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# Terminal Insanity: CodeJacker: **Privacy Policy**
**Last Updated:** December 2025
**Ongakken Corporation OÜ** ("Company") respects the privacy of all users and is committed to protecting personal data. This Privacy Policy explains how the Company collects, uses, discloses, and safeguards information when users access Terminal Insanity: CodeJacker (the "Game") and related services.
This Privacy Policy applies to users in all jurisdictions, including the European Union (GDPR), California (CCPA), and the United States (COPPA). The Company has designed this policy to comply with applicable data protection laws in all regions where the Game is available.
---
## 1. Data Controller
The data controller responsible for personal data is:
**Ongakken Corporation OÜ**
**Kalaranna 8/2-30, 10415, Tallinn, Estonia**
Email: **cj@ongakken.com**
For GDPR purposes, the Company is the controller of the personal data it collects, except where the Company processes data on behalf of Valve Corporation (Steam), in which case Valve is the controller for that data.
---
## 2. Information the Company Collects
### 2.1 Account Data (via Steam)
When a user plays CodeJacker through Steam, the Company receives certain information from Valve Corporation:
- **Steam ID:** The user's unique 64-bit Steam identifier
- **Display Name:** The user's public Steam username
- **Avatar:** The user's Steam profile picture
- **Country/Region:** General geographic location (country level)
- **Friends List:** Only when using friend-related features (e.g., inviting friends to matches)
The Company does not have access to the user's Steam password, email address, payment information, and/or other sensitive account details held by Valve.
### 2.2 Gameplay Data
During gameplay, the Company collects:
- **Match Data:** Game mode, team assignments, match results, scores, round outcomes
- **In-Game Actions:** Cursor positions, code edits, use of game utilities (flashbang, smoke, etc.)
- **Voice Communications:** If the user uses in-game voice chat, audio data is transmitted to other players in real-time via Steam's voice relay infrastructure (subject to Valve's Privacy Policy). Voice data is not stored on Company servers after transmission during standard gameplay. **Exception:** During the Steam Playtest program, voice communications may be recorded and stored by the Company pursuant to Section 2.6 and EULA Section 6, to which Users expressly consent upon enrollment. Additionally, other players may independently record gameplay sessions, including voice communications (see Section 15.1).
- **Text Chat:** Messages sent through in-game chat
- **Leaderboard Data:** Scores and rankings the user achieves
- **Workshop Interactions:** Content the user subscribes to, uploads, and/or downloads
### 2.3 Technical Data
The Company automatically collects:
- **Device Information:** Operating system, hardware specifications, graphics card, available memory
- **Performance Data:** Frame rates, loading times, network latency
- **Crash Reports:** Via Sentry (see Section 6.2), including stack traces, error messages, and system state at the time of crash
- **Log Data:** Connection timestamps, session duration, IP addresses (for network functionality)
### 2.4 Telemetry Data (Opt-In Only)
If the user chooses to participate in the Company's telemetry program, the Company additionally collects:
- **Detailed Gameplay Analytics:** Button presses, navigation patterns, feature usage frequency
- **Behavioral Data:** How the user interacts with menus, tutorials, and game systems
- **Session Recordings:** Anonymized gameplay patterns for balancing purposes
**Participation in telemetry is entirely voluntary.** The user can enable and/or disable telemetry at any time through the Game's settings menu. The Company genuinely appreciates those who help improve CodeJacker.
### 2.5 Campaign Progress
The user's single-player campaign progress is stored:
- **Locally:** On the user's device in encrypted format
- **Steam Cloud:** If the user has Steam Cloud enabled, progress syncs across devices via Valve's infrastructure
### 2.6 Playtest Program Recordings
If the user participates in the Steam Playtest program, as described in Section 6 of the End User License Agreement, the Company may record the user's gameplay sessions and voice communications. These recordings are retained perpetually for promotional purposes as consented to upon enrollment.
