Privacy Policy

Last updated 19 October 2026

This policy explains what personal data the game Countervalue and the website countervalue.game process, why, for how long, and what rights you have. We collect as little as the game needs to work: there is no advertising, no analytics, no tracking and no selling of data.

Who is responsible

The data controller is Nominandum AS, Foretaksregisteret 923 937 293 MVA, Nordskjørveien 1114, 7180 Roan, Norway.

For anything about privacy, write to support@countervalue.game.

We process personal data under the General Data Protection Regulation (GDPR) as it applies in Norway through the Personal Data Act (personopplysningsloven).

What we process, and why

Your account

You sign in with Game Center (Apple) or Steam (Valve). We do not ask for your email address, real name or password. When you sign in we store:

• a random account number we create for you;
• the player identifier your platform gives us: your Game Center team player ID, or your Steam ID;
• your display name, taken from Game Center or Steam and updated each time you sign in;
• when the account was created and when the sign-in was linked.

Why: to recognise you between sessions and show your name to the players you play with. Legal basis: performance of our agreement with you to provide the game (GDPR Art. 6(1)(b)).

Proof of purchase

To check that a copy was bought, we verify a purchase record from the store when you sign in, and keep:

• App Store: whether the copy is owned, the original purchase date, the version first installed, and whether it is a test build.
• Steam: whether the copy is owned, whether the licence is permanent or a trial, and the Steam ID of the account that owns the copy. If you play a copy lent to you through Steam Family Sharing, that is the lender's Steam ID, not yours.

Why: to make sure the game is played on legitimately obtained copies. Legal basis: our legitimate interest in protecting the game against unlicensed use (Art. 6(1)(f)).

Playing a game

While a multiplayer game is running, the server holds the players' account numbers, display names and in-game actions. A running game is saved to disk every 30 seconds so it survives a server restart. The saved copy is deleted when the game ends, or after 7 days without activity.

Your display name is visible to the other players in your games, and in the list of open games that anyone can browse, because a game is named after its host.

Legal basis: performance of our agreement with you (Art. 6(1)(b)).

Game records

Every online game is recorded on the game server: how the map changed, and every order each player gave, under their display name. When the game ends, the game server sends us a summary of it: who played, with their account numbers, display names, factions and scores; when it started and ended; and its chat, as described below. Both are deleted 30 days after the game ends, unless a report about the game is still being handled.

Why: to handle reports about a game, and to investigate problems in it. Legal basis: our legitimate interest in a safe community and a working game (Art. 6(1)(f)).

Chat

Messages in a game's chat and in alliance chat are kept with the game's record, for 30 days after the game ends. We read them only when someone reports a player or appeals a moderation decision.

Direct messages between two players are held only in the game server's memory and are never stored, unless one of the two reports a message in the conversation (see below).

A muted player is muted for the current server session only.

If you block a player, we store that you blocked them, so their messages stay hidden in every game. The block is deleted when you unblock them.

Legal basis: passing messages and enforcing blocks is performance of our agreement with you (Art. 6(1)(b)); keeping game chat is our legitimate interest in handling reports (Art. 6(1)(f)).

Reports and moderation

When a player reports a chat message, we store:

• the reported message and the reason given;
• up to ten messages before it and five after it in the same conversation, so the report can be understood in context. For a direct message, this is the only part of the conversation that is stored;
• the account numbers and display names of the reporter and the reported player;
• which game, server and channel it was in, and when.

We email the reported message to our moderation inbox so a person reviews it; the surrounding messages are not emailed. The report also appears in the game server's log.

Why: to keep the game free of harassment and abuse, to act against players who break the rules, and to handle appeals. Legal basis: our legitimate interest, and that of other players, in a safe community (Art. 6(1)(f)).

Server logs

Our servers keep technical logs for security and troubleshooting. These include IP addresses of connections to the game servers and the websites, the account numbers and display names of players joining games, and sign-in and moderation events. Logs are deleted automatically as they rotate.

Legal basis: our legitimate interest in running a secure, working service (Art. 6(1)(f)).

Emails you send us

If you write to us, we receive your email address and what you write. Mail sent from the game's Feedback screen also includes the game's version and build, the platform and store, and your operating system version, so we can investigate. Nothing is sent until you choose to send the email.

Legal basis: our legitimate interest in answering you and improving the game (Art. 6(1)(f)).

Stored only on your device

Settