DRAFT — requires review by a lawyer. Not in force.
Emberdust privacy policy
Version 1, effective 19 October 2026.
1. Who we are and how to contact us
Patryk Wałaski (sole trader, NIP PL8992925980), ul. św. Mikołaja 8/11 lok. 208, 50-125 Wrocław, Poland ("we") is the controller of your personal data. For any privacy question or request, write to playemberdust@gmail.com. We are not required to appoint a data protection officer and have not done so.
This policy explains what data the game Emberdust (Android and iOS), its servers and this website use, why, for how long, who receives it and what your rights are.
2. Where the data comes from
- From the game on your phone: what the game sends to our server while you play.
- From you: the character name and guild name you choose, chat messages and reports, and e-mails you send us.
- From Google or Apple: a confirmation of your identity if you sign in with them, and purchase and refund records from their stores.
- From the ad network: a confirmation that you watched a rewarded ad.
We do not ask for your real name, e-mail address, phone number, contacts, photos or location.
3. What we use, why, and on what legal basis
The game is always online: your character, items and currencies are kept on our server, not on your phone.
| Data | Purpose | Legal basis (GDPR art. 6(1)) |
|---|---|---|
| Account ID (a random number we create) and sign-in tokens | Keep you signed in and connect your game to you | (b) contract |
| Google or Apple account identifier, if you sign in with them (only the provider's user ID; we store no e-mail or name) | Open the same character on a new phone | (b) contract |
| Phone model, operating system version, processor type, game version | Run the game correctly on your device and find device-specific errors | (f) legitimate interest: a working game |
| Game data: character, class, level, stages, items, currencies, settings kept on the server, history of currency and item changes | Provide the game; restore lost items through support | (b) contract |
| Character name, appearance, guild, Combat Power, ranking places | Shown to other players in rankings, town, chat, player card and guild | (b) contract |
| Chat messages (world, town, stage, guild, private) | Deliver them to other players. They are passed on and not stored, unless a player reports one (see next row) | (b) contract |
| Chat reports: who reported, who was reported, channel, the reported line, time; mutes | Moderation, player safety and our duties as an online platform | (f) legitimate interest: a safe community; (c) legal obligation (Digital Services Act) |
| Purchase records: store, order number, product, date, what was given, refund date | Deliver purchases, handle refunds and disputes, keep accounts | (b) contract; (c) legal obligation (tax and accounting law) |
| Rewarded ad records: the ad network's transaction number, placement, time | Give the reward for a watched ad, once | (b) contract |
| Play sessions (start, end, number of actions), days played, last seen, progress per day (level, stage, play time, rewards earned), first-time events | Improve the game and its balance, count active players, support | (f) legitimate interest: running and improving the game |
| Anti-cheat counters, review flags, bans and their reasons, log of operator actions, device integrity result (when enabled) | Prevent cheating and fraud; protect honest players | (f) legitimate interest: fair play and security |
| Diagnostics: error reports from the game (the kind of error, how often it happened, a shortened error text and the place in the game's code, with anything that looks like an e-mail, address, token or identifier removed; game version, platform, operating system, phone model, graphics type, memory, time since the game started, game screen). They are stored per error and game version, without your account or name. Crashes of the app itself are reported to us by Google Play and Apple from their own systems. | Find and fix errors in the game | (f) legitimate interest: a working game |
| IP address | Limit request floods. It is held in memory only while you are connected and is not written to our database or request logs | (f) legitimate interest: security |
| Data the ad network collects when you watch a rewarded ad (section 5) | Show ads; personalised ads only with your consent | (a) consent for personalised ads and device storage; (f) for non-personalised ads |
The account and game data are needed to play: without them the game cannot work. Chat, guilds, sign-in with Google or Apple and rewarded ads are optional.
We make no decision with legal or similarly significant effects about you by automated means alone (GDPR art. 22). Anti-cheat only flags an account; a person reviews it before any ban or deletion.
4. How long we keep it
| Account, game data, name, rankings, guild, sign-in links | While your account exists. On deletion they are removed at once; an archive copy is kept 30 days so a mistaken deletion can be undone, then erased. |
| Chat reports | 365 days after the report, or until the reporting or the reported account is deleted, whichever comes first |
| Sign-in tokens | Each is valid 30 days; its record is erased 30 days after it expires, or with the account |
| Item history | 730 days |
| Currency history | Each change for 3 months; changes relevant to purchases and support for 24 months; after that only daily totals, while the account exists |
| Copies of your game state for support restores | Daily copies 30 days; copies made before an operator action, refund or rollback 90 days |
| Play sessions and days played | 90 days (after that only totals over all players, without your account) |
| Progress per day | 400 days |
| First-time events | 730 days |
| Anti-cheat review flags | 180 days |
| Operator action log | 730 days |
| Balance mismatch alerts | 365 days |
| Account deleted by us for breaking the rules | Archived 365 days for appeals and payment disputes, then erased |
| Purchase records | After account deletion, kept without any link to you for 5 years after the end of the year of purchase (tax law) |
| Deletion register (account number and date only) | Kept so that restoring a database backup cannot bring a deleted account back |
| Game error reports (no account) | 90 days after the same error was last reported |
| Server error logs | 30 days |
| Database backups | The 14 newest copies on our server; copies stored off-site are deleted after 14 days |
5. Who receives your data
- Hetzner Online GmbH (Germany) hosts our servers, database and backups as our processor, under a data processing agreement. Our servers are in the European Union.
- Google (Google Ireland Limited) and Apple (Apple Distribution International Ltd., Ireland) distribute the game and handle payments as independent controllers under their own privacy policies. If you sign in with Google or Apple, they confirm your identity to us.
- Google AdMob shows rewarded ads. When you choose to watch one, the AdMob software in the game collects data such as your device's advertising ID, IP address, approximate location derived from it and how you interact with the ad. In the EEA, the UK and Switzerland the game asks for your consent before showing personalised ads; without it you see non-personalised ads. You can change your choice at any time in Settings → Privacy options (at the top of the Settings window, shown where consent applies). Google explains its use here: How Google uses information from sites or apps that use its services.
- Other players see your public data (name, appearance, guild, Combat Power, ranking places) and the chat messages you send.
- Authorities, when the law requires it.
We do not sell your data and do not share it for advertising beyond the ad network above.
6. Transfers outside the EEA
Our own servers are in the EU. Google and Apple may process data in the United States and other countries; for that they rely on the EU–US Data Privacy Framework and the European Commission's standard contractual clauses.
7. Your rights
You may ask us to give you access to your data, correct it, erase it, restrict its use, or send it to you in a portable format. You may object to uses based on legitimate interest, and withdraw consent at any time (earlier use stays lawful).
- Copy of your data or any other request: e-mail playemberdust@gmail.com and give the account number shown in the game's settings. We may ask you to confirm from the game that the account is yours. We answer within one month.
- Deletion: Settings → Players → Account → Delete account in the game, or /account/delete.
- Name: you can change your character name in the game.
- Ads: Settings → Privacy options.
You may also complain to a supervisory authority. In Poland this is the Prezes Urzędu Ochrony Danych Osobowych (PUODO), ul. Stawki 2, 00-193 Warszawa, uodo.gov.pl; you may also go to the authority of the EU country where you live or work.
8. Children
The game is meant for players aged 16 and over and is not directed to children under 13. In the EU the age at which you can consent to online services yourself (GDPR art. 8) is between 13 and 16 depending on the country; in Poland it is 16. If you are younger than that, do not use the game. If you think a child has given us data, tell us and we will delete the account.
9. Security
All traffic between the game and our servers is encrypted (HTTPS / TLS). We store sign-in tokens only as hashes. The operator console cannot be reached from the internet.
10. Cookies and storage on your device
This website sets no cookies and uses no analytics. On your phone the game stores its sign-in token, your settings and your list of blocked players; the blocked-players list never leaves your device. The ad software may store data on your device as described in section 5.
11. Changes to this policy
We will announce important changes in the game before they apply. Earlier versions are available on request.