Политика конфиденциальности

This privacy policy informs you, in accordance with the EU General Data Protection Regulation (GDPR, Regulation 2016/679) and the Austrian Data Protection Act (DSG), about the nature, scope and purpose of the processing of personal data within our online service Front-Risk.

1. Controller

The controller within the meaning of Art. 4(7) GDPR is:
William Comploi
Unterberg 59
6835 Dafins, Austria
Email: front-risk@gmx.net

2. General Information

We process personal data exclusively in accordance with the provisions of the GDPR and all other applicable laws. Personal data means any information relating to an identified or identifiable natural person.

3. Legal Bases for Processing

• Art. 6(1)(a) GDPR – consent (e.g. newsletter sign-up)
• Art. 6(1)(b) GDPR – performance of a contract and pre-contractual steps (e.g. account, gameplay)
• Art. 6(1)(c) GDPR – legal obligation (e.g. tax retention)
• Art. 6(1)(f) GDPR – legitimate interests (e.g. IT security, fraud prevention, statistics not linked to an account)

4. Categories of Data and Purposes

4.1 Account / Login

On registration we collect: email address, password (hashed, never stored in plaintext), nickname, registration timestamp, and login timestamps / IP addresses for abuse prevention. Purpose: providing access to the game and managing the account. Legal basis: Art. 6(1)(b) GDPR. Retention: until the account is deleted by the user; IP logs for a maximum of 30 days.

Sign-in with Google. If you choose “Sign in with Google”, you are redirected to Google and sign in there. This sign-in is processed by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) as an independent controller; Google’s privacy policy applies (policies.google.com/privacy). With your permission, Google sends us: your email address and whether it is verified, an identifier of your Google account, the name stored with Google and the address of your Google profile picture. We use the email address and the identifier to create your account and to recognise it on later sign-ins. Name and picture address are stored only in the Google link held by our authentication service (Supabase, see section 5); we do not display them, do not use them as your player name or profile picture, and do not pass them on. On your first sign-in you receive a provisional player name, which you can change in your account. If an account with the same email address already exists, the Google sign-in is attached to that account. If that account had not yet been confirmed, its password is removed in the process. No password is created this way, and we get no access to your Google account or any other data in it. Legal basis: Art. 6(1)(b) GDPR. Retention: until the account is deleted. Use is voluntary; signing in with email address and password remains possible.

Sign-in with Discord. If you choose “Sign in with Discord”, you are redirected to Discord and sign in there. This sign-in is processed by Discord Netherlands BV (Schiphol Boulevard 195, 1118 BG Schiphol, Netherlands) as an independent controller; Discord’s privacy policy applies (discord.com/privacy). With your permission, Discord sends us: your email address and whether it is verified, an identifier of your Discord account, your username and display name, and the address of your Discord profile picture. We use the email address and the identifier to create your account and to recognise it on later sign-ins. Username, display name and picture address are stored only in the Discord link held by our authentication service (Supabase, see section 5); we do not display them, do not use them as your player name or profile picture, and do not pass them on. On your first sign-in you receive a provisional player name, which you can change in your account. If an account with the same email address, verified with Discord, already exists, the Discord sign-in is attached to that account. If that account had not yet been confirmed, its password is removed in the process. No password is created this way, and we get no access to your Discord account, your servers or your messages. Legal basis: Art. 6(1)(b) GDPR. Retention: until the account is deleted. Use is voluntary; signing in with email address and password remains possible.

Sign-in with Twitch. If you choose “Sign in with Twitch”, you are redirected to Twitch and sign in there. This sign-in is processed by Twitch Interactive, Inc. (350 Bush Street, 2nd Floor, San Francisco, CA 94104, USA) as an independent controller; Twitch’s privacy notice applies (twitch.tv/p/legal/privacy-notice). Twitch is based in the USA; how Twitch protects your data there is governed by that notice. With your permission, Twitch sends us: your email address as verified by Twitch, an identifier of your Twitch account, your login and display name, the address of your profile picture, and public channel details (channel description, account and partner status, address of the offline image, view count). We use the email address and the identifier to create your account and to recognise it on later sign-ins. Everything else is stored only in the Twitch link held by our authentication service (Supabase, see section 5); we do not display it, do not use your Twitch name as your player name or your Twitch picture as your profile picture, and do not pass it on. On your first sign-in you receive a provisional player name, which you can change in your account. If an account with the same email address already exists, the Twitch sign-in is attached to that account. If that account had not yet been confirmed, its password is removed in the process. No password is created this way, and we get no access to your Twitch account, your channel or your messages. Legal basis: Art. 6(1)(b) GDPR. Retention: until the account is deleted. Use is voluntary; signing in with email address and password remains possible.

Linking sign-in methods. In your account you can link one of the sign-in methods named above to your existing account, even if the provider knows a different email address than your account. The provider sends the same details as when signing in (see above); they are stored in the link held by our authentication service (Supabase, see section 5), and we use the email address and the identifier only to attach later sign-ins through this provider to your account. Linking does not change your account’s email address. In your account you can see which sign-in methods are linked (with a shortened email address) and unlink a provider as long as another sign-in method remains; the link is deleted in the process together with the provider’s details. If your account’s email address came from the unlinked provider, the account takes over the confirmed address of a remaining sign-in method; if none of them has a confirmed address, unlinking is not possible. Legal basis: Art. 6(1)(b) GDPR. Retention: we keep the provider’s details until you unlink it, at the latest until the account is deleted. Use is voluntary.

Protection against automated accounts. When you submit the form for signing in, signing up or resetting your password by email, we use Cloudflare Turnstile (Cloudflare, Inc., 101 Townsend St, San Francisco, CA 94107, USA) to check that a human is acting. For this, your browser loads a script from Cloudflare at that moment – and only then. Cloudflare processes your IP address, a technical fingerprint of the encrypted connection (TLS fingerprint), your browser identifier (user agent), and our site key and the requesting address, and only returns the result of the check to us. Usually this happens invisibly; only in case of doubt a box to click appears. For this check Cloudflare acts as our processor (see section 5). In addition, Cloudflare uses the signals as an independent controller to improve its bot detection; Cloudflare’s privacy notice applies to that (cloudflare.com/turnstile-privacy-policy). Purpose: preventing programs from creating accounts in bulk or trying out sign-ins. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in abuse prevention and cost control). Cloudflare is based in the USA (see section 6). Without this check, signing in or signing up by email is not possible; signing in with Google, Discord or Twitch still works.

4.2 Forum Posts

When you create threads or replies, the content, timestamp and author (nickname / account ID) are stored and made visible to other registered users. Legal basis: Art. 6(1)(b) GDPR (performance of the forum service). Retention: until deletion by the user or moderation action. Anonymisation of deleted posts is technically possible.

To prevent mass posting, we count each account’s posts in the current hour; this counter contains your account ID and is deleted after two days at the latest (Art. 6(1)(f) GDPR).

4.3 Chat inside a game room

Messages inside a running game room are processed ephemerally — they exist only in server memory for the duration of the session and are discarded once the match ends. These messages are not written to the database – except when a player is reported (see below). Legal basis: Art. 6(1)(b) and (f) GDPR.

An automatic word filter replaces insults and similar expressions in the chat with asterisks before the message reaches others; nothing is stored in the process. Muting a player only takes effect in your browser and is saved there (localStorage); we are not informed.

If you report a player, we store the report in our database: the reason and your optional text, account ID (if any) and player name of you and of the reported player, game room, mode, time and, as evidence, up to the last ten chat messages of the reported player from that match (unfiltered). Purpose: enforcing the rules of use and protecting other players. Only we as the operator can see the report; the reported player is not told who reported them. Legal basis: Art. 6(1)(f) GDPR. Retention: 6 months from receipt of the report. If a report leads to a ban, the chat excerpt may be included as the reason in the ban record; 4.11 then applies to it.

4.4 Direct messages between friends

Private messages between befriended accounts are — unlike the chat inside a game room — stored in our database: sender, recipient, message text and timestamp. The text is stored in plaintext; the messages are not end-to-end encrypted. People with administrative database access can technically read them. Messages older than 7 days are deleted; the deletion is triggered when the next message is sent, so individual messages may persist slightly longer if a conversation goes quiet. Legal basis: Art. 6(1)(b) GDPR.

4.5 Friendships, invitations and block lists

We store friend requests and confirmed friendships (both account IDs, status, timestamp), lobby invitations (both account IDs, room, timestamp) and the accounts you have blocked (both account IDs, timestamp). Purpose: friends list, invitations and protection against unwanted contact. Legal basis: Art. 6(1)(b) and (f) GDPR. Retention: until removed by the parties involved, at the latest until the account is deleted.

4.6 Online status

While you are signed in we store the time of your last activity (“last seen”) for your account. It is visible only to you, to your confirmed friends (friend list: “online” or “last online”) and to us as the operator; it is not public. Legal basis: Art. 6(1)(f) GDPR. Retention: until the account is deleted.

4.7 Player statistics and match history

After each match we store the result (mode, duration, winning team, win condition, room ID) and, per participant, faction, team, result, tiles captured, remaining troops and the rating before and after the match. From this we maintain per-account statistics (wins, losses, forfeits, rating, streaks, matches played, last played). The per-account statistics are publicly readable, because the leaderboard is built on them. The per-match history is not public — only you (your own participations) and we as the operator can see it; the landing page shows nothing from it but totals across all matches of the last 24 hours. Legal basis: Art. 6(1)(b) GDPR. Retention: until the account is deleted.

4.8 In-game currency, items and season pass

Per account we store the gold balance including the time of the last weekly grant, the unlocked items (“skins”) with their timestamp, and the season pass state (season, experience points, premium status, claimed tiers). Equipped skins are visible to the other players in the same match. Legal basis: Art. 6(1)(b) GDPR. Retention: until the account is deleted.

For the skill tree we store per account the account experience points and the number of rated matches, the unlocked nodes of the skill tree and the saved loadouts including the name you gave them. This data is readable only by your own account. Legal basis: Art. 6(1)(b) GDPR. Retention: until the account is deleted.

4.9 Newsletter

When you sign up for the newsletter on the website we store your email address, the time of sign-up and the IP address used (proof of sign-up, abuse prevention). If you sign up from your profile page, we store account ID, email address and timestamp. Legal basis: Art. 6(1)(a) GDPR; consent can be withdrawn at any time. Retention: until withdrawal (sign-up IP: deleted 6 months after sign-up).

4.10 Support tickets

When you contact support we store your request, our team’s replies and the associated account details. Legal basis: Art. 6(1)(b) and (f) GDPR. Retention: 2 years after the ticket is closed.

4.11 Violations and bans

If an account is banned we store the account ID, nickname and email address of the banned account, the administrator account issuing the ban, the reason, duration, expiry and timestamp. Purpose: enforcing the rules of use and keeping moderation decisions traceable. Legal basis: Art. 6(1)(f) GDPR. Retention: 3 years from the date of the ban entry.

4.12 Post-match feedback

If you fill in the form shown after a match, we store your account ID, match ID, mode, the ratings you gave and your free-text notes on bugs, wishes and suggestions. Legal basis: Art. 6(1)(f) GDPR (improving the game). Retention: 12 months from submission.

4.13 Profile picture

If you upload your own profile picture, it is stored in a bucket that is publicly readable: anyone who knows the file URL can retrieve it without signing in. Only your own account can write or delete it. Preset profile pictures are not uploaded; they are served statically. Legal basis: Art. 6(1)(b) GDPR. Retention: until you replace or delete it, or until the account is deleted.

4.14 AI assistant (chat bubble)

The chat bubble on the website is answered by an AI language model. For this, your input and the conversation so far are transmitted to and processed by Anthropic PBC, San Francisco, USA. Please do not enter personal data into this field that you do not wish to transmit. In addition, to limit abuse we store the IP address of the request together with a per-minute counter in our database; stale counters are removed on the next request from the same IP address. Legal basis: Art. 6(1)(f) GDPR (providing the help function, abuse prevention). Use is voluntary.

4.15 Trailer (YouTube)

The trailer video is hosted on YouTube. Loading our page establishes no connection to Google: the preview image is served from our own server. Only when you click the preview image is the player loaded from youtube-nocookie.com. At that point Google Ireland Limited / Google LLC, USA receives your IP address and further details about your browser, and may set cookies. Legal basis: Art. 6(1)(a) GDPR — the embed happens only on your explicit click. Google’s privacy policy: policies.google.com/privacy

4.16 Server log files

When you access the website, our hosting provider automatically processes technical data: IP address, date and time, requested URL, user agent, referrer. Retention: maximum 30 days. Legal basis: Art. 6(1)(f) GDPR (IT security).

4.17 Cookies and analytics

We use strictly necessary cookies and comparable browser storage only (sign-in session, language, colour scheme) on the basis of Art. 6(1)(f) GDPR and § 165(3) Austrian TKG 2021. No consent is required for these.

For displaying the app interface we additionally store:

• the cookie fr_app (value “1”, lifetime one year): it records that Front-Risk was started as an installed app, so that the home page shows the app interface there directly. In a normal browser tab it is deleted again;
• in the browser's session storage (sessionStorage) the flags fr_app_sitzung (this tab is in the app – “back” from a match leads to the app menu instead of the website), fr_app_einstieg (start page already seen in this session) and fr_app_intro (start animation already shown in this session). They are deleted when the tab or the app is closed.

These entries contain no identifier and are not used for statistics or recognition; they are strictly necessary to display the app interface (Art. 6(1)(f) GDPR and § 165(3) Austrian TKG 2021).

So that next time you do not have to wonder whether you signed in with your email address or one of the sign-in methods from 4.1, we store the flag fr_letzter_anmeldeweg in your browser’s local storage after a successful sign-in. It contains only the name of the method (e.g. “google”), no email address and no identifier, is not sent to us and is used solely to show “Last used” on the matching button; no expiry, can be deleted via your browser settings. While a sign-in through a provider is in progress, the chosen method is briefly kept in session storage (fr_anmeldeweg_versuch, with the time of the attempt) so that it is only taken over once the sign-in succeeds; deleted when taken over or when the tab is closed, invalid after ten minutes.

We do not use any analytics, audience-measurement or marketing tools. Your usage behaviour on the website is not analysed. In the game we only count totals of how matches are left, without linking them to your account (see 4.18). For the same reason there is no consent banner on this site: there would be nothing to consent to.

4.18 Statistics on leaving matches

To find out where matches are too hard or unclear, our game server counts when and how matches are left. Only weekly totals are stored, without account, name, IP address, time of day or match ID: calendar week, game mode, whether it was one of your first three matches or a guest session, the time played in coarse steps, the way the match was left (e.g. match ended, surrender, connection lost) and a rough game situation in the minute before (e.g. city lost, purchase declined for lack of money, no game command for a longer time).

To determine whether it is one of your first three matches, the server reads the number of matches you have played when you join and keeps only this classification while you are in the game room. Nothing is stored in or read from your browser for this, no third parties are involved, and the totals are not public. In weeks with very few matches a total could in theory be linked to the public match results (4.7); we do not carry out any such matching and only evaluate totals of five cases or more.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in improving the game). Your rights under section 8 apply; as the totals are not linked to any account, we cannot single out individual entries (Art. 11 GDPR). Retention: 180 days.

4.19 Creator verification (optional)

Purpose. If you verify your own Twitch or YouTube channel, we mark your player name with a badge and a link to your channel. If you wish, you can take your channel name as your player name and have it protected against imitation. We re-check the requirements (at least 11 followers or subscribers) regularly.

Legal bases. The public link between channel and player name is based on your consent (Art. 6(1)(a) GDPR), which you give before the check; it requires you to be at least 14 years old. You can withdraw it at any time in your account (“Remove creator link”); this does not affect the lawfulness of processing before the withdrawal. The check and re-checks serve to provide the feature you requested (Art. 6(1)(b) GDPR). We keep the log of name changes on the basis of our legitimate interest in resolving disputes about player names (Art. 6(1)(f) GDPR).

Data stored. Platform, the channel ID at the provider, channel name (for YouTube the handle, e.g. “@channel”), channel address, follower or subscriber count at the last check, times of check, consent and removal, your chosen main platform and, if applicable, your reserved name. For Twitch only, additionally a refresh key for the monthly re-check, stored encrypted and without permissions on your Twitch account; it is deleted when you disconnect the app on Twitch or the badge ends. We receive neither your Twitch or Google password nor an email address from Twitch or Google.

Publicly visible are the platform, the channel name and the channel address next to your player name (game, leaderboard, forum, friend lists, profile).

Sources and recipients. For Twitch you sign in to Twitch Interactive, Inc. (USA) for the check; we then read your channel ID, login name and follower count via the Twitch interface. For YouTube we only read public channel information (description, handle, subscriber count) via the YouTube API Services of Google; you do not sign in to Google for this. Google’s privacy policy applies to processing by Google (policies.google.com/privacy). Twitch and Google are based or have their group headquarters in the USA; the transfer relies on the EU-US Data Privacy Framework (Art. 45 GDPR), see section 6.

