Rechtliches

Privacy policy

We ask for very little data, keep it in the European Union and you can delete your account whenever you like. Everything is here, with a plain summary at the start of each section.

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Gedruckt von https://colonized.work/de/legal/privacy/ · Zuletzt aktualisiert: · Version 1.8

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  1. Key information
  2. Who is the controller
  3. What data we process
  4. Why we use it and on what legal basis
  5. How long we keep it
  6. Who we share it with
  7. International transfers
  8. Your rights and how to exercise them
  9. Deleting your account
  10. Minors
  11. How we protect your data
  12. Automated decisions
  13. Changes to this policy

Key information

Kurz gesagt

This table sums up the essentials. The rest of the document explains each point.

Topic In a nutshell
Controller Guillermo Fernández Cadarso («vanguille») · admin at colonized.work
Purposes Running your pilot account (with Discord or with email) and your closed alpha application; answering what you ask in the Compis’ chat (processed by an AI on our own server and, only when needed, by an AI provider acting on our behalf) and improving it by keeping your questions without personal data for 90 days, unless you object with one click; keeping the website secure; measuring traffic without cookies; sending you news by email and Discord notifications only if you ask for them; and, if you link your game account, showing you your account in the Global Market and processing the operations you sign with your passkey (buying, selling, listing and cancelling).
Legal basis The terms you accept when you sign up (contract); your consent, to add you to our Discord, for news and for Discord direct message notifications; our legitimate interest, for security, statistics and improving the Compis’ chat.
Source of the data You and, when you sign up with or link your Discord account, Discord itself with your authorisation. If you link your game account, the bank of the game (a system of ours) gives us the name of that account.
Recipients We do not sell or share your data. Our technology providers, including the artificial intelligence providers of the Compis’ chat, process it only on our behalf.
Transfers Cloudflare and our email provider may process data in the US under the EU-U.S. Data Privacy Framework. Groq, the chat’s AI provider, may process in the US the text of your questions to the Compi, under standard contractual clauses. The disaster recovery backup is stored encrypted in Australia (Oracle), where nobody can read it, under standard contractual clauses.
Rights Access, rectification, erasure, objection, restriction, portability and withdrawal of consent. You can delete your account yourself from “My account”.
Complaints To the Spanish Data Protection Agency (aepd.es) or the authority in your country.

Who is the controller

Kurz gesagt

We are Guillermo Fernández Cadarso («vanguille»), the person behind COLONIZED. For anything privacy-related, write to admin at colonized.work.

The controller of your personal data is:

  • Owner: Guillermo Fernández Cadarso («vanguille»)
  • Tax ID (NIF): Entfällt (Privatperson)
  • Registered address: Madrid, España
  • Email: admin at colonized.work

We have not appointed a data protection officer because, given the type and volume of our processing, the law does not require one. Any privacy question goes straight to the team in charge via admin at colonized.work.

This policy applies to colonized.work and the services we offer through it: the pilot account, the closed alpha application, the waiting list, the contact form and the Global Market on the web.

What data we process

Kurz gesagt

Only what is needed: basic details of your Discord account (or your email and a password we only keep as an irreversible hash), your callsign, your application answers if you send one, and visit statistics that do not identify you. If you use the Global Market, the link to your game account, the public part of your passkeys and, for a short time, the operations you prepare. We do not store your Discord credentials or your IP address in the statistics.

When you create your pilot account with Discord or with email

You can sign up and log in with your Discord account (the main way) or with your email and a password, and link Discord later from “My account”.

With Discord. When you authorise us on Discord’s permission screen, Discord sends us data from your account, of which we only keep the following:

  • your Discord user ID, your username and your display name;
  • your avatar identifier (a code that points to the image; we do not store the image itself), to show it to you in “My account” and in the website header while you are logged in;
  • your email address, only if Discord has verified it.

We do not keep or display the rest of what Discord includes in its response (such as your banner or your subscription type). We look at some data on the spot without storing it: whether the account is a bot and how old it is (worked out from your ID), to stop accounts created in bulk; the language of your Discord app, to suggest the initial language of a new account; and, only when a team account is linked, whether it has two-step verification turned on.

Your avatar is shown from our own domain: our server fetches the image from Discord and keeps it in memory for at most 24 hours, so your browser does not connect to Discord to display it. On the website only you can see it, plus the administration team on your account page.

We do not store the access codes (tokens) that Discord gives us: we use them on the spot to read that data and, if you ticked the box to join our Discord server, to add you to it, and then we revoke them with Discord. We never see your Discord password and we have no access to your messages, your friends or your list of servers. Each time you log in with Discord, we update your username, your display name and your avatar with what Discord reports.

With email and password. We keep your email, the date you verified it and your password only as an irreversible hash (argon2id): we never see it or store it as is. To verify your email we send you a 6-digit code and a link. Until you verify it, we keep separately your email, the password hash, the language, the invitation code if you arrived with one, your acceptance boxes with their date and version, and the approximate country; the account is only created when you verify your email. If you do not verify it within 30 minutes, the sign-up expires and is deleted at most 24 hours later. Codes and links sent by email (including password reset ones) are stored only as hashes, work once and allow few attempts. If you signed up with Discord, you can add a password to also log in with your verified email, and if you signed up with email, you can link Discord.

