Draft: pending legal review, not final. This document is a structured placeholder for games/IP counsel to replace with binding language. Nothing on this page is legally binding, final, or a representation of the operator's actual terms.
Privacy Policy
Status: draft · Last reviewed: not yet reviewed
1. Overview
TODO (counsel): What this policy covers, the data controller identity, and effective date. This draft enumerates the actual data touchpoints in the current architecture so counsel can turn them into binding disclosures.
2. Data We Collect
Proposed disclosure pending owner/privacy review: Clerk handles authentication; Neon stores account and authoritative game records. Optional PostHog analytics, browser errors, page-performance measurements, rating surveys and presentation experiments are off until you allow the current choices in Privacy choices. Surveys collect only a voluntary numeric rating; presentation experiments do not affect gameplay. When permitted, an opaque hashed account identifier links consented visits across characters. We do not send names, email addresses, conversation text, payment details, request bodies or gameplay records as analytics. Separately approved, minimized server operational diagnostics contain redacted exceptions and fixed operational log messages with service/release context without account or session identity. Xsolla processes payments; we do not store full card or bank details.
3. How We Use Your Data
TODO (counsel): Purposes: operating the game account, saving progression, preventing cheating/fraud, providing support, processing purchases via the MoR, and improving the game via aggregate analytics. Map each purpose to a lawful basis (GDPR) where applicable.
4. Third-Party Processors
Proposed processor list pending privacy review: Clerk (identity), Neon (game database), Vercel (web hosting), Railway (gateway hosting), PostHog US Cloud (optional analytics, permitted replay, errors, browser performance, voluntary ratings, presentation experiments and minimized operational logs), Cloudflare (DNS/object storage), and Xsolla (payments). PostHog ingestion uses US Cloud. Review the applicable data processing agreements and international-transfer safeguards before external-player rollout.
5. Data Retention
The operator must approve and record effective PostHog retention and deletion controls before rollout; the deployment runbook records the verified settings. Withdrawing optional telemetry consent stops future collection and clears local telemetry identity and pending deliveries; it does not by itself erase events already delivered. Data-erasure requests require deletion of the associated events/profile and recordings, verified separately.
6. Your Rights
Use Privacy choices to accept, reject or withdraw optional telemetry. Rejecting does not prevent gameplay. Global Privacy Control and Do Not Track are respected for optional browser collection. Replay additionally requires explicit tester eligibility and an approved screen; text and inputs are masked, conversations/media are blocked, and authentication, account, payment and staff surfaces are excluded. Contact the operator for access, correction or deletion requests. Owner/privacy review of the formal rights process remains required.
7. Children's Privacy & Age Rating
TODO (counsel): COPPA / age-gating stance, minimum age to hold an account, and how underage accounts are handled. Must align with the age-rating declared to the MoR and app stores. Owner decision required on target age rating.
8. International Data Transfers
TODO (counsel): Where data is processed/stored (hosting regions) and the safeguards for transfers out of the player's region.
9. Contact
TODO (owner): Privacy contact / DPO address. Placeholder until finalized.