Privacy notice

1. Who handles your data

The data controller is Gabriel Rossi, Italia. You can write to us at info@spiravium.com, or using the form on the Contact page.

2. What data, why, and for how long

Your account

Your public key (not the 12 words: they stay in your browser), the name you choose, the bio, the portrait, your birth month and year, your settings, the day the account was born, your sign-ins (when they started and when you signed out), the last day you stopped by, and which version of the terms you accepted and when.

They let you play: the legal basis is the contract (the Terms of service page). Your birth month and year are there to keep anyone under 13 from playing and to protect minors (a legal obligation and a legitimate interest of ours): the game asks for them before the account is born (for an account born before this rule, before letting it play). This data stays as long as the account exists: an account doesn't expire on its own, and you delete it yourself, whenever you like (section 6).

The game

Your cards, decks, games, gems (each one, received or spent, with its day), the tournament, challenges and Limited Edition hand-overs. They make the game work and prove who owns what (the contract). They're the game's history, and they stay; the lines of the public ledger, forever (section 4).

Private messages

The text, who writes to whom, when, and when it was read. You and whoever receives them read them; a moderator reads only a reported message, with the three before and the three after, and can remove it if it goes against the law or the rules. They're there so you can write to each other (the contract). A sent message stays until you delete the account, or until we close it (section 6): then whoever received it reads “message deleted”. If we close it for the rules, the messages stay as they were.

Photos of prints

The photos you upload to have a print verified, without the location data. They're shown on the print's verification page, unless your profile is private. They stay even if you remove or change the print, until you delete the account or until we close it (closed for the rules, they stay but aren't shown); a photo that goes against the rules is hidden.

Reports and decisions

What is reported and why (with a copy of what was reported), and the custodians' decisions, with the facts and the reasons. The name and address of whoever reports, only if they leave them, to reply to them; whoever reports from their account without leaving an address stays linked to the report, so they can read in the game how it ended. The legal basis is a legal obligation: the EU Digital Services Act. The reporter's name and address are deleted six months after the decision; reports and decisions stay on record, so they can be reviewed and challenged. If the account of the person who was reported is deleted, what was reported (the message, the photo, the copy of the name or the bio) stays with the custodians for six months at most, counted from the deletion or, if it comes later, from the last decision, and is then deleted.

The closures of accounts also stay written (when, the reason and, for the rules, the rule), after a reopening or a deletion; the facts of a closure for the rules go away with what was frozen (section 6).

Messages to the custodians

What you write in the form on the Contact page: the topic, the text and, if you leave it, where to reply to you; and when it arrived, and from a page in which language. They let us reply to you (a legitimate interest of ours, or the contract). They're deleted six months after we close the request, and in any case after a year.

Technical data

To protect the game from abuse (too many requests from the same network) we keep, for three days at most, a fingerprint of your IPv4 address or of your IPv6 network, made with a secret key of the server: never the address in clear. The server doesn't keep a log of visits: an IP address can only appear in an error message of the machine, and those messages are deleted after 14 days. The legal basis is a legitimate interest of ours: the security of the game and of its players.

To know how many people are playing, and to make whoever arrives wait in a queue when the game is full, we keep for at most ten minutes your account and the time of your last request; and, if you wait in the queue, your ticket (your place, what you're waiting for, when), while you wait and then at most an hour. The basis is our legitimate interest: that the game holds up.

The session cookie keeps you signed in, and your browser keeps your choices and a copy of the game so you can play offline too: the Cookies and browser storage page explains it.

The game's numbers

We count how many times the game is opened, how many people stop by and how many games are played, day by day: with no extra cookies and no IP addresses. To count who stops by we keep on your account the last day you stopped by; the quick games you play in the browser go into your account's tally and into the game's numbers. It's a legitimate interest of ours: knowing how the game is doing.

Donations

The site doesn't handle donations: they happen on Bitcoin (on-chain or over Lightning) or on Monero, outside the game, and we don't know who donates. On the Bitcoin blockchain every payment is public; on Lightning and on Monero it isn't.

3. What others see

Everyone sees your name, the leaderboard and the roll of honour, and the Limited Edition public ledger, with your public key next to the cards you've had. If your profile is public they also see the bio, the portrait, your Limited Editions, how many cards you have, your rank and your tournament numbers, the day the account was born, the photos of your prints, and your name in the history of each Limited you've had.

If it's private they see your name, and that's all: on public pages you're “a player”, and the photos of your prints aren't shown. Under 14 the profile is always private; from 14 to 18 it is until you choose to make it public; from 18 it's public, unless you choose private (without your birth month and year, private).

4. The public ledger and Bitcoin

Everything that happens to a Limited Edition is a line in the public ledger: keys, cards, numbers and hashes, never names. Every day the ledger's hash is anchored to Bitcoin with OpenTimestamps: its servers only receive a hash, no data about you.

These lines can't be changed or deleted: that's how anyone can check who owns what. A public key, on its own, doesn't say who you are: the link between the key and your name is in the game, and a Limited's page only shows it if your profile is public.

