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Privacy Policy

Last updated: May 8, 2026

1Data Controller

The data controller responsible for your personal data is:

Organization: HSR Games

E-mail: [email protected]

Address: Hungary

If a Data Protection Officer (DPO) is appointed, their contact details will be published here.

2Data We Collect

We process the following categories of personal data to operate the Service:

2.1 Roblox Account Data

  • Roblox user ID
  • Username and display name
  • Avatar/profile picture URL (Roblox CDN)
  • OAuth access and refresh tokens

2.2 Discord Account Data

  • Discord user ID
  • Discord username and avatar
  • Roles held on the HSR Discord server – automatically refreshed every 60 seconds
  • Discord OAuth tokens

2.3 Game Integration Data (Roblox)

Our Roblox game server (HSRServer) records the following:

  • Join and leave events with timestamps
  • Team assignment (Train Driver / Dispatcher / Passenger)
  • Playtime, distance traveled, XP and level
  • Aggregated gameplay statistics (UserStats)

2.4 Duty and Schedule Data

  • Active and completed duties (type, start/end time, train assignment)
  • Weekly duty summaries and compliance status
  • Supervisor requests (SupervisorRequest)
  • Schedule requests and train assignments
  • iOS Live Activity APNs push tokens – stored only during an active duty

2.5 Exam and Training Data

  • Exam attempts and their status (IN_PROGRESS, COMPLETED, TIMED_OUT, VIOLATION)
  • Per-question answers
  • Violation logs: browser tab switching and application focus loss events
  • Training registrations and attendance records
  • Training strikes for unexcused absences
  • Weekly duty strikes (WeeklyDutyStrike) and appeals

2.6 Support and Communication Data

  • Submitted support ticket content, messages, and agent assignments
  • Guest user identifier stored in a cookie (guest-support-id) for anonymous tickets

2.7 Push Notification Data

  • Web Push VAPID subscription endpoints and public keys
  • Mobile app Expo push tokens (Android and iOS)
  • APNs Live Activity push tokens (iOS, linked to an active duty entry)

2.8 Technical Logs

  • Full audit trail (e.g. LOGIN, DISCORD_LINK, BANNED, MOBILE_LOGIN, admin operations)
  • IP and device metadata for session security events
  • Session identifiers and session security data

3Purposes of Processing and Legal Bases

We process personal data only where a valid legal basis under Article 6 GDPR applies.

PurposeData UsedLegal Basis
Account registration, login, and authenticationRoblox/Discord ID, OAuth tokens, session data(1)(b) – Contract
Core service deliveryProfile data, activity, technical logs(1)(b) – Contract
Game integration and statisticsGame events, team assignment, UserStats(1)(b) – Contract
Duty and schedule systemDuty data, schedule requests, weekly summaries(1)(b) – Contract
Exam and training systemExam attempts, answers, violation logs(1)(b) – Contract
Security monitoring and abuse preventionIP/device metadata, audit log(1)(f) – Legitimate interests
Mandatory service emailsEmail address, notification records(1)(b) – Contract
Compliance with legal obligationsRelevant account and legal records(1)(c) – Legal obligation
Optional newslettersEmail address, preference choices(1)(a) – Consent

Where processing is based on legitimate interests, we conduct a balancing test to ensure your fundamental rights are not overridden.

4Third Parties

The Service relies on the following third-party providers:

Roblox CorporationOAuth authentication and game integrationroblox.com/info/privacy
Discord Inc.OAuth authentication and role managementdiscord.com/privacy
Stripe Inc.PCI DSS-compliant payment processingstripe.com/privacy
Cloudflare Inc.File storage (R2 object storage), CDN and infrastructure
Expo / Expo SDKMobile app push notification infrastructure
Apple Inc. (APNs)iOS push notifications and Live Activityapple.com/legal/privacy

5International Data Transfers

Due to the use of Roblox OAuth and Discord APIs, your data may be transferred outside the European Economic Area (EEA), including to countries without an EU adequacy decision. We apply appropriate safeguards, including:

  • Standard Contractual Clauses (SCCs) approved by the European Commission, where applicable
  • Transfer impact assessments and supplementary technical measures as needed
  • Data minimization and strict access controls for transferred data

6Email Communications

We send two types of emails:

Mandatory emails – GDPR Art. 6(1)(b)

Security alerts, account notices, legal updates, schedule reminders, and weekly duty summaries. These are part of contract performance and cannot be opted out of.

Optional emails – GDPR Art. 6(1)(a)

Newsletters and feature announcements – sent only with your consent. Opt out at any time via the unsubscribe link or by contacting [email protected].

8Children's Data

The Service is not intended for children under 16 years of age in the EEA, unless the member state permits a lower digital age of consent (not below 13) and all legal requirements are met. If we learn that data has been collected from a child without the required consent, we will delete it without undue delay.

9Security Measures

We implement technical and organizational measures appropriate to risk, including:

  • Encryption in transit (TLS) and at rest for sensitive data
  • Role-based access controls and least-privilege administrative access
  • Secure handling, rotation, and storage of authentication tokens and secrets
  • Full audit logging, anomaly monitoring, and incident response procedures
  • Regular updates, patching, and security hardening of infrastructure
  • Backups, recovery controls, and data integrity safeguards

10Data Retention

We retain personal data only for as long as necessary for the relevant purpose:

  • Account and profile data: for the duration of the account and up to 30 days after a deletion request, unless longer retention is legally required.
  • Authentication and security logs: up to 12 months to investigate abuse and incidents.
  • Support and dispute records: up to 24 months after case closure.
  • Game, duty, and schedule data: for the duration of the account.
  • Exam and training logs: for the duration of the account, or as required by law.
  • Consent records (optional emails): up to 3 years after withdrawal.
  • Legal compliance records: as required by applicable law.

When retention is no longer necessary, data is deleted or irreversibly anonymized.

11Your GDPR Rights

Subject to legal conditions, you have the following rights:

  • Right of access – request a copy of your personal data
  • Right to rectification – request correction of inaccurate data
  • Right to erasure ("right to be forgotten")
  • Right to restriction of processing
  • Right to object to processing
  • Right to data portability – request your data in machine-readable format
  • Right to withdraw consent at any time (where processing is consent-based)
  • Right to lodge a complaint with your local supervisory authority (in Hungary: NAIH)

How to exercise your rights: Email [email protected] with the subject "GDPR Request". We may request identity verification before completing your request. We respond within 30 days.

12Payment Data and Donations

Donations are processed exclusively by Stripe, a PCI DSS-compliant payment processor. HSR does not collect, store, or access full card details (card number, CVV, expiry date).

We retain the following donation-related data: the amount, the timestamp, the Stripe reference identifier, and the fact of a successful payment. This is used solely to award Supporter status, send confirmation emails, and maintain financial records as required by law.

Your payment data is never sold, shared, or used for marketing. For details on how Stripe handles your data, see stripe.com/privacy.

13Policy Changes

We update this Privacy Policy when required by legal, technical, or operational changes. For material changes, we notify you via the Service and/or email, and update the "Last updated" date. We recommend reviewing this page periodically.

14Contact

For privacy inquiries and GDPR requests, contact us at:

E-mail: [email protected]

For GDPR requests, use the subject line: "GDPR Request". We respond within 30 days.