---
## 3. How the Company Collects Information
| Collection Method | Data Types | User Control |
|-------------------|------------|--------------|
| **From Steam** | Account data, friends list | Managed via Steam settings |
| **Automatically during gameplay** | Match data, in-game actions, technical data | Necessary for game function |
| **Crash reporting (Sentry)** | Crash reports, error logs | Can be disabled in settings |
| **With user consent** | Telemetry data | Opt-in; toggle in settings |
| **Playtest enrollment** | Gameplay/voice recordings | Consent given upon enrollment |
---
## 4. Legal Basis for Processing (GDPR)
For users in the European Economic Area (EEA), United Kingdom, and Switzerland, the Company processes personal data on the following legal bases:
### 4.1 Contract Performance (Article 6(1)(b) GDPR)
Processing necessary to provide the Game and Services the user requested:
- Account authentication via Steam
- Multiplayer matchmaking and gameplay
- Leaderboard functionality
- Steam Cloud saves
### 4.2 Legitimate Interests (Article 6(1)(f) GDPR)
Processing necessary for the Company's legitimate business interests, balanced against user rights:
- Fraud prevention and anti-cheat measures
- Security monitoring and abuse prevention
- Game balancing and improvement based on aggregated data
- Crash reporting and bug fixes
### 4.3 Consent (Article 6(1)(a) GDPR)
Processing based on the user's explicit consent:
- Telemetry data collection (opt-in)
- Playtest recordings for promotional use
- Voice chat transmission to other players
The user may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
### 4.4 Legal Obligation (Article 6(1)(c) GDPR)
Processing necessary to comply with legal obligations:
- Tax reporting for prize winnings
- Responding to lawful government requests
---
## 5. How the Company Uses Information
The Company uses collected information to:
| Purpose | Data Used |
|---------|-----------|
| **Provide the Game** | Account data, gameplay data |
| **Enable multiplayer** | Steam ID, cursor positions, edits, voice |
| **Maintain leaderboards** | Steam ID, scores, rankings |
| **Improve game quality** | Crash reports, telemetry (if opted in) |
| **Prevent cheating** | Gameplay patterns, technical data |
| **Customer support** | Account data, match history |
| **Promotional materials** | Playtest recordings (with consent) |
| **Legal compliance** | As required by law |
The Company does **NOT** use user data for:
- Targeted advertising
- Selling to data brokers
- Profiling for purposes unrelated to the Game
---
## 6. Data Sharing
### 6.1 Valve Corporation (Steam)
The Game operates through Steam, and Valve processes data according to their own privacy policy. The Company shares:
- Match results (for achievements and stats)
- Leaderboard scores
- Workshop content metadata
**Valve-Operated Services:** Certain services are provided directly by Valve, and data processing for these services is governed by Valve's Privacy Policy, not this Privacy Policy:
- **Matchmaking:** Player connection and lobby services
- **Voice Chat Relay:** Voice communication transmitted through Steam's relay servers
- **Steam Cloud:** Cloud save data
- **Steam Workshop:** Workshop content hosting and distribution
- **Steam Networking:** Network relay and connection services
For data processed by Valve through these services, refer to Valve's Privacy Policy.
Valve's Privacy Policy: https://store.steampowered.com/privacy_agreement/
### 6.2 Sentry (Functional Software, Inc.)
The Company uses Sentry for crash reporting and error tracking. When crashes occur, Sentry receives:
- Error type and stack trace
- Device and OS information
- Game version and state
Sentry processes this data under Standard Contractual Clauses for EU data transfers.
Sentry's Privacy Policy: https://sentry.io/privacy/
### 6.3 Other Players
During multiplayer sessions, other players can see:
- The user's Steam display name
- The user's cursor position and in-game actions
- The user's team assignment
- The user's voice (if using voice chat)
### 6.4 No Sale of Personal Data
**The Company does not sell personal data.** The Company does not share personal data with third parties for any marketing purposes, whether such third party's own marketing, joint marketing, and/or any other marketing purpose.
### 6.5 Legal Disclosures
The Company may disclose user information if required by law, court order, and/or governmental authority, and/or if the Company believes disclosure is necessary to:
- Protect the Company's rights, property, and/or safety
- Prevent fraud and/or abuse
- Comply with legal process
---
## 7. International Data Transfers
### 7.1 Server Locations
The Company's game servers are located in **Germany (European Union)**. User gameplay data is primarily processed within the EU.
### 7.2 Valve Infrastructure
Steam's matchmaking, networking, and relay services are operated by Valve Corporation globally. For data processed by Valve, refer to Valve's Privacy Policy and their data processing practices.
### 7.3 Sentry (United States)
Sentry is based in the United States. For transfers of personal data from the EU to Sentry, the Company relies on Standard Contractual Clauses approved by the European Commission.
### 7.4 Safeguards
For any transfers of personal data outside the EEA, the Company ensures appropriate safeguards are in place, including:
- Standard Contractual Clauses (SCCs)
- Data processing agreements
- Technical security measures
---
## 8. Data Retention
The Company retains user data according to the following schedule:
| Data Type | Retention Period |
|-----------|------------------|
| **Personal data (Steam ID, username, match history)** | 2 years from last activity |
| **Leaderboard entries** | Indefinite (public scores) |
| **Anonymized/aggregated gameplay statistics** | Indefinite |
| **Crash reports** | 90 days |
| **Telemetry data** | 2 years, then anonymized |
| **Playtest recordings** | Perpetual (per EULA Section 6 consent) |
| **Steam Cloud saves** | User-controlled via Steam |
| **Campaign progress (local)** | Until the user deletes it |
After the retention period, personal data is either deleted and/or anonymized so it can no longer be associated with the user.
### 8.1 Anonymization
When the Company anonymizes data, the Company removes and/or irreversibly alters all identifiers so the data cannot reasonably be linked back to the user. Anonymized data is no longer considered personal data and may be retained indefinitely for research, analytics, and game improvement.
### 8.2 Account Deletion
If the user requests deletion of data and/or deletes the user's Steam account, the Company shall delete personal data within 30 days, except:
- Leaderboard entries (which display username only)
- Anonymized and/or aggregated data
- Data the Company is legally required to retain
- Playtest recordings (perpetual license per EULA)
---
## 9. User Rights
### 9.1 Rights for EU/EEA/UK Users (GDPR)
If the user is located in the European Economic Area, United Kingdom, and/or Switzerland, the user has the following rights:
| Right | Description |
|-------|-------------|
| **Access** | Request a copy of personal data |
| **Rectification** | Request correction of inaccurate data |
| **Erasure** | Request deletion of data ("right to be forgotten") |
| **Restriction** | Request limited processing of data |
| **Portability** | Receive data in a structured, machine-readable format |
| **Objection** | Object to processing based on legitimate interests |
| **Withdraw Consent** | Withdraw consent for consent-based processing |
| **Complaint** | Lodge a complaint with a supervisory authority |
To exercise these rights, contact the Company at **cj@ongakken.com**. The Company shall respond within 30 days.
### 9.2 Rights for California Residents (CCPA)
If the user is a California resident, the user has the following rights under the California Consumer Privacy Act:
| Right | Description |
|-------|-------------|
| **Know** | Request disclosure of personal information collected, used, and shared |
| **Delete** | Request deletion of personal information |
| **Opt-Out of Sale** | The Company does not sell personal information |
| **Non-Discrimination** | The Company shall not discriminate against users for exercising rights |
To exercise these rights, contact the Company at **cj@ongakken.com**.
**Verification:** The Company may need to verify the user's identity before processing requests. The Company shall use the user's Steam ID and associated email for verification.
### 9.3 Rights for Other Jurisdictions
Depending on the user's location, the user may have similar rights under local data protection laws. Contact the Company to inquire about specific rights.
---
## 10. Children's Privacy (COPPA Compliance)
### 10.1 Age Restriction
**CodeJacker is not intended for children under the age of 13.** The Company does not knowingly collect personal information from children under 13 years of age.
### 10.2 No Knowing Collection
The Company does not knowingly:
- Request and/or collect personal information from children under 13
- Allow children under 13 to register and/or use the Game
- Target marketing and/or advertising to children under 13
### 10.3 Parental Notice
If a parent and/or guardian believes their child under 13 has provided personal information to the Company, they should contact the Company immediately at **cj@ongakken.com**. The Company shall:
- Verify the claim
- Delete the child's personal information promptly
- Terminate any associated account access
### 10.4 Age Verification
The Company relies on Steam's age verification mechanisms. By using the Game, the user certifies that the user is at least 13 years of age.
---
## 11. Security Measures
The Company implements appropriate technical and organizational measures to protect personal data, including:
### 11.1 Technical Measures
- **Encryption:** Data encrypted in transit (TLS 1.3) and at rest
- **Access Controls:** Role-based access to personal data
- **Network Security:** Firewalls, intrusion detection, DDoS protection
- **Secure Development:** Regular security audits and code reviews
### 11.2 Organizational Measures
- **Limited Access:** Only authorized personnel can access personal data
- **Training:** Staff trained on data protection requirements
- **Incident Response:** Procedures for detecting and responding to data breaches
### 11.3 Breach Notification
In the event of a personal data breach that poses a risk to user rights, the Company shall:
- Notify the relevant supervisory authority within 72 hours (GDPR requirement)
- Notify affected users without undue delay if the breach poses a high risk
- Document the breach and remediation steps
---
## 12. Third-Party Links and Services
The Game may contain links to third-party websites and/or services (e.g., Steam Community, Workshop). The Company is not responsible for the privacy practices of these third parties. Users are encouraged to review their privacy policies before providing any personal information.
