PRIVACY POLICY (Game)
PRIVACY POLICY (Game)
PRIVACY POLICY
BATTLE LIFE ONLINE (GAME)
Last Updated: July 10, 2026
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TABLE OF CONTENTS
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1. Controller
2. Scope of this Policy
3. Overview: What Data We Process
4. Game Account (Steam ID)
5. Gameplay Data
6. Game Server Connections (IP Addresses)
7. In-Game Feedback Tracker
8. Text Chat and Voice Chat
9. Cheat Protection
10. Crash Reports (Unreal Engine Crash Reporter)
11. Contact by Email
12. Recipients and Processors
13. Data Transfers to Third Countries
14. Storage Periods
15. Your Rights
16. Right to Object (Art. 21 GDPR)
17. No Automated Decision-Making
18. Obligation to Provide Data
19. Data Security
20. Changes to this Privacy Policy
21. Contact
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1. CONTROLLER
The controller within the meaning of the General Data Protection Regulation
(GDPR) is:
Matthias Gechter
c/o IP-Management #21243
Ludwig-Erhard-Str. 18
20459 Hamburg
Germany
Email: support@battlelifeonline.com
Website: https://www.battlelifeonline.com
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2. SCOPE OF THIS POLICY
This Privacy Policy applies exclusively to the game "Battle Life Online"
(the "Game"), distributed via Steam, including its online services.
It does NOT apply to:
(a) our website https://www.battlelifeonline.com, which has its own
separate privacy policy;
(b) the Steam platform. Steam (Valve Corporation) is an independent
controller. For Steam's data processing (including account data,
payments, purchases of BLO Keys, and the Steam Community Market),
see Steam's Privacy Policy:
https://store.steampowered.com/privacy_agreement
(c) external services linked from within the Game (e.g. our Discord
server or social media channels). Clicking such a link opens your
web browser; the respective provider's privacy policy applies.
No data is transmitted to these providers unless you click the link.
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3. OVERVIEW: WHAT DATA WE PROCESS
We process only the data necessary to operate the Game:
(a) your Steam ID (as your account identifier);
(b) gameplay data linked to your Steam ID (progress, statistics,
in-game currency, vehicles, items);
(c) your IP address when connecting to game servers (temporary
server logs, deleted after 30 days at the latest);
(d) content you submit via the in-game feedback tracker;
(e) the content of emails you send to us;
(f) crash reports - only if you actively choose to send them after a
crash. Crash reports are transmitted to Epic Games, not to us
(see Section 10).
We do NOT collect your email address or a password for the Game. We do NOT
record voice chat or text chat. We do NOT use in-game advertising, tracking,
or analytics services, and we do NOT sell or share your data for advertising
purposes.
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4. GAME ACCOUNT (STEAM ID)
When you first launch the Game, a game account is created for you
automatically. This account is identified solely by your Steam ID, which we
receive from the Steam client during authentication. You do not need to
register, and we do not collect an email address or a user-chosen password.
Purpose: providing the Game, saving your progress, enforcing our EULA.
Legal basis: Art. 6(1)(b) GDPR (performance of contract).
Account management is operated on AWS infrastructure (Amazon Cognito) in
the European Union (Frankfurt, Germany).
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5. GAMEPLAY DATA
Your game progress and related data (statistics, in-game currency balances,
vehicles, items, and similar gameplay values) are stored linked to your
Steam ID.
Purpose: providing the Game and its persistent open-world features.
Legal basis: Art. 6(1)(b) GDPR (performance of contract).
Gameplay data is stored on AWS infrastructure (Amazon DynamoDB) in the
European Union (Frankfurt, Germany).
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6. GAME SERVER CONNECTIONS (IP ADDRESSES)
When you connect to a game server, your IP address is processed and
temporarily written to server logs.
Purpose: establishing the connection, server security, preventing attacks,
and cheat protection.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in the secure and fair
operation of the Game).
