name, and role or category (such as studio, solo developer, modder, or other), where relevant to the form you submit.
Subscription metadata: the source page or form through which you subscribed, your communication preferences, and timestamps for subscribe, confirm, and unsubscribe actions.
Inquiry content: any information you choose to include when contacting us through a form, including the form in the Software, or by email.
Server log and analytics data: when you visit the Website, our hosting and analytics providers automatically receive standard technical information, including your IP address, online identifiers (such as cookie IDs), date and time of access, pages viewed, the referring URL, and your browser and operating system.
Operational telemetry: the Software sends us operational telemetry only when you use it during development. This is technical data about how the Software runs and does not include your name, contact details, or project content. It includes operating system, CPU, RAM, GPU, and VRAM, server launches and installations, model identifiers, download results, a summary of agent configurations and parameter changes without their names or content, number of turns, Software version, platform, a random installation identifier, and a random project identifier. You cannot turn off operational telemetry.
Content telemetry: only if the studio or its developers choose to turn it on in the Software settings, the Software also sends us prompts, user messages, and model responses processed during development. Content telemetry is off by default. We ask studios not to submit personal data of players or testers through content telemetry.
IP address: we receive your IP address when the Software sends us data. We use it only to deliver the request, and we do not store it.
Download information: the company or studio name and the game name you enter when you download the Software.
Release and royalty information: information the studio provides in the release form and in royalty reports under the Tryll Engine License Agreement, such as product details and revenue figures, including the name, title, and contact details of the person who submits them.
Partner information: if you buy a license or service from one of our partners through the Software, the partner may tell us that you came to it through Tryll and how much you paid.
Community data: if you join our Discord server, your Discord username, the profile information you make public, and the messages you post.

2.2 Providing operational telemetry is a condition of the Tryll Engine License Agreement. If you do not want us to collect it, you cannot use the Software. Providing other information is voluntary, unless a form marks a field as required.

2.3 We do not deliberately collect special categories of personal data (such as health, biometric, or political data), and we ask that you do not submit them through our forms.

2.4 The Software does not collect any data about players or other end users of products built with it. Builds of the Software that studios distribute in their games do not send us any telemetry or other data.

2.5 The Website and the Software are not directed to children under the age of 16, and the Software is intended only for users aged 18 or older, and we do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us at [email protected] and we will take steps to delete it.

3. HOW WE USE YOUR INFORMATION¶

3.1 We use the information we collect to:

respond to your inquiries, demo requests, and partnership outreach (legitimate interests);
send you the newsletter or product updates you have subscribed to (consent);
operate, secure, and improve the Website (legitimate interests);
provide, maintain, secure, and improve the Software, and measure its performance and compatibility (legitimate interests);
manage releases, royalty reports, and payments under the Tryll Engine License Agreement (contractual necessity);
receive and calculate referral fees from our partners (legitimate interests);
verify compliance with the Tryll Engine License Agreement, including identifying releases of products built with the Software (legitimate interests);
run our community channels (legitimate interests);
understand how visitors use the Website, in aggregate (consent);
comply with legal obligations (legal obligation).

3.2 We will not use your prompts, project files, source assets, configuration data, or other materials provided to or processed by the Software to train, fine-tune, or otherwise improve any machine learning model, except with the prior written consent of the studio or on aggregated and anonymized telemetry that cannot reasonably be re-associated with you or any specific project. We may use aggregated and anonymized data that no longer reasonably identifies any individual or studio for any lawful business purpose, including product analytics and reporting to investors.

3.3 We do not engage in automated decision-making that produces legal or similarly significant effects concerning you, within the meaning of Article 22 GDPR.

4. COOKIES AND ANALYTICS¶

4.1 The Website uses cookies and similar technologies. Cookies are small text files placed on your device by your browser.

4.2 We use:

Strictly necessary cookies to operate the Website.
Analytics cookies set by Google Analytics and Google Tag Manager, which help us understand how the Website is used in aggregate.

4.3 We require your prior consent to deploy non-essential cookies (including analytics cookies) on your device. When you first visit our Website, you can accept, reject, or customize your preferences through our interactive Cookie Consent Banner. You can subsequently manage, modify, or withdraw your consent at any time by clicking the “Cookie Settings” link in the Website.

4.4 Additionally, you can configure your browser to reject cookies or to alert you before a cookie is set. Some Website features may not function correctly if you reject all cookies. To opt out of Google Analytics specifically, you can install the Google Analytics Opt-out Browser Add-on.

4.5 We do not use cookies for cross-site advertising, and we do not share personal data with third parties for their own advertising purposes.

5. LEGAL BASES FOR PROCESSING¶

5.1 To the extent the GDPR or the UK GDPR applies, we rely on the following legal bases for processing personal data:

Consent, when you subscribe to our newsletter or otherwise opt in to a specific use of your data, including, where required, the use of non-essential cookies.
Legitimate interests, in operating, securing, and improving the Website and the Software, analyzing Software telemetry, verifying compliance with the Tryll Engine License Agreement, receiving referral fees from our partners, and running our community channels, and in communicating or following up with prospective customers, partners, and investors who have contacted us. You have the right to object to processing based on legitimate interests (see Section 9).
Contractual necessity, where we process data to perform an agreement with you, including the Tryll Engine License Agreement, release forms, and royalty reports, if you are a party to it. If you act on behalf of a studio, we process your data based on our legitimate interest in performing our agreement with that studio.
Legal obligation, where processing is necessary for compliance with applicable laws and regulatory requirements.

5.2 You may withdraw consent at any time by emailing [email protected] or by using the unsubscribe link in our emails. Withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

6.1 Scope. This section applies when you subscribe to our newsletter, opt in to product or company updates, or otherwise ask to receive ongoing communications from us.

6.2 Information collected through subscription. Depending on the form, we collect: email address, name, company or studio name, the form or page that originated the subscription, communication preferences, and timestamps for subscribe, confirm, and unsubscribe events.

6.3 Double opt-in. We use double opt-in for newsletter subscriptions. After you submit a signup form, we send a confirmation email and only begin sending updates after you confirm. If you do not confirm, we retain limited information necessary to manage the signup attempt and prevent duplicate processing, but we will not treat you as a subscribed recipient.

6.4 Contact and demo forms. If you contact us through a contact, demo, partnership, or waitlist form, including the form in the Software, we use your information to respond to your inquiry and to manage the resulting business conversation. We may follow up by email about the subject of your inquiry under our legitimate interest in operating our business. We will not add you to our ongoing marketing newsletter without your explicit consent through a separate subscription action. We do not link information you submit through these forms to Software telemetry.

6.5 Your choices. You can unsubscribe at any time using the unsubscribe link in our emails or by emailing [email protected]. After you unsubscribe, we may retain your email address in a suppression list to make sure we do not contact you again. Unsubscribing from the newsletter does not automatically delete contact records we keep for legitimate business purposes (such as responding to a prior inquiry); to request deletion, see Section 9.

6.6 Community channels. If you join our Discord server, we see your Discord username, the profile information you make public, and the messages you post. We use this information only to run the community and respond to you. We do not add it to our mailing lists or contact databases without your consent. Discord processes your data as an independent controller under its own privacy policy.

7.1 We share personal data with third-party service providers that help us run the Website and the Software, communicate with you, and analyze usage. These providers act as data processors and are bound by written agreements to use the data only on our instructions and as necessary to provide their services.

7.2 Current providers include:

GitHub Pages (website hosting) - Microsoft Corporation, USA.
HubSpot (contact forms and customer records) - HubSpot, Inc., USA; our account is hosted in the EUFormspree (contact form processing) - Formspree, Inc., USA.
Slack (team notifications about contact form messages) - Slack Technologies, LLC, USA.
Cloudflare (passes contact form messages on to our team chat) - Cloudflare, Inc., USA.
MailerLite (newsletter and marketing automation) - UAB MailerLite, Lithuania (EU).
Google Analytics and Google Tag Manager (website analytics) - Google LLC, USA, and Google Ireland Limited.
PostHog (storage and analysis of Software telemetry) - PostHog, Inc., USA; our project is hosted in the EU.
[Payment provider] (receiving royalty payments) - [legal entity and country].

7.3 Discord Inc., USA, operates our Discord server as an independent controller, not as our processor.

7.4 If you download a third-party AI model through the Software, the Software connects directly to the model provider or another repository that hosts the model. That provider or repository processes your data as an independent controller under its own privacy policy.

7.5 Partners that provide third-party models or services through the Software process your data as independent controllers under their own privacy policies. To attribute your purchase to us, we may share with them a referral identifier.

7.6 We do not sell, rent, or share personal data with third parties for advertising purposes.

7.7 We may also disclose personal data when required by law, court order, or to protect our legal rights, or in connection with a corporate transaction (such as a merger, acquisition, or financing) subject to appropriate confidentiality and data protection commitments.

8. INTERNATIONAL DATA TRANSFERS¶

8.1 We are based in the United States, and some of our service providers operate in the United States or other countries outside the European Economic Area (“EEA”). When we transfer personal data outside the EEA or the United Kingdom, we rely on appropriate safeguards required under GDPR and UK GDPR, including:

the European Commission’s or the UK government’s adequacy decisions, where applicable;
Standard Contractual Clauses (SCCs) approved by the European Commission and, for transfers from the United Kingdom, the UK International Data Transfer Addendum to them;
our service providers’ data processing agreements that incorporate such safeguards.

8.2 You can request a copy of the relevant safeguards by contacting [email protected].

9. YOUR RIGHTS¶

9.1 Subject to applicable law, you have the following rights regarding your personal data:

Access: request information about the data we hold about you.
Correction: request that we correct inaccurate or incomplete data.
Deletion (the “right to be forgotten”): request that we delete data we hold about you, subject to certain exceptions provided by law.
Restriction: request that we limit how we use your data.
Objection: object to processing based on our legitimate interests, including direct marketing.
Portability: request a copy of your data in a structured, commonly used, machine-readable format.
Withdrawal of consent: where we rely on consent, withdraw it at any time without affecting the lawfulness of prior processing.
Complaint: lodge a complaint with a data protection supervisory authority in your jurisdiction.

9.2 To exercise any of these rights, email [email protected]. We will respond within the time frames required by applicable law.

10. DATA RETENTION¶

10.1 We retain personal data for as long as necessary to fulfill the purposes described in this Policy, to comply with legal obligations, to resolve disputes, and to enforce our agreements. Specifically:

Newsletter subscribers: retained until you unsubscribe or request deletion. After unsubscribe, your email address may be kept in a suppression list for up to 3 years to prevent re-subscription by mistake.
Inquiry and contact form records: typically retained for up to 3 years after the last contact, unless a longer period is required by law or by an ongoing business relationship.
Server logs: typically retained for up to 12 months.
Analytics data: retained according to the configured retention period in Google Analytics, typically up to 14 months.
Software telemetry: up to 12 months after collection, after which we delete or anonymize it. We do not store IP addresses received from the Software.
Release forms, royalty reports, partner reports, and payment records: for the term of the Tryll Engine License Agreement and 7 years after it ends, or longer if required by law.
Community data: for as long as you remain a member of our Discord server or until you delete your messages, subject to Discord’s own retention practices.

11. SECURITY¶

11.1 We implement reasonable administrative, technical, and physical safeguards designed to protect personal data against loss, misuse, unauthorized access, disclosure, alteration, and destruction. No method of transmission over the Internet is fully secure, however, and we cannot guarantee absolute security. In the event of a personal data breach affecting your rights and freedoms, we will notify you and the competent supervisory authority as required by applicable law.

12. ADDITIONAL INFORMATION FOR US RESIDENTS¶

12.1 This section applies to residents of US states with comprehensive privacy laws, such as California. It supplements the rest of this Policy.

12.2 Personal information we collect. We collect, and in the last 12 months may have collected, the following categories of personal information: identifiers (such as name, email address, IP address, and random installation and project identifiers); professional information (such as company name and role); commercial information (such as release and royalty information); internet or other electronic network activity (such as Website usage data and operational telemetry); and the content of your communications with us, including content telemetry. We collect this information from you, from your use of the Website and the Software, from our partners, and from our Discord server. We use it for the purposes described in Section 3 and disclose it to the service providers described in Section 7.

12.3 No sale or sharing. We do not sell personal information or share it for cross-context behavioral advertising, and we have not done so in the last 12 months. We do not knowingly sell or share personal information of consumers under 16. We do not use or disclose sensitive personal information for purposes that would give you a right to limit its use.

12.4 Your rights. Depending on your state of residence, you may have the right to know what personal information we collect and how we use it, to access it, to correct it, to delete it, and to opt out of its sale, sharing, targeted advertising, or profiling. You can exercise these rights as described in Section 9. We will verify your request using information you have already provided to us. You may use an authorized agent, who must provide proof of authorization. If we deny your request, you may appeal by replying to our decision. We will not discriminate against you for exercising your rights.

12.5 Do Not Track and Global Privacy Control. The Website does not respond to Do Not Track browser signals. We honor Global Privacy Control signals where applicable law requires it.

12.6 Retention. We keep each category of personal information for the periods described in Section 10.

13. CHANGES TO THIS POLICY¶

13.1 We may update this Policy from time to time. The “Last updated” date at the top reflects the most recent revision. Material changes will be communicated through the Website, within the Software where practical, or, where appropriate, by email.

14. CONTACT¶

14.1 For questions or requests related to this Policy: [email protected].

14.2 For general inquiries: [email protected].

14.3 Mailing address: Tryll Engine, Inc., 1201 N. Orange Street, Suite 7587, Wilmington, DE 19801-1186, USA.