This policy explains what the Game and its online features collect, why, how it is handled, and what choices you have. It applies to the online matchmaking, ranked, quick, and custom-lobby features (together, the "Online Service") and to files the Game stores locally on your device. The short version: the Game has no Developer server, no account database, no advertising, no analytics, and no sale of data; online play sends a small set of game records to the player who hosts your match, and offline play sends nothing anywhere.
1. Who Is Responsible
The Game is developed by a single independent developer, the publisher named on the Game's Steam store page (the "Developer"), who is the party responsible for the processing described here. Because the Online Service is hosted by players on their own machines, the player who hosts a ladder or match also holds the records described in section 2 for that ladder or match, on their own device. Contact the Developer through the support channel published on the Game's Steam store page and Steam community hub; that page always carries the current contact.
The Developer has not appointed a data protection officer or a representative in the European Union or the United Kingdom, relying on the exemptions for occasional, low-risk processing without a server of its own. This will be revisited if the Online Service changes in a way that requires it.
2. What Is Collected
Held by the Online Service (stored in the player-record store on the machine of the player who hosts the ladder or match):
- A randomly generated player id (pid) that identifies you to the Online Service without requiring your real name;
- Where you play through Steam: your Steam account id (a numeric SteamID) and a single-use Steam authentication ticket, presented when you join a host so the host can ask Steam to confirm you are the account you claim. The host keeps only the verdict and the SteamID; the ticket is not stored. The verified SteamID is bound to your player id so that ranked eligibility and any enforcement action (for example a Steam Game Ban) apply to the right account;
- Your chosen call sign;
- Your faction preference;
- Match outcomes (win/loss), matchmaking rating (MMR), experience points (XP), win/loss streaks, season history, cosmetic unlocks, and the presence records used to score absences (time away from a live match, desertions, and any ranked lock that results);
- Chat messages sent through in-match chat, which are relayed by the Online Service to other participants in the same match;
- Match records (the sequence of orders every seat gave, and integrity hashes of the shared simulation), which every participant's Game keeps locally and which the host relays so that a disconnected player can rejoin;
- A one-byte summary of your system's security posture (section 13), sent when you join, which sets the matchmaking tier you may enter; and
- Your IP address, transiently, as technically required to operate matchmaking and match relay (to connect you to a match host). IP addresses are used operationally and are not stored as part of your long-term player record.
Stored locally on your device only (never uploaded except for the specific fields above needed to run matchmaking, ranking, and leaderboards):
- profile.ron, containing your local identity, keys, and career statistics;
- Settings and calibration files, the legal-acceptance record, and preferences, stored in your operating system's standard per-user configuration directory;
- Match artifacts and replays of the battles you played, stored in the Game's matches directory.
The Game writes no crash-report file and sends no crash report anywhere; if it fails, its diagnostic output goes only to the console it was started from. Your operating system or the Steam client may record a crash under their own policies, outside the Game's control.
The Game does not include voice chat, does not access your microphone, camera, contacts, location, or files outside its own directories, and does not read the contents of other programs or your screen.
3. What Is Not Collected
The Developer does not use cookies, trackers, third-party advertising, third-party analytics, or telemetry services, does not sell, rent, or trade your personal data, does not "sell" or "share" personal information as those terms are defined in California law, does not use or disclose sensitive personal information to infer characteristics about you, and does not build profiles of you for any purpose other than the ranking and anti-abuse functions described here. If this ever changes, it will be disclosed in an updated version of this policy and you will be asked to re-accept.
4. Why It Is Collected
Data is collected only for purposes necessary to operate the Game's online features:
- Matchmaking: pairing you with other players for ranked, quick, and custom lobbies, and connecting you through the match relay;
- Identity: confirming, through Steam, that a ranked seat belongs to the account that claims it;
- Ranking integrity: computing and maintaining MMR, win/loss records, XP, streaks, seasons, and cosmetic unlocks so competitive results are meaningful and consistent;
- Presence and fairness: scoring absences from live matches and applying the documented penalties for abandonment;
- Reconnection: relaying match records so a player who disconnects can rejoin the same match;
- Anti-abuse and enforcement: identifying cheating, exploitation, or chat abuse, keeping evidence of it, and applying enforcement actions; and
- Operating the relay: IP addresses are used only as required to route matchmaking and relay traffic.
5. Legal Bases (where applicable)
Where a legal basis is required (for example under the GDPR, the UK GDPR, or Canada's PIPEDA), the Developer relies on: performance of the service you request (matchmaking, ranked play, and reconnection); the Developer's legitimate interests in operating a fair, functioning, abuse-resistant competitive service and in protecting its rights; compliance with legal obligations; and, where the law requires it for a specific use, your consent, which you may withdraw at any time. You may object to processing based on legitimate interests as described in section 9.
6. Who Receives It
- Other players: your call sign, faction, rank, records, orders, and chat messages are visible to the other participants of your match and, for ladder entries, to anyone who views that ladder's leaderboard.
- The hosting player: the player who hosts your match or ladder holds the records described in section 2 on their device and can see them.
- Valve (Steam): where you play through Steam, Valve processes your Steam account data under its own policy (section 11), and validates the authentication ticket described in section 2.
- Nobody else, except as required by law, a court order, or a lawful request by a public authority, to protect the rights, property, or safety of the Developer, players, or the public, or to a successor of the Game if it is transferred, in which case this policy continues to apply.
The Developer does not use data processors, cloud services, or servers of its own for the Online Service.