In both cases, we also keep:

  • your pilot callsign (your name on the website), which you choose when you finish signing up;
  • the website language (the one you choose from those available);
  • whether or not you agree to receive news by email and whether you want Discord notifications, with the date you turned them on;
  • the date and time you accepted the terms and this policy, and the version of the texts you accepted;
  • the approximate country you sign up from, which Cloudflare tells us based on your connection (we store the country code, never your IP address);
  • if you arrived through another pilot’s invitation link, who invited you;
  • your sign-up and last login dates;
  • your role (pilot or team member) and, if we suspend your account, the date and the reason. Team accounts also keep their second verification factor (TOTP), encrypted.

If you turn on Discord notifications

If you tick the box “I want to turn on Discord notifications” when you sign up (it is unticked by default) or turn it on in “My account” → Preferences, we keep that choice and the date you gave it. From then on, our Discord bot may send you direct messages about your application and the closed alpha (for example, a status change or your invitation), and the team may send you a test message. To send them we only use your Discord ID; we do not store the content of the messages or the conversation. If Discord does not let us message you (for example, because you closed your direct messages or blocked the bot), the message is not delivered and we do not insist.

They can only be turned on with a linked Discord account. You can turn them off at any time by unticking the box in “My account”; they also stop if you delete your account.

While you are logged in

  • A technical cookie, __Host-col_sess, containing a random code. Our database only stores a hash of that code, so even someone with access to it could not hijack your session.
  • For each open session: the approximate country, the browser and operating system (for example, “Chrome · Windows”), how you logged in, whether two-step verification was used and a keyed hash (HMAC) of your IP address, never the IP address itself. This lets you see your open sessions and close them from “My account”, and lets us investigate unauthorised access.
  • When the session was created, last used and when it expires.

If you apply for the closed alpha

  • Platform (PC · Steam), region, languages you play in and hours you play per week.
  • Your preferred playstyles and the genres you play most.
  • Your hardware, if you choose to tell us: processor, graphics card and RAM.
  • Whether you have tested games before (alpha, beta or QA).
  • Your motivation for taking part (free text). Please do not include sensitive information such as details about your health, beliefs or religion.
  • If you choose to give them: your Steam profile URL, a Discord username for contact and your channel or website as a content creator.
  • Approximate country (from Cloudflare, no IP), your referral code, the status of your application (applied, in review, approved, key sent, redeemed, waitlisted or declined), the wave in which you have a place, and their dates.
  • If you get in: the Steam Playtest key we assign you (stored encrypted; our panel only shows its last characters), when it was assigned and which team member did it, whether we emailed it to you or told you on Discord and when, and, if you confirm it or the team marks it, when you activated it.
  • The date and version of the closed alpha terms you accepted when you sent it.

If you sign up through another pilot’s link, we store that relationship to give them their bonus on the list. That person only sees how many referrals they have, never who you are.

You can browse the Global Market and use it on the web to buy, sell, list items and cancel. To see your game account and trade with it, you first link it to your pilot account: the game gives you a one-time code that lasts 5 minutes and you type it on the website while logged in. When you link it:

  • we store the name and the internal identifier of your game account and the dates of the link;
  • the bank of the game (the system that keeps the game’s credits and the custody of its items; it is ours, not a third party’s) records that your game account is linked to your pilot account through a pseudonymous identifier (a prefix and a number), never your email, your name or your Discord.

Your balance, orders, storage, deliveries in transit and statement are not stored on the website: we ask the bank of the game for them when you open the market and show them to you. The operations you sign (buy and sell orders, purchases, listings and cancellations) are carried out by the bank of the game and stay in its records, like any operation made inside the game; those records only contain the pseudonymous identifier of your game account.

Signatures in the bank of the game. Every operation is an authorisation that a passkey of yours signs and that the bank of the game itself checks, with the public part of that passkey that it keeps: so nobody, not even our website, can operate your game account without your signature. That is why the bank of the game keeps, for each passkey you authorise with a code from the game, its public part, its identifier, the key type, a usage counter, the device name (such as “Chrome · Windows”) and the dates it was added, starts signing, was last used and was revoked; and for each authorisation, the operation and its amounts, the signature (the data your device returns when signing, never your fingerprint or face) and the result, as proof of what you authorised. Authorisations that expire unsigned or are annulled are deleted after 7 days; signed ones are part of the game account’s records.

Security hold. When you link the account, when you authorise a new device and after a sensitive change to your pilot account (email, password, account recovery, a revoked passkey or a session of another device that you close), the bank of the game stops moving value from the web for 72 hours (you can still browse and cancel). About the sensitive change we only tell it what kind of change it was, never the new data. It also keeps track of what you move from the web in 24 hours, to apply the limits for new accounts.

