Last updated: [date]. Text in [square brackets] must be filled in or reviewed before this service goes public.

1. Who is responsible

The controller of your personal data is [operator name and address]. Contact: [contact email].

2. What we collect

• Account data: your email address, your username, and a salted scrypt hash of your password (we never store or log the password itself), the date you registered, which invite code you used and, once you have bought a subscription, which invite code is yours.
• Network data: the IP address of your requests. For rate limiting, session lists and abuse detection we keep a keyed hash (HMAC) of it. In addition, for every account we store the full IP addresses from which the account used the website, the loader and the cheat software (the 50 most recent different addresses, with the first and last time, how often, and through which of the three), together with the approximate location of each address (country, and city and region where available), which the content delivery network in front of the site (Cloudflare) derives from the address and passes to us with the request. Administrators can see these addresses and locations to detect abuse and account sharing; no other member can. The raw address is also kept in our administrative audit log of actions performed by administrators.
• Hardware identifiers: when you use the loader it sends hashes (computed on your computer) of several hardware identifiers - the Windows machine GUID, the system UUID, a disk serial number, a volume serial number and a CPU identifier. The server hashes them again with a secret before storing them. We cannot read the original values. They are used to bind a subscription to your registered devices and to block devices that were banned.
• Cheat revealer (only while it is switched on in the software): the software then sends your Steam ID, an identifier of the match you are in and the Steam IDs of the other players in that match, and the server uses them only to tell other users of the software in that same match that you use it (and you who they are); this data is processed only while the software is running with the revealer on, is never kept in the logs, and is deleted when the software ends or the revealer is turned off.
• Usage logs: website logins and sessions (time, hashed IP, browser name), loader logins and periodic loader checks (time, hashed IP, loader version, result), loader downloads, and refused attempts.
• Payment records: the plan you bought, the cryptocurrency, the payment address generated for your order, the amount, the blockchain transaction identifiers and times. Blockchain data is public by nature.
• Cookies: strictly necessary cookies only - a session cookie, security tokens against cross-site request forgery and a one-time notice cookie. No analytics, no advertising, no tracking.

3. Why we use it

• To provide the Service: accounts, login, subscriptions, delivery of the loader and the software (contract).
• To enforce the licence and prevent abuse, fraud, account sharing and attacks (legitimate interest).
• To process payments and keep the records the law requires (contract, legal obligation).
• To send you a password reset email or a payment confirmation when you ask for one (contract).

4. Who receives data (processors)

• Google reCAPTCHA on the registration page: Google receives your IP address and browser data to tell people from bots. See Google's privacy policy.
• Email/SMTP provider [provider name]: receives your email address and the message text when we send you a message.
• Blockchain explorers / node providers [provider names]: we query public payment addresses and transaction data; no account data is sent.
• Hosting provider [hosting provider and country] and, if used, a content delivery network that sits in front of the site ([Cloudflare or none]).

We do not sell your data and we do not share it for advertising.

5. How long we keep it

• Account data: while your account exists, and for up to [12] months after deletion where needed to prevent ban evasion or to resolve disputes.
• Session records: until they expire or you sign out. Loader and security logs: up to [12] months.
• Payment records: [the period required by tax and accounting law].
• Stored IP addresses and approximate locations: while your account exists (the 50 most recent addresses); they are deleted together with the account.
• Banned hardware identifiers (hashes): as long as the ban applies.

6. Security

Passwords are hashed with scrypt, sessions are random tokens stored only as hashes, hardware identifiers are stored only as keyed hashes (so are IP addresses in sessions and logs; the full addresses kept per account are described in section 2 and are visible to administrators only), uploaded software is encrypted at rest, and the loader and the server communicate over TLS with signed and encrypted messages. No system is perfectly secure; tell us if you find a problem.

7. Your rights

Depending on where you live you may have the right to access, correct, delete or export your data, to restrict or object to processing, and to complain to a supervisory authority. Email [contact email] to exercise them. Some data (for example payment records and hashes needed to enforce a ban) may have to be kept even after your account is deleted. Your email address and password can be changed on the account page.

8. Children

The Service is not for people under [18]. If you believe a child has registered, contact us and we will delete the account.

9. International transfers

Our providers may process data outside your country. Where required we rely on appropriate safeguards: [describe, e.g. standard contractual clauses].

10. Changes

We may update this policy; the date at the top shows the current version.