Server logs are deleted after 30 days at the latest.
Game servers are operated on AWS infrastructure (Amazon GameLift), including
servers located in the United States (US East, Virginia). See Section 13 for
details on third-country transfers.
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7. IN-GAME FEEDBACK TRACKER
The Game includes a feedback tracker through which you can report bugs and
submit suggestions. The content you submit is stored together with your
Steam ID so that we can process the report.
Purpose: identifying and fixing bugs, improving the Game.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in maintaining and
improving the Game).
Please do not include personal data of third parties or sensitive personal
information in feedback submissions.
Feedback is stored for as long as necessary to process the report and is
deleted upon request.
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8. TEXT CHAT AND VOICE CHAT
The Game offers text chat and voice chat between players.
We do NOT record, store, or actively monitor chat communications. Voice chat
is transmitted in real time only.
If another player reports a violation of our conduct rules, the reported
content included in the report may be reviewed to investigate the report.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in enforcing our conduct
rules and protecting players).
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9. CHEAT PROTECTION
We use server-side systems to protect players against cheating and unfair
play. For this purpose, gameplay and connection data (see Sections 5 and 6)
are evaluated for irregularities.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in the integrity and
fairness of the Game).
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10. CRASH REPORTS (UNREAL ENGINE CRASH REPORTER)
The Game is built on Unreal Engine, a game engine by Epic Games. If the
Game crashes, the Unreal Engine Crash Reporter window may appear.
A crash report is transmitted ONLY if you actively click "Send and Close".
If you close the window or click "Close Without Sending", no data is
transmitted. Sending crash reports is voluntary and has no effect on your
use of the Game.
A crash report contains technical information about the crash: the error
type, callstacks, system and hardware information, game log files, a
randomly generated crash ID, and any comment you choose to enter. Log files
may contain file paths that include your local operating system user name.
Crash reports are transmitted directly to Epic Games and are NOT received
or stored by us.
Recipient: Epic Games, Inc., 620 Crossroads Blvd., Cary, NC 27518, USA.
Epic Games processes crash reports as an independent controller in
accordance with its privacy policy:
https://www.epicgames.com/privacypolicy
Legal basis: your consent (Art. 6(1)(a) GDPR), given by actively submitting
the report. The associated transfer to the USA is based on your explicit
consent pursuant to Art. 49(1)(a) GDPR. Please note that the USA may not
provide a level of data protection equivalent to that of the EU. According
to its privacy policy, Epic Games relies on safeguards such as the EU
Standard Contractual Clauses for international data transfers.
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11. CONTACT BY EMAIL
If you contact us by email (e.g. support requests, data protection
requests), we process your email address and the content of your message to
handle your request.
Legal basis: Art. 6(1)(b) GDPR if your request relates to the contract;
otherwise Art. 6(1)(f) GDPR (legitimate interest in responding to
inquiries).
Emails are deleted once your request has been fully resolved, unless
statutory retention obligations apply.
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12. RECIPIENTS AND PROCESSORS
We use the following processor within the meaning of Art. 28 GDPR:
Amazon Web Services EMEA SARL, 38 Avenue John F. Kennedy, L-1855
Luxembourg ("AWS") - hosting of account management (Amazon Cognito),
database (Amazon DynamoDB), and game servers (Amazon GameLift).
AWS privacy notice: https://aws.amazon.com/privacy/
A data processing agreement pursuant to Art. 28 GDPR is in place with AWS.
If you actively choose to send a crash report, Epic Games, Inc. receives it
as an independent controller (see Section 10). Epic Games is not our
processor.
Beyond this, we do not disclose your data to third parties unless we are
legally obliged to do so (e.g. to law enforcement authorities on the basis
of a lawful request).
Steam (Valve Corporation) is not our processor but an independent
controller (see Section 2).
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13. DATA TRANSFERS TO THIRD COUNTRIES
Account data, gameplay data, and feedback are stored exclusively in the
European Union (AWS region Frankfurt, Germany).
Game servers are additionally operated in the United States (AWS region
US East, Virginia). When you connect to these servers, your IP address and
session-related connection data are processed in the USA. These transfers
are safeguarded by:
(a) the EU-U.S. Data Privacy Framework, under which Amazon Web Services
is certified; and
(b) the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR), which are
part of the AWS Data Processing Addendum.
If you actively choose to send a crash report (Section 10), it is
transmitted to Epic Games, Inc. in the USA on the basis of your explicit
consent (Art. 49(1)(a) GDPR).
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14. STORAGE PERIODS
(a) Server logs (IP addresses): deleted after 30 days at the latest.
(b) Game account and gameplay data: stored until you request deletion
or until the Game is discontinued; deleted thereafter.
(c) Feedback submissions: stored for as long as necessary to process
the report; deleted upon request.
(d) Emails: deleted once the request has been resolved, unless
statutory retention obligations require longer storage.
(e) Crash reports: not received or stored by us; retention is
determined by Epic Games in accordance with its privacy policy.
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15. YOUR RIGHTS
Under the GDPR, you have the following rights:
(a) Right of access (Art. 15 GDPR);
(b) Right to rectification (Art. 16 GDPR);
(c) Right to erasure (Art. 17 GDPR);
(d) Right to restriction of processing (Art. 18 GDPR);
(e) Right to data portability (Art. 20 GDPR);
(f) Right to withdraw consent (Art. 7(3) GDPR), where processing is
based on consent, with effect for the future;
(g) Right to lodge a complaint with a supervisory authority
(Art. 77 GDPR). You may contact any data protection supervisory
authority, for example the authority competent for us:
Der Hamburgische Beauftragte fuer Datenschutz und
Informationsfreiheit (Hamburg Commissioner for Data Protection and
Freedom of Information), https://datenschutz-hamburg.de
To exercise your rights, contact: support@battlelifeonline.com
To verify your identity, we may ask you to submit your request in a way
that demonstrates control over the Steam account concerned.
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16. RIGHT TO OBJECT (ART. 21 GDPR)
WHERE WE PROCESS YOUR PERSONAL DATA ON THE BASIS OF LEGITIMATE INTERESTS
(ART. 6(1)(F) GDPR), YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING AT ANY
TIME ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION.
IF YOU OBJECT, WE WILL NO LONGER PROCESS THE PERSONAL DATA CONCERNED UNLESS
WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH
OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE
ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS.
WE DO NOT PROCESS PERSONAL DATA FOR DIRECT MARKETING PURPOSES.
To object, contact: support@battlelifeonline.com
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17. NO AUTOMATED DECISION-MAKING
We do not use automated decision-making within the meaning of Art. 22 GDPR.
Our server-side cheat protection may flag suspicious activity automatically.
However, permanent enforcement decisions are subject to human review: you
may appeal any enforcement action by contacting
support@battlelifeonline.com (see our EULA, Section 12).
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18. OBLIGATION TO PROVIDE DATA
You are not legally obliged to provide personal data. However, the data
described in Sections 4 to 6 is technically required to operate the Game.
Without it, you cannot play Battle Life Online. Sending crash reports
(Section 10) is entirely optional.
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19. DATA SECURITY
We use appropriate technical and organizational measures to protect your
data against loss, misuse, and unauthorized access, including encrypted
transmission, server-side authentication of game clients, and access
restrictions on our infrastructure. No internet-based transmission can be
guaranteed to be completely secure.
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20. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy when the Game's data processing changes
or legal requirements make it necessary. The current version is available
in the Game and at our website. The "Last Updated" date at the top
indicates the latest revision.
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21. CONTACT
For all privacy-related questions and to exercise your rights:
Matthias Gechter
c/o IP-Management #21243
Ludwig-Erhard-Str. 18
20459 Hamburg
Germany
Email: support@battlelifeonline.com
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