Prepared operations. Before you sign, the website shows you a review (the good or item, the price, the quantity, the hub, the fees, the tax, the freight and the total, calculated by the bank of the game) and keeps the prepared operation so that what you sign is exactly what you reviewed: what you reviewed, a key for the operation, the bank’s authorisation and its challenge, which passkey signed it and the result returned by the bank. It expires after 5 minutes and is deleted 24 hours later.

Notices. We email you when your game account is linked or unlinked and when a new device is authorised to sign in the bank of the game, so you can react if it was not you (the game tells you too).

Unlinking. You can unlink your game account at any time from “My account” (we will ask you to confirm it and to identify yourself again). The link is removed on the website and in the bank of the game; your credits and items do not change. To link it again you will need a new code from the game. If you delete your pilot account, we unlink it too.

If you authorise a device (passkeys)

A passkey lets you sign market operations with the fingerprint, face or PIN of your device and, on the website, confirm it is you before a sensitive change to your account (downloading your data, deleting it, changing the password or unlinking the game account) without logging in with Discord again: the website checks that signature with the passkey’s public part. It is created when you authorise the device with a code from the game (the link code, or one you ask for in the game for another device), and the bank of the game also keeps its public part, as explained above. The check of your fingerprint or face is done by your device: it never reaches us. For each passkey we only keep its public part (the private part never leaves your device), its identifier, the key type, a usage counter, whether it is synced across your devices, a name (the browser and system, such as “Chrome · Windows”) and the dates it was added and last used. We also keep a random identifier that your device associates with your account, which is not your email or your name, and, while you add a passkey or confirm with it that it is you, a temporary challenge that expires after 5 minutes and is deleted 24 hours later.

If you talk to a Compi (the website chat)

The Compis’ chat answers, whenever it can, from our own server in the European Union: the catalogue of answers written in each Compi’s voice and the website’s public data cover most questions, and those answers are put together there, without sending anything out. When the Compi has no ready answer, our server may ask an artificial intelligence provider to write it. These providers work on our behalf, as processors: Cloudflare (Workers AI) and Groq, both headquartered in the US (see Who we share it with and International transfers). If neither can answer, an artificial intelligence model running on our own server replies. When you send a message we receive its text, the last few questions and answers of that same conversation (only a few, so the Compi knows what you were talking about), the Compi you are talking to, the language and the page you are writing from. The answer is generated in memory and answers are not stored.

Exactly what is sent to that provider. Only the text of your question and, so the Compi knows what you were talking about, the last messages of that same conversation (up to four, yours and the Compi’s), together with the Compi’s instructions, a few notes taken from the website’s public information and, if we know it, the title of the page you are writing from. Before sending your text we apply the same automatic filter as before keeping your questions (it removes email addresses, phone numbers, web addresses, IP addresses, long numbers, passwords, @usernames and any name or username you give about yourself), and messages with personal data, illegal or sexual content, attempts to manipulate the Compi or about self-harm are not sent to any provider. Your IP address, your account, your session and any identifiers or headers of your browser are not sent: the provider only sees requests from our server and does not know who you are.

What each provider does with it. Cloudflare (Workers AI): according to its documentation, it does not use the content processed by Workers AI to train models and processes it only for as long as needed to provide the service; it only keeps operational data (model, time, token count, latency) that does not include the content. Groq: we have its zero data retention turned on, under which it does not retain the content of requests, not even for service reliability or abuse monitoring, and it processes it only to provide us with the service and on our instructions, under its data processing addendum.

Legal basis and objection. We do this because you ask for it by writing in the chat (Art. 6(1)(b)) and because of our legitimate interest in letting the Compi also answer what it has no ready answer for (Art. 6(1)(f)), which we have weighed up: most questions never leave our server, what does leave is filtered and carries no identifiers, and the providers process it only to answer you, without using it to train models. Because we keep nothing that identifies you, we cannot recognise your questions afterwards: the way to object to a question reaching a provider is not to write it (the rest of the website works the same). The “Don’t keep my questions” button (see below) stops us from keeping your questions, but not the Compi from consulting its provider to answer you.

What we do keep to improve the Compi: your questions, without personal data. To learn what people ask and what the Compi cannot answer, we keep the text of each question after automatically removing email addresses, phone numbers, web addresses, IP addresses, long numbers (cards, accounts, documents), passwords, @usernames and any name or username you give about yourself (“my name is…”, “my username is…”). With the cleaned question we keep the Compi, the language, the page you asked from, whether the Compi could answer it and from which source, how long it took and your rating (👍/👎) if you give one. We do not keep your IP, your account, your session or any identifier of your browser, so we cannot know who asked or link your questions together. Messages about self-harm or with sexual content are never kept. Only the COLONIZED administration team sees them, in the internal panel, and they are deleted automatically after 90 days. We do this based on our legitimate interest in improving the service (Art. 6(1)(f)), which we have weighed up: the text no longer contains data that identifies you, the period is short and you can object at any time, without giving a reason, with the “Don’t keep my questions” button in the chat itself (your browser remembers your choice in col_compi_chat_nolog); from then on none is kept. If you wrote something about yourself anyway and want us to delete it, write to admin at colonized.work with the approximate date and the text.

