# Privacy notice This notice explains how the PRG32 multiplayer server operated by **[controller name]** processes personal data, as required by Articles 13 and 14 of the EU General Data Protection Regulation (GDPR). Last updated: [date]. ## Who is responsible - Controller: [legal name, postal address] - Contact for privacy questions and requests: [email address or web form] - Data protection officer: [name or role, contact], if one is appointed ## What we process When a console, emulator, or app connects to play, the server processes: - a **pseudonymous device ID**, derived on the server with a secret key from the identifier your client sends. The raw MAC address, IDFV, or installation ID is never stored or logged; - the client **platform** (for example `esp32c6`, `qemu`, `ios`, `qt`); - the **room**, which is the signature of the cartridge being played; - **connection times** and **message sizes in bytes**; - operational **event types** such as join, leave, rejected, blocked. We do **not** store IP addresses, names, e-mail addresses, advertising identifiers, game positions, button inputs, or message contents. Game state is relayed to the other players in the room and immediately discarded. The public status page shows only aggregate counts of connections and rooms. ## Why, and on what legal basis - To run multiplayer sessions and relay game state between players. - To keep the service secure and available: rate limiting, abuse prevention, blocking misbehaving devices. - To produce aggregate statistics about service use. Legal basis: [choose and justify, for example Article 6(1)(e) public task for a university or school, or Article 6(1)(f) legitimate interests, with the balancing test documented]. We do not rely on consent for this processing. Providing the data is necessary to use online multiplayer; you can always play cartridges offline without connecting. ## Who receives the data Administrators of this server, authorized by [controller], can see the telemetry. Hosting is provided by [hosting provider, location] under a data processing agreement. Data is not sold and not shared with advertisers. International transfers: [none, or the destination and the safeguard used, for example an adequacy decision or standard contractual clauses]. ## How long we keep it Telemetry events are deleted automatically after **30 days**, or earlier when the configured event limit is reached. Erasing a device removes its record and all of its events at once. Backups follow [backup expiry policy]. ## Your rights You have the right to access, rectify, and erase your data, to restrict or object to processing, and to data portability. To exercise them, contact [contact] and give the **public device ID** your client shows. We will not ask for your MAC address or other raw identifiers. We answer within one month. You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence. Our lead authority is [authority name, website]. There is no automated decision-making or profiling with legal or similarly significant effects. ## Data stored in your browser These web pages set **no cookies** and load **no third-party resources**, fonts, analytics, or trackers, so nothing needs your consent. - If you choose Day or Night with the switch in the menu bar, that choice is saved in your browser's local storage under `prg32-theme`. If you never use the switch, nothing is stored. Switch back to your system setting to remove it. - Administrators who sign in have their admin token kept in session storage under `prg32-admin-token` for that browser tab only. It is removed on sign-out or when the tab is closed. ## Changes We will update this notice when processing changes and show the date of the latest version above.