HEROES OF THE VOID

PRIVACY POLICY

(Privacy and Personal Data Processing Policy)

Version: 1.0

Effective Date: September 9, 2026


1. General Provisions

This Privacy Policy (hereinafter referred to as the "Policy") defines the procedure for collecting, using, storing, transferring and otherwise processing the personal data of users of the online game Heroes of the Void (hereinafter referred to as the "Game", "Service") and related websites, mobile applications, game servers, forums, support services and other digital services.

The policy has been developed in accordance with applicable legislation on the protection of personal data, including, but not limited to:

By using the Game, creating an account, or otherwise interacting with the Service, the User acknowledges that they have read this Policy and agrees to the processing of their personal data in accordance with its terms.

If the User does not agree with this Policy, he/she is obliged to stop using the Game and related services.

This Policy is publicly available on the Company's official website at [https://heroesofthevoid.net/privacy] (or another permanent link). The version of the Policy accessible via this link is current and takes precedence over any local copies, including files distributed within the game client, unless they are updated.

2. Personal data operator

The personal data operator is a legal entity or individual entrepreneur that develops, maintains, and operates the Heroes of the Void online game (hereinafter referred to as the “Company,” “Operator,” or “We”).

At the time of publication of this Policy, information about the Operator includes:

If the Company is required to appoint a Data Protection Officer (DPO) or an EU Representative, the relevant information will be published on the Company's official website. If a representative has not yet been appointed at the time of publication, the Company undertakes to appoint one within 30 days of the commencement of activities covered by the GDPR and publish the relevant information on the official website.

3. Scope of the Policy

This Policy applies to the processing of personal data carried out using:

The policy applies regardless of the platform used, including: Windows; macOS; Linux; Android; iOS; Steam Deck; game consoles; cloud gaming services.

4. Terms and definitions

For the purposes of this Policy, the following definitions are used.

4.1. Personal data

Any information relating directly or indirectly to an identified or identifiable natural person.

4.2. User

Any individual using the Game, regardless of the method of registration or platform used.

4.3. Account

A set of information that allows the User to be identified in the Game and provides access to the game process.

4.4 Game data

Any information generated during the use of the Game, including characters, achievements, inventory, statistics, in-game currency, match history, rating, friends, guilds, settings, user preferences.

4.5. Processing of personal data

Any action or set of actions with personal data, including collection, recording, systematization, storage, clarification, usage, transmission, spreading, depersonalization, blocking, removal, destruction.

4.6. Device

Any equipment used by the User to access the Game, including personal computers, laptops, mobile phones, tablets, game consoles and other compatible devices.

4.7. Cookies

Small text files saved by a browser or application on the User's device and used to ensure the correct operation of services.

4.8. SDK

A set of software components (Software Development Kit) provided by third-party developers to implement certain functions of the Game, including analytics, authorization, payment processing, notifications, error detection, and fraud protection.

4.9. Data Processor

Any individual or legal entity processing personal data on behalf of the Operator.

4.10. Data Controller

An individual who independently determines the purposes and methods of processing personal data within the meaning of the GDPR and the UK GDPR.

5. Basic principles of personal data processing

The company processes personal data based on the following principles:

6. Categories of personal data subjects

This Policy applies to registered users, unregistered visitors, participants in gaming events, buyers of in-game goods, newsletter subscribers, support service users, participants in testing programs (Alpha, Beta, Early Access), candidates for affiliate programs, streamers/content creators, and other persons interacting with Heroes of the Void services.

7. Applicable law

This Policy shall be interpreted in accordance with the legislation of the state of registration of the Company, taking into account mandatory provisions of international legislation on personal data protection applicable to a specific User.

8. Categories of personal data

The Company processes personal data only to the extent necessary to provide the User with the functionality of the Game, fulfill contractual obligations, comply with legal requirements, protect the legitimate interests of the Company, and ensure the security of the Service.

8.1 Account details

Includes: username, display game name (Nickname), unique account identifier, email address, password (secure hashed form), email confirmation info, interface language, country/region, registration date, last login date, account status, history of username changes, 2FA info, and account recovery details.

8.2. User profile data

Includes: avatar, profile description, time zone, language of communication, preferred gaming region, social network links, friends list, blocked users list, privacy settings, user preferences.

8.3 Game data

Includes: characters, classes, levels, experience, skills, characteristics, inventory, achievements, ratings, statistics of victories/defeats, session history, tournament participation, event participation, match history, progress saves, configurations, clan/guild information.

8.4. Transaction Information

Includes: purchased digital goods, in-game currency, subscriptions, premium accounts, Battle Pass, purchase history, refunds, cancelled transactions, transaction IDs. The company does not store full bank card numbers or CVV codes.

8.5. Customer Support Data

Includes: username, email address, text of appeal, attached files, error logs, screenshots, video recordings, correspondence with support staff, and request processing history.

9. Data collected automatically

When using the Game, the Company automatically receives technical information necessary for the functioning of the Service.

9.1 Device data

Device model, manufacturer, OS version, processor architecture, RAM, free disk space, screen resolution, graphics adapter parameters, driver version, device identifiers, advertising identifiers (Advertising ID, IDFA, GAID - with consent).

9.2 Network data

IP address, country/region of connection, Internet provider, approximate location determined by IP, ping delay, connection quality and breaks, connection type (Wi-Fi, mobile network, Ethernet).

9.3. Event Logs

Entry/exit date and time, IP address, game session identifier, platform used, error logs, authorization logs, network logs, system events, exception messages, unauthorized access attempts.

9.4. Telemetry

Level loading time, client performance, frame rate (FPS), CPU/RAM load, server response time, crash reports, failures, and game server performance.

10. Data received from third parties

The Company may receive information from third-party services (gaming platforms, authorization services, payment systems) including platform account ID, display name, avatar, friends list, interface language, and country.

11. Cookies and similar technologies

The Company uses cookies, local browser storage, session storage, pixel tags, and SDKs to save authorization, store user settings, ensure security, prevent fraud, analyze service usage, and improve performance.

12. Analytical data

Processed to analyze duration of sessions, launch frequency, sequence of functions, interface usage statistics, popularity of game modes, bug fixing, game balancing, and infrastructure optimization.

13. User Content

In-game chat messages, personal messages, character/guild names, comments, forum posts, support requests, and reviews. Used solely for gameplay functionality, moderation, investigating rule violations, and fraud prevention.

14. Special categories of personal data

The Company does not request or carry out targeted processing of special categories of personal data (racial/ethnic origin, political views, religious beliefs, health status, genetic/biometric data, sexual orientation).

15. Data that the Company does not collect

The Company does not knowingly collect full bank card details, PIN/CVV codes, passwords to third-party services, personal files, phone book contacts, SMS contents, phone call recordings, or GPS geolocation without explicit consent.

16. Purposes of personal data processing

Personal data is processed exclusively for legitimate, predetermined, and transparent purposes:

17. Legal grounds for processing personal data

Under GDPR and UK GDPR, processing is carried out based on: Execution of the Agreement (Art. 6(1)(b)), Legitimate Interests of the Company (Art. 6(1)(f)), Fulfillment of Legal Obligations (Art. 6(1)(c)), and User Consent (Art. 6(1)(a)).

18. Automated decision-making and profiling

Automated processes are used for player matchmaking, server distribution, fraud detection, and cheat detection. Decisions with significant legal impact (e.g., permanent bans) provide the possibility of human review.

19. Processing of anonymized and aggregated data

The Company may aggregate or anonymize data for analytics, performance research, statistical reports, and gameplay balancing.

20. Principle of minimization of processing

The Company limits data collection to the necessary minimum, regularly reviews data lists, and deletes or anonymizes data once processing purposes are completed.

21. Transfer of personal data to third parties

The Company does not sell personal data. Transfers occur only to trusted categories of recipients: cloud infrastructure providers, payment operators, email/push providers, analytical services, anti-cheat providers, legal/auditing consultants, and government authorities under lawful requests.

22. International transfer of personal data

Carried out in compliance with GDPR/UK GDPR using Adequacy Decisions, Standard Contractual Clauses (SCC), International Data Transfer Agreements (IDTA), and supplementary technical measures (encryption, pseudonymization).

23. Personal data storage periods

Personal data is retained no longer than necessary to achieve processing purposes, execute contracts, and fulfill legal requirements.

