Draft – not legally reviewedThis text is a draft written from the game's actual data processing. It has not been checked by a lawyer yet and is not in force.
Privacy Policy
1. In short
- Draftborn shows no ads and contains no analytics, tracking or advertising tools. It does not read your location, contacts, photos, camera or microphone, and it uses no advertising ID.
- Your hero's progress lives on our own server, tied to an account the game makes for you. The account needs no e-mail address, no real name, no phone number and no password: the game makes a random account code and a secret key on your phone. Without a connection only the training ground can be played.
- Other players see your player name, your profile card and your hero; in the auction house they see your name on what you sell, and in a guild its members see whether you are online.
- Payments are handled by Google Play or the Apple App Store. We never see your card or bank details.
- You can delete your account in the game at any time (Settings → Account → Delete Online Account), and your hero with it.
2. Who is responsible
The controller under the General Data Protection Regulation (GDPR) is:
Manuel Ennsfellner (sole trader)
Gadern 45, 4775 Taufkirchen an der Pram, Austria
E-mail: info@proofdocs.de
For every question about your data, write to info@proofdocs.de. We answer in English or German.
3. Data on your phone
The game keeps a copy of your hero on your phone, so the camp can show it without a connection (with a backup copy of the previous save). The copy holds what our server last sent (section 4.2). Beside it the phone keeps what belongs only to the device: your settings (such as sound, controls and the monthly purchase limit), the first-time hints already seen, the players you met online recently, the money spent in the current month for the monthly limit, store purchases our server has not confirmed yet, run reports not answered yet, a name or look you chose while offline and not sent yet, and your account code with its secret key.
The copy cannot change your progress: only our server does. The phone sends the parts named in section 4 to our server. Storing these files is strictly necessary to provide the game you asked for (Art. 5(3) of the ePrivacy Directive and its national implementation; for what the server receives, Art. 6(1)(b) GDPR).
The files are removed when you uninstall the game or choose "Reset Progress" in the settings. "Reset Progress" and "Delete Online Account" also delete your account and your hero on the server (section 4.10).
4. Your account and your hero on our server
4.1 Your account
The first time the game reaches our server, normally on its first start, the server creates an account. It consists of a random account code (for example "A1B2C3D4E5", shown as your friend code) and a secret key. Your phone keeps the key; our server keeps only a one-way hash of it, so even we cannot read the key.
The server stores for your account:
- the account code, the hash of the key, the time the account was created and the time you were last online;
- your player name and your profile card: profile icon, frame, title, hero level, guild name, the ranks of your two ratings (Ranked 1 vs 1 and Ranked 3 vs 3), match statistics (matches, wins, win rate, MVPs, takedowns, dungeon runs), up to three showcased achievements, your three most picked abilities and your weapon;
- your ratings and your record (wins, losses, draws) per ranked mode and season, and your dungeon rating of the season;
- your friends, friend requests and the players you blocked;
- your Starshards, the order numbers of your purchases, and the looks, premium season rows and comfort (stash space, auction slots, loadout places) you bought (section 5);
- while a transfer code exists, its hash (section 4.8).
4.2 Your hero
The server keeps your hero's progress and is the only one that changes it: your hero's name and appearance, gold, Honor, items and gear, consumables and materials, gems, ability and hero levels, talents, saved loadouts, arena gear, quests, achievements and their counters, the Chronicle, the records of dungeons, the raid, the tower, survival, the world boss, the tournament and the Brawl, season progress and the season path, the looks you own and wear, emotes and poses, your last matches and runs and your career numbers. Every change you make in the game (equipping, selling, crafting, claiming a reward) is a request to the server, which checks it and sends back what changed.
Purpose and legal basis (4.1 and 4.2): providing the game, online matches, matchmaking, ratings, leaderboards, friends, guilds and the auction house, and keeping what you earned and bought; this is the service you ask for (Art. 6(1)(b) GDPR). Keeping progress on the server also protects the shared economy of all players from forged saves (Art. 6(1)(f) GDPR).
4.3 Runs played on your phone
Solo dungeons, the solo raid, the tower, survival and the world boss are played on your phone. Before such a run the server issues a ticket (random seeds and the supplies you take), which it keeps with your hero. At the end the phone sends a report of the run (result, time, enemies defeated, what dropped). The server checks the report against the ticket (the time it took, and kills and drops against what the ticket's seeds can produce) and grants the rewards once, rolling the loot again from the ticket.
If a report fails these checks, its rewards are not granted, and the server writes the account code, the player name at that time, the kind of run and the reason into its report log, which is mailed to us like a player report (section 4.9), at most once a day per account. We look at every such line by hand before any measure against an account. Legal basis: our legitimate interest and that of all players in a fair game and a sound economy (Art. 6(1)(f) GDPR). Refusing the rewards of one run inside the game is not a decision with legal effect on you (no automated decision within the meaning of Art. 22 GDPR).
