Privacy notice
Pontar Online. Version of .
In short
- Who is responsible: Jordan Aquilina and Gary Aquilina from Malta. Contact: pontaronline@gmail.com.
- What we store: your Discord id and display name, your Steam id once you link a Steam account, the date and time you confirmed that you are an adult, your characters and what they do in the game world, and a record of sign-ins, of each start of the game and of staff actions.
- Why: to run your account and the game, and to keep the game fair and secure.
- What we do not store: your e-mail address, any password, any Discord token, any payment detail. We sell nothing, show no advertising and build no profiles.
- Adults only: this server is for people aged 18 and over.
- Your rights: you can get a copy of what is stored about you, and you can have it erased. In our Discord server, use
/mydataand/forgetme, or write to pontaronline@gmail.com.
1. Who is responsible
Jordan Aquilina and Gary Aquilina from Malta run this server together as private persons and decide together how your data is used. You can reach both through pontaronline@gmail.com, and you can use your rights with either of them.
2. Where the data comes from
- From Discord. When you sign in, when you use one of our commands in our Discord server, or when staff use one about you (a ban, for example), we receive your Discord id and your display name. At sign-in, and then every few seconds while our staff tools run, we also read from Discord who is a member of our server and which of its roles each member holds, to end the access of whoever leaves or loses the player role and to know who is staff. We read nothing else. The access token Discord gives us at sign-in is used only for this; we then ask Discord to revoke it at once, and we never store it.
- From Steam, when you link your Steam account: your Steam id. We then ask Steam whether that account owns the game.
- From you and your play: everything else below.
3. What we store, why, and for how long
| What | Why | Legal basis | Kept |
|---|---|---|---|
| Your account: Discord id and display name, when the account was made, when you last signed in, when your access was last ended, your play time, and whether you have had your starter kit | To know who you are and give you your characters | Contract (GDPR art. 6(1)(b)): we cannot run your account without it | Until you ask for erasure |
| Your Steam id (a linked Steam account is needed to play here), and when you linked it | So that one Steam account belongs to one player, against evasion of bans, and to check that you own the game | Our legitimate interest in a fair game (art. 6(1)(f)) | Until staff unlink it at your request, or you ask for erasure. A note of each link and unlink, with the Steam id, stays in the record of sign-ins and staff actions for that record's term |
| The date and time you confirmed that you are 18 or older | This server is for adults only | Our legitimate interest in keeping minors out (art. 6(1)(f)) | Until you ask for erasure |
| Your characters: names, looks, place in the world, belongings, in-game money, skills, offices and standing | To run the game world | Contract (art. 6(1)(b)) | Until you ask for erasure |
| Records of what your characters do, and of what characters do to one another: the history of each purse, deaths, searches, arrests and sentences, trades, and the like | To run the game world and settle disputes between players | Contract (art. 6(1)(b)) | Item and experience logs: 90 days. Searches: one year. The rest: until you ask for erasure; what you share with another player then stays as a bare number without your name |
| The money watch: a second, tamper-evident ledger of every movement of crowns | To find cheating and duplication | Our legitimate interest in a fair game (art. 6(1)(f)) | Single lines 30 days, daily sums six months; after that one running total for each character remains. Lines marked for review one year. While a fault in this ledger is being looked into, nothing is deleted from it, nor from the record of searches |
| The record of sign-ins and sign-outs, of each start of the game, of changes to your characters (made, renamed, deleted), of Steam links, of your age confirmation, of your requests for a copy or for erasure, of what you do with permadeath tickets, and of staff actions, including each time staff look up your account or end your access; with your display name at each sign-in and a keyed hash of your internet address | Security, and so that staff answer for what they do | Our legitimate interest in a secure, accountable service (art. 6(1)(f)) | 365 days |
| Bans and appeals: the reason, the dates, what you wrote in an appeal, the decision | To enforce the rules | Our legitimate interest in enforcing the rules (art. 6(1)(f)) | Until you ask for erasure. A ban in force is kept until it ends (a permanent ban: for good), with the Discord and Steam ids it is tied to |
| Permadeath tickets: what you wrote as evidence, and the decision | To administer a rule of the game | Contract (art. 6(1)(b)) | Until you ask for erasure |
| Notices: messages the game or staff leave for you (the decision on an appeal, for example) | To tell you what happened while you were away | Contract (art. 6(1)(b)) | Until you have been given them and they are 30 days old |
| Sessions: a hash of your sign-in token | To keep you signed in | Contract (art. 6(1)(b)) | 24 hours |
Your internet address is never stored in full in our database: the record of sign-ins holds a keyed hash of it, which lets us see that two sign-ins came from the same place. The web server's logs hold your address cut down to its network, together with what your browser or launcher says about itself: its access log for 14 days, its error log for 30 days.
Chat is passed to the players near you and is not stored in the database. When staff switch on chat logging to look into rule-breaking, chat lines are written to the server's log and kept 30 days.