---
## 13. Changes to This Privacy Policy
The Company may update this Privacy Policy from time to time. Changes shall be effective when posted, and the Company shall update the "Last Updated" date at the top.
For material changes, the Company shall provide notice through:
- In-game notification
- Steam announcement
- Email (if the Company has the user's email address)
The user's continued use of the Game after changes constitutes acceptance of the updated Privacy Policy.
---
## 14. Contact the Company
If users have questions, concerns, and/or requests regarding this Privacy Policy and/or personal data, contact the Company:
**Ongakken Corporation OÜ**
**Kalaranna 8/2-30, 10415, Tallinn, Estonia**
Email: **cj@ongakken.com**
### 14.1 EU Representative
For users in the European Union, the Company's representative for GDPR purposes can be contacted at:
**Ongakken Corporation OÜ**
**Kalaranna 8/2-30, 10415, Tallinn, Estonia**
Email: **cj@ongakken.com**
### 14.2 Supervisory Authority
If the user is in the EU and believes the Company has not adequately addressed concerns, the user has the right to lodge a complaint with the local data protection supervisory authority.
For Germany: Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI)
Website: https://www.bfdi.bund.de/
---
## 15. Additional Information for Specific Features
### 15.1 Voice Chat and Public Communications
**PUBLIC COMMUNICATIONS DOCTRINE:** All voice communications, text communications, and visible player actions transmitted through the Game's multiplayer features are treated as public communications, analogous to unencrypted radio broadcast communications. The user has NO expectation of privacy in any multiplayer communication and/or action.
- Voice data is transmitted peer-to-peer and/or via Steam relay during gameplay
- **Voice chat relay is provided by Valve through Steam's infrastructure; voice data transmitted through Steam relay is subject to Valve's Privacy Policy**
- **Standard Gameplay (Non-Playtest):** Voice is not stored on Company servers after transmission during standard gameplay sessions
- **Steam Playtest Exception:** If the user participates in the Steam Playtest program, voice communications may be recorded and stored by the Company pursuant to Section 6 of the EULA and Section 2.6 of this Privacy Policy; the user expressly consents to such recording upon Playtest enrollment
- Other players in the user's match can hear the user's voice
- The user can mute themselves and/or other players at any time
- For questions regarding voice data handling by Steam relay, contact Valve through Steam Support
**Other Players May Record:** The user acknowledges and agrees that:
- All in-game communications and actions are public and carry no expectation of privacy
- Other players in the user's match may record, stream, and/or broadcast gameplay, including the user's voice communications, pursuant to Section 7 of the EULA
- The Company does not control and/or prevent other players from recording
- While the Company does not automatically record and/or store voice data on Company servers during standard gameplay, other players may independently choose to record their gameplay sessions, which may include the user's voice and/or in-game actions
- By using multiplayer features, the user waives privacy claims arising from observation and/or recording by other players
- If the user does not wish to be recorded by other players, the user should mute their microphone and/or refrain from using voice chat and/or multiplayer features
### 15.2 Steam Workshop
- Content the user uploads is governed by Steam's Workshop terms, policies, and guidelines
- Workshop Content shall comply with Valve's Steam Workshop policies and shall not contain material illegal in any jurisdiction where Steam Workshop is served
- The Company defers to Valve's policies regarding Workshop content compliance
- The Company receives metadata about subscriptions and uploads
- User-generated content is subject to the EULA licensing terms (see EULA Sections 4.6A, 4.7, 4.8, and 4.9)
- The user bears sole responsibility for Workshop Content they upload
### 15.3 Leaderboards
- Leaderboard entries are public
- The user's Steam display name and score are visible to all users
- Users cannot opt out of leaderboard display while participating in ranked play
### 15.4 Esports and Tournaments
- Official competitions may require additional data (real name, age verification, tax information for prizes)
- Tournament participation is governed by separate Competition Rules
- Match recordings from official tournaments may be used for broadcast and promotional purposes
---
*This Privacy Policy is effective as of December 2025.*
***Terminal Insanity: CodeJacker™** is a trademark of **Ongakken Corporation OÜ**. All rights reserved.*
**Last Updated:** December 2025
**Ongakken Corporation OÜ** ("Company") respects the privacy of all users and is committed to protecting personal data. This Privacy Policy explains how the Company collects, uses, discloses, and safeguards information when users access Terminal Insanity: CodeJacker (the "Game") and related services.
