Privacy Policy
Draft of October 4, 2026
1. Who is responsible
The controller of your personal data is [LEGAL NAME], a sole proprietorship in Norway, organization number [ORG NUMBER], [ADDRESS], email [EMAIL]. Sunderkeep is a one-person studio; privacy questions go to the same address.
2. What we collect, and why
| Data | Why | Legal basis (GDPR) |
|---|---|---|
| Account: email address, a password hash (never the password itself), or the name and email Google or Discord share when you sign in with them | To give you an account and let you sign in on any device | Contract, art. 6(1)(b) |
| Game data: your characters, their names, levels, items, gold, progress, settings and collections | To save your game and play it online | Contract |
| What other players see: character names, guilds, chat messages, leaderboard places | The online part of the game | Contract |
| Chat: messages you send (public chat for 24 hours, whispers and party chat for 30 minutes, then deleted) | So chat survives a reload; handling reports of abuse | Contract; legitimate interest, art. 6(1)(f) |
| Fair-play records: unusual changes to gold, items or progress, flagged by the game server | Protecting the game's economy and other players from cheating | Legitimate interest |
| Error reports: the error and where in the game's code it happened, the game build, browser and system name, where in the game you were, the last few things the game logged, and your account id. Email addresses, IP addresses and ids are removed from the text before it is sent | Finding and fixing bugs (kept 30 days) | Legitimate interest |
| Bug reports and suggestions you send (Send Feedback in the Game Menu, or /bug): what you write, a picture of the game's 3D view if you leave it attached (no windows or chat), the game build, where in the game you were, your character's level and class, browser, screen and graphics card, the game's last log lines (never chat), and your account id | Fixing what you report and deciding what to build next (kept 180 days, pictures 30 days) | Legitimate interest |
| Reports and moderation: reports you send about other players (the reason, your note, and the chat lines the game server saw from that player in the last 30 minutes where you could see them), reports about you, and every moderation decision on your account (warnings, mutes, forced renames, suspensions, bans, appeals) with its reason. Someone without an account can report illegal content with the form on the report page and an optional email address for the answer | Keeping chat and play safe; telling you why a decision was made and letting you appeal it (EU Digital Services Act, art. 16, 17 and 20); reporting how many decisions we made | Legitimate interest; legal obligation |
| Ban evasion signals: a keyed one-way hash of your IP address and of a random id the game keeps on your device. We never store the address or the id themselves, and the hash can't be turned back into them. Only used to flag, for a moderator to look at, a new account on the same device or network as a suspended one; nothing happens automatically | Stopping suspended players from coming straight back on a new account (kept 30 days) | Legitimate interest |
| Connection data: IP address and the time of a connection, in the servers' logs | Running the servers safely, stopping attacks | Legitimate interest |
| Store purchases: see section 5 | Delivering what you bought, refunds, bookkeeping | Contract; legal obligation, art. 6(1)(c) |
We don't use advertising, tracking cookies or third-party analytics, and we never sell your data.
3. Stored on your device
The game keeps your settings, a copy of your save and your sign-in session in your browser's local storage. This is needed for the game to work and is not used for tracking. You can clear it in your browser; signed in, your characters stay safe on our servers.
4. Who processes your data for us
| Service | What for | Where |
|---|---|---|
| Supabase Inc. | Accounts, sign-in and the game database | EU (Frankfurt, Germany) |
| Hetzner Online GmbH | The game server | EU (Germany) |
| [Sentry (Functional Software, Inc.)] (only if switched on) | A copy of error reports, without your account id or IP address | [EU (Frankfurt) or US; EU-US Data Privacy Framework and standard contractual clauses] |
| Cloudflare Inc. | DNS and protection of the game server's connections | Global network; EU-US Data Privacy Framework and standard contractual clauses |
| Vercel Inc. | Hosting the website and the game's files | Global network; EU-US Data Privacy Framework and standard contractual clauses |
| Google / Discord (only if you choose to sign in with them) | Signing in | Their own privacy policies apply |
| [Stripe / Paddle] (only when you buy something) | Payments, see section 5 | [EU / UK / US, with safeguards] |
Lawyer: confirm a data processing agreement (DPA) is in place with each processor and that the transfer mechanisms listed are current.
5. Payments in the Store
- We never see your card. You pay on the payment provider's own page. Your card number and bank details go only to them.
- What we keep about a purchase: your account id, what you bought, the price and currency, the date, the payment provider's order id, whether it was refunded, and for gifts the buyer's character name and the receiver's account. For a gold purse, the character it went to.
- Why: to deliver the item to your account, to handle refunds and chargebacks, and because Norwegian bookkeeping law (bokføringsloven) requires sales records to be kept for 5 years.
- The provider receives your email, payment details, billing country and the order, and handles fraud
checks. [Choose one:]
- [Stripe:] Stripe Payments Europe Ltd. processes the payment for us; for its own legal duties (anti-money-laundering, fraud) it is an independent controller. See stripe.com/privacy.
- [Paddle:] Paddle.com Market Ltd is the merchant of record: it sells to you on our behalf and is an independent controller of the payment data. See paddle.com/legal/privacy.
- Gifts: when you buy a gift, the receiver sees your character name with it.
6. How long we keep it
- Account and game data: while your account exists. When you delete your account (in the game, or by asking us), it is removed 14 days later; until then you can change your mind. Backups roll over within a further [30] days.
- Purchase records: 5 years after the end of the accounting year (bokføringsloven), even if the account is deleted, without your account id (the payment provider keeps its own records); then deleted.
- What you accepted (the Terms version, that you are 13 or older, and when): while your account exists.
- Chat: 24 hours (public), 30 minutes (whispers and party). Error reports: 30 days. Bug reports and suggestions: 180 days (their pictures 30 days). Ban evasion hashes: 30 days. Reports and moderation decisions: [2 years] (the decisions log is also kept for transparency reports). Server logs: [14] days. Fair-play records: [12 months].
7. Your rights
In the game, under Account (the account menu on the character screen), you can download everything we keep about your account as a file (Download my data) and delete your account (Delete account). You can also ask to see the data we hold about you, have it corrected, deleted or handed over to you in a common format, object to processing based on legitimate interest, or ask us to limit it. Write to [EMAIL] from your account's email address; we answer within a month. You can also complain to the Norwegian Data Protection Authority (Datatilsynet, datatilsynet.no) or the authority where you live.
8. Children
Sunderkeep is not made for children under 13, and they should not create an account. Players under 18 need a parent's or guardian's permission to buy in the Store. [Lawyer: Norway sets the age of digital consent at 13 (personopplysningsloven § 5); confirm this section.]
9. Changes
If we change this policy or the Terms in a way that matters, the game asks you to accept the new version the next time you sign in.