Technical logs of the servers (character names, account numbers, hashed addresses) are kept 30 days on the server. Backups of the database are kept 14 days on the server. Our hosting company keeps its own daily copies of the whole machine for us, each for about a week. Copies we take off the server ourselves are encrypted, and we keep none longer than 30 days.
Staff channels on Discord: our staff tools post to channels of our Discord server that are closed to players: bans and their reasons, appeals, permadeath tickets and notable in-game events, with account numbers, display names, character names and, when staff unlink a Steam account, its Steam id. These messages stay until they are deleted; when you ask for erasure, the owners delete the ones about you by hand.
The legal basis for these logs, backups and staff messages is our legitimate interest in a secure, working and fairly run service (art. 6(1)(f)).
4. Who else receives your data
- Our staff: the moderators and admins of our Discord server see, through the staff tools, what they need for their work: your account number, display name and Steam id, your characters, bans, the game's records, and the latest entries about you in the record of sign-ins and staff actions.
- Our hosting company: Hetzner Online GmbH, Germany. It runs the machine for us under a data processing agreement and does not use your data for anything of its own. The data is stored in that country.
- Discord: you sign in with your Discord account, our staff tools run inside our Discord server, they can send you a direct message there (for example, the decision on an appeal), and the copy of your data that
/mydatagives you reaches you through Discord. For people in the European Economic Area, Discord Netherlands B.V. is responsible for Discord's own handling of your data; Discord Inc. in the United States is certified under the EU-U.S. Data Privacy Framework. - Valve (Steam), when you link your Steam account: you sign in at Steam yourself. We send your Steam id to Steam to ask whether the account owns the game. Valve Corporation in the United States is certified under the EU-U.S. Data Privacy Framework.
- People and services that help us maintain the software: when we ask them to look into a fault, they see technical logs (character names and account numbers, no Discord or Steam ids). Some of them are outside the European Union; they receive such a log for that purpose only, under terms that hold them to the European Union's data protection standards (an adequacy decision of the European Commission, or its standard contractual clauses).
Nobody else. We do not sell your data, and we do not send it outside the European Union ourselves, apart from what is said above.
5. Your rights
You have the right to:
- a copy of what is stored about you. In our Discord server,
/mydatasends it to you as a file, once a day; the file itself lists the few things it leaves out, and why; - correction of anything that is wrong;
- erasure. In our Discord server,
/forgetmeasks for it. It is carried out 27 days later (after an outage of our service or a restore of our database, up to two days after that), unless you take it back before then with/forgetme cancel:true; we may carry it out sooner, and if the law gives us a reason not to carry it out, we tell you the reason. Your account and characters are stripped of everything that says who you are; your belongings and in-game money are removed from the world; records you share with other players stay as bare numbers without your name. If you are banned at that moment, the ban, its reason, any appeal and the Discord and Steam ids it is tied to are kept until the ban ends. If you were one of our staff, the record of what you did as staff is kept for its term, under your account number and without your name. Copies in backups and in the servers' logs disappear within 37 days. Erasure cannot be undone; - restriction of what we do with your data while a question about it is open;
- your data in a machine-readable form (the copy is a zip file that holds your data as JSON, with a short guide).
You can also write to pontaronline@gmail.com for any of these. We answer within one month, free of charge.
Your right to object. Where this notice says "legitimate interest", you can object at any time, for reasons that have to do with your own situation. We then stop, unless we have compelling reasons to go on (for example, a ban that must hold).
Your right to complain. If you think we handle your data wrongly, you can complain to the data protection authority: in Malta, the Office of the Information and Data Protection Commissioner, Floor 2, Airways House, Triq Il-Kbira, Tas-Sliema SLM 1549, https://idpc.org.mt/. You can also complain to the authority of the country you live in.
6. Do you have to give us this data?
You do not have to, but without signing in through Discord, linking a Steam account and confirming that you are an adult you cannot play here: we need to know which account and which characters are yours.
7. No automated decisions
No decision about you is made by a machine alone. The money watch marks unusual movements for the owners to look at; a person decides what follows. A few things happen by themselves, by fixed rules of the service or of the game and not by any judgment about you: if you leave our Discord server or lose the player role there, your access ends; a request for erasure is carried out when its waiting time is over; a ban ends when its time is up; a Steam account that does not own the game cannot be linked; a Steam account that is already linked to another account cannot be linked; and the game applies its own rules (a vault whose rent stays unpaid is closed, for example).
8. Adults only
This server is for people aged 18 and over. The first time you sign in, we ask you to confirm it, and we store when you did. If we learn that someone is under 18, we ban the account and erase what is stored about it; the ban, and the Discord and Steam ids it is tied to, are kept for as long as the ban stands, so that it holds.
9. Changes
When the text of this notice changes, the date at the top changes, and we say so in the launcher's news. The names, the contact address and the terms shown are always the ones in force.