This Privacy Policy applies to users in all jurisdictions, including the European Union (GDPR), California (CCPA), and the United States (COPPA). The Company has designed this policy to comply with applicable data protection laws in all regions where the Game is available.
---
## 1. Data Controller
The data controller responsible for personal data is:
**Ongakken Corporation OÜ**
**Kalaranna 8/2-30, 10415, Tallinn, Estonia**
Email: **cj@ongakken.com**
For GDPR purposes, the Company is the controller of the personal data it collects, except where the Company processes data on behalf of Valve Corporation (Steam), in which case Valve is the controller for that data.
---
## 2. Information the Company Collects
### 2.1 Account Data (via Steam)
When a user plays CodeJacker through Steam, the Company receives certain information from Valve Corporation:
- **Steam ID:** The user's unique 64-bit Steam identifier
- **Display Name:** The user's public Steam username
- **Avatar:** The user's Steam profile picture
- **Country/Region:** General geographic location (country level)
- **Friends List:** Only when using friend-related features (e.g., inviting friends to matches)
The Company does not have access to the user's Steam password, email address, payment information, and/or other sensitive account details held by Valve.
### 2.2 Gameplay Data
During gameplay, the Company collects:
- **Match Data:** Game mode, team assignments, match results, scores, round outcomes
- **In-Game Actions:** Cursor positions, code edits, use of game utilities (flashbang, smoke, etc.)
- **Voice Communications:** If the user uses in-game voice chat, audio data is transmitted to other players in real-time via Steam's voice relay infrastructure (subject to Valve's Privacy Policy). Voice data is not stored on Company servers after transmission during standard gameplay. **Exception:** During the Steam Playtest program, voice communications may be recorded and stored by the Company pursuant to Section 2.6 and EULA Section 6, to which Users expressly consent upon enrollment. Additionally, other players may independently record gameplay sessions, including voice communications (see Section 15.1).
- **Text Chat:** Messages sent through in-game chat
- **Leaderboard Data:** Scores and rankings the user achieves
- **Workshop Interactions:** Content the user subscribes to, uploads, and/or downloads
### 2.3 Technical Data
The Company automatically collects:
- **Device Information:** Operating system, hardware specifications, graphics card, available memory
- **Performance Data:** Frame rates, loading times, network latency
- **Crash Reports:** Via Sentry (see Section 6.2), including stack traces, error messages, and system state at the time of crash
- **Log Data:** Connection timestamps, session duration, IP addresses (for network functionality)
### 2.4 Telemetry Data (Opt-In Only)
If the user chooses to participate in the Company's telemetry program, the Company additionally collects:
- **Detailed Gameplay Analytics:** Button presses, navigation patterns, feature usage frequency
- **Behavioral Data:** How the user interacts with menus, tutorials, and game systems
- **Session Recordings:** Anonymized gameplay patterns for balancing purposes
**Participation in telemetry is entirely voluntary.** The user can enable and/or disable telemetry at any time through the Game's settings menu. The Company genuinely appreciates those who help improve CodeJacker.
### 2.5 Campaign Progress
The user's single-player campaign progress is stored:
- **Locally:** On the user's device in encrypted format
- **Steam Cloud:** If the user has Steam Cloud enabled, progress syncs across devices via Valve's infrastructure
### 2.6 Playtest Program Recordings
If the user participates in the Steam Playtest program, as described in Section 6 of the End User License Agreement, the Company may record the user's gameplay sessions and voice communications. These recordings are retained perpetually for promotional purposes as consented to upon enrollment.