5. Who else sees the data

The provider of the server that hosts the game, in the European Union, handles it on our behalf, under a contract, as a data processor. Authorities, only when a law requires us to.

Nobody else: we don't sell data, we don't advertise, we don't use third-party analytics. The game's pages don't load anything from other sites.

The nightly backup is encrypted: the last 14 stay on the server, and we keep one copy, the latest, in the European Union, replacing it with the new one as soon as we can, usually every night. The server's provider also keeps a copy of the server's disk, one day old.

Your data is on a server in the European Union, in France, and the backups stay in the European Union too. For security and maintenance, the server's provider may also handle it remotely from its own companies in the United Kingdom and Canada, countries that the European Commission considers to protect data adequately. We don't send it anywhere else.

6. Your rights

You can ask us to see your data and get a copy of it, to correct it, to delete it, to restrict its use, to receive it in a machine-readable format, and you can object to what we do based on a legitimate interest of ours.

You can do many things yourself, in the game: change the bio and the portrait, choose whether your profile is public or private, decide who can write to you, block someone, and delete your account.

You delete your account from the game's settings, signing with your 12 words. Right away, your name, the bio, the portrait, your birth month and year, the settings, your sign-ins, the last day you stopped by and the terms you had accepted are deleted; the messages you sent become “message deleted” for whoever received them; the photos of your prints are deleted; your gems are gone, and your Limited Editions burn (first you can give them to whoever you like; from the game's coming of age, instead, they stay with your key, on Bitcoin). Your 12 words no longer open anything in the game.

Nobody will be able to use your name again: we keep only a fingerprint of it, made with a secret key, never the name in plain text. What remains, without your name, is the history of the game (the matches, the tournament, the gems and the transfers) and the lines of the public register with your key, which on its own doesn't say who you are. In the backups your data stays until the backups delete themselves (at most two weeks, and one more day in the copy of the provider's disk); if we have to restore one, we redo the deletions and closures that came after it (except, if the whole server were lost, those made after the last backup).

For the rest write to us using the form on the Contact page, choosing “Privacy and data”, or at info@spiravium.com. Since your account is a key, we'll ask you to prove that it's yours. We reply within a month.

If you no longer have the 12 words and want to delete your account, write to us: once you've shown it's yours, we close it. A closed account loses what a deleted account loses (the name, the bio, the portrait, the birth month and year, the settings, the sign-ins, the messages, the photos) and leaves the rankings; the cards and gems stay with its key, frozen, because without the 12 words nobody, not even us, can move them. If you find the words again, we can reopen it.

If we close your account because it didn't respect the rules (the terms, section 5), we delete nothing: the name, the bio, the portrait, the month and year of birth, the settings, the messages, the photos and the decks stay frozen, and nobody sees them (others read “Closed account”); we also keep the facts we wrote to you. We keep them as long as the account stays closed, to give them back to you if the decision changes and to defend it if needed (the European regulation on digital services, and our legitimate interest). If you want to delete it, write to us from the form on the Contact page, choosing “Privacy and data”, with the account code: once you've shown it's yours, it's deleted like an account closed on request.

Some things can't be deleted, because they're the game's history or because the law requires us to keep them: the lines of the public ledger, games, gems and hand-overs, reports and moderation decisions. Your birth month and year are written once: you can't change them yourself (it protects minors), but if you got them wrong we'll correct them, if you ask us using the form on the Contact page.

If you think we're mishandling your data, you can lodge a complaint with the Italian Data Protection Authority, the Garante per la protezione dei dati personali (garanteprivacy.it), or with the authority of the country where you live.

7. If you're under 18

You must be at least 13 to play: if you say you're younger, the account isn't born, and your browser remembers it (the Cookies and browser storage page); nothing reaches us. Young people use the game too, and that's why it protects them: until you're 18 only people you've already written to can write to you, and your profile is private (from 14 you can choose to make it public); under 14 private messages are turned off. If you're under 14, play with a parent's permission.

If you're a parent and you think your child gave us data they shouldn't have, write to us using the form on the Contact page, choosing “Privacy and data”: we reply within a month. If they're under 13, we close their account: the name, the bio, the date of birth, the messages and the photos are deleted; what stays, without a name, is the account's key and the reason it was closed, so that it doesn't reopen on its own.

8. Security

The 12 words never leave your browser. The game only opens over HTTPS, every Limited Edition hand-over is signed, and backups are encrypted.

9. Only one automated decision

We don't profile you. The game makes only one decision on its own: if you say you're under 13, the account isn't born (and nothing reaches us: only your browser knows), or, if it already existed, it closes. If an account was closed by mistake, write to us from the Contact page: a person, one of the custodians, looks into it and reopens it. The game also makes whoever arrives wait in a queue when it's full, and slows down a network that makes too many requests: these apply to everyone in the same way, without looking at who you are. Moderation decisions and closures for the rules are always taken by a person.

10. If this notice changes

If it changes, we say so in the game, and the date at the top here changes.