4.4 During a connection, a match and a group run
While you are connected, the server processes your hero's appearance, gear, abilities and weapon for a match or a group run, your moves in the fight, and the emotes and quick messages you send. Matches against other players, matches against bots and dungeon and raid runs played online in a group run on the server. Emotes and quick messages are fixed lines from the game; they are passed on to the other players in the match, to your guild members online or to the friend you address, and are not stored. There is no free text chat. This data is held in the server's memory only for the connection, the match or the run; the result goes into your hero and your record. Legal basis: Art. 6(1)(b) GDPR.
4.5 The auction house
In the auction house players sell items and goods to each other for gold. When you list something, the server takes it out of your hero and keeps it with the listing until it is sold, its time (12, 24 or 48 hours) runs out or you take it back. The server stores the listing with your account code, your player name at that time, the item or goods, the price and the times. Other players see your player name, the item and the price. What you buy, the gold from a sale and what comes back unsold go to your mailbox on the server and stay there until you collect them. For the market value of goods the server keeps the units sold and the gold paid per good and day for seven days, without any link to the players. Legal basis: Art. 6(1)(b) GDPR.
4.6 Guilds
If you found or join a guild, the server stores the guild with its name, crest, whether anyone may join, its message of the day and the time it was founded, and for every member the account code, the rank, the time of joining and the weekly contribution to the guild's goal (wins and finished group runs online). Open invitations are stored with the inviter for 7 days. The message of the day is free text of up to 120 characters, written by the guild master or an officer; it passes the word filter (section 4.9) and is shown to every member until it is changed or cleared. Guild members see each other's names, profile cards, ranks and contributions, whether a member is online, in a match or offline, and when they were last online. Anyone can find a guild that is open to all by its name. Legal basis: Art. 6(1)(b) GDPR.
4.7 What other players see
Other players see your player name, your profile card, your hero's look and your ratings in matches and group runs, in the friend list, in your guild and in the auction house. The leaderboards (Ranked 1 vs 1, Ranked 3 vs 3 and the dungeon rating, per season) show the best 100 with their player name, rating and place. Your friends and your guild members also see whether you are online, in a match or offline, and when you were last online. Players you block no longer reach you with friend requests, invitations, emotes or quick messages.
4.8 Moving to a new phone
Under Settings → Account → "Transfer to Another Phone" the game shows a transfer code. It is valid for 24 hours and works once. The server keeps only a hash of it. When you enter it on a new phone, your account and your hero move there and the old phone is signed out. The account the new phone had before is deleted only if it holds nothing: no rating, no friends, requests or blocks, no Starshards or purchases, no guild, no listing or mail in the auction house, and a hero that was never played. Otherwise it stays on the server; no phone holds its key any more, so it is deleted after 24 months without a sign-in like any other account, or earlier if you ask us by e-mail (section 11).
4.9 Names, reports and moderation
Player names, guild names and guild messages pass an automatic word filter on your phone and on the server; a text with a listed word is not accepted. Titles can only come from the game's own list. These checks protect other players (Art. 6(1)(f) GDPR) and are not a decision with legal effect on you (no automated decision within the meaning of Art. 22 GDPR).
You can report a player on their profile card (reasons: name, behavior or other) and a guild on its page (reasons: name, message or other). The server stores a report with your account code, the reported account or guild, the reason and the time, and a copy of what was reported as it was then: the player's name, or the guild's name and message of the day. You can send a limited number of reports a day. Once a day the server sends new reports by e-mail to our address in section 2. We read every report and decide by hand.
If a name, a guild or behavior breaks the Terms of Use, we can reset a player name (to "Hero"; the game then asks for a new one), rename or dissolve a guild (its members are told), clear a guild's message or suspend an account (section 6 of the Terms of Use). A suspension is stored with the account, with its reason, its time and who set it, until we lift it. While it lasts, the account is refused at sign-in and a connected phone is disconnected, the account is left out of every leaderboard, and its listings in the auction house are held: hidden, not buyable and not running out. Every measure and every lookup we make is written to the server journal and to a moderation log with the account or guild, the measure, its reason, the result and the time. Legal basis: our legitimate interest and that of all players in a fair and safe game, and the duties of a hosting service under the Digital Services Act (Art. 6(1)(f) and (c) GDPR).
4.10 Deleting the account
"Delete Online Account" in the settings (Settings → Account) removes your account at once from the server: your hero with all its progress, items and gold, your name, profile card, ratings and leaderboard rows, friends, requests and blocks, your guild membership and the invitations sent to you, your listings in the auction house with what they hold, your mailbox, Starshards, the link between your purchases and your account, and what you bought. Reports about you are deleted, and in the reports you sent your account code is removed. The bare order ids of your purchases stay on the server without any link to you, so that no purchase can be credited twice. The phone forgets its copy of your hero too. "Reset Progress" does the same and also deletes the game's files on your phone. Without the app, you can ask us by e-mail; the page Delete Your Account explains both ways.
5. Purchases
You buy Starshards and packs through Google Play (Android) or the App Store (iOS). The store handles the payment, the price in your currency, taxes, the receipt and refunds. We never receive your card or bank details, nor the name or e-mail address of your Google or Apple account.