---
## 3. How the Company Collects Information
| Collection Method | Data Types | User Control |
|-------------------|------------|--------------|
| **From Steam** | Account data, friends list | Managed via Steam settings |
| **Automatically during gameplay** | Match data, in-game actions, technical data | Necessary for game function |
| **Crash reporting (Sentry)** | Crash reports, error logs | Can be disabled in settings |
| **With user consent** | Telemetry data | Opt-in; toggle in settings |
| **Playtest enrollment** | Gameplay/voice recordings | Consent given upon enrollment |
---
## 4. Legal Basis for Processing (GDPR)
For users in the European Economic Area (EEA), United Kingdom, and Switzerland, the Company processes personal data on the following legal bases:
### 4.1 Contract Performance (Article 6(1)(b) GDPR)
Processing necessary to provide the Game and Services the user requested:
- Account authentication via Steam
- Multiplayer matchmaking and gameplay
- Leaderboard functionality
- Steam Cloud saves
### 4.2 Legitimate Interests (Article 6(1)(f) GDPR)
Processing necessary for the Company's legitimate business interests, balanced against user rights:
- Fraud prevention and anti-cheat measures
- Security monitoring and abuse prevention
- Game balancing and improvement based on aggregated data
- Crash reporting and bug fixes
### 4.3 Consent (Article 6(1)(a) GDPR)
Processing based on the user's explicit consent:
- Telemetry data collection (opt-in)
- Playtest recordings for promotional use
- Voice chat transmission to other players
The user may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
### 4.4 Legal Obligation (Article 6(1)(c) GDPR)
Processing necessary to comply with legal obligations:
- Tax reporting for prize winnings
- Responding to lawful government requests
---
## 5. How the Company Uses Information
The Company uses collected information to:
| Purpose | Data Used |
|---------|-----------|
| **Provide the Game** | Account data, gameplay data |
| **Enable multiplayer** | Steam ID, cursor positions, edits, voice |
| **Maintain leaderboards** | Steam ID, scores, rankings |
| **Improve game quality** | Crash reports, telemetry (if opted in) |
| **Prevent cheating** | Gameplay patterns, technical data |
| **Customer support** | Account data, match history |
| **Promotional materials** | Playtest recordings (with consent) |
| **Legal compliance** | As required by law |
The Company does **NOT** use user data for:
- Targeted advertising
- Selling to data brokers
- Profiling for purposes unrelated to the Game
---
## 6. Data Sharing
### 6.1 Valve Corporation (Steam)
The Game operates through Steam, and Valve processes data according to their own privacy policy. The Company shares:
- Match results (for achievements and stats)
- Leaderboard scores
- Workshop content metadata
**Valve-Operated Services:** Certain services are provided directly by Valve, and data processing for these services is governed by Valve's Privacy Policy, not this Privacy Policy:
- **Matchmaking:** Player connection and lobby services
- **Voice Chat Relay:** Voice communication transmitted through Steam's relay servers
- **Steam Cloud:** Cloud save data
- **Steam Workshop:** Workshop content hosting and distribution
- **Steam Networking:** Network relay and connection services
For data processed by Valve through these services, refer to Valve's Privacy Policy.
Valve's Privacy Policy: https://store.steampowered.com/privacy_agreement/
### 6.2 Sentry (Functional Software, Inc.)
The Company uses Sentry for crash reporting and error tracking. When crashes occur, Sentry receives:
- Error type and stack trace
- Device and OS information
- Game version and state
Sentry processes this data under Standard Contractual Clauses for EU data transfers.
Sentry's Privacy Policy: https://sentry.io/privacy/
### 6.3 Other Players
During multiplayer sessions, other players can see:
- The user's Steam display name
- The user's cursor position and in-game actions
- The user's team assignment
- The user's voice (if using voice chat)
### 6.4 No Sale of Personal Data
**The Company does not sell personal data.** The Company does not share personal data with third parties for any marketing purposes, whether such third party's own marketing, joint marketing, and/or any other marketing purpose.
### 6.5 Legal Disclosures
The Company may disclose user information if required by law, court order, and/or governmental authority, and/or if the Company believes disclosure is necessary to:
- Protect the Company's rights, property, and/or safety
- Prevent fraud and/or abuse
- Comply with legal process
---
## 7. International Data Transfers
### 7.1 Server Locations
The Company's game servers are located in **Germany (European Union)**. User gameplay data is primarily processed within the EU.
### 7.2 Valve Infrastructure
Steam's matchmaking, networking, and relay services are operated by Valve Corporation globally. For data processed by Valve, refer to Valve's Privacy Policy and their data processing practices.
### 7.3 Sentry (United States)
Sentry is based in the United States. For transfers of personal data from the EU to Sentry, the Company relies on Standard Contractual Clauses approved by the European Commission.
