Legal

Embershroud Game Privacy Policy

Version 1.10 - Last updated: 1 September 2026 (added authenticated leaderboard relationship indicators and their account-level cross-character disclosure). When this notice changes, the new version and date appear here with a summary of what changed; earlier versions remain available on request. This is an information notice, not a contract - continued play is never treated as consent.

This notice covers the Embershroud game client and its online service. It does not cover this marketing website (see the website privacy policy), the wiki, our Discord, or the store platforms, each of which has its own policy.

Embershroud is an online game: your characters, items, and progress live on our servers, not on your device. Playing it therefore requires processing some personal data. We keep that to what the game needs, our gameplay analytics run on our own servers in the EU rather than through advertising companies, and we do not sell personal data. Ever.

This notice applies wherever you play. Because Iterative Studios AB is established in Sweden, the GDPR applies to personal data processed in the context of that establishment regardless of where the player lives. You therefore have the GDPR rights described below, and additional or stronger local rights may also apply where you live.

Who is responsible

The data controller is:

Iterative Studios AB (registered in Sweden)
Organisation number: 559392-0605
Privacy contact: [email protected] - or the contact form

We have not appointed a formal data protection officer; the privacy contact above handles all data protection matters.

What we collect and why

Account and sign-in - required

You sign in through the platform you play on - Steam on PC, and Google Play Games or Apple Game Center on mobile when those versions are available. We receive from the platform and store your platform identifier (for example your Steam ID) and platform display name, and we generate an internal account ID and session tokens. We never see or store your platform password. Without this data an account cannot exist, so it is required to play. Legal basis: performance of our contract with you (GDPR Art. 6(1)(b)).

Signing in with an email address. You can also create an account, or add an email address to an existing one, using your email address and a one-time code we send to it. There is no password: we ask for a six-digit code instead, which is valid for ten minutes, accepts a limited number of attempts, and is discarded from our authentication systems as soon as it is used or expires. The email carrying the code is delivered by our email provider and follows its retention, described under "Who else is involved". We store the email address itself for as long as it is linked to your account, and use it to sign you in, to let you recover access if you lose your platform login, and to contact you about your account when we must. Using an email address is optional in the sense that you may sign in by platform instead - but if you choose this method, the address is required for it to work. Legal basis: performance of our contract with you (Art. 6(1)(b)). You can change the address in your profile at any time, and you can ask us to remove it entirely - see "Your rights" (if it is your only way to sign in, we help you link another first so you are not locked out).

Your device identifier. Whichever way you sign in, the game generates a random identifier, stores it on your device, and stores it with your account. It is generated by us, not read from your hardware, and we use it to recognise the device, sign you in, and support the client-integrity checks described under "Technical and connection data". It is deleted with your account. On some platforms you can also start playing with only this identifier, before any platform or email sign-in: in that case it is the only key to the account until you link one, so losing the device without linking means losing access - the game tells you this. Legal basis: performance of our contract with you (Art. 6(1)(b)); our legitimate interest in a secure and fair service (Art. 6(1)(f)) for the integrity part.

Gameplay and account state - required

We store the gameplay and account-state data needed to provide, secure, support, and improve the game: characters and their names, levels, items, crafting history, combat reports, achievements, leaderboard entries, guild and social relationships, chat messages, settings, and records of which terms version you accepted. High-volume live combat streams are processed transiently to run and display fights and are not retained as such - what persists is the resulting game state and summary reports. An online game cannot function without server-side state, so this is required. Legal basis: contract performance (Art. 6(1)(b)).

Technical and connection data - required

When you connect we process your IP address, approximate region derived from it, your client version and platform, connection timestamps, and crash or error diagnostics. We use these to run the service, route your connection, fix problems, prevent abuse, and enforce the terms of service. The game also uses server-side validation and client integrity measures to detect tampering, unauthorized clients, and automation. Legal basis: our legitimate interest in a secure, functioning, and fair service (Art. 6(1)(f)) - specifically protecting accounts and infrastructure, preventing fraud, bots, RMT and exploits, and maintaining fair competition.

Moderation and enforcement

When content or an account is reported, or our integrity systems flag something, we process the report, the evidence it points at (such as the reported message or name), and the resulting decision. Enforcement decisions against your account - warnings, restrictions, suspensions, bans, and forced changes - are recorded: what was decided, the rule category, when it applies, who or what decided it, and the statement of reasons you receive with its case reference. Chat filtering itself is automatic and immediate (a rejected message simply is not delivered); it creates no case record unless it escalates into a decision against your account. We use these records to act on reports, keep enforcement consistent and explainable, handle your appeal, and defend the decision if it is challenged. Legal bases: our legitimate interest in a safe and fair service and in explainable enforcement (Art. 6(1)(f)); legal obligation (Art. 6(1)(c)) for the statement-of-reasons and notice content EU platform law requires. If you delete your account, the decision record survives under a pseudonym so the case can still be resolved - your case reference remains usable - but it no longer names your account. How long these records are kept is described under "How long we keep it".

Purchases - required for purchases

Payments are handled by the Store Platform, which may be the merchant of record depending on the platform and region; we do not receive your full card or bank details. We receive and store transaction records (such as order identifiers, what was bought, when, refunds, and chargebacks), together with purchased and earned Cinder balances and relevant spend history. We use them to deliver purchases, apply the proportionate corrections described in the terms, investigate payment fraud, meet accounting duties, and resolve refunds, disputes, or outstanding purchased-value claims after account deletion. We retain only the transaction and claim evidence needed for those purposes. After account deletion, a purchased-value claim record contains only the amount claimed or owed, the relevant Store Platform order references, relevant dates, and claim status; it carries no account or contact identifier and is matched only when the player supplies a corresponding receipt. Legal bases: contract performance (Art. 6(1)(b)); legal obligation (Art. 6(1)(c)) for statutory accounting; legitimate interest (Art. 6(1)(f)) for fraud prevention and for settling or defending claims.

Gameplay analytics

We record gameplay events linked to your account - for example session start and end, level-ups, deaths and combat outcomes, crafting and economy events, and feature usage - together with your platform and game version, to balance the game, find bugs, decide what to improve, and compare seasons year over year. Our gameplay analytics are operated by us, on our own infrastructure in the EU: they are never used for advertising, never sold, and no third-party analytics service is involved. Where a platform or infrastructure provider necessarily sees limited connection or diagnostic data, that is described under "Who else is involved" below. Legal basis: our legitimate interest in operating, balancing, and improving the game (Art. 6(1)(f)).

You can object at any time, and we always honour it: if you object, we stop collecting gameplay analytics for your account and delete the analytics already collected. Email [email protected]. Objecting never affects your ability to play.

Hardware details are separate and off by default. Device hardware specifications - such as device model, graphics card, processor, and screen resolution - are collected only if you say yes to the optional hardware question the game asks once at first launch, and you can change your answer at any time in the game's settings. Legal basis for that stream: your consent (Art. 6(1)(a)), which you can withdraw as easily as you gave it.

Active-player counting (legal duty)

EU law (the Digital Services Act, Art. 24(3)) requires us to tell the authorities, on request, the average number of monthly active players our service has in the EU. So that we can answer, we record a pseudonymised monthly token derived from your account when you are exposed to public chat, together with a momentary check of whether your connection is from the EU. The token is deleted once the month's count is successfully finalised; if a month's close fails, its tokens are kept only until the close is recovered and completed. Only aggregate monthly totals are kept after that. Legal basis: compliance with a legal obligation (Art. 6(1)(c)).

Support - when you contact us

If you contact us, we process what you send (such as your email address and message) to help you. Legal basis: contract performance where your request concerns your account or purchases (Art. 6(1)(b)); otherwise our legitimate interest in supporting players (Art. 6(1)(f)); legal obligation or legal claims where a dispute requires it.

Optional data

Some data is only processed if you opt in, and declining never blocks ordinary play: a push notification token (mobile versions, when live - disabling notifications stops only the notifications) and rewarded-ad data (mobile only, if offered - see "Mobile versions" below).

Product news by email. If you give us an email address, you may separately choose to receive occasional news about the game. This is a distinct choice from the address itself: the box is never pre-ticked, ticking it is never a condition of signing in or of anything else, and leaving it unticked has no effect on your account. Sign-in codes and other messages we must send about your account are not marketing and are sent regardless. Legal basis: your consent (Art. 6(1)(a)). You can withdraw consent at any time via the unsubscribe link in any such email or by contacting us, and withdrawing is as easy as giving it; withdrawal does not affect messages already sent. If you change your email address, the opt-in resets and we ask again rather than carrying your answer over to a new address.

Automated decisions

Automated systems may detect suspicious activity, filter chat, flag reports, or apply an urgent temporary restriction pending review. We review such restrictions without undue delay. The notice names the automation and the rule involved. We do not permanently ban an account or make another decision with similarly significant effects on you by solely automated means: a person reviews major enforcement decisions, and you can contest any enforcement action via the contact form (see the terms, section 5).