23.2. Approximate storage periods

Data CategoryApproximate Retention Period
Account detailsUntil account deletion and expiration of mandatory retention periods
Game progressBefore deleting your account
Purchase historyIn accordance with tax and accounting legislation
Security logsUp to 24 months, unless a longer period is required to investigate the incident
Correspondence with support serviceUp to 5 years after the closure of the appeal, unless a longer period is required by law
BackupsBefore the completion of the established backup cycle

24. Information security

The Company applies robust organizational and technical measures: access segregation (least privilege), employee training, TLS transmission encryption, encryption at rest, firewalls, intrusion detection/prevention systems, backups, and security monitoring.

25. Rights of personal data subjects

Users have the right to information, right of access, right to rectification, right to erasure ("Right to be forgotten"), right to restrict processing, right to data portability, right to object, right to withdraw consent, and right to lodge a complaint with a supervisory authority.

26. Procedure for exercising rights

To exercise rights, users may submit requests via customer support or email: support@heroesofthevoid.net. Requests are processed within statutory deadlines free of charge.

27. California Residents' Rights (CCPA/CPRA)

California residents have rights to know, delete, correct, opt-out of sale/sharing of personal information, limit the use of sensitive personal information, and non-discrimination.

28. Children's Privacy Protection Act (COPPA)

The Company does not knowingly collect data from children under 13 without verifiable parental consent. Parents possess full rights to inspect, modify, or delete their children's data.

29. Users from the European Economic Area and the United Kingdom

The Company ensures full compliance with the GDPR and UK GDPR for all users residing within the EEA and UK.

30. Non-discrimination

The Company never discriminates against users for exercising their data privacy rights.

31. Using third-party services and SDKs

SDKs are integrated for authorization, payments, analytics, push notifications, and anti-cheat, adhering strictly to privacy guidelines.

32. Analytical services

Used to evaluate game stability, client performance, and user interface efficiency, utilizing aggregated data whenever possible.

33. Fraud Detection and Anti-Cheat Systems

Automated anti-cheat systems safeguard fair play by monitoring unauthorized software, bot scripts, and client tampering.

34. In-game communications

Communications may be moderated to protect players from spam, toxicity, fraud, and violations of Community Rules.

35. Google Play User Data Policy Requirements

Complies with Google Play User Data Policy and Data Safety Section requirements, maintaining transparency and security standards.

36. Apple App Store Requirements

Complies with Apple App Store Review Guidelines and Privacy Nutrition Labels.

37. Notifications of Changes to the Policy

Updates become effective upon publication. Material changes will be communicated via in-game notices, email, or official website announcements.

38. Contact information

For questions related to the processing of personal data, the User may contact the Company using the following contact information:

If the Company is required to appoint a Data Protection Officer (DPO) or representative in the European Economic Area or the United Kingdom, details of them will be published on the official website and made available upon the User's request.

39. Final Provisions

This Policy is an integral part of the User Agreement (Terms of Service / EULA) governing the use of the Game.

If individual provisions of this Policy are deemed invalid or unenforceable, this shall not affect the validity of the remaining provisions.

In all matters not regulated by this Policy, the provisions of applicable law governing the activities of the Company and personal data processing shall apply.

Appendix A. Categories of Personal Data

CategoryExamplesPurpose of Processing
Identification dataNickname, account ID, email addressAccount creation and maintenance
Game dataCharacters, achievements, statistics, inventoryProviding gameplay
Technical dataIP address, OS version, device modelEnsuring the operation and security of the Game
Transaction dataPurchase history, payment statusContract execution and accounting
Customer support detailsAppeals, attachments, correspondenceReviewing requests and troubleshooting problems
Analytical dataPerformance, error logs, telemetryImproving the quality of the game
User-generated contentChat messages, character names, commentsProviding communication functions and moderation

Appendix B. Main Retention Periods

Data CategoryRetention Period
AccountUntil account deletion and expiration of mandatory retention periods
Game progressBefore deleting your account
Security logsUp to 24 months, unless a longer period is required for the investigation
Financial documentsWithin the periods established by applicable law
Support requestsUp to 5 years, but not less than the statute of limitations established by applicable law (usually 3 years), and not more than the period provided by archiving legislation
BackupsDuring the established backup cycle