### 7.4 Safeguards
For any transfers of personal data outside the EEA, the Company ensures appropriate safeguards are in place, including:
- Standard Contractual Clauses (SCCs)
- Data processing agreements
- Technical security measures
---
## 8. Data Retention
The Company retains user data according to the following schedule:
| Data Type | Retention Period |
|-----------|------------------|
| **Personal data (Steam ID, username, match history)** | 2 years from last activity |
| **Leaderboard entries** | Indefinite (public scores) |
| **Anonymized/aggregated gameplay statistics** | Indefinite |
| **Crash reports** | 90 days |
| **Telemetry data** | 2 years, then anonymized |
| **Playtest recordings** | Perpetual (per EULA Section 6 consent) |
| **Steam Cloud saves** | User-controlled via Steam |
| **Campaign progress (local)** | Until the user deletes it |
After the retention period, personal data is either deleted and/or anonymized so it can no longer be associated with the user.
### 8.1 Anonymization
When the Company anonymizes data, the Company removes and/or irreversibly alters all identifiers so the data cannot reasonably be linked back to the user. Anonymized data is no longer considered personal data and may be retained indefinitely for research, analytics, and game improvement.
### 8.2 Account Deletion
If the user requests deletion of data and/or deletes the user's Steam account, the Company shall delete personal data within 30 days, except:
- Leaderboard entries (which display username only)
- Anonymized and/or aggregated data
- Data the Company is legally required to retain
- Playtest recordings (perpetual license per EULA)
---
## 9. User Rights
### 9.1 Rights for EU/EEA/UK Users (GDPR)
If the user is located in the European Economic Area, United Kingdom, and/or Switzerland, the user has the following rights:
| Right | Description |
|-------|-------------|
| **Access** | Request a copy of personal data |
| **Rectification** | Request correction of inaccurate data |
| **Erasure** | Request deletion of data ("right to be forgotten") |
| **Restriction** | Request limited processing of data |
| **Portability** | Receive data in a structured, machine-readable format |
| **Objection** | Object to processing based on legitimate interests |
| **Withdraw Consent** | Withdraw consent for consent-based processing |
| **Complaint** | Lodge a complaint with a supervisory authority |
To exercise these rights, contact the Company at **cj@ongakken.com**. The Company shall respond within 30 days.
### 9.2 Rights for California Residents (CCPA)
If the user is a California resident, the user has the following rights under the California Consumer Privacy Act:
| Right | Description |
|-------|-------------|
| **Know** | Request disclosure of personal information collected, used, and shared |
| **Delete** | Request deletion of personal information |
| **Opt-Out of Sale** | The Company does not sell personal information |
| **Non-Discrimination** | The Company shall not discriminate against users for exercising rights |
To exercise these rights, contact the Company at **cj@ongakken.com**.
**Verification:** The Company may need to verify the user's identity before processing requests. The Company shall use the user's Steam ID and associated email for verification.
### 9.3 Rights for Other Jurisdictions
Depending on the user's location, the user may have similar rights under local data protection laws. Contact the Company to inquire about specific rights.
---
## 10. Children's Privacy (COPPA Compliance)
### 10.1 Age Restriction
**CodeJacker is not intended for children under the age of 13.** The Company does not knowingly collect personal information from children under 13 years of age.
### 10.2 No Knowing Collection
The Company does not knowingly:
- Request and/or collect personal information from children under 13
- Allow children under 13 to register and/or use the Game
- Target marketing and/or advertising to children under 13
### 10.3 Parental Notice
If a parent and/or guardian believes their child under 13 has provided personal information to the Company, they should contact the Company immediately at **cj@ongakken.com**. The Company shall:
- Verify the claim
- Delete the child's personal information promptly
- Terminate any associated account access
### 10.4 Age Verification
The Company relies on Steam's age verification mechanisms. By using the Game, the user certifies that the user is at least 13 years of age.
---
## 11. Security Measures
The Company implements appropriate technical and organizational measures to protect personal data, including:
### 11.1 Technical Measures
- **Encryption:** Data encrypted in transit (TLS 1.3) and at rest
- **Access Controls:** Role-based access to personal data
- **Network Security:** Firewalls, intrusion detection, DDoS protection
- **Secure Development:** Regular security audits and code reviews
### 11.2 Organizational Measures
- **Limited Access:** Only authorized personnel can access personal data
- **Training:** Staff trained on data protection requirements
- **Incident Response:** Procedures for detecting and responding to data breaches
### 11.3 Breach Notification
In the event of a personal data breach that poses a risk to user rights, the Company shall:
- Notify the relevant supervisory authority within 72 hours (GDPR requirement)
- Notify affected users without undue delay if the breach poses a high risk
- Document the breach and remediation steps
---
## 12. Third-Party Links and Services
The Game may contain links to third-party websites and/or services (e.g., Steam Community, Workshop). The Company is not responsible for the privacy practices of these third parties. Users are encouraged to review their privacy policies before providing any personal information.
