Privacy Policy
Effective Date: March 9, 2026
Summary: Eternel Games is built with privacy first. We collect the minimum data needed to operate the platform, we do not sell your data, and we use PostHog for product and performance analytics. This policy explains what we collect, why, and your rights.
1. Data Controller
Data Controller: Eternel Games LLC
Contact: contact@eternel.games
Note: No Data Protection Officer (DPO) is currently appointed. This may need to be reassessed if processing reaches a scale requiring one under GDPR Article 37.
2. Data We Collect
2.1 Account Data
Collected at registration:
- Email address
- Display name and optional public handle
- Password (cryptographically hashed — never stored in plain text)
- Phone number and country code
- Signup security signals (for example IP address and device fingerprint hash)
2.2 Purchase Data
- Gem purchase history (date, pack purchased, amount paid)
- Current Gem balance
Payment method details are handled by third-party payment processors. We do not store full card numbers.
2.3 Gameplay Data
- Game session history (date, duration, tier, outcome)
- In-game statistics (kills, deaths, placements, survival time)
- Ranking and seasonal scores
2.4 Technical Data
Collected automatically for security and anti-fraud purposes:
- IP address
- Device type and browser
- Session timestamps
We use security/session cookies and PostHog for product analytics. We do not use advertising trackers.
2.5 Communication Data
- Support tickets and correspondence
- Email communications
3. Data We Do Not Collect
We believe in transparency. Here is an explicit list of what we do not do with your data:
- We do not use advertising trackers of any kind
- We do not sell, rent, or share personal data with advertisers
- We do not build advertising or behavioral profiles
- We do not collect biometric data
- We do not perform automated decision-making or profiling beyond anti-fraud and anti-collusion
- We do not store payment card numbers (handled entirely by payment processors)
4. Why We Process Your Data (GDPR Art. 6)
| Data Category | Purpose | Legal Basis |
|---|---|---|
| Account Data | Create and manage your account | Contract performance |
| Purchase Data | Process gem purchases, maintain records | Contract + Legal obligation |
| Gameplay Data | Provide game services, rankings | Contract performance |
| Technical Data | Security, anti-fraud | Legitimate interest |
| Analytics Data | Measure product usage and improve performance | Consent where required / Legitimate interest where permitted |
| Communication | Respond to support requests | Contract performance |
| Anti-teaming data | Detect and prevent collusion | Legitimate interest |
We do not rely on “consent” as a legal basis for core data processing. Consent is only used where specifically required (e.g., marketing emails, if introduced in the future).
5. Data Storage & Security
- All data is stored on servers hosted by Hetzner in the European Union
- Data does not leave the EU except where strictly necessary for payment processing, in which case Standard Contractual Clauses (SCCs) apply
- Security measures include: encryption at rest, encryption in transit (TLS), cryptographically hashed passwords, access controls, and regular security audits
6. Data Retention
| Data Category | Retention Period |
|---|---|
| Account Data | Duration of account + 3 years after closure |
| Purchase Data | 7 years (tax and accounting obligations) |
| Gameplay Data | Duration of account + 1 year after closure |
| Technical Data | 6 months (rolling deletion) |
| Communication Data | 2 years after last interaction |
| Anti-teaming logs | 6 months (rolling deletion) |
After the retention period expires, data is permanently deleted or irreversibly anonymized.
7. Your Rights (GDPR Articles 15-22)
As a data subject, you have the following rights:
- Access — Request a copy of all personal data we hold about you (response within 30 days)
- Rectification — Correct inaccurate or incomplete data
- Erasure — Request deletion of your data (subject to legal retention requirements — e.g., tax records for gem purchases cannot be deleted before the mandatory retention period)
- Restriction — Request that we stop processing your data in certain circumstances
- Portability — Receive your data in a structured, machine-readable format
- Object — Object to processing based on legitimate interest
- Withdraw consent — Where consent is the legal basis (currently limited to marketing, if applicable)
- Complaint — Lodge a complaint with the data protection authority in your country of residence
To exercise your rights: Email contact@eternel.games with subject “Data Rights Request.” We will respond within 30 days (extendable by 60 days for complex requests, with notification).
8. Third-Party Processors
The following third parties process data on behalf of Eternel Games:
| Processor | Purpose | Data Shared | Location |
|---|---|---|---|
| Hetzner | Server hosting | All data (encrypted) | EU |
| PostHog | Product analytics | Usage and event analytics data | US/EU (service dependent) |
| Clerk | Authentication & transactional emails | Email address, account data | US |
All processors are bound by Data Processing Agreements (DPAs) compliant with GDPR. We do not share data with advertisers, data brokers, or social media platforms.
10. Children’s Privacy
Free practice gameplay may be available to users under 18 where lawful. Gem purchases are restricted to users 18+.
If we discover a minor purchasing Gems, we may disable purchase access and apply account restrictions required for compliance.
If you are a parent or guardian and believe your child has created an account, please contact us immediately at contact@eternel.games.
11. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated via email and/or in-platform notification at least 14 days in advance. The “Last Updated” date at the top of this policy always reflects the current version.
Continued use of the Platform after changes take effect constitutes acceptance of the updated policy.
12. Contact
For privacy-related questions: contact@eternel.games
For general support: contact@eternel.games
Eternel Games LLC
contact@eternel.games