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1. Who we are

The data controller is the trader identified in our Impressum. Contact for privacy matters: [email protected].

A Data Protection Officer is not appointed and not required: we are not a public body, our core activity is not large-scale regular monitoring of individuals, and we do not process special-category data at scale (Art 37(1) GDPR).

2. What we collect, why, and our lawful basis

DataWhyLawful basis
Email (if you sign up with email)Account identity, login, security noticesContract, Art 6(1)(b)
Sign-in provider identifierLetting you log in with GoogleContract
Account id, BUNKERTAG, display nameYour identity in the verseContract
Wallet / vault addressHolding what you own on-chainContract
Purchase and billing recordsFulfilling and accounting for your orderContract; legal obligation
Gameplay and progression stateRunning the gameContract
Affinity / class signalsGameplay identity expression — cosmetic only, with no legal or financial effectContract
Security and audit logsFraud prevention, abuse handling, account safetyLegitimate interests, Art 6(1)(f)

We do not sell your personal data, and we do not use it to make decisions with legal or financial effect about you.

3. Cookies

This website sets no advertising, analytics or tracking cookies, and it embeds no third-party tracking scripts. The only cookies it sets are the ones without which the thing you asked for cannot work, so none of them requires consent under § 25 Abs. 2 TTDSG:

CookieWhat it is forLifetime
bv_sessionKeeps you signed in to your accountUntil you sign out or it expires
bv_accessRemembers that you have been granted access to the private preview of this site, so you are not asked for the code on every pageSet when you enter a valid code or open an invitation link; expires with the preview

Both are HttpOnly, meaning no script on the page can read them, and both are signed so they cannot be forged. Neither is readable by anyone but this site, and neither is shared with a third party.

When you submit a preview access code we briefly hold the request’s network address in memory in order to rate-limit guessing. It is not written to disk, not linked to any account, and is discarded within minutes. The lawful basis is our legitimate interest in not letting the gate be brute-forced, Art 6(1)(f).

Development videos on this site are hosted on YouTube and embedded behind a click. Nothing is requested from Google or YouTube — and no cookie of theirs is set — until you choose to open a video. Reading a page contacts them not at all.

4. No personal data on the blockchain

On-chain records hold addresses, token ids, and game state — not your name, email, or other directly identifying data. This is deliberate: a blockchain cannot be erased, so personal data must never be written to it.

5. Your rights

  • Access and export — get a copy of your data (Art 15, 20). Available in-app.
  • Erasure — delete your account (Art 17). Available in-app: your identity, provider binding, and custodial key envelope are destroyed, sessions revoked, live listings cancelled. Financial ledger rows are retained pseudonymously where the law requires, referencing no identifiable person.
  • Rectification (Art 16), restriction (Art 18), and objection (Art 21).
  • Complaint — you may lodge one with your local supervisory authority.

Requests to [email protected], or use the in-app controls.

6. How long we keep it

Account data for as long as your account exists, then deleted on erasure. Records we are legally required to retain (for example accounting records) are kept for the statutory period, pseudonymised where possible.

7. Sharing and processors

We share personal data only with the processors needed to run the service, under data-processing agreements, and disclose to authorities only when legally compelled.

RecipientRoleReceives
Stripe (Ireland)Card payments. Under Managed Payments, Stripe is the merchant of record — an independent controller and the legal seller, not merely our processorPayment and billing data, email. We never see or store card numbers.
GoogleSign-in provider, if you choose GoogleAn authentication assertion — we store only a pseudonymous subject hash
Hosting / infrastructureRuns the platformThe data above, at rest

8. International transfers

Platform data is processed on infrastructure in the EU/EEA. Where a processor transfers data outside the EEA, we rely on the EU Standard Contractual Clauses, or on an adequacy decision where one applies.

9. Children

The service is not directed to children under 16, and accounts require you to be 16 or older. Where a member state sets a lower digital-consent age (Art 8(1) GDPR permits 13–16), the local age applies to consent-based processing. We do not knowingly process a younger child’s data; if we learn we have, we erase it.

10. Changes

We update this policy when the platform changes. Material changes are announced in advance.