7. Retention
Your player-record data is retained by the host of a ladder for as long as that ladder operates and your account remains active on it, so ranking and matchmaking stay accurate. Match records are retained by each participant for their own replays and are relayed only during the match they belong to. Chat messages are relayed to support live matches and are not retained by the Developer beyond operating the match and investigating abuse reports. Transient IP addresses used for connections are not retained as part of your long-term player record. Anti-cheat evidence, and the binding of a player id to a SteamID that supports it, is retained as described in section 13. Local files remain on your device until you delete them.
8. Children
The Game is not directed at children under 13 (or the equivalent minimum age in your jurisdiction), and the Developer does not knowingly collect personal information from such children through the Online Service. If you believe a child has provided information to the Online Service, contact the Developer so it can be reviewed and removed.
9. Your Rights and Choices
Depending on where you live, you may have the right to access, correct, export, or request deletion of your data, to object to or restrict certain processing, to withdraw consent, and to complain to a data-protection authority (for example the Office of the Privacy Commissioner of Canada, your national or regional authority in the European Union, the Information Commissioner's Office in the United Kingdom, or your state authority in the United States). To exercise these rights, contact the Developer through the published support channel. The Developer will make reasonable efforts to respond to verified requests within the time the law requires, and in any case within a reasonable period consistent with a solo-developed service. Because ladder records live on hosting players' machines, the Developer may need to ask the relevant host to act on a deletion request. You will not be treated differently for exercising any of these rights.
You may request deletion of your player-record data at any time. Local files (profile, settings, replays, logs) remain under your control and can be deleted directly from your device. You can play entirely offline in Skirmish, where nothing leaves your device, and you can avoid any particular host by declining its lobby.
10. Automated Decisions
No automated decision that has a legal or similarly significant effect on you is made by the Game. Automated signals (for example anti-cheat observations, absence scoring, the matchmaking tier, and matchmaking) affect in-game outcomes only, and consequential enforcement actions are decided by a human reviewing the evidence (section 13).
11. Steam Platform Layer
Where you access the Game through Steam, Valve independently collects and processes data under its own Steam Privacy Policy (for example your Steam account information, friends, achievements, and cloud save data). That processing is governed by Valve's policies, not this one. The practices above apply to data collected by the Game itself, separately from the Steam platform layer.
12. Security
The Developer takes reasonable technical steps to protect data handled by the Game and the Online Service: match traffic is signed and, over Steam's networking relay, encrypted by that relay; the player-record store and evidence log are tamper-evident; and the anti-cheat runs only inside the Game's own process. No method of transmission or storage is completely secure, and the Developer cannot guarantee absolute security. If a breach affecting your personal data comes to the Developer's attention, the Developer will notify you and any authority as required by applicable law.
13. Anti-Cheat and Security Telemetry
The Game includes built-in anti-cheat components. In the interest of transparency, this section states plainly what they do.
What the Game checks, on your own device: whether a debugger is attached to the Game; whether the Game's own code in memory has been altered; whether the running Game executable carries a valid digital signature (a build that carries no signature at all is not penalized; only a signature that is present and invalid counts); the names of loaded modules, running processes, and window titles, compared against a short list of known cheat tools (names only; the Game never reads the contents of other programs, files, documents, or your screen); and, once at startup, your operating system's security posture (Secure Boot, TPM, memory integrity, DMA protection, test-signing mode, kernel debugger), which determines which matchmaking tier you may join. Ranked play may be unavailable on systems with test-signing or a kernel debugger enabled; the Game never blocks single-player play.
What is sent, and where: when you join a match, a one-byte summary of the startup posture check (a tier, not the underlying details) is sent to the host so it can place you in the right queue. During online matches only, the Game may also send small numeric reports (a detection category, a count, and a timestamp, for example "integrity check failed, twice, at 14:03") to the host of your match over the signed networking session, so the host can verify they came from your Game. These reports contain no chat, no names, and no text you can influence. If no check has triggered, nothing else is sent: a clean session produces no telemetry beyond the one-byte tier. The Game runs no Developer server: reports are stored in a tamper-evident evidence log on the match host's own machine, and the Developer sees them only if a host submits that log for review.
Retention: nothing is retained from a clean session because nothing leaves your device. Flagged evidence is kept by the host for up to three years (1095 days by default; the host's Game prunes it automatically after that) to support enforcement review and appeals, then deleted.
No automated bans: no score or program ever bans you by itself. Any enforcement action (for example a Steam Game Ban) is decided by a human reviewing the collected evidence, normally requiring corroboration from independent sources. You may contest any action through the support channel in section 9, and the evidence will be re-reviewed.
What the Game does not do: it installs no kernel-level driver, no system service, and no component that runs when the Game is closed. All anti-cheat components run inside the Game's own process, only while the Game runs.
14. International Transfers
The Online Service is not run from a central Developer server. Each match is hosted on one participating player's machine, and the player-record store for a ladder lives on the machine of the player who hosts it. The data described in section 2 may therefore be processed in whatever country that host plays from, which may differ from yours and may not provide the same level of data protection. Where your local law requires a basis for such a transfer, the Developer relies on the transfer being necessary to provide the service you request: joining that host's match. You can avoid any particular host by declining its lobby, and you can play entirely offline in Skirmish, where nothing leaves your device.
15. Changes to This Policy
This policy may be updated as the Game and Online Service evolve, especially during Early Access. Material changes will be reflected in a new legal document version number, and you will be asked to review and re-accept the next time you launch the Game. The date of the current version is shown on the gate that presents it.