People affected by a name change. If your player name is reserved for a verified creator, we store your previous and your new player name, the time and your account ID in the log.

Retention. Channel data for as long as the badge exists; information from the YouTube interface is refreshed or deleted at least every 30 days. After withdrawal or removal we delete the channel data after 30 days. We delete the log after 12 months. If you delete your account, we remove your channel data immediately and anonymise your entries in the log (your ID and names attributable only to you are removed).

To limit the check requests we send to YouTube, we count each account’s requests per day; this counter contains your account ID and is deleted once the day has ended, at the latest on the following day (Art. 6(1)(f) GDPR).

5. Processors and Recipients

The following services process data on our behalf pursuant to Art. 28 GDPR:

• Website hosting: Vercel Inc., USA
• Game server hosting: Fly.io (Fly Services Inc.), USA — the server instances run in the Frankfurt am Main region
• Database, authentication and file storage: Supabase Inc., USA — project region: eu-central-1 (Frankfurt am Main)
• Email delivery (newsletter, support, ban notices): Resend (Plus Five Five, Inc.), USA
• AI assistant in the chat bubble: Anthropic PBC, USA (see 4.14)
• Video player after clicking the trailer: Google Ireland Limited / Google LLC (see 4.15) — embedded only after your click
• Protection against automated accounts: Cloudflare, Inc., USA (Turnstile, see 4.1) — as a processor for the check itself; as an independent controller for improving its bot detection

6. Transfers to Third Countries

The services that store personal data permanently do so within the EU: the game servers run on Fly.io in Frankfurt am Main, and the database, authentication and file storage sit with Supabase in the eu-central-1 region (also Frankfurt am Main). This has to be distinguished from the providers’ place of establishment: both companies are based in the USA. That alone is what raises the question of a third country transfer, even though the data does not physically leave the EU.

Where data is transferred to providers outside the EEA (e.g. USA), such transfers rely on the EU-US Data Privacy Framework or the Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR. An adequate level of protection is ensured contractually. Which of these bases applies to each provider listed in section 5, and where the corresponding data processing agreement was concluded, still has to be documented individually: ⟨per provider, still to be filled in⟩.

Cloudflare (Turnstile, see 4.1) processes the check signals in the USA. Cloudflare, Inc. is certified under the EU-US Data Privacy Framework; in addition, Cloudflare has included Standard Contractual Clauses pursuant to Art. 46(2)(c) GDPR in its data processing terms (cloudflare.com/trust-hub/gdpr).

7. Retention Periods

We store personal data only for as long as necessary to achieve the respective purpose or as required by statutory retention obligations. Once the purpose ceases to apply, the data is deleted or anonymised.

8. Your Rights as a Data Subject

You have the following rights:

• Right of access (Art. 15 GDPR)
• Right to rectification (Art. 16 GDPR)
• Right to erasure / “right to be forgotten” (Art. 17 GDPR)
• Right to restriction of processing (Art. 18 GDPR)
• Right to data portability (Art. 20 GDPR)
• Right to object (Art. 21 GDPR)
• Right to withdraw consent (Art. 7(3) GDPR)

Right to object: Where we process data on the basis of legitimate interests (Art. 6(1)(f) GDPR), you may object to this processing at any time on grounds relating to your particular situation (Art. 21 GDPR). We will then no longer process the data unless there are compelling legitimate grounds or the processing serves the establishment, exercise or defence of legal claims.

To exercise these rights, please contact us using the address listed above.

9. Right to Lodge a Complaint

You have the right to lodge a complaint with a data protection supervisory authority. In Austria:
Austrian Data Protection Authority
Barichgasse 40–42, 1030 Vienna
Phone: +43 1 52 152-0
Email: dsb@dsb.gv.at
Web: www.dsb.gv.at

10. Data Security

We employ technical and organisational measures (TOMs) in accordance with Art. 32 GDPR, in particular TLS encryption of data transfers, password hashing, access restrictions and regular security reviews.

11. Minors

Our service is not directed at children under the age of 14 (§ 4(4) DSG in conjunction with Art. 8 GDPR). If we become aware that a minor has created an account without parental consent, we will delete the account.

12. Changes to this Policy

We reserve the right to update this privacy policy whenever new features or changes in the legal landscape make this necessary. The current version is always available on this page.