Legal

Embershroud Game Privacy Policy

Version 1.0 - Last updated: 13 July 2026. 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. The rights described below follow EU/EEA data protection law (the GDPR), which we apply as our baseline worldwide; depending on where you live, additional local rights may apply, and we will honour them.

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)).

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, device model and operating system, client version, 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.

Purchases - required for purchases

All payments are handled by the store platform, which is the merchant of record - we never receive your card or bank details. We store the transaction records the platform sends us (transaction IDs, what was bought, when, refunds and chargebacks) together with your premium currency (Cinder) balance and spend history, so we can deliver what you bought, process the platform's refund notifications (including the balance adjustments described in the terms), investigate payment fraud, and keep the accounting records the law requires. Legal bases: contract performance (Art. 6(1)(b)); legal obligation (Art. 6(1)(c)) for records that form part of our statutory accounting; legitimate interest (Art. 6(1)(f)) for fraud prevention.

Gameplay analytics

We record gameplay events - sessions, progression milestones, feature usage, economy events, deaths and combat outcomes - to balance the game, find bugs, and understand what is and is not working. We do not use third-party advertising or profiling analytics for gameplay: our gameplay analytics are operated by us, on our infrastructure in the EU, and are not used for advertising. Where a platform or infrastructure provider necessarily sees limited connection or diagnostic data, that is described under "Who else is involved" below. Legal basis: legitimate interest in operating and improving the game (Art. 6(1)(f)). You may object at any time (see "Your rights"); objections are assessed individually rather than auto-rejected.

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).

Automated decisions

Automated systems may detect suspicious activity, filter chat, or flag reports for review. 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 4).

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. Chat sent to a channel is visible to that channel and may be reviewed when reported. 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 delete your account, your public traces are removed or irreversibly anonymised, except copies other players already legitimately received (such as a blueprint they imported).

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.

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 and gameplay data: for as long as your account exists. If you delete your account, personal data is erased or irreversibly anonymised, normally within 30 days.
Backups: expire on a fixed rotation of at most 90 days and are not used to restore deleted accounts.
Routine chat: kept up to 90 days, unless a message is reported or needed for safety or legal claims - then kept until the case and any appeal are closed.
Moderation, enforcement, and fraud records: kept as long as needed to handle appeals, prevent repeat abuse, and defend legal claims, then deleted.
Connection and security logs: kept up to 90 days, unless an incident or fraud investigation requires longer.
Support correspondence: kept for a period after the ticket closes, longer where a purchase or dispute requires it.
Transaction records: kept for the legally required accounting period - in Sweden generally seven years after the end of the relevant financial year - for the records that form part of our statutory accounting.
Analytics: account-linked events are erased or anonymised on account deletion; long-term balancing history is kept in aggregated or anonymised form.
Terms acceptance records: kept as evidence for as long as claims under the contract could arise.

We keep data beyond these periods only where a legal obligation, fraud prevention, an open dispute, or the protection of others requires it.

Your rights

Under the GDPR you can ask us at any time to access the personal data we hold about you (Art. 15), correct it (Art. 16), erase it (Art. 17), restrict its processing (Art. 18), receive the data you provided in a portable format (Art. 20, where processing is based on contract or consent and carried out by automated means), or object to processing based on legitimate interest (Art. 21). Where processing is based on consent you may withdraw it at any time (Art. 7(3)). Some rights have legal limits - for example, we cannot erase records we must keep for accounting, fraud prevention, or an open dispute, and an objection triggers an individual assessment rather than automatic deletion. To protect your account we may need to verify your identity before acting. Requests are free (unless manifestly unfounded or excessive) and answered within one month, extendable where the law allows for complex requests. 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 supervisory authority; ours 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 - or older where your country sets a higher minimum age for consenting to information-society services. 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.

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.