Privacy Policy and Data Protection Manifesto
Effective Date: July 6, 2026
Fightlunes Production sro takes its data protection responsibilities seriously. This Privacy Policy outlines our protocols regarding the collection, processing, security, storage, and erasure of personal data acquired through your interaction with our browser-based MMOTRPG.
Our operations are aligned with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), the Czech Act on Personal Data Processing, and associated European digital privacy standards.
Article I: Data Controller and Structural Contact
- Corporate Entity: Fightlunes Production sro
- Registration Number: 29689830
- Registered Office: Čenětická 2413/1a, Chodov, 149 00 Prague, Czech Republic
- Legal Inquiries: legal@fightlunes.cz
Article II: Categories of Personal Data Processed
2.1 Account and Registration Data
- Valid, verifiable email addresses
- Usernames and character names
- Cryptographically hashed and salted passwords
- Language settings and regional localization preferences
2.2 Financial, KYC, and Transactional Data
Inbound Purchases: Records of fiat transactions (EUR, GBP, USD), timestamps, amounts, payment method, and billing identifiers. The Company does not store primary account numbers (PANs) or CVV codes; cardholder data is processed via PCI-DSS compliant third-party gateways.
Outbound Withdrawals: Legal names, physical addresses, bank account numbers (IBAN/BIC), digital wallet information, and KYC verification documents.
2.3 Gameplay and Technical Telemetry
- IP addresses, browser type/version, OS, hardware specifications, referrer headers
- Game-state telemetry logs, Denarii/Aureus expenditure, Arena combat inputs, Auction House ledger activities
- Public and private in-game chat logs with timestamps and recipient identifiers
Article III: Legal Bases and Purposes of Processing
| Data Category | Purpose of Processing | GDPR Legal Basis |
|---|---|---|
| Account Data, Game Telemetry | Provision of the Game, save progress, core mechanics | Art. 6(1)(b): Performance of a Contract |
| Transaction History, Billing Data | Payments for Denarii/Aureus and real-money payouts | Art. 6(1)(b) / Art. 6(1)(c): Legal Obligation |
| KYC Documentation, Identity Checks | Prevent fraud, money laundering, tax compliance | Art. 6(1)(c): Legal Obligation |
| IP Addresses, Behavioral Logs, UI Cookie Preferences | Detect cheating, botting, DDoS; preserve layout preferences | Art. 6(1)(f): Legitimate Interests |
| Analytical Cookies, Performance Metrics | Server latency, platform performance, browser diagnostics | Art. 6(1)(a): User Consent (Opt-In) |
Article IV: Data Retention Schedules
Core Account and Gameplay Logs: Retained for the duration of the account’s active lifespan. Inactive accounts (24 consecutive months) will be purged or anonymized, subject to financial holding requirements.
Financial Ledgers and KYC Documents: Retained for a minimum of ten (10) years following the fiscal year of the transaction.
Article V: Data Sharing and Cross-Border Transfers
The Company does not sell, lease, or monetize your personal information. Data sharing is confined to:
- Payment infrastructure providers within the EEA
- Cloud infrastructure providers located entirely within the EU (EEA)
- Competent administrative, tax, or law enforcement bodies when legally mandated
Article VI: Data Subject Rights Under the GDPR
Under Articles 15–22 of the GDPR, you have the right of access, rectification, erasure (“right to be forgotten”), restriction of processing, data portability, and to object to automated profiling or legitimate-interest processing.
Submit formal inquiries to our registered address in Prague or via our data management portal. Complaints may be lodged with:
Czech Office for Personal Data Protection (ÚOOÚ) — Pplk. Sochora 27, 170 00 Prague 7, Czech Republic. Web: www.uoou.cz
Article VII: Amendments to This Policy
We may revise this Privacy Policy periodically. Material updates will be notified via our core interface or email 30 days prior. Continued use constitutes acknowledgement of the updated Privacy Policy.
Article VIII: Governing Law and Litigation Disputes
This Policy shall be governed exclusively by the laws of the Czech Republic. Prior to formal proceedings, submit complaints in writing to the Company’s legal department. Amicable settlement window: 60 calendar days.