The conversation is kept only in your browser, in that tab’s storage (col_compi_chat_log), and disappears when you close it; you can also clear it with “Start over”. To stop abuse we apply the same attempt limits as on the rest of the website (with a keyed hash of your IP and of a random tab identifier, for at most 24 hours) and, if enabled, Cloudflare’s anti-bot check. Automatic filters stop messages with insults, illegal or sexual content, attempts to manipulate the Compi or personal data (emails, phone numbers, passwords) before they reach the model, and answer with a fixed line.

We also keep, from the chat, aggregated daily counts: how many messages there were, with which Compi, in which language, how long the answers took and whether someone marked an answer as helpful or not. They contain no text, no IP and nothing that identifies you.

It is an AI and it can make mistakes: what a Compi says is not a promise about the game. Do not write personal data in the chat.

If you use the contact form

If you write to us through the contact form (investors, press, creators or other topics), we keep the type of enquiry, your name, your email address, your organisation if you give it, your message, the language, the approximate country (from Cloudflare, no IP), the date you accepted this policy and the status of the enquiry. These messages are not linked to any account. If you email admin at colonized.work directly, we process your address, your name if you give it and the content of your message.

To learn which pages people find interesting and where they come from, we record each visit with:

  • the page visited (without URL parameters, except the campaign parameters utm_source, utm_medium and utm_campaign);
  • the domain of the referring website, if any (for example, “youtube.com”);
  • the approximate country (from Cloudflare), the device type (mobile, tablet or desktop, worked out from the screen width and the browser) and the page language;
  • a pseudonymous daily identifier that lets us count unique visitors for that day.

That identifier is calculated from your IP address and your browser, mixed with a random key that changes every day and is destroyed after 48 hours. We do not store your IP address or your browser, we do not use cookies for this and, once the key is destroyed, the identifier can no longer be recalculated or linked to any other day or to your account. More details in the Cookie policy.

To protect the website

To stop attacks and abuse, we limit the number of sign-up, email verification, login, password reset, application, contact and account deletion attempts and, in the Global Market, of queries, game code redemptions and purchases. To do so, we keep for at most 24 hours a keyed hash (HMAC) of your IP address, never the IP address itself.

In addition, Cloudflare, our network provider, processes your IP address and the technical data of each request to deliver the website to you and protect it from attacks. On some forms, such as the contact form or email sign-up and login, we may use its bot check (Turnstile), which analyses technical signals from your browser and connection to tell people apart from automated programs. Cloudflare also uses those signals, as a controller, to improve its bot detection, without identifying you.

If the administration team takes any action on your account (for example, suspending it), it is recorded in an internal audit log together with a keyed hash of the IP address of the person who did it. If you delete your account, your name in that log is replaced with a number that no longer identifies anyone.

In your browser

If you arrive through an invitation link (?ref=), your browser keeps that code (col_ref) during your visit, so it can be counted when you sign up. If you choose a language, a preference cookie (col_lang) remembers it, and if you close the notice suggesting another language, your browser remembers it during your visit (col_lang_hint). If you ask us not to count your visits, your browser remembers it (col_analytics_optout). If you are logged in and your account has a Discord avatar, your browser keeps the address of that image on our domain (col_avatar) to show it in the header; it is removed when you log out. As for the Compi, your browser remembers which one you chose (col_compi_chat), whether you objected to us keeping your questions (col_compi_chat_nolog), whether you put it to sleep (col_compi) and, during your visit, your conversation with it (col_compi_chat_log) and whether it has already greeted you (col_compi_*). It is all explained in the Cookie policy.

Kurz gesagt

To provide the service you ask for (account, alpha and market), to keep the website secure and to understand, without identifying you, how it is used. To add you to our Discord, send you news and notify you on Discord, only with your permission.