For each purchase we receive from the store the product, an order number, the time, the purchase status and a purchase token (Google) or a signed transaction (Apple), and on your phone the store's price in your currency (for the monthly limit). Our server checks every purchase with the store before it is granted: it sends the token to the Google Play Developer API or the transaction to the App Store Server API and receives whether the purchase is valid. Then it grants the purchase once per order number and keeps the order number, your Starshards and what you bought with them on your account.
Once a day the server asks Google for purchases that were refunded or cancelled; Starshards from such a purchase are taken back as far as they are still unspent. The server does not learn of refunds made by Apple.
Legal basis: delivering what you bought (Art. 6(1)(b) GDPR) and preventing fraud with purchases (Art. 6(1)(f) GDPR).
Google and Apple process your payment and their own records of your purchases as independent controllers, under their own terms and privacy policies: Google Privacy Policy, Apple Privacy Policy. They also process data outside the European Union; their policies name the safeguards they use.
6. Server logs, security and backups
- Web server log (Nginx): our web server receives every connection first and passes it on to the game server, which does not see your IP address. For each connection the web server logs the IP address, time, requested address, status, amount of data and the app's user agent, and it uses the IP address to limit how many connections come from one address, against abuse. The log is kept 7 days, then deleted. Purpose: finding errors and fending off attacks.
- Server journal: connections, matches, errors, refused run reports and moderation measures with the account code, without IP addresses. Kept 7 days.
- Backups: a daily copy of the server data (accounts, heroes, guilds, the auction house, reports and the moderation log) and one before every update of the server, each kept 14 days. Data you deleted can therefore remain in a backup for up to 14 days and is then gone for good. We also copy the backups by hand to a computer of ours, where they are kept for the same 14 days. Backups are only used to restore the server after a fault.
Legal basis: our legitimate interest in a secure and working service (Art. 6(1)(f) GDPR).
7. Recipients
- Hosting: our server runs on a rented server of OVH GmbH, St. Johanner Str. 41–43, 66111 Saarbrücken, Germany, which processes the data only on our behalf under a data processing agreement (Art. 28 GDPR). The server is located in Germany.
- Google and Apple: for the distribution of the app and for purchases, as described in section 5.
- Other players: what sections 4.5 to 4.7 name.
- Authorities: only where the law obliges us.
We do not sell data and do not pass it on for advertising.
8. Countries outside the EU
We do not transfer your data to countries outside the European Union or the European Economic Area ourselves. Google and Apple may process data outside the EU under their own responsibility (section 5).
9. How long we keep data
| Data | Kept |
|---|---|
| The game's files on your phone | until you uninstall the game or choose "Reset Progress"; the copy of your hero also goes when the account is deleted |
| Account and hero with everything in sections 4.1 and 4.2 | until you delete the account; an account without a sign-in for 24 months is deleted automatically |
| Ratings of past seasons | after two seasons reduced to the best rating per mode |
| Listings and mailbox in the auction house | a listing until it is sold, taken back or its time runs out; mail until you collect it; both at the latest until the account is deleted |
| Sales per good and day (without players) | 7 days |
| Guild membership | until you leave the guild, are removed from it, the guild is dissolved or the account is deleted |
| Guild invitations | 7 days, or until accepted, declined or withdrawn |
| Suspension of an account (reason, time) | until it is lifted, at the latest until the account is deleted |
| Moderation log (measures and lookups) | 6 months, like the reports, then deleted automatically; lines about a deleted account go at once |
| An account left behind by a transfer | deleted at once if it holds nothing (section 4.8); otherwise after 24 months without a sign-in, or earlier on request |
| Transfer code (hash) | 24 hours or until used |
| Data of a connection, match or group run (moves, emotes, quick messages) | until the connection, match or run ends |
| Reports about players and guilds, and refused run reports | 6 months, then deleted automatically; the e-mail copy sent to us is deleted after the same time. Reports about a deleted account go at once, and in the reports a deleted account sent, its account code is removed. |
| Web server log with IP addresses | 7 days |
| Server journal (without IP addresses) | 7 days |
| Backups | 14 days |
10. Age
Draftborn is made for players aged 13 and older. The game does not ask for your age, and the account holds no real name or contact details. If you are a minor, ask a parent or guardian before you buy anything; both stores offer parental controls for purchases.
11. Your rights
You have the right to access your data (Art. 15 GDPR), to have it corrected (Art. 16), deleted (Art. 17) or restricted (Art. 18), to receive it in a common format (Art. 20) and to object to processing based on our legitimate interests (Art. 21). You can change your player name in the game and delete your account in the game yourself.
For everything else write to info@proofdocs.de and give your account code (shown as your friend code on the Friends page). Because the account has no e-mail address or password, we may ask for details that show the account is yours before we hand out or change data. We answer within one month.
You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU country where you live or work. The authority responsible for us is the Austrian Data Protection Authority (Datenschutzbehörde), Barichgasse 40–42, 1030 Vienna, Austria, www.dsb.gv.at.
12. Changes
When the game starts to process data differently, we update this policy and the date at the top. The current version is always at this address and is linked in the game under Settings → Info → Legal.