Skip to content
Shards of Dawn
Draft. This document is not final yet. The parts in square brackets are still to be filled in, and the whole text is waiting for a lawyer's review.

Privacy Policy — "Odłamki Świtu"

Effective from: [DATA WEJŚCIA W ŻYCIE] · Version: 1.0 · Wersja polska

In short

1. Who is the controller of your data

The controller of your personal data is [IMIĘ I NAZWISKO OPERATORA], [ADRES], e-mail: [E-MAIL KONTAKTOWY] ("we", "the operator"). We run the game "Odłamki Świtu" at https://shardsofdawn.com (the "Game").

We have not appointed a data protection officer, because at this scale of processing one is not required. For any data matter, write to the address above.

2. Where your data comes from

Most data you give us yourself: your e-mail and password when you register, your character name, your messages. Some data is created as you play: progress, items, trade history. Some data your browser sends automatically: your IP address and browser details. Other players may also tell us about your character, for example in a report.

3. What data we process

3.1 Account

3.2 Character and gameplay

3.3 Friends and guilds

3.4 Messages

3.5 Trading

3.6 Moderation

3.7 Technical data

3.8 Correspondence

If you write to us: your e-mail address, the content of your message, and the data needed to handle it.

3.9 What we do not collect

Your name, date of birth, address, phone number, device location, payment data, or special categories of data (e.g. health or beliefs). Please do not put them in chat or in your character's name.

PurposeDataLegal basis (GDPR)Retention
Creating the account and providing the Game: login, character, gameplay, chat, friends, guilds, trades, auctions, duels§3.1–3.5Art. 6(1)(b) — contract (the terms of service)Until the account is deleted, i.e. 14 days after you ask for its deletion (§9). Accounts unused for [24 months] are deleted after prior notice.
Keeping you logged insession token hashArt. 6(1)(b)Until you log out, log in on another device, or after 30 days of inactivity
Password reset at your request: sending a link to set a new passwordthe account's e-mail, hash of the one-time linkArt. 6(1)(b)The link works for one hour and only once; its hash is gone after use, after a new request, or with the account
E-mail address confirmation: a link after registration and after an address change, a notice to the current address about a change request, a "you already have an account" message on a registration with an address that has an accountthe account's e-mail and the new address, hash of the one-time linkArt. 6(1)(b); Art. 6(1)(f) — account securityThe link works for 24 hours and only once; its hash is gone after use, after a new request, or with the account. An account whose address nobody confirmed is deleted 7 days after registration
Chat messages (all channels)§3.4Art. 6(1)(b) (delivery), Art. 6(1)(f) (moderation)90 days from sending; longer only for a message under an open report
Investigating trade scams, detecting botstrade and auction logArt. 6(1)(f) — legitimate interest: fair play and protecting players12 months from the event, also after account deletion
Moderation, reports and appeals, enforcing the terms§3.6, reported contentArt. 6(1)(f); Art. 6(1)(c) for obligations under the Digital Services Act (DSA)12 months after the case is closed or the sanction ends; longer only during an ongoing dispute
Security: protection against password guessing, spam and attacksIP, e-mail at loginArt. 6(1)(f) — security of the serviceCounters: 15 minutes to 1 hour
Server logsIP, browser, time, requested addressArt. 6(1)(f)Overwritten automatically, usually after a few days to two weeks
Backupsthe whole game databaseArt. 6(1)(f) and Art. 32 GDPR30 days
Handling data requests, complaints and correspondence§3.8Art. 6(1)(c) (GDPR obligations), Art. 6(1)(f)12 months after the matter is closed
Establishing, exercising or defending legal claimsdata needed in the specific caseArt. 6(1)(f)Until the matter ends

We do not process data on the basis of consent and do not send marketing messages.

Providing an e-mail address and a password is required to create an account — you cannot play without them. All other data arises during play.

Live notifications (a new message, an invitation, other players moving) pass through our notification server, which does not store them. Each notification reaches only the people it concerns.

5. Who can access your data

The game server belongs to the operator and is located in Poland; we do not use third-party hosting. We do not sell data or pass it to advertisers.

6. Transfers outside the European Economic Area

Cloudflare, Inc. is based in the USA and may also process data there. The transfer relies on the European Commission's adequacy decision under the EU-U.S. Data Privacy Framework (Cloudflare is a listed participant) and, in addition, on the standard contractual clauses included in Cloudflare's data processing agreement. You can obtain a copy of the safeguards by writing to [E-MAIL KONTAKTOWY].

7. Browser storage and cookies

The Game stores in your browser's localStorage only what is strictly necessary for the Game you asked to use. That is why we do not ask for consent (Article 399 of the Polish Electronic Communications Law), but we tell you what it is:

NameWhat it isWhyHow long
flutter.margolatro.tokensession tokenso you do not have to log in after every page reloaduntil you log out or the session expires
flutter.margolatro.zoom.map.2, flutter.margolatro.zoom.worldyour chosen map zoomremembers your setting; never sent to the serveruntil you clear browser data

We do not use cookies or any analytics, advertising or tracking tools. Cloudflare may set technical security cookies (e.g. __cf_bm, cf_clearance) when it needs to tell humans from bots. The administration panel, used only by staff, uses a session cookie.

You can delete this data in your browser settings. Deleting the token logs you out.

8. Your rights

You have the right to:

We reply without undue delay and within one month at the latest; for complex requests we may extend this by two months and will tell you so. To make sure we are talking to the account owner, please write from the e-mail address linked to the account or make the request in the Game while logged in. We do not ask for scans of ID documents.

9. What happens when you delete your account

10. Children

You may create an account if you are at least [MINIMALNY WIEK] years old. You confirm your age when registering. If we learn that an account belongs to a younger person, we will delete it. A parent or guardian who believes their child has created an account can write to [E-MAIL KONTAKTOWY].

11. Security

We store passwords only as hashes and session tokens only as token hashes. The connection to the Game is encrypted (HTTPS). Login is protected against password guessing, only authorised people can access the administration panel, and backups are accessible only to the operator. We never ask for your password — neither in chat nor by e-mail. If someone asks for it pretending to be us, report it.

If a personal data breach occurs that may put your rights at risk, we will notify you and the supervisory authority as required by the GDPR.

12. Automated decisions

We do not make decisions about you based solely on automated processing that produce legal effects or similarly significantly affect you. The only automated measures are short-lived limits that protect the Game: at most 5 messages per 10 seconds, and a limit on login and registration attempts. Every moderation decision is made by a human.

13. Changes to this policy

We will announce changes in the Game in advance. The current version is always available at https://shardsofdawn.com/prywatnosc-en.html; its date and version number are at the top of the document.

14. Contact

[IMIĘ I NAZWISKO OPERATORA], [ADRES], [E-MAIL KONTAKTOWY].