Last updated: [DATE]
⚠️ Template — replace bracketed placeholders and have a privacy lawyer review, especially for GDPR (EU/UK) and US state privacy laws. If you process EU users' data you likely need a lawful basis analysis, a DPA with processors, and possibly a representative.
[COMPANY NAME], [ADDRESS] — contact [CONTACT EMAIL].
| Data | Purpose | Retention |
|---|---|---|
| IP address | Connecting you, country display, rate limiting, ban enforcement, abuse prevention | For the session; banned IPs kept until the ban is lifted |
| Approximate country (derived from IP) | Shown to your battle opponent; matchmaking statistics | For the session |
| Camera frames (≈1 per second during a live battle) | AI judging of shown items; automated content moderation | In memory only; deleted within minutes of the battle ending — except frames from reported or moderation-flagged battles, which are preserved as evidence (up to [1 year] where required, e.g. for NCMEC reports under 18 U.S.C. §2258A) |
| Battle metadata (battle ID, timestamps, verdicts, report reasons) | Operating the Service, moderation, statistics | [90 days] |
| Terms-acceptance timestamp (stored in your browser) | Remembering that you accepted the age gate and Terms | Until you clear your browser storage |
Your live video/audio stream travels directly to your opponent's device (or through a relay server we operate, which forwards encrypted packets without storing them). We do not record the live stream. Only the sampled frames described above reach our servers. Because connections are peer-to-peer, your IP address may be technically observable by your opponent's device.
International transfers are safeguarded by [SCCs / DPF — complete with counsel].
Depending on where you live you may have rights to access, correct, delete, or port your data, and to object to or restrict processing. Contact [CONTACT EMAIL]. You may also complain to your supervisory authority. Note that most battle data is deleted automatically within minutes; preserved abuse evidence may be exempt from deletion requests where retention is legally required.
The Service is strictly 18+. We do not knowingly process children's data. If we become aware of a minor using the Service we terminate the session, ban the user, and preserve and report evidence where legally required.
All traffic is encrypted in transit (HTTPS/WSS; WebRTC media is encrypted with DTLS-SRTP). Frames are held in server memory, not written to disk, except for preserved abuse evidence, which is access-restricted.
Material changes will be announced on the Service.