Purpose Legal basis (GDPR)
Creating and running your pilot account (with Discord or with email and password), verifying your email, resetting your password, showing you your Discord avatar, keeping you logged in and showing you your open sessions so you can close them Performance of the contract you accept with the Terms of use (Art. 6(1)(b))
Adding you to the COLONIZED Discord server, only if you tick the box when signing up Your consent, given with that box (unticked by default) and on Discord’s permission screen (Art. 6(1)(a)); you can withdraw it by leaving the server
Sending you Discord direct message notifications, only if you tick the box “I want to turn on Discord notifications” Your consent, given with that box (unticked by default) (Art. 6(1)(a)); you can withdraw it at any time by unticking it in “My account”
Handling your closed alpha application, your position on the list and your referrals; selecting participants in waves and getting your Steam Playtest key to you (in “My account” and, if your account has an email address, by email) Performance of the contract and pre-contractual steps at your request (Art. 6(1)(b))
Linking and unlinking your game account; showing you your balance, orders, storage and statement in the Global Market, and processing with the bank of the game the operations you sign Performance of the contract: it is the service you ask for when you link it (Art. 6(1)(b))
Protecting your operations with your passkey’s signature, checked by the bank of the game; recording which passkey signed each one; applying the 72-hour hold and the web limits, and emailing you about changes to the link and to your devices Performance of the contract (Art. 6(1)(b)) and our legitimate interest in the security of your account and in preventing fraud (Art. 6(1)(f))
Sending you necessary service messages by email: codes to verify your email or reset your password, the notice that your password has changed, your application status, security notices or changes to the terms Performance of the contract (Art. 6(1)(b))
Sending you game news by email (devlogs, new alpha waves, launch) Your consent (Art. 6(1)(a) GDPR and Art. 21 LSSI-CE), which you can withdraw at any time
Answering messages from the contact form and by email Your request and any pre-contractual steps you ask for (Art. 6(1)(b)), and our legitimate interest in helping you (Art. 6(1)(f))
Answering what you ask in the Compis’ chat, also with artificial intelligence providers (Cloudflare, Groq) when the catalogue has no answer Your request when you use the chat (Art. 6(1)(b)) and our legitimate interest in helping you and keeping the service secure (Art. 6(1)(f))
Counting, in aggregate and without any text, how the chat is used (messages, timings and ratings) Legitimate interest in running and improving it (Art. 6(1)(f))
Keeping your questions to the chat, already without personal data and without IP or account, to study what is asked and improve the Compi’s answers Legitimate interest in improving the service (Art. 6(1)(f)); you can object with the chat’s “Don’t keep my questions” button
Measuring website traffic with cookie-free statistics Legitimate interest in understanding, in aggregate, how the website is used in order to improve it (Art. 6(1)(f))
Producing aggregate statistics about applications (for example, how many applicants prefer each genre) to plan testing Legitimate interest in organising the alpha (Art. 6(1)(f))
Protecting the website and accounts: attempt limits, bot checks, checking whether your Discord email is verified, whether your Discord account is a bot and how old it is, requiring two-step verification on team accounts, preventing fake or duplicate accounts on the list and in referrals, investigating unauthorised access Legitimate interest in network and information security and in fraud prevention (Art. 6(1)(f) and Recitals 47 and 49)
Recording the administration team’s actions on accounts Legitimate interest in security and in being accountable for those actions (Art. 6(1)(f) and Art. 5(2))
Handling your rights and complying with legal obligations Legal obligation (Art. 6(1)(c))
Defending possible claims Legitimate interest (Art. 6(1)(f))

We have balanced our legitimate interests against your rights: the statistics do not identify you and security data lasts hours. You can object at any time (see Your rights).

We do not use your data for advertising, we do not sell it and we do not build commercial profiles.

How long we keep it

Kurz gesagt

Your account and application, until you delete them. Sessions, until they expire. Security data, hours. Statistics, at most 25 months and with nothing that identifies you.

Data Retention
Pilot account (including the data we receive from Discord) For as long as you keep the account. If you delete it, it is erased immediately.
Unfinished sign-up (you logged in but did not choose a callsign) At most 30 days; then we delete it.
Unverified email sign-up (email, password hash and acceptances) 30 minutes to verify it; otherwise it is deleted at most 24 hours later.
Codes and links sent by email (email verification and password reset, only as hashes) Valid for 30 minutes and a single use; deleted at most 24 hours after they expire.
Alpha application For as long as you keep the account. When the game’s closed testing ends, we will delete or anonymise the questionnaire answers within 6 months at the latest.
The Playtest key we assign you and its record (when and how it reached you) For as long as you keep the account. If you delete it, the key stays marked as used, with none of your data, so that it is never assigned to anyone else.
News and Discord notification preferences (with their date) Until you withdraw them or delete your account.
Link to your game account (name, identifier and dates) Until you unlink it or delete your account.
Passkeys (public part, identifier, counter, name and dates) On the website, until you remove or revoke them, unlink your game account or delete your account. In the bank of the game, once revoked, they are part of the game account’s records.
Prepared Global Market operations (what you reviewed, the key, which passkey signed it and the result) and passkey challenges (sign-up and identity confirmation) They expire after 5 minutes and are deleted 24 hours later. What you traded stays in the bank of the game.
Sessions (code hash, country, browser and keyed hash of the IP) While you use it: until you log out (on that device or from “My account”, where you see all your signed-in devices), delete the account or 180 days pass without using it. Sessions with administration permissions also expire after 12 hours without use and at most 180 days after logging in.
Audit log of team actions As long as needed for security and at most 2 years. If you delete your account, your name is replaced with a number.
Contact form messages and emails As long as needed to help you and then up to 12 months. Requests to exercise your rights, 3 years, so we can show we handled them.
Visit statistics The daily key is destroyed after 48 hours; from then on the identifier cannot be recalculated. Visit records, which contain no IP or browser, are kept for at most 25 months.
Compis’ chat: the answers Not stored: generated in memory. The conversation lives only in your browser until you close the tab.
Compis’ chat: what is sent to an artificial intelligence provider to write the answer Groq: nothing (zero retention). Cloudflare (Workers AI): the time needed to answer; it does not keep the content. We do not keep it (only the cleaned question, in the next row).
Compis’ chat: your questions, without personal data (with the Compi, language, page, outcome and your rating) 90 days, then deleted automatically. None if you press “Don’t keep my questions”.
Compis’ chat: aggregated daily counts (no text, no IP) At most 25 months.
Attempt limits (HMAC of the IP) At most 24 hours.
Encrypted backups (of the website and of the bank of the game) Daily ones, 7 days; weekly ones, 5 weeks; monthly ones, 12 months; in Madrid and in the disaster recovery copy in Australia. If you delete your account, your data disappears from the backups as they expire, and if we ever had to restore a backup, we would delete again the accounts removed after it was made.
Notices of changes to these documents (who was notified, by which channel and when) While you keep your account, as proof that we notified you.
Data stored in your browser The retention of each item is listed in the Cookie policy.

If a law required us to keep any data for longer, we would keep it blocked, available only to judges, courts and authorities, and only for the legal period.

Who we share it with

Kurz gesagt

With nobody who does not work for us. Our hosting, network, email and artificial intelligence providers process data only on our instructions and under contract.

We do not sell, rent or share your data with third parties. Only team members who need it for their work and the providers that supply our technical services can access it, as processors, under a contract that requires them to process it only on our instructions and to protect it (Art. 28 GDPR):

Provider What for Where Safeguards
Oracle (Oracle Cloud Infrastructure) Hosting of the website’s server and its two databases: the website’s and the bank of the game’s, kept apart (separate database, service and system user); and encrypted backups European Union (Madrid region, Spain). Only the disaster recovery backup, end-to-end encrypted, is in Australia (Sydney region) Oracle’s data processing agreement, with the European Commission’s standard contractual clauses for anything stored or accessed outside the EU; EU-U.S. Data Privacy Framework (Oracle America, Inc.) if its support accessed data from the US
Cloudflare, Inc. Content delivery network, DNS, attack protection, encrypted tunnel to the server and email routing for colonized.work Global network; headquartered in the US Data processing agreement with standard contractual clauses; EU-U.S. Data Privacy Framework
Cloudflare, Inc. (Workers AI) Writing what a Compi replies when the chat catalogue has no answer: it receives the filtered text of the question and the last messages of the conversation Global network; headquartered in the US The same Cloudflare data processing agreement, with standard contractual clauses and the EU-U.S. Data Privacy Framework; it does not use the content to train models
Groq, Inc. The same, as the chat’s second artificial intelligence provider US Groq data processing addendum with the European Commission’s standard contractual clauses; zero data retention turned on: it does not keep the content
Google (Gmail) Mailbox where we receive and answer emails, and delivery of the website’s emails (email verification, password reset and account notices) UE / EE. UU. Data processing agreement; Marco de Privacidad de Datos UE-EE. UU. (Google LLC adherida) y cláusulas contractuales tipo

The Compis’ chat answers from our Oracle server and only turns to Cloudflare (Workers AI) or Groq when an answer we have not prepared has to be written, with what is described in If you talk to a Compi. The cleaned questions we keep to improve the service stay on our Oracle server and are not sent to any provider.

The bank of the game is not a third party: it is a system of ours. It runs on our Oracle server in Madrid, with its own database, kept apart from the website’s (separate database, service and system user), and it can only be reached from inside that server: it is not exposed to the internet. The website talks to the bank inside the server itself, with signed requests, and only sends it the pseudonymous identifier of your pilot account, what each query or operation needs and your passkey’s signature; never your email, your name or your Discord data. When the game servers are up, they will connect to the bank over a private, encrypted network; if that changed where your data is stored, we would update this policy first.

Backups of both databases are made at least once a day and encrypted on the server itself before they leave it, with keys that only we hold and that are kept in the European Union. They are stored in Madrid and, as a disaster recovery copy, in another Oracle account in Australia: whoever stores them cannot read them.

The website’s emails are sent from that same mailbox: the provider receives your address and the content of the email in order to deliver it. Before using another email delivery provider (for example, for news), we will add it to this table.

We would only disclose data to authorities, judges or courts when required by law.

Discord. Discord processes your Discord account data as an independent controller under its own terms and privacy policy. When you sign up, Discord passes us the data listed above with your authorisation; if you tick the box to join our server, Discord also asks you for that permission and we ask Discord to add you, and from then on your profile will be visible to the other members of the server, as in any Discord server. On our server, the team moderates the channels and can see what you post there. If you turn on Discord notifications, our bot’s messages reach you through Discord, which processes them under its own terms.

Steam. If you take part in the closed alpha, you will get access through Steam (Valve Corporation), which processes your data as an independent controller under its own terms. We give you a Steam Playtest key and you activate it in your own Steam account: we do not pass your colonized.work data to Valve. If you give us your Steam profile, we use it only to manage your participation.

International transfers

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Your data is stored in the European Union, in Madrid: your pilot account data and the bank of the game’s data. The only copy outside the EU is the disaster recovery backup, in Australia, end-to-end encrypted: nobody can read it there. Because of how its network works, Cloudflare may process technical data in the US; it participates in the EU-U.S. Data Privacy Framework. Groq, the chat’s artificial intelligence provider, is also in the US and relies on standard contractual clauses. Our email provider may also process emails outside the EU, with the safeguards described.

The database holding your account and application and the bank of the game’s database, used by the Global Market, are on an Oracle server in the European Union (Madrid).

A backup of both is kept, to recover from a disaster, in Oracle’s Sydney region (Australia). That backup is encrypted on our Madrid server before it leaves, with keys that never leave the European Union, so only unreadable information is stored in Australia. Australia does not have a European Commission adequacy decision: the transfer relies on the European Commission’s standard contractual clauses included in Oracle’s data processing agreement (Art. 46(2)(c) GDPR), reinforced by that end-to-end encryption as a supplementary measure.

Cloudflare provides its service from a global network of data centres and is headquartered in the United States, so it may process technical connection data there (such as your IP address). Cloudflare, Inc. participates in the EU-U.S. Data Privacy Framework, for which the European Commission adopted an adequacy decision on 10 July 2023 (Implementing Decision (EU) 2023/1795). Its participation is listed as active on the official programme list (checked on 13. Oktober 2026). If that framework ceased to be valid, the European Commission’s standard contractual clauses included in its data processing agreement would apply.

When the Compis’ chat turns to an artificial intelligence provider, the filtered text of your question and the last messages of the conversation (what is described in If you talk to a Compi) travel to that provider: to Cloudflare (Workers AI), which provides the service from its global network of data centres and is covered by the same data processing agreement and safeguards, or to Groq, Inc., headquartered in the US. Groq’s data processing addendum, published by the company itself (version of 15 October 2025), incorporates the European Commission’s standard contractual clauses (Implementing Decision (EU) 2021/914, module two, controller to processor) and the UK addendum. For Groq we do not rely on the EU-U.S. Data Privacy Framework but on those clauses. With zero data retention turned on, Groq does not keep the content of the request.

Oracle America, Inc. also participates in that framework (official list), which covers any support access from outside the European Union.

Emails, both those you send us and those the website sends you, are processed by Google (Gmail) (UE / EE. UU.), with these safeguards: Marco de Privacidad de Datos UE-EE. UU. (Google LLC adherida) y cláusulas contractuales tipo.

Discord, Inc., headquartered in the United States, acts as an independent controller of your Discord account data and is also listed under that framework (official list).

Your rights and how to exercise them

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You can ask us to see, correct, delete or take away your data, object to or restrict its use, and withdraw your consent. It is free and we reply within one month at most.

You have the right to:

  • Access: know what data about you we process and get a copy.
  • Rectification: correct data that is inaccurate or incomplete.
  • Erasure: have your data deleted. You can do it yourself by deleting your account (see the next section).
  • Object: to processing based on legitimate interest, including visit statistics and the logging of your questions to the Compis’ chat (for the latter, the chat’s “Don’t keep my questions” button is enough). For a question not to reach an artificial intelligence provider, do not write it in the chat: we keep nothing that would let us recognise it afterwards.
  • Restriction: have us keep your data without using it while a complaint is resolved.
  • Portability: receive the data you gave us in a structured, commonly used format.
  • Withdraw your consent at any time, without affecting anything done before: for news, with the unsubscribe link every email will include; for your presence on our Discord, by leaving the server; for Discord notifications, by unticking the box in “My account”.
  • Not be subject to decisions based solely on automated processing that significantly affect you.

From “My account” you can download a copy of your data (including the link to your game account, your passkeys without their secret part and the prepared operations still kept), see and close your open sessions, change your preferences (news and Discord notifications), link Discord, add or change your password, authorise another device or revoke its passkeys, unlink your game account and delete your account. To download the copy or delete the account, we will ask you to identify yourself again: with a passkey of your device, with your password or with Discord.

By email. Write to admin at colonized.work from your account’s email address, with the subject “Data protection” and the right you want to exercise. If we have reasonable doubts about your identity, we may ask for additional information to confirm it. You can also act through a representative.

We will reply within one month, which may be extended by two further months if the request is complex or there are many requests; if so, we will let you know within the first month. Exercising your rights is free of charge.

To revoke COLONIZED’s access to your Discord account, go to User Settings → Authorized Apps in Discord. We do not need that access after you sign up, because we do not store Discord’s access codes. To stop receiving messages from our bot, besides unticking the box in “My account”, you can block it or close your direct messages in Discord.

To stop your visits being counted, you can switch on the opt-out in the Cookie policy or set your browser to send the Global Privacy Control or “Do Not Track” signal: we honour them.

Complaints to the authority. If you believe we have not handled your data properly, you can lodge a complaint with the Spanish Data Protection Agency (C/ Jorge Juan, 6, 28001 Madrid, Spain · www.aepd.es · e-office) or with the authority of your country of residence in the EU. We would appreciate it if you wrote to us first: we will try to sort it out.

Deleting your account

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From “My account”. Deletion is real, immediate and permanent.

You can delete your account at any time from My account: confirm with your callsign (or with your password, if your account has one) and, if needed, identify yourself with Discord again. When you do:

  • your account (including the data we received from Discord), your sessions and your alpha application, with all its answers, are erased immediately;
  • if your game account was linked, we first remove the link in the bank of the game (which revokes your passkeys there) and then delete your passkeys and prepared operations. Your game account and what is in it (credits and items) are not deleted: they belong to the game. If the bank of the game does not answer at that moment, we do not delete anything halfway: we will tell you so you can repeat it in a few minutes;
  • the pilot who invited you loses the bonus you gave them, and the pilots you invited no longer appear as invited by you;
  • the session cookie is removed from your browser;
  • visit statistics are not affected, because they are not linked to your account and do not identify you.

Deleting your account does not remove you from the COLONIZED Discord server: you can leave it from Discord whenever you like.

Deletion cannot be undone. If you want to come back, you will need to create a new account and send a new application, which will go to the end of the list.

Minors

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You must be at least 16 to create an account and 18 to take part in the alpha.

The pilot account is for people aged 16 or over, and the closed alpha for people aged 18 or over. When you sign up, you confirm that you meet the minimum age. Bear in mind that Discord also has a minimum age for using its service.

We do not knowingly collect data from people below those ages. If we find that an account belongs to someone under 16, we will delete it. If you are a parent or guardian and believe a minor in your care has given us their data, write to admin at colonized.work and we will sort it out.

How we protect your data

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Passwords only as irreversible hashes, no Discord tokens stored, IP addresses only as keyed hashes, encrypted connections, a server in the EU with no direct internet exposure and restricted, audited internal access.

We apply technical and organisational measures appropriate to the risk (Art. 32 GDPR), including:

  • if you log in with Discord, your account needs no password of its own and Discord’s access codes are revoked after use; if you use email and password, the password is stored only as an argon2id hash, and the codes sent by email as hashes that expire after 30 minutes and allow few attempts;
  • an HttpOnly, Secure and SameSite=Lax session cookie, and only a hash of the session code in the database;
  • always-encrypted connections (HTTPS with HSTS) and a strict content security policy;
  • the application is not directly exposed to the internet: it can only be reached through an encrypted Cloudflare tunnel;
  • attempt limits against abuse; IP addresses for limits and sessions are stored only as keyed hashes;
  • secrets we need to keep are encrypted (AES-256-GCM), and every backup is encrypted on the server before it leaves it;
  • the databases and the bank of the game only listen inside the server itself: they cannot be reached from the internet;
  • in the Global Market, your browser never talks to the bank of the game or sees its key: our server does, with signed requests; and every operation is signed by a passkey of yours over exactly that operation, and it is the bank of the game itself that checks the signature;
  • administrative access is restricted to expressly authorised team accounts, with a password protected with argon2id and their own second verification factor (TOTP) in every session, also when logging in with Discord, and their actions are logged.

If we suffered a security breach that put your data at risk, we would notify the Spanish Data Protection Agency within 72 hours and, if the risk were high, you too.

Automated decisions

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Your position on the list is calculated with a public rule. A person decides who gets into the alpha.

Your position on the waiting list is calculated automatically with a simple, public rule: order of arrival, moving up 10 places for each pilot you invite who completes their application. Participants are selected by a member of the team, who may also take into account the variety of hardware, regions and languages the test needs. We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly affect you.

In the Compis’ chat, answers are generated automatically by an artificial intelligence model and automatic filters may stop a message (insults, personal data…). None of this has legal effects or decides anything about you, your account or your application.

To stop fake accounts, sign-up automatically rejects Discord accounts that are bots or were created very recently, and reserved callsigns or callsigns containing insults are rejected when you choose one. If you think this has affected you by mistake, write to admin at colonized.work and a person will review it.

Changes to this policy

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If we change anything important, we will let you know beforehand.

We may update this policy to reflect changes to the website, the game or the law. The date of the last update is always shown at the top. If the change is significant, we will let you know by email or with a visible notice on the website before it applies.

Recent changes

  • Version 1.8, 22 October 2026. The closed alpha runs as an invite-only Steam Playtest: if you get in, we assign you a personal key, which you will see in “My account” and which we also email to you if your account has an email address. We add what we keep about that key and for how long, and the new application statuses. The sections “If you apply for the closed alpha”, “Why we use it and on what legal basis”, “How long we keep it” and “Who we share it with” (Steam) change.
  • Version 1.7, 22 October 2026. The Compis’ chat may rely on external artificial intelligence providers (Cloudflare Workers AI and Groq) to write the answers it has not prepared. Until now we said the chat ran only on our own server with no third parties. The sections “If you talk to a Compi”, “Who we share it with”, “International transfers”, “How long we keep it” and “Your rights and how to exercise them” change.

We publish this policy in several languages. In case of any discrepancy between versions, the Spanish version prevails.

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