Privacy Policy
Last updated: [DATA PUBLIKACJI]
1. Who is responsible for your data
The controller of personal data of Bell of Ash (“the Game”) players is [IMIĘ I NAZWISKO ALBO NAZWA FIRMY], [ADRES]. Contact for data protection matters: [ADRES E-MAIL].
We have not appointed a data protection officer — we are not required to.
2. The short version
- The Game never asks for your name, e-mail address or phone number. Accounts have no passwords.
- You can play offline — nothing leaves your phone then. Data reaches the server only when you use online features (online Camp, chat, Order, Ash Bazaar, rankings, purchases).
- The Game server is located in Germany. We do not transfer data outside the European Economic Area.
- No ads, no advertising identifiers, no third-party analytics.
- You can delete your account yourself — in the Game (Options → Account → Delete account) or through this site.
3. How we recognise your account
The first time you enter the Camp, the Game draws a player identifier on your device — the prefix boa- followed by 32 random characters. It is not a phone number, a serial number or any identifier issued by Android or iOS: it comes from a random number generator and is stored only in the app's storage on your device and on our server as the account key.
Worth knowing: whoever has that identifier has access to the account. Uninstalling the Game or clearing the app's data erases the identifier and may cut you off from your progress for good.
4. What we process, why, and on what legal basis
| Data | Purpose | Legal basis (GDPR) |
|---|---|---|
| Player identifier, technical account name, creation and last login date | so the account exists and you can return to it | Art. 6(1)(b) — performance of a contract (the Game's terms) |
| Game progress: characters, levels, gear, currencies, talents, achievements, Season Pass, expedition log | keeping progress on the server, shared across devices and resistant to cheating | Art. 6(1)(b) |
| Character names — visible to other players | recognising players in social features | Art. 6(1)(b) |
| Friends: friend list, sent and received requests, highest number of friends (Chronicle deed), Order invitations from friends | the friend list; friends see each other's character name, class, level, best floor and CP, and in the character preview — equipped gear, Wings and cosmetics (no Stash, gold or materials) | Art. 6(1)(b) |
| Last activity: the moment the Game last contacted the server (at least every 2 minutes while the Game is running) | the “online” / “last seen …” status shown to your friends and members of your Order | Art. 6(1)(b) |
| Order: membership, rank, Treasury contribution, completed Tasks, Bell participation | running guilds and weekly rankings | Art. 6(1)(b) |
| Chat: message content (global, Order, private), sender, time sent, conversation list | delivering the chat | Art. 6(1)(b) |
| Chat reports and blocks; lists of blocked and muted players | moderation and player safety | Art. 6(1)(f) — legitimate interest |
| Chat translations (only if you turn the option on): message text and its translation | letting players from different countries understand each other; translation runs on our own server, the text never reaches a third-party company | Art. 6(1)(b) |
| Ash Bazaar: listings, seller, buyer, mail with items and gold | player-to-player trading | Art. 6(1)(b) |
| Beacons (game invitations): your account's code, whose code was entered and when, for 30 days the days with a cleared floor and the best floor — the inviter sees your nickname and this progress | invitations and rewards for active invitees | Art. 6(1)(b) |
| Purchases: store receipt, transaction and product identifier, date, verification status | confirming the purchase, preventing receipt reuse, handling complaints | Art. 6(1)(b) and (c) |
| Gameplay statistics: how long a floor took, the wave a run ended on and why | tuning the pace of the Game — we want to know whether a floor drags on; the numbers go into a daily aggregate counter, with no player identifier | Art. 6(1)(f) — legitimate interest (developing the Game) |
| Game updates: at launch and from time to time the Game asks our server whether a new fix is available and downloads it — the request contains only the platform and the Game's version number, no player identifier; the update server does not store IP addresses | delivering fixes without waiting for a new version in the store | Art. 6(1)(b) |
| Technical connection data: IP address, time and type of request — in server logs | security, fault diagnosis, protection against abuse | Art. 6(1)(f) |
What we do not collect
Names, e-mail addresses, phone numbers, postal addresses, dates of birth, phone contacts, photos, location (GPS), advertising identifiers, the list of installed apps, microphone or camera recordings. The Game shows no ads and contains no advertising or analytics libraries. We do not profile players and make no automated decisions with legal effects.
We never see payment details
Payment is handled entirely by the app store (Google Play or the App Store) under its own rules. Card numbers, billing addresses and bank details go to the store, not to us. All we receive is a receipt, which we verify with the store operator to confirm the purchase is genuine.
5. Who we share data with
- Hetzner Online GmbH (Germany) — the provider of the server the Game runs on. A processor.
- Google LLC / Apple Inc. — only to verify purchase receipts. For the payment itself the stores are separate controllers and their own privacy policies apply.
- Public authorities, where the law requires it.
We do not sell player data and do not share it with marketing companies.
6. Where the data is
All Game data sits on a server in a data centre in Germany. We do not transfer it outside the European Economic Area. Purchases are the exception: verifying a receipt means a request to Google's or Apple's systems, which operate globally under their own compliance mechanisms.
7. How long we keep data
| Data | Period |
|---|---|
| Account and Game progress | until you delete the account — we do not remove unused accounts automatically |
| Chat messages | the Game shows only the last 14 days; older ones stay on the server and nobody sees them any more; we delete them together with your account when you delete it |
| Chat reports | 12 months — we need them to judge repeated violations |
| Bazaar listings and mail | a listing expires after 48 hours; mail — until the player collects it |
| Friends and last activity | until the friendship or the account is removed; for activity we keep only the latest moment — each new one overwrites it; an Order invitation expires after 7 days |
| Purchase receipts | 5 years from the end of the year of purchase — required by tax law |
| Gameplay statistics (aggregated, no player identifier) | kept indefinitely — they are not personal data |
| Server logs (including IP addresses) | 30 days |
8. Your rights
You have the right to access your data and obtain a copy, to rectification, erasure, restriction of processing, data portability, and to object to processing based on our legitimate interest. Send your request to [ADRES E-MAIL] — we reply within one month.
Because we do not know your name or e-mail address, we need your player identifier (Options → Account) or a character name to handle the request; without it we cannot link the request to an account and, under Art. 11 GDPR, we may refuse to act on it.
You also have the right to lodge a complaint with a supervisory authority — in Poland, the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw).
9. Deleting your account
You delete your account together with progress, character names, friends, chat messages, Bazaar listings and Order membership yourself — in the Game (Options → Account → Delete account) or through this site.
Deletion is immediate and irreversible. Only data we are required to keep remains: purchase receipts for tax purposes, moderation reports filed by other players in which your message is the evidence, and your contribution to the Order's Bell — once the account is gone it is merely part of the Order's shared total and points to no individual player.
10. Children
The Game is not directed at children. It includes open chat with other players, so we intend it for people aged 16 and over. We do not knowingly collect data from children below that age; if a guardian finds that a child has created an account, please contact us and we will delete it.
11. Security
The connection between the Game and the server is encrypted (HTTPS/TLS). Administrative access to the server and the database goes exclusively through a private VPN and SSH keys, with no panels exposed to the public internet. The database is not reachable from outside. We store no player passwords, because the Game does not use any.
12. Changes to this policy
We may change this policy as the Game develops — for example when a new online feature arrives. The current version always sits on this page together with the date of the last change. We will announce significant changes in the Game.
13. Contact
[IMIĘ I NAZWISKO ALBO NAZWA FIRMY], [ADRES] · [ADRES E-MAIL]