---
## 13. Changes to This Privacy Policy
The Company may update this Privacy Policy from time to time. Changes shall be effective when posted, and the Company shall update the "Last Updated" date at the top.
For material changes, the Company shall provide notice through:
- In-game notification
- Steam announcement
- Email (if the Company has the user's email address)
The user's continued use of the Game after changes constitutes acceptance of the updated Privacy Policy.
---
## 14. Contact the Company
If users have questions, concerns, and/or requests regarding this Privacy Policy and/or personal data, contact the Company:
**Ongakken Corporation OÜ**
**Kalaranna 8/2-30, 10415, Tallinn, Estonia**
Email: **cj@ongakken.com**
### 14.1 EU Representative
For users in the European Union, the Company's representative for GDPR purposes can be contacted at:
**Ongakken Corporation OÜ**
**Kalaranna 8/2-30, 10415, Tallinn, Estonia**
Email: **cj@ongakken.com**
### 14.2 Supervisory Authority
If the user is in the EU and believes the Company has not adequately addressed concerns, the user has the right to lodge a complaint with the local data protection supervisory authority.
For Germany: Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI)
Website: https://www.bfdi.bund.de/
---
## 15. Additional Information for Specific Features
### 15.1 Voice Chat and Public Communications
**PUBLIC COMMUNICATIONS DOCTRINE:** All voice communications, text communications, and visible player actions transmitted through the Game's multiplayer features are treated as public communications, analogous to unencrypted radio broadcast communications. The user has NO expectation of privacy in any multiplayer communication and/or action.
- Voice data is transmitted peer-to-peer and/or via Steam relay during gameplay
- **Voice chat relay is provided by Valve through Steam's infrastructure; voice data transmitted through Steam relay is subject to Valve's Privacy Policy**
- **Standard Gameplay (Non-Playtest):** Voice is not stored on Company servers after transmission during standard gameplay sessions
- **Steam Playtest Exception:** If the user participates in the Steam Playtest program, voice communications may be recorded and stored by the Company pursuant to Section 6 of the EULA and Section 2.6 of this Privacy Policy; the user expressly consents to such recording upon Playtest enrollment
- Other players in the user's match can hear the user's voice
- The user can mute themselves and/or other players at any time
- For questions regarding voice data handling by Steam relay, contact Valve through Steam Support
**Other Players May Record:** The user acknowledges and agrees that:
- All in-game communications and actions are public and carry no expectation of privacy
- Other players in the user's match may record, stream, and/or broadcast gameplay, including the user's voice communications, pursuant to Section 7 of the EULA
- The Company does not control and/or prevent other players from recording
- While the Company does not automatically record and/or store voice data on Company servers during standard gameplay, other players may independently choose to record their gameplay sessions, which may include the user's voice and/or in-game actions
- By using multiplayer features, the user waives privacy claims arising from observation and/or recording by other players
- If the user does not wish to be recorded by other players, the user should mute their microphone and/or refrain from using voice chat and/or multiplayer features
### 15.2 Steam Workshop
- Content the user uploads is governed by Steam's Workshop terms, policies, and guidelines
- Workshop Content shall comply with Valve's Steam Workshop policies and shall not contain material illegal in any jurisdiction where Steam Workshop is served
- The Company defers to Valve's policies regarding Workshop content compliance
- The Company receives metadata about subscriptions and uploads
- User-generated content is subject to the EULA licensing terms (see EULA Sections 4.6A, 4.7, 4.8, and 4.9)
- The user bears sole responsibility for Workshop Content they upload
### 15.3 Leaderboards
- Leaderboard entries are public
- The user's Steam display name and score are visible to all users
- Users cannot opt out of leaderboard display while participating in ranked play
### 15.4 Esports and Tournaments
- Official competitions may require additional data (real name, age verification, tax information for prizes)
- Tournament participation is governed by separate Competition Rules
- Match recordings from official tournaments may be used for broadcast and promotional purposes
---
*This Privacy Policy is effective as of December 2025.*
***Terminal Insanity: CodeJacker™** is a trademark of **Ongakken Corporation OÜ**. All rights reserved.*