What other players can see

Embershroud is a shared world. Other players can see your character and display names, your presence in zones, and - where those features are available - your achievements, leaderboard entries, guild membership, shared build blueprints, and messages you send in chat channels. Where Social relationship features are available, the service resolves account-level relationship capability for the characters listed on an authenticated player's leaderboard page so the row menu can show Add Friend when a friend request may be sent or Request Sent when that player already has an outgoing request. Other relationship states show no relationship action. Because the capability applies to the account rather than only the displayed character, seeing Request Sent on separately named characters may reveal that they belong to the same account. Chat sent to a channel is visible to that channel and may be reviewed when reported. The terms permit players to record, publish, and monetize ordinary gameplay, so footage may incidentally show the character or display names, public profile details, guild membership, presence, or channel messages visible through the recording player's client. That permission does not give another player rights to extract or reuse your User Content or personal data outside the gameplay context. Once another player lawfully publishes footage through a third-party service, we do not control that copy and cannot remove it through an Embershroud account-erasure request; you may contact the publisher or hosting service about its copy. Shared blueprints show the build and its author name. In-game privacy settings control profile visibility where the feature provides them; you can report and block other players where those tools are available. Chat is moderated: messages may be automatically filtered, and reported content is reviewed for rule and law violations. If you report something, we do not reveal your identity to the player you reported; where the law requires it or an authority needs it, a report's details - including who reported - may be disclosed to authorities. If you delete your account, your public traces are removed or irreversibly anonymised, except copies other players already legitimately received or published (such as an imported blueprint or permitted gameplay footage) - and except legitimate results on the in-game leaderboards, which keep their competitive outcome under a pseudonymous marker as described under "How long we keep it". Results may instead be removed or invalidated under the competition rules where cheating or another integrity violation affected them.

Who else is involved

Processors working under our instructions (bound by data processing agreements):

Hetzner Online GmbH and OVHcloud - game servers, databases, and backups, in European Union data centers. Your game data lives here: the playtest environment runs on Hetzner, and the production environment runs on OVHcloud.
Cloudflare - network security and traffic routing between your client and our servers; it processes connection metadata (such as IP addresses) to deliver that service.
Resend - delivery of the emails we send you, such as sign-in codes and, if you opted in, product news. It processes your email address and the content of those messages (sign-in codes included) in order to deliver them, and retains sent-message content and delivery metadata for a short period under its processor terms.

Independent controllers - services with their own privacy policies that process your data for their own purposes when you use them:

Valve (Steam), and on mobile Apple and Google - platform sign-in, store purchases, refunds, achievements, and platform features. We receive from them the account and transaction data described above; what they process on their side is governed by their policies.

Other recipients: professional advisers (such as accountants and lawyers) where needed; authorities where the law requires disclosure; and, if Iterative Studios is ever part of a merger, financing, or sale, a prospective or successor business - under confidentiality, with safeguards, and with notice where the law requires it. We also disclose data to establish or defend legal claims. We do not sell personal data.

Where data lives and international transfers

Primary storage and processing happen in the European Union. Where a provider processes data outside the EU - for example Cloudflare's global network or US-based platform providers - transfers rely on an EU adequacy decision (including the EU-US Data Privacy Framework, where the specific recipient is certified under it) or on the EU Commission's standard contractual clauses, with supplementary measures where required. You can ask us for information about, or a copy of, the safeguards used for a specific transfer.

How long we keep it

Account, identity, and gameplay records: kept while your account exists or while needed to provide the relevant feature. After deletion, we erase or irreversibly anonymise them without undue delay, except for the limited records described below or data another player or third-party service controls. Short-lived sign-in codes are discarded when used or expired; the email address and marketing choice are removed when no longer linked to an account.
Chat, moderation, support, and rights records: routine chat expires after 90 days. Content-rich moderation evidence is normally kept for up to six months after the case outcome; the smaller typed decision record is normally kept for up to 24 months from the later of the outcome and the restriction's end. A record may remain longer while a restriction, appeal, concrete legal claim, or legally required hold remains active. Support correspondence is normally kept for 12 months after closure, and the minimal receipt showing how a rights request was handled for 24 months.
Transactions and Cinder: accounting records are kept for the period required by law. Other purchase, refund, chargeback, balance, spend, and purchased-value claim evidence is kept only while needed for fraud prevention, settlement, or an applicable claim period.
Security, operational records, and backups: logs expire on a short fixed rolling window set for incident detection and troubleshooting. Encrypted backups are overwritten through the recovery cycle, currently within 90 days, and are not used to restore a deleted account. Pseudonymised active-player tokens last only until the relevant count is finalised; aggregate totals may remain.
Analytics: account-linked gameplay analytics are kept for no more than two years so current versions and seasons can be compared and faults investigated, and are deleted earlier when you delete your account or object. Long-term trends are retained only in aggregated or anonymised form.
Competitive and contract records: every legitimate leaderboard result - including a current, temporary, seasonal, or completed board - may remain for as long as that competition history is maintained. If you delete your account, your name and other identifying details are removed and the result is held under a random marker created at deletion, with no stored link back to your account. Account deletion does not void a result, promote another player, or move a reward; a result may be removed or invalidated where cheating or another competition-integrity violation affected it. Legal basis: our legitimate interest in a fair and stable competitive history for all players (Art. 6(1)(f)). Terms-acceptance evidence is kept with your account and is deleted with it.

