Terms Watch

Last Updated: August 2026

Ongakken Corporation OU ("Company") respects the privacy of all users and is committed to protecting personal data. This Privacy Policy explains how the Company collects, uses, discloses, and safeguards information when users access Crosstalk (the "Game") and related services.

This Privacy Policy applies to users in all jurisdictions, including the European Union (GDPR), California (CCPA), and the United States (COPPA). The Company has designed this policy to comply with applicable data protection laws in all regions where the Game is available.

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The data controller responsible for personal data is:

Ongakken Corporation OU
Kalaranna 8/2-30, 10415, Tallinn, Estonia
Email: [email protected]

For GDPR purposes, the Company is the controller of the personal data it collects, except where data is processed by Valve Corporation (Steam) through Valve-operated services, in which case Valve is the controller for that data.

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The Company's game service servers receive authentication state, Steam identity, and the in-game events that unlock achievements and update statistics. These exchanges are necessary to run the Game. They are stored in encrypted form over the wire and at rest, using post-quantum algorithms wherever possible and reasonable.

Designs, game state, and log files are created and held on the user's device. The Company receives them where the user submits a report through the built-in reporter with the attachment box ticked, and/or attaches files to a support email.

All other data leaves the user's device through Valve's Steam infrastructure, through Discord infrastructure where the user uses the Discord integration (see Section 2.9), and/or through channels the user initiates.


When a user plays Crosstalk through Steam, the Game receives certain information from Valve Corporation on the user's device:

• Steam ID: The user's unique 64-bit Steam identifier
  
• Display Name: The user's public Steam username
  
• Avatar: The user's Steam profile picture

The Company does not have access to the user's Steam password, email address, payment information, and/or other sensitive account details held by Valve.


During gameplay, the Game processes the following on the user's device:

• Design and Game State: Board designs, component placements, trace routes, city state, scenario progress, and in-game statistics. Written to the user's local save files and, where Steam Cloud is enabled, synchronized by Valve
  
• Leaderboard Data: Scores and rankings the user achieves, submitted to Valve's Steam leaderboard infrastructure where offered
  
• Workshop Interactions: Content the user subscribes to, uploads, and/or downloads via Steam Workshop

The Game reports the in-game events that unlock achievements and the events that update statistics, such as a component being placed or simulation time accruing.

• To Valve: So the achievement and statistic appear on the user's Steam profile
  
• To the Company: Achievements and statistics for Crosstalk are server-authoritative, so the Company's servers evaluate the event and record the result

These events describe that something happened and are associated with the identifiers in Section 2.7. The design and game state the event arose from remain on the user's device.


Where enabled, the Game publishes a short status line describing what the user is doing, such as the active window and whether a design is running.

• To Steam: Published through Valve's Steam infrastructure, subject to the user's Steam privacy settings
  
• To Discord: Published where the user has connected a Discord account and left rich presence enabled in the Game's settings. Either may be switched off at any time

Rich presence reaches Valve and, at the user's option, Discord.


The Game generates and/or collects:

• Device Information: Operating system, hardware specifications, graphics card, available memory. Held on the user's device and included where the user submits a report
  
• Connection Data: The IP address used to reach the Company's authentication service
  
• Log Data: Local log files including session events, errors, and crash information

Log, crash, and device data remain on the user's device. The Company receives such data where the user submits it, by using the built-in reporter with the attachment box ticked (see Section 2.8) and/or by attaching log files to a support email.


If the Game offers a telemetry program and the user chooses to participate, the Company additionally collects:

• Detailed Gameplay Analytics: Feature usage frequency, navigation patterns, and gameplay patterns
  
• Behavioral Data: How the user interacts with menus, tutorials, and game systems
  
• Session Data: Anonymized gameplay patterns for balancing purposes

Participation in telemetry is entirely voluntary. The user can enable and/or disable telemetry at any time through the Game's settings menu. The Company genuinely appreciates those who help improve Crosstalk.


The user's game progress and designs are stored:

• Locally: On the user's device
  
• Steam Cloud: If the user has Steam Cloud enabled, saves sync across devices via Valve's infrastructure

If the user participates in the Steam Playtest program, as described in Section 6 of the End User License Agreement, the Company may record the user's gameplay sessions. These recordings are retained for promotional purposes as consented to upon enrollment. The user may withdraw this consent at any time as described in EULA Section 6.2.4 and Section 9 of this Privacy Policy.


Data handled by the Company's authentication service is associated with the following identifiers:

• The user's Steam ID, Steam name, and/or Steam profile overall
  
• The IP address used to connect

This data is stored in encrypted form at rest, using post-quantum algorithms wherever possible and reasonable, for up to one (1) year after the user's last attempted connection to the game service servers, after which it is deleted and/or anonymized.


The Game includes a built-in bug reporter. The bug reporter is fully optional: it serves as an avenue should the user choose to transmit debugging information to the Company, and transmitting any data through it is entirely at the user's discretion, though greatly appreciated. When the user chooses to send a report, the transmission may include log data, crash information, device information, and any description the user provides. Bug reports are handled as described in Sections 7 and 8.


The Game integrates with Discord. Where the user links a Discord account, data is exchanged with Discord Inc., which acts as an independent controller for data held on its own infrastructure (see Section 6.1A).

2.9.1 When the integration applies

• Retail: The Discord integration is optional and is controlled by the user through the Game's settings, which include a master switch for the integration, a presence toggle, a voice toggle, and controls to link and unlink the Discord account.
  
• Steam Playtest: Where the user participates in the Steam Playtest program, linking a Discord account and membership of the Company's Discord server are required conditions of participation, as described in Section 6 of the End User License Agreement. A user who does not wish to link a Discord account should not enroll in the Playtest.

2.9.2 Data exchanged with Discord

• Authorization: An OAuth authorization performed through the user's own Discord client, and the resulting access and refresh tokens, which are stored on the user's device
  
• Account Identifiers: The user's Discord user ID, username, and display name
  
• Server Membership: Whether the user is a member of the Company's Discord server, checked periodically while the integration is active
  
• Rich Presence: Where the presence toggle is enabled, the user's current in-game activity and status, which Discord displays on the user's profile to whoever can see it
  
• Messages: Where the user uses the in-game chat and/or lobby features, message content, message metadata, and message history retrieved for display
  
• Voice: Where the user uses in-game voice chat, audio is carried over Discord's infrastructure

2.9.3 Playtest enrollment notices

On Playtest builds only, the Game posts an automated notice to a private, access-restricted channel on the Company's Discord server when a Playtest user links an account, and when a linked Playtest user leaves the Company's Discord server. Each notice contains the user's Steam display name, Steam ID, Discord display name, and Discord user ID, which together constitute a link between the user's Steam and Discord identities.

• Purpose: Verifying eligibility for the Playtest gate and administering the Playtest programme.
  
• Access: The channel is restricted. It is accessible to the Company and to the third-party moderation tooling operating on the Company's Discord server; it is not visible to other Playtest participants and/or to the general membership of the server.
  
• Retail: These notices are not sent on retail builds.

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For users in the European Economic Area (EEA), United Kingdom, and Switzerland, the Company processes personal data on the following legal bases:


Processing necessary to provide the Game and Services the user requested:

• Account authentication via Steam
  
• Online game services provided through the Company's game service servers
  
• Leaderboard functionality
  
• Steam Cloud saves
  
• Steam Workshop functionality
  
• Discord account linking, server membership verification, and the Playtest enrollment notice described in Section 2.9.3, where the user participates in the Steam Playtest program and these are conditions of that participation

Processing necessary for the Company's legitimate business interests, balanced against user rights:

• Fraud prevention and anti-cheat measures
  
• Security monitoring and abuse prevention
  
• Game balancing and improvement based on aggregated data
  
• Bug fixing based on user-submitted reports

Processing based on the user's explicit consent:

• Telemetry data collection (opt-in)
  
• Bug report transmission via the built-in bug reporter (at the user's discretion)
  
• Playtest recordings for promotional use
  
• The Discord integration on retail builds, including account linking, rich presence, chat, and voice, each of which the user enables and may disable through the Game's settings

The user may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.


Processing necessary to comply with legal obligations:

• Tax reporting for prize winnings
  
• Responding to lawful government requests

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The Company uses collected information to:


The Company does NOT use user data for:

• Targeted advertising
  
• Selling to data brokers
  
• Profiling for purposes unrelated to the Game

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The Game operates through Steam, and Valve processes data according to their own privacy policy. Data shared through Steam includes:

• Achievement and stats data
  
• Leaderboard scores
  
• Workshop content metadata

Valve-Operated Services: Certain services are provided directly by Valve, and data processing for these services is governed by Valve's Privacy Policy, not this Privacy Policy:

• Steam Cloud: Cloud save data
  
• Steam Workshop: Workshop content hosting and distribution
  
• Authentication: Steam account services
  
• Purchases and Refunds: Steam store transactions

For data processed by Valve through these services, refer to Valve's Privacy Policy.

Valve's Privacy Policy: https://store.steampowered.com/privacy_agreement/


Where the user uses the Discord integration (Section 2.9), data is exchanged with Discord Inc. Discord acts as an independent controller for data held on its infrastructure, and its processing is governed by Discord's own privacy policy, not this Privacy Policy.

Data reaching Discord includes the user's Discord account identifiers, server membership status, rich presence where enabled, message content and history where the user uses the chat features, voice audio where the user uses voice chat, and, on Playtest builds only, the enrollment notice described in Section 2.9.3.

The Company's own Discord server, including the restricted channel described in Section 2.9.3, is hosted on Discord's infrastructure and is subject to Discord's terms and policies. Third-party moderation tooling operating on that server processes data available to it within the server.

Discord's Privacy Policy: https://discord.com/privacy


The Company does not sell personal data. The Company does not share personal data with third parties for any marketing purposes, whether such third party's own marketing, joint marketing, and/or any other marketing purpose.


The Company may disclose user information if required by law, court order, and/or governmental authority, and/or if the Company believes disclosure is necessary to:

• Protect the Company's rights, property, and/or safety
  
• Prevent fraud and/or abuse
  
• Comply with legal process

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Data the Company holds (including game service server data, support correspondence, user-submitted reports, telemetry if opted in, and Playtest recordings) is processed within the European Union. User data is processed exclusively at the Falkenstein data center (Germany) and/or the Helsinki data center (Finland).


Steam Cloud, Steam Workshop, leaderboards, and authentication are operated by Valve Corporation globally. For data processed by Valve, refer to Valve's Privacy Policy and their data processing practices.


Discord Inc. is established in the United States and operates globally. Where the user uses the Discord integration (Section 2.9), the data described in Section 6.1A is transferred to and processed on Discord's infrastructure outside the European Economic Area, under Discord's own terms and safeguards. Section 7.1 describes where the Company processes data and does not apply to data held by Discord and/or Valve.


For any transfers of personal data outside the EEA, the Company ensures appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs)
  
• Data processing agreements
  
• Technical security measures

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The Company retains user data according to the following schedule:


After the retention period, personal data is either deleted and/or anonymized so it can no longer be associated with the user.


When the Company anonymizes data, the Company removes and/or irreversibly alters all identifiers so the data cannot reasonably be linked back to the user. Anonymized data is no longer considered personal data and may be retained indefinitely for research, analytics, and game improvement.


If the user requests deletion of data and/or deletes the user's Steam account, the Company shall delete personal data within 30 days, except:

• Leaderboard entries (which display username only)
  
• Anonymized and/or aggregated data
  
• Data the Company is legally required to retain
  
• Playtest recordings already incorporated into published promotional materials (per EULA Section 6.2.4)

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If the user is located in the European Economic Area, United Kingdom, and/or Switzerland, the user has the following rights:


To exercise these rights, contact the Company at [email protected]. The Company shall respond within 30 days.


If the user is a California resident, the user has the following rights under the California Consumer Privacy Act:


To exercise these rights, contact the Company at [email protected].

Verification: The Company may need to verify the user's identity before processing requests. The Company shall use the user's Steam ID and associated email for verification.


Depending on the user's location, the user may have similar rights under local data protection laws. Contact the Company to inquire about specific rights.

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Crosstalk is not intended for children under the age of 13. The Company does not knowingly collect personal information from children under 13 years of age.


The Company does not knowingly:

• Request and/or collect personal information from children under 13
  
• Allow children under 13 to register and/or use the Game
  
• Target marketing and/or advertising to children under 13

If a parent and/or guardian believes their child under 13 has provided personal information to the Company, they should contact the Company immediately at [email protected]. The Company shall:

• Verify the claim
  
• Delete the child's personal information promptly
  
• Terminate any associated account access

The Company relies on Steam's age verification mechanisms. By using the Game, the user certifies that the user is at least 13 years of age.


The minimum age in Sections 10.1 and 10.4 applies to the Game. Individual items of Additional Content ("DLC", as defined in Section 1.1 of the End User License Agreement) carry their own age ratings, stated on that item's store listing, and some are rated for adults only with a minimum age of eighteen (18) years.

By purchasing, installing, and/or using any such item, the user certifies that the user meets the minimum age stated for it. The Company relies on Steam's age gating and account mechanisms for such content, and does not knowingly collect personal information from any user who does not meet the applicable minimum age. See Section 14.1A of the End User License Agreement.

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The Company implements appropriate technical and organizational measures to protect personal data, including:

• Encryption: Data handled by the Company's game service servers is encrypted over the wire and at rest, using post-quantum algorithms wherever possible and reasonable
  
• Minimal Collection: The Company collects only the data needed to provide the Game and its online services

• Limited Access: Only authorized personnel can access personal data
  
• Incident Response: Procedures for detecting and responding to data breaches

In the event of a personal data breach that poses a risk to user rights, the Company shall:

• Notify the relevant supervisory authority within 72 hours (GDPR requirement)
  
• Notify affected users without undue delay if the breach poses a high risk
  
• Document the breach and remediation steps

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The Game may contain links to third-party websites and/or services (e.g., Steam Community, Workshop). The Company is not responsible for the privacy practices of these third parties. Users are encouraged to review their privacy policies before providing any personal information.

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The Company may update this Privacy Policy from time to time. Changes shall be effective when posted, and the Company shall update the "Last Updated" date at the top.

For material changes, the Company shall provide notice through:

• In-game notification
  
• Steam announcement
  
• Email (if the Company has the user's email address)

The user's continued use of the Game after changes constitutes acceptance of the updated Privacy Policy.

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If users have questions, concerns, and/or requests regarding this Privacy Policy and/or personal data, contact the Company:

Ongakken Corporation OU
Kalaranna 8/2-30, 10415, Tallinn, Estonia
Email: [email protected]


For users in the European Union, the Company's representative for GDPR purposes can be contacted at:

Ongakken Corporation OU
Kalaranna 8/2-30, 10415, Tallinn, Estonia
Email: [email protected]


If the user is in the EU and believes the Company has not adequately addressed concerns, the user has the right to lodge a complaint with the local data protection supervisory authority.

For Estonia: Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate)
Website: https://www.aki.ee/

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• Content the user uploads is governed by Steam's Workshop terms, policies, and guidelines
  
• Workshop Content shall comply with Valve's Steam Workshop policies and shall not contain material illegal in any jurisdiction where Steam Workshop is served
  
• The Company defers to Valve's policies regarding Workshop content compliance
  
• The Company receives metadata about subscriptions and uploads
  
• User-generated content is subject to the EULA licensing terms (see EULA Sections 4.6A, 4.7, 4.8, and 4.9)
  
• The user bears sole responsibility for Workshop Content they upload

• Linking a Discord account is optional on retail builds and is controlled through the Game's settings; it is a required condition of participation in the Steam Playtest program
  
• Rich presence, where enabled, displays the user's in-game activity on the user's Discord profile to whoever can see that profile
  
• Chat and voice features carry message content and audio over Discord's infrastructure
  
• The user may unlink the Discord account at any time through the Game's settings, which stops further exchange of data with Discord through the Game
  
• Unlinking does not delete data already held by Discord; such data is subject to Discord's own policies and the user's rights against Discord

• Leaderboard entries are public
  
• The user's Steam display name and score are visible to all users
  
• Users cannot opt out of leaderboard display while participating in ranked play

• Official competitions may require additional data (real name, age verification, tax information for prizes)
  
• Tournament participation is governed by separate Competition Rules
  
• Match recordings from official tournaments may be used for broadcast and promotional purposes

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This Privacy Policy is effective as of August 2026.

Crosstalk is a trademark of Ongakken Corporation OU. All rights reserved.

            <div class="bb_h1">Crosstalk: Privacy Policy</div><br><b>Last Updated:</b> August 2026<br><br><b>Ongakken Corporation OU</b> ("Company") respects the privacy of all users and is committed to protecting personal data. This Privacy Policy explains how the Company collects, uses, discloses, and safeguards information when users access Crosstalk (the "Game") and related services.<br><br>This Privacy Policy applies to users in all jurisdictions, including the European Union (GDPR), California (CCPA), and the United States (COPPA). The Company has designed this policy to comply with applicable data protection laws in all regions where the Game is available.<br><br><hr><br><br><div class="bb_h2">1. Data Controller</div><br>The data controller responsible for personal data is:<br><br><b>Ongakken Corporation OU</b><br><b>Kalaranna 8/2-30, 10415, Tallinn, Estonia</b><br>Email: <b><a href="mailto:[email protected]">[email protected]</a></b><br><br>For GDPR purposes, the Company is the controller of the personal data it collects, except where data is processed by Valve Corporation (Steam) through Valve-operated services, in which case Valve is the controller for that data.<br><br><hr><br><br><div class="bb_h2">2. Information the Company Collects</div><br><b>The Company's game service servers receive authentication state, Steam identity, and the in-game events that unlock achievements and update statistics.</b> These exchanges are necessary to run the Game. They are stored in encrypted form over the wire and at rest, using post-quantum algorithms wherever possible and reasonable.<br><br><b>Designs, game state, and log files are created and held on the user's device.</b> The Company receives them where the user submits a report through the built-in reporter with the attachment box ticked, and/or attaches files to a support email.<br><br>All other data leaves the user's device through Valve's Steam infrastructure, through Discord infrastructure where the user uses the Discord integration (see Section 2.9), and/or through channels the user initiates.<br><br><div class="bb_h3">2.1 Account Data (via Steam)</div><br>When a user plays Crosstalk through Steam, the Game receives certain information from Valve Corporation on the user's device:<br><br><ul class="bb_ul"><li><b>Steam ID:</b> The user's unique 64-bit Steam identifier<br></li><li><b>Display Name:</b> The user's public Steam username<br></li><li><b>Avatar:</b> The user's Steam profile picture</li></ul><br>The Company does not have access to the user's Steam password, email address, payment information, and/or other sensitive account details held by Valve.<br><br><div class="bb_h3">2.2 Gameplay Data</div><br>During gameplay, the Game processes the following <b>on the user's device</b>:<br><br><ul class="bb_ul"><li><b>Design and Game State:</b> Board designs, component placements, trace routes, city state, scenario progress, and in-game statistics. Written to the user's local save files and, where Steam Cloud is enabled, synchronized by Valve<br></li><li><b>Leaderboard Data:</b> Scores and rankings the user achieves, submitted to Valve's Steam leaderboard infrastructure where offered<br></li><li><b>Workshop Interactions:</b> Content the user subscribes to, uploads, and/or downloads via Steam Workshop</li></ul><br><div class="bb_h3">2.2A Achievement and Statistic Events</div><br>The Game reports the in-game events that unlock achievements and the events that update statistics, such as a component being placed or simulation time accruing.<br><br><ul class="bb_ul"><li><b>To Valve:</b> So the achievement and statistic appear on the user's Steam profile<br></li><li><b>To the Company:</b> Achievements and statistics for Crosstalk are server-authoritative, so the Company's servers evaluate the event and record the result</li></ul><br>These events describe that something happened and are associated with the identifiers in Section 2.7. The design and game state the event arose from remain on the user's device.<br><br><div class="bb_h3">2.2B Rich Presence</div><br>Where enabled, the Game publishes a short status line describing what the user is doing, such as the active window and whether a design is running.<br><br><ul class="bb_ul"><li><b>To Steam:</b> Published through Valve's Steam infrastructure, subject to the user's Steam privacy settings<br></li><li><b>To Discord:</b> Published where the user has connected a Discord account and left rich presence enabled in the Game's settings. Either may be switched off at any time</li></ul><br>Rich presence reaches Valve and, at the user's option, Discord.<br><br><div class="bb_h3">2.3 Technical Data</div><br>The Game generates and/or collects:<br><br><ul class="bb_ul"><li><b>Device Information:</b> Operating system, hardware specifications, graphics card, available memory. Held on the user's device and included where the user submits a report<br></li><li><b>Connection Data:</b> The IP address used to reach the Company's authentication service<br></li><li><b>Log Data:</b> Local log files including session events, errors, and crash information</li></ul><br><b>Log, crash, and device data remain on the user's device.</b> The Company receives such data where the user submits it, by using the built-in reporter with the attachment box ticked (see Section 2.8) and/or by attaching log files to a support email.<br><br><div class="bb_h3">2.4 Telemetry Data (Opt-In Only)</div><br>If the Game offers a telemetry program and the user chooses to participate, the Company additionally collects:<br><br><ul class="bb_ul"><li><b>Detailed Gameplay Analytics:</b> Feature usage frequency, navigation patterns, and gameplay patterns<br></li><li><b>Behavioral Data:</b> How the user interacts with menus, tutorials, and game systems<br></li><li><b>Session Data:</b> Anonymized gameplay patterns for balancing purposes</li></ul><br><b>Participation in telemetry is entirely voluntary.</b> The user can enable and/or disable telemetry at any time through the Game's settings menu. The Company genuinely appreciates those who help improve Crosstalk.<br><br><div class="bb_h3">2.5 Game Progress and Saves</div><br>The user's game progress and designs are stored:<br><br><ul class="bb_ul"><li><b>Locally:</b> On the user's device<br></li><li><b>Steam Cloud:</b> If the user has Steam Cloud enabled, saves sync across devices via Valve's infrastructure</li></ul><br><div class="bb_h3">2.6 Playtest Program Recordings</div><br>If the user participates in the Steam Playtest program, as described in Section 6 of the End User License Agreement, the Company may record the user's gameplay sessions. These recordings are retained for promotional purposes as consented to upon enrollment. The user may withdraw this consent at any time as described in EULA Section 6.2.4 and Section 9 of this Privacy Policy.<br><br><div class="bb_h3">2.7 Identifiers and Server-Side Retention</div><br>Data handled by the Company's authentication service is associated with the following identifiers:<br><br><ul class="bb_ul"><li>The user's Steam ID, Steam name, and/or Steam profile overall<br></li><li>The IP address used to connect</li></ul><br>This data is stored in encrypted form at rest, using post-quantum algorithms wherever possible and reasonable, for up to one (1) year after the user's last attempted connection to the game service servers, after which it is deleted and/or anonymized.<br><br><div class="bb_h3">2.8 Built-In Bug Reporter (Optional)</div><br>The Game includes a built-in bug reporter. The bug reporter is <b>fully optional</b>: it serves as an avenue should the user choose to transmit debugging information to the Company, and transmitting any data through it is entirely at the user's discretion, though greatly appreciated. When the user chooses to send a report, the transmission may include log data, crash information, device information, and any description the user provides. Bug reports are handled as described in Sections 7 and 8.<br><br><div class="bb_h3">2.9 Discord Integration</div><br>The Game integrates with Discord. Where the user links a Discord account, data is exchanged with Discord Inc., which acts as an independent controller for data held on its own infrastructure (see Section 6.1A).<br><br><b>2.9.1 When the integration applies</b><br><br><ul class="bb_ul"><li><b>Retail:</b> The Discord integration is <b>optional</b> and is controlled by the user through the Game's settings, which include a master switch for the integration, a presence toggle, a voice toggle, and controls to link and unlink the Discord account.<br></li><li><b>Steam Playtest:</b> Where the user participates in the Steam Playtest program, linking a Discord account and membership of the Company's Discord server are <b>required conditions of participation</b>, as described in Section 6 of the End User License Agreement. A user who does not wish to link a Discord account should not enroll in the Playtest.</li></ul><br><b>2.9.2 Data exchanged with Discord</b><br><br><ul class="bb_ul"><li><b>Authorization:</b> An OAuth authorization performed through the user's own Discord client, and the resulting access and refresh tokens, which are stored on the user's device<br></li><li><b>Account Identifiers:</b> The user's Discord user ID, username, and display name<br></li><li><b>Server Membership:</b> Whether the user is a member of the Company's Discord server, checked periodically while the integration is active<br></li><li><b>Rich Presence:</b> Where the presence toggle is enabled, the user's current in-game activity and status, which Discord displays on the user's profile to whoever can see it<br></li><li><b>Messages:</b> Where the user uses the in-game chat and/or lobby features, message content, message metadata, and message history retrieved for display<br></li><li><b>Voice:</b> Where the user uses in-game voice chat, audio is carried over Discord's infrastructure</li></ul><br><b>2.9.3 Playtest enrollment notices</b><br><br>On Playtest builds only, the Game posts an automated notice to a <b>private, access-restricted channel</b> on the Company's Discord server when a Playtest user links an account, and when a linked Playtest user leaves the Company's Discord server. Each notice contains the user's <b>Steam display name, Steam ID, Discord display name, and Discord user ID</b>, which together constitute a link between the user's Steam and Discord identities.<br><br><ul class="bb_ul"><li><b>Purpose:</b> Verifying eligibility for the Playtest gate and administering the Playtest programme.<br></li><li><b>Access:</b> The channel is restricted. It is accessible to the Company and to the third-party moderation tooling operating on the Company's Discord server; it is not visible to other Playtest participants and/or to the general membership of the server.<br></li><li><b>Retail:</b> These notices are not sent on retail builds.</li></ul><br><hr><br><br><div class="bb_h2">3. How the Company Collects Information</div><br><div class="bb_table"><div class="bb_table_tr"><div class="bb_table_th">Collection Method</div><div class="bb_table_th">Data Types</div><div class="bb_table_th">User Control</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>From Steam (on-device)</b></div><div class="bb_table_td">Account data</div><div class="bb_table_td">Managed via Steam settings</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Automatically, to the Company and to Valve</b></div><div class="bb_table_td">Authentication state, Steam identity, IP address, achievement and statistic events</div><div class="bb_table_td">Mandatory; necessary to run the Game</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Automatically, to Valve and optionally Discord</b></div><div class="bb_table_td">Rich presence</div><div class="bb_table_td">Steam privacy settings; Discord requires a connected account and the settings toggle</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>On the user's device</b></div><div class="bb_table_td">Designs, game state, logs, device information</div><div class="bb_table_td">Held locally; sent where the user submits a report</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>User-initiated submission (built-in reporter with the attachment box ticked, support email)</b></div><div class="bb_table_td">Bug reports, designs, log files, crash information</div><div class="bb_table_td">Fully optional; sent only at the user's discretion</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>With user consent</b></div><div class="bb_table_td">Telemetry data</div><div class="bb_table_td">Opt-in; toggle in settings</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Playtest enrollment</b></div><div class="bb_table_td">Gameplay recordings; Steam/Discord identity notice</div><div class="bb_table_td">Consent given upon enrollment; required for Playtest</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Discord integration</b></div><div class="bb_table_td">Discord account identifiers, server membership, presence, messages, voice</div><div class="bb_table_td">Optional in retail (settings toggles); required for Playtest</div></div></div><br><hr><br><br><div class="bb_h2">4. Legal Basis for Processing (GDPR)</div><br>For users in the European Economic Area (EEA), United Kingdom, and Switzerland, the Company processes personal data on the following legal bases:<br><br><div class="bb_h3">4.1 Contract Performance (Article 6(1)(b) GDPR)</div><br>Processing necessary to provide the Game and Services the user requested:<br><ul class="bb_ul"><li>Account authentication via Steam<br></li><li>Online game services provided through the Company's game service servers<br></li><li>Leaderboard functionality<br></li><li>Steam Cloud saves<br></li><li>Steam Workshop functionality<br></li><li>Discord account linking, server membership verification, and the Playtest enrollment notice described in Section 2.9.3, where the user participates in the Steam Playtest program and these are conditions of that participation</li></ul><br><div class="bb_h3">4.2 Legitimate Interests (Article 6(1)(f) GDPR)</div><br>Processing necessary for the Company's legitimate business interests, balanced against user rights:<br><ul class="bb_ul"><li>Fraud prevention and anti-cheat measures<br></li><li>Security monitoring and abuse prevention<br></li><li>Game balancing and improvement based on aggregated data<br></li><li>Bug fixing based on user-submitted reports</li></ul><br><div class="bb_h3">4.3 Consent (Article 6(1)(a) GDPR)</div><br>Processing based on the user's explicit consent:<br><ul class="bb_ul"><li>Telemetry data collection (opt-in)<br></li><li>Bug report transmission via the built-in bug reporter (at the user's discretion)<br></li><li>Playtest recordings for promotional use<br></li><li>The Discord integration on retail builds, including account linking, rich presence, chat, and voice, each of which the user enables and may disable through the Game's settings</li></ul><br>The user may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.<br><br><div class="bb_h3">4.4 Legal Obligation (Article 6(1)(c) GDPR)</div><br>Processing necessary to comply with legal obligations:<br><ul class="bb_ul"><li>Tax reporting for prize winnings<br></li><li>Responding to lawful government requests</li></ul><br><hr><br><br><div class="bb_h2">5. How the Company Uses Information</div><br>The Company uses collected information to:<br><br><div class="bb_table"><div class="bb_table_tr"><div class="bb_table_th">Purpose</div><div class="bb_table_th">Data Used</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Provide the Game</b></div><div class="bb_table_td">Account data; designs and game state remain on-device</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Authenticate and provide online services</b></div><div class="bb_table_td">Authentication state, Steam identity, identifiers (Section 2.7)</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Award achievements and maintain statistics</b></div><div class="bb_table_td">Achievement and statistic events</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Maintain leaderboards</b></div><div class="bb_table_td">Steam ID, scores, rankings</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Improve game quality</b></div><div class="bb_table_td">User-submitted reports, telemetry (if opted in)</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Prevent cheating</b></div><div class="bb_table_td">Gameplay patterns, technical data</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Customer support</b></div><div class="bb_table_td">Account data, information the user provides</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Promotional materials</b></div><div class="bb_table_td">Playtest recordings (with consent)</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Discord features (linking, presence, chat, voice)</b></div><div class="bb_table_td">Discord identifiers, membership, presence, messages, voice</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Playtest eligibility and administration</b></div><div class="bb_table_td">Steam and Discord identifiers (Section 2.9.3)</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Legal compliance</b></div><div class="bb_table_td">As required by law</div></div></div><br>The Company does <b>NOT</b> use user data for:<br><ul class="bb_ul"><li>Targeted advertising<br></li><li>Selling to data brokers<br></li><li>Profiling for purposes unrelated to the Game</li></ul><br><hr><br><br><div class="bb_h2">6. Data Sharing</div><br><div class="bb_h3">6.1 Valve Corporation (Steam)</div><br>The Game operates through Steam, and Valve processes data according to their own privacy policy. Data shared through Steam includes:<br><ul class="bb_ul"><li>Achievement and stats data<br></li><li>Leaderboard scores<br></li><li>Workshop content metadata</li></ul><br><b>Valve-Operated Services:</b> Certain services are provided directly by Valve, and data processing for these services is governed by Valve's Privacy Policy, not this Privacy Policy:<br><ul class="bb_ul"><li><b>Steam Cloud:</b> Cloud save data<br></li><li><b>Steam Workshop:</b> Workshop content hosting and distribution<br></li><li><b>Authentication:</b> Steam account services<br></li><li><b>Purchases and Refunds:</b> Steam store transactions</li></ul><br>For data processed by Valve through these services, refer to Valve's Privacy Policy.<br><br>Valve's Privacy Policy: <a class="bb_link" href="https://store.steampowered.com/privacy_agreement/" target="_blank" rel="">https://store.steampowered.com/privacy_agreement/</a><br><br><div class="bb_h3">6.1A Discord Inc.</div><br>Where the user uses the Discord integration (Section 2.9), data is exchanged with <b>Discord Inc.</b> Discord acts as an <b>independent controller</b> for data held on its infrastructure, and its processing is governed by Discord's own privacy policy, not this Privacy Policy.<br><br>Data reaching Discord includes the user's Discord account identifiers, server membership status, rich presence where enabled, message content and history where the user uses the chat features, voice audio where the user uses voice chat, and, on Playtest builds only, the enrollment notice described in Section 2.9.3.<br><br>The Company's own Discord server, including the restricted channel described in Section 2.9.3, is hosted on Discord's infrastructure and is subject to Discord's terms and policies. Third-party moderation tooling operating on that server processes data available to it within the server.<br><br>Discord's Privacy Policy: <a class="bb_link" href="https://steamcommunity.com/linkfilter/?u=https%3A%2F%2Fdiscord.com%2Fprivacy" target="_blank" rel=" noopener">https://discord.com/privacy</a><br><br><div class="bb_h3">6.2 No Sale of Personal Data</div><br><b>The Company does not sell personal data.</b> The Company does not share personal data with third parties for any marketing purposes, whether such third party's own marketing, joint marketing, and/or any other marketing purpose.<br><br><div class="bb_h3">6.3 Legal Disclosures</div><br>The Company may disclose user information if required by law, court order, and/or governmental authority, and/or if the Company believes disclosure is necessary to:<br><ul class="bb_ul"><li>Protect the Company's rights, property, and/or safety<br></li><li>Prevent fraud and/or abuse<br></li><li>Comply with legal process</li></ul><br><hr><br><br><div class="bb_h2">7. International Data Transfers</div><br><div class="bb_h3">7.1 Company Servers</div><br>Data the Company holds (including game service server data, support correspondence, user-submitted reports, telemetry if opted in, and Playtest recordings) is processed within the European Union. User data is processed exclusively at the Falkenstein data center (Germany) and/or the Helsinki data center (Finland).<br><br><div class="bb_h3">7.2 Valve Infrastructure</div><br>Steam Cloud, Steam Workshop, leaderboards, and authentication are operated by Valve Corporation globally. For data processed by Valve, refer to Valve's Privacy Policy and their data processing practices.<br><br><div class="bb_h3">7.2A Discord Infrastructure</div><br>Discord Inc. is established in the United States and operates globally. Where the user uses the Discord integration (Section 2.9), the data described in Section 6.1A is transferred to and processed on Discord's infrastructure outside the European Economic Area, under Discord's own terms and safeguards. Section 7.1 describes where the <b>Company</b> processes data and does not apply to data held by Discord and/or Valve.<br><br><div class="bb_h3">7.3 Safeguards</div><br>For any transfers of personal data outside the EEA, the Company ensures appropriate safeguards are in place, including:<br><ul class="bb_ul"><li>Standard Contractual Clauses (SCCs)<br></li><li>Data processing agreements<br></li><li>Technical security measures</li></ul><br><hr><br><br><div class="bb_h2">8. Data Retention</div><br>The Company retains user data according to the following schedule:<br><br><div class="bb_table"><div class="bb_table_tr"><div class="bb_table_th">Data Type</div><div class="bb_table_th">Retention Period</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Authentication state, Steam identity, achievement and statistic events</b></div><div class="bb_table_td">Up to 1 year after the last attempted connection</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Support correspondence</b></div><div class="bb_table_td">2 years from last contact</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Leaderboard entries</b></div><div class="bb_table_td">Indefinite (public scores)</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Anonymized/aggregated gameplay statistics</b></div><div class="bb_table_td">Indefinite</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>User-submitted bug reports and crash/log data</b></div><div class="bb_table_td">90 days</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Telemetry data</b></div><div class="bb_table_td">2 years, then anonymized</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Playtest recordings</b></div><div class="bb_table_td">Until consent withdrawal (per EULA Section 6.2.4)</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Playtest enrollment notices on Discord (Section 2.9.3)</b></div><div class="bb_table_td">Retained in the restricted channel for the duration of the Playtest programme; deleted on request and/or when the programme closes</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Data held by Discord</b></div><div class="bb_table_td">Governed by Discord's own retention practices</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Steam Cloud saves</b></div><div class="bb_table_td">User-controlled via Steam</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Game progress (local)</b></div><div class="bb_table_td">Until the user deletes it</div></div></div><br>After the retention period, personal data is either deleted and/or anonymized so it can no longer be associated with the user.<br><br><div class="bb_h3">8.1 Anonymization</div><br>When the Company anonymizes data, the Company removes and/or irreversibly alters all identifiers so the data cannot reasonably be linked back to the user. Anonymized data is no longer considered personal data and may be retained indefinitely for research, analytics, and game improvement.<br><br><div class="bb_h3">8.2 Account Deletion</div><br>If the user requests deletion of data and/or deletes the user's Steam account, the Company shall delete personal data within 30 days, except:<br><ul class="bb_ul"><li>Leaderboard entries (which display username only)<br></li><li>Anonymized and/or aggregated data<br></li><li>Data the Company is legally required to retain<br></li><li>Playtest recordings already incorporated into published promotional materials (per EULA Section 6.2.4)</li></ul><br><hr><br><br><div class="bb_h2">9. User Rights</div><br><div class="bb_h3">9.1 Rights for EU/EEA/UK Users (GDPR)</div><br>If the user is located in the European Economic Area, United Kingdom, and/or Switzerland, the user has the following rights:<br><br><div class="bb_table"><div class="bb_table_tr"><div class="bb_table_th">Right</div><div class="bb_table_th">Description</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Access</b></div><div class="bb_table_td">Request a copy of personal data</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Rectification</b></div><div class="bb_table_td">Request correction of inaccurate data</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Erasure</b></div><div class="bb_table_td">Request deletion of data ("right to be forgotten")</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Restriction</b></div><div class="bb_table_td">Request limited processing of data</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Portability</b></div><div class="bb_table_td">Receive data in a structured, machine-readable format</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Objection</b></div><div class="bb_table_td">Object to processing based on legitimate interests</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Withdraw Consent</b></div><div class="bb_table_td">Withdraw consent for consent-based processing</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Complaint</b></div><div class="bb_table_td">Lodge a complaint with a supervisory authority</div></div></div><br>To exercise these rights, contact the Company at <b><a href="mailto:[email protected]">[email protected]</a></b>. The Company shall respond within 30 days.<br><br><div class="bb_h3">9.2 Rights for California Residents (CCPA)</div><br>If the user is a California resident, the user has the following rights under the California Consumer Privacy Act:<br><br><div class="bb_table"><div class="bb_table_tr"><div class="bb_table_th">Right</div><div class="bb_table_th">Description</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Know</b></div><div class="bb_table_td">Request disclosure of personal information collected, used, and shared</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Delete</b></div><div class="bb_table_td">Request deletion of personal information</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Opt-Out of Sale</b></div><div class="bb_table_td">The Company does not sell personal information</div></div><div class="bb_table_tr"><div class="bb_table_td"><b>Non-Discrimination</b></div><div class="bb_table_td">The Company shall not discriminate against users for exercising rights</div></div></div><br>To exercise these rights, contact the Company at <b><a href="mailto:[email protected]">[email protected]</a></b>.<br><br><b>Verification:</b> The Company may need to verify the user's identity before processing requests. The Company shall use the user's Steam ID and associated email for verification.<br><br><div class="bb_h3">9.3 Rights for Other Jurisdictions</div><br>Depending on the user's location, the user may have similar rights under local data protection laws. Contact the Company to inquire about specific rights.<br><br><hr><br><br><div class="bb_h2">10. Children's Privacy (COPPA Compliance)</div><br><div class="bb_h3">10.1 Age Restriction</div><br><b>Crosstalk is not intended for children under the age of 13.</b> The Company does not knowingly collect personal information from children under 13 years of age.<br><br><div class="bb_h3">10.2 No Knowing Collection</div><br>The Company does not knowingly:<br><ul class="bb_ul"><li>Request and/or collect personal information from children under 13<br></li><li>Allow children under 13 to register and/or use the Game<br></li><li>Target marketing and/or advertising to children under 13</li></ul><br><div class="bb_h3">10.3 Parental Notice</div><br>If a parent and/or guardian believes their child under 13 has provided personal information to the Company, they should contact the Company immediately at <b><a href="mailto:[email protected]">[email protected]</a></b>. The Company shall:<br><ul class="bb_ul"><li>Verify the claim<br></li><li>Delete the child's personal information promptly<br></li><li>Terminate any associated account access</li></ul><br><div class="bb_h3">10.4 Age Verification</div><br>The Company relies on Steam's age verification mechanisms. By using the Game, the user certifies that the user is at least 13 years of age.<br><br><div class="bb_h3">10.5 Additional Content with Higher Age Requirements</div><br>The minimum age in Sections 10.1 and 10.4 applies to the Game. Individual items of Additional Content ("DLC", as defined in Section 1.1 of the End User License Agreement) carry their own age ratings, stated on that item's store listing, and some are rated for adults only with a minimum age of <b>eighteen (18) years</b>.<br><br>By purchasing, installing, and/or using any such item, the user certifies that the user meets the minimum age stated for it. The Company relies on Steam's age gating and account mechanisms for such content, and does not knowingly collect personal information from any user who does not meet the applicable minimum age. See Section 14.1A of the End User License Agreement.<br><br><hr><br><br><div class="bb_h2">11. Security Measures</div><br>The Company implements appropriate technical and organizational measures to protect personal data, including:<br><br><div class="bb_h3">11.1 Technical Measures</div><br><ul class="bb_ul"><li><b>Encryption:</b> Data handled by the Company's game service servers is encrypted over the wire and at rest, using post-quantum algorithms wherever possible and reasonable<br></li><li><b>Minimal Collection:</b> The Company collects only the data needed to provide the Game and its online services</li></ul><br><div class="bb_h3">11.2 Organizational Measures</div><br><ul class="bb_ul"><li><b>Limited Access:</b> Only authorized personnel can access personal data<br></li><li><b>Incident Response:</b> Procedures for detecting and responding to data breaches</li></ul><br><div class="bb_h3">11.3 Breach Notification</div><br>In the event of a personal data breach that poses a risk to user rights, the Company shall:<br><ul class="bb_ul"><li>Notify the relevant supervisory authority within 72 hours (GDPR requirement)<br></li><li>Notify affected users without undue delay if the breach poses a high risk<br></li><li>Document the breach and remediation steps</li></ul><br><hr><br><br><div class="bb_h2">12. Third-Party Links and Services</div><br>The Game may contain links to third-party websites and/or services (e.g., Steam Community, Workshop). The Company is not responsible for the privacy practices of these third parties. Users are encouraged to review their privacy policies before providing any personal information.<br><br><hr><br><br><div class="bb_h2">13. Changes to This Privacy Policy</div><br>The Company may update this Privacy Policy from time to time. Changes shall be effective when posted, and the Company shall update the "Last Updated" date at the top.<br><br>For material changes, the Company shall provide notice through:<br><ul class="bb_ul"><li>In-game notification<br></li><li>Steam announcement<br></li><li>Email (if the Company has the user's email address)</li></ul><br>The user's continued use of the Game after changes constitutes acceptance of the updated Privacy Policy.<br><br><hr><br><br><div class="bb_h2">14. Contact the Company</div><br>If users have questions, concerns, and/or requests regarding this Privacy Policy and/or personal data, contact the Company:<br><br><b>Ongakken Corporation OU</b><br><b>Kalaranna 8/2-30, 10415, Tallinn, Estonia</b><br>Email: <b><a href="mailto:[email protected]">[email protected]</a></b><br><br><div class="bb_h3">14.1 EU Representative</div><br>For users in the European Union, the Company's representative for GDPR purposes can be contacted at:<br><br><b>Ongakken Corporation OU</b><br><b>Kalaranna 8/2-30, 10415, Tallinn, Estonia</b><br>Email: <b><a href="mailto:[email protected]">[email protected]</a></b><br><br><div class="bb_h3">14.2 Supervisory Authority</div><br>If the user is in the EU and believes the Company has not adequately addressed concerns, the user has the right to lodge a complaint with the local data protection supervisory authority.<br><br>For Estonia: Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate)<br>Website: <a class="bb_link" href="https://steamcommunity.com/linkfilter/?u=https%3A%2F%2Fwww.aki.ee%2F" target="_blank" rel=" noopener">https://www.aki.ee/</a><br><br><hr><br><br><div class="bb_h2">15. Additional Information for Specific Features</div><br><div class="bb_h3">15.1 Steam Workshop</div><br><ul class="bb_ul"><li>Content the user uploads is governed by Steam's Workshop terms, policies, and guidelines<br></li><li>Workshop Content shall comply with Valve's Steam Workshop policies and shall not contain material illegal in any jurisdiction where Steam Workshop is served<br></li><li>The Company defers to Valve's policies regarding Workshop content compliance<br></li><li>The Company receives metadata about subscriptions and uploads<br></li><li>User-generated content is subject to the EULA licensing terms (see EULA Sections 4.6A, 4.7, 4.8, and 4.9)<br></li><li>The user bears sole responsibility for Workshop Content they upload</li></ul><br><div class="bb_h3">15.1A Discord</div><br><ul class="bb_ul"><li>Linking a Discord account is optional on retail builds and is controlled through the Game's settings; it is a required condition of participation in the Steam Playtest program<br></li><li>Rich presence, where enabled, displays the user's in-game activity on the user's Discord profile to whoever can see that profile<br></li><li>Chat and voice features carry message content and audio over Discord's infrastructure<br></li><li>The user may unlink the Discord account at any time through the Game's settings, which stops further exchange of data with Discord through the Game<br></li><li>Unlinking does not delete data already held by Discord; such data is subject to Discord's own policies and the user's rights against Discord</li></ul><br><div class="bb_h3">15.2 Leaderboards</div><br><ul class="bb_ul"><li>Leaderboard entries are public<br></li><li>The user's Steam display name and score are visible to all users<br></li><li>Users cannot opt out of leaderboard display while participating in ranked play</li></ul><br><div class="bb_h3">15.3 Esports and Tournaments</div><br><ul class="bb_ul"><li>Official competitions may require additional data (real name, age verification, tax information for prizes)<br></li><li>Tournament participation is governed by separate Competition Rules<br></li><li>Match recordings from official tournaments may be used for broadcast and promotional purposes</li></ul><br><hr><br><br><i>This Privacy Policy is effective as of August 2026.</i><br><br><b>Crosstalk</b> is a trademark of <b>Ongakken Corporation OU</b>. All rights reserved.