Privacy policy

1. Data we process

We process the bare minimum needed to make the game work:

• Account data: email address and the Director name chosen by the user.
• Game data: career, progress, Credit transactions, settings and language.
• Technical data: IP address, device and browser type, access and security logs, session identifiers.
• Source (attribution) data: campaign parameters (UTM), advertising click identifiers (ttclid, fbclid, gclid), city or variant of the page visited, any invite code. Advertising data is stored only with your consent to marketing.
• Purchase data: product, amount, outcome and transaction identifier. Card details are processed directly by the payment provider and are not disclosed to us in full.
• Communications: the messages you send to support.
• Content shared with other players: board posts and replies, alliance chat messages, alliance name and description, reports made and received, blocks of other players, acceptance of the Community rules (version and date).
• Director card and presence: level, municipality of the game headquarters (not your residence), active services, alliance and role; the on-duty state and a coarse last-seen indication (today, this week), visible to allies only and switchable off.

2. Purposes and legal bases

We process data for the following purposes:

• Providing the game, authenticating you with a one-time code by email, saving progress, managing purchases and bonuses — performance of the contract (Art. 6(1)(b) GDPR).
• Security, prevention of fraud and abuse (including in the referral programme), defence of legal rights — legitimate interest (Art. 6(1)(f)).
• Accounting and tax obligations relating to purchases — legal obligation (Art. 6(1)(c)).
• Site usage statistics and measurement of advertising campaigns via cookies and pixels — consent (Art. 6(1)(a)), which can be withdrawn at any time from “Cookie preferences”.
• Promotional communications by email — consent, optional and revocable via the link included in every message.

3. Recipients and data processors

Data is processed by authorised personnel and by providers acting as data processors under a contract pursuant to Art. 28 GDPR:

• Hosting and cloud infrastructure provider: [HOSTING PROVIDER].
• Transactional email provider (access codes, receipts): [EMAIL PROVIDER].
• Stripe Payments Europe Ltd. — payment processing (also acts as an independent controller for its own obligations).
• Analytics and advertising providers, only with consent: Google Ireland Ltd. (Google Analytics), TikTok Technology Ltd. (TikTok Pixel), Meta Platforms Ireland Ltd. (Meta Pixel).
• Rewarded video provider, if enabled: [AD PROVIDER].
• Content protection and delivery (CDN) provider: [CDN PROVIDER].

4. Transfers outside the European Economic Area

Some providers may process data in countries outside the EEA. In that case the transfer takes place on the basis of an adequacy decision (e.g. the EU-U.S. Data Privacy Framework) or the standard contractual clauses approved by the European Commission.

5. Retention periods

We keep data for as long as necessary for the purposes stated:

• Account and game data: until the account is deleted; accounts inactive for more than 24 months are deleted after advance notice by email.
• One-time access codes: a few minutes; the related security logs for up to 90 days.
• Technical and security logs: up to 12 months.
• Attribution data: up to 25 months in a form linked to the account, then aggregated.
• Accounting data on purchases: 10 years, as required by law.
• Support requests: up to 24 months after closure.
• Chat messages: 90 days. Board posts and replies: as long as the alliance exists and 30 days after removal.
• Reports, decisions and sanctions, with the copy of the reported content: 12 months from the closing of the case. Blocks, Director card and acceptance of the Rules: as long as the account exists.
• On account deletion: game data erased and account anonymised within 7 days of the request; the text of shared content erased within the following 30 days.

6. Your rights

You may at any time exercise the rights provided for in Articles 15–22 GDPR: access, rectification, erasure, restriction, portability, objection to processing based on legitimate interest, and withdrawal of consent, without affecting the lawfulness of prior processing.

Write to [PRIVACY EMAIL]: we reply within one month. You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali, www.garanteprivacy.it) or with the authority of your country of residence.

7. Minors

The Service is reserved for those aged 14 or over. We do not knowingly collect data from children under 14; if we become aware of it, we delete the account. No personalised advertising is shown to minors.

From 14 years on you may write on boards and in chats. As we do not know the users' age, the same protections apply to everybody: text only, no private messages, automatic filter, one-tap report and block, no age information shown or inferable, the municipality of the game headquarters instead of the residence, on-duty state visible to allies only and switchable off, message notifications off by default. The Community rules are written to be understood by a fourteen-year-old and by a parent.

8. Security and automated decisions

We adopt appropriate technical and organisational measures: encryption in transit, access codes stored only in non-reversible form, administrative access with multi-factor authentication, audit logs.

Anti-fraud checks may automatically flag anomalous behaviour; decisions affecting the account (e.g. cancellation of a bonus) can always be reviewed by a person at your request.

9. Changes

We may update this notice. Significant changes are communicated by email or in the game.

10. Content between players and moderation

The texts you publish in an alliance are visible to its members; the Director's name and the alliance name to every registered player. The Service administration reads conversations only from a report or from a notice of the automatic filter, and every access is logged. There is no free reading of chats.

The automatic filter is a check of words and patterns, not a final decision: what it blocks or flags is reviewed by a person on request. Sanctions are decided by a person and can always be contested (Terms, §15). Legal bases: performance of the contract for the board and chat to work; legitimate interest of the Controller and of the other users for moderation, safety and the protection of minors; legal obligation for the reports the law requires us to handle.