We keep data beyond these periods only where a legal obligation, fraud prevention, an open dispute, or the protection of others requires it, and only for as long as that reason applies. Connection and security logs are not held beyond their fixed rotation merely for an ordinary fraud, dispute, investigation, or protection purpose. We preserve them longer only where law compels that preservation, and only for as long as the legal requirement applies.

Your rights

Under the GDPR you may ask to access, correct, delete, restrict, object to, or receive a portable copy of your personal data, withdraw consent, or contest certain automated decisions. These rights arise under Articles 15-22, and consent may be withdrawn under Article 7(3). Some rights have legal limits - for example, we cannot erase records we must keep for accounting, fraud prevention, or an open dispute. Objections to gameplay analytics are always honoured (see "Gameplay analytics"); objections to other processing based on legitimate interest, such as security and moderation, are assessed individually. To protect your account we may need to verify your identity before acting. Requests are free, although the GDPR permits a reasonable charge or refusal for a manifestly unfounded or excessive request. We answer without undue delay and normally within one month; the GDPR permits an extension of up to two further months for a complex request or multiple requests, and if we extend the time we tell you within the first month and explain why. Additional or stronger rights, shorter deadlines, or other remedies may apply where you live. You can also delete your account from within the game's account management. If you believe we are mishandling your data you may lodge a complaint with your local privacy authority; our lead authority is the Swedish Authority for Privacy Protection (IMY, imy.se).

Send requests to [email protected].

Children and young players

You must be at least 13 years old to play. Where local law requires parental authorisation for an optional consent-based feature, we obtain it or leave that feature off. Being old enough to play is not the same as being old enough to enter contracts or make purchases on your own: the terms explain when a parent or guardian must be involved, and purchases by minors follow the store platform's parental controls and applicable law. The game includes chat and other social features; reporting and blocking tools are available where those features exist, and we encourage parents to use the platform's family tools. We do not knowingly collect personal data from children below the permitted age, we do not profile children for advertising, and if we learn we hold such data we delete it. Parents or guardians can contact us at [email protected] about a child's data.

Mobile versions (when live, iOS/Android)

The mobile versions will add two optional features, each off unless you enable it:

Push notifications - delivered through Apple (APNs) and Google (FCM) using a device token, controlled by an opt-in setting with separate treatment for service messages and promotional ones.
Rewarded ads - if offered, shown only when you actively choose to watch one, and declining never blocks ordinary gameplay. Before any ad functionality goes live we will update this notice with the ad partner's identity, the data involved, the consent mechanism, and how minors are protected - and no ad SDK will collect data before that update and your consent.

The PC version contains no ads and no ad-related processing.

Security

The service is server-authoritative; connections are encrypted in transit; production access follows least-privilege access controls with logging and monitoring; and backups support recovery. No online service can promise absolute security, but limiting what we collect in the first place is our primary safeguard. If a breach ever puts your rights at risk, we will notify you and the supervisory authority as the law requires.

If you report a security vulnerability through our security route, we use the report to investigate and fix the problem and, where required, meet EU product-security reporting duties. We process the reporter's email and chosen report content under our legitimate interest in product and player security (GDPR Art. 6(1)(f)) and, where a report becomes legally reportable, under our legal obligation (Art. 6(1)(c)). The email thread is kept while the report is handled and for up to 12 months after closure. A separate technical case record that does not name the reporter is kept for up to 24 months after closure. The security page names the processors, authority recipients, minimisation rules, and rights route.

Changes to this notice

We will update this notice as the game evolves - for example before the mobile versions add push notifications or rewarded ads. Material changes are announced in the game and on this site with a plain-language summary, and the version and date above are updated. Where a change relies on your consent, we ask for it - continued play alone is never treated as consent.

Contact

[email protected] - or the contact form. We respond to all data-rights requests in accordance with applicable law.

Digital Services Act contact point (Articles 11 and 12): for authorities, including the Digital Services Coordinator and the European Commission, and for players and other recipients of the service, our single point of contact is [email protected]. You can write in English or Swedish. Messages are read by a person; this channel is not solely automated.