Privacy Policy

1. Who We Are

This Privacy Policy describes how Cool And Good Games d.o.o. ("we", "us", "our") processes your personal data in connection with the video game Starminer (the "Game") and the website starminer.net (the "Website").

Data controller:

Contact for privacy matters: starminer@coolandgoodgames.com

2. Scope

This Privacy Policy applies to personal data we process when you:

• play Starminer on PC via Steam;
• interact with online features of the Game (authentication, leaderboards, player statistics);
• submit a crash report from within the Game;
• visit starminer.net.

It does not apply to the practices of Valve Corporation (Steam), Microsoft Corporation (PlayFab / Azure) or any other third party operating its own services, which are governed by their respective privacy policies.

3. What Data We Collect and Why

3.1 Account and authentication data

When you launch the Game while signed in to Steam, we use PlayFab (a service operated by Microsoft) to authenticate you and create a player profile linked to your Steam account. The following data is processed:

• your Steam ID;
• a PlayFab player identifier generated for you;
• login timestamps and session data;
• the IP address from which you connect (used to establish the connection and detect abuse; not retained as a separate profile attribute).

Purpose: to identify you as a player, sign you in, and operate the online features of the Game.

Legal basis: performance of a contract (GDPR Article 6(1)(b)) — we need this data to provide the Game's online services to you.

3.2 Gameplay data

While you play, PlayFab stores gameplay-related data on our behalf, including:

• leaderboard entries (your in-game name, score and ranking);
• player statistics and progress;
• in-game events necessary for the operation of online features.

Purpose: to provide leaderboards, track player progress, and operate gameplay features.

Legal basis: performance of a contract (GDPR Article 6(1)(b)).

3.3 Crash reports (optional)

If the Game crashes, you may be presented with a dialog asking whether you would like to send a crash report. If you choose to send it, the following data is transmitted to our servers hosted on Microsoft Azure:

• the technical crash information (callstack, minidump, recent log entries, engine and game version);
• hardware and system information (operating system, CPU, GPU, memory, graphics driver version);
• a machine identifier generated by the Game;
• your in-game / Steam user name, if present in the crash data;
• any optional description you choose to add.

Sending a crash report is entirely voluntary. If you do not press "Send", no crash data leaves your device.

Purpose: to diagnose and fix bugs and improve the stability of the Game.

Legal basis: your consent (GDPR Article 6(1)(a)), given by choosing to send the crash report.

3.4 Website data

The Website starminer.net does not use cookies or analytics. Standard server access logs (such as IP address, requested URL and timestamp) may be retained by our hosting provider for a short period for security and operational purposes.

4. Third Parties We Use

We rely on the following third-party service providers ("processors") to operate the Game. Each of them processes personal data only on our instructions and under a data processing agreement.

4.1 Microsoft Corporation — PlayFab and Azure

PlayFab provides authentication, player profiles, leaderboards and player statistics. Crash reports are stored on Microsoft Azure infrastructure (Azure Storage, Azure Functions). PlayFab data is hosted on Microsoft Azure infrastructure, which may include servers located in the United States.

Microsoft's privacy statement: https://privacy.microsoft.com/en-us/privacystatement

4.2 Valve Corporation — Steam

Steam is the platform through which the Game is distributed and through which you authenticate. We receive limited data about you from Steam (such as your Steam ID and ownership of the Game) via the Steamworks API.

Steam's privacy policy: https://store.steampowered.com/privacy_agreement/

5. International Data Transfers

Some of the processors listed above (in particular Microsoft and Valve) are located in the United States or process data on servers outside the European Economic Area (EEA). When personal data is transferred outside the EEA, we rely on appropriate safeguards, including:

• the EU-U.S. Data Privacy Framework, under which Microsoft is certified;
• Standard Contractual Clauses approved by the European Commission, where applicable.

6. How Long We Keep Your Data

• Account and gameplay data (in PlayFab): for as long as your player profile exists, or until you request deletion.
• Crash reports: up to 12 months from the date they are received, after which they are deleted.
• Website server logs: retained by the hosting provider for a short period, typically no longer than 30 days.

7. Your Rights Under the GDPR

If you are located in the European Economic Area, the United Kingdom or Switzerland, you have the following rights regarding your personal data:

• right of access (Article 15);
• right to rectification (Article 16);
• right to erasure / "right to be forgotten" (Article 17);
• right to restriction of processing (Article 18);
• right to data portability (Article 20);
• right to object (Article 21);
• right to withdraw consent for processing based on consent (such as crash reports), at any time, without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, contact us at starminer@coolandgoodgames.com. We will respond to your request within 30 days. Account and gameplay data deletion is performed manually by us upon request.

You also have the right to lodge a complaint with a data protection authority. The competent authority in Slovenia is:

8. Children

The Game is not directed at children under the age of 16. We do not knowingly collect personal data from children under 16. If you believe a child has provided personal data to us, please contact us and we will delete it.

9. Security

We use industry-standard measures to protect personal data, including encryption in transit (HTTPS / TLS), access controls on our backend systems, and limited internal access on a need-to-know basis. No system can be guaranteed to be 100% secure, but we work to protect your data against unauthorised access, alteration, disclosure or destruction.

10. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Version" and "Effective date" at the top of this document. For material changes, we will additionally inform players through the Game or via the Website.

11. Contact

For any questions about this Privacy Policy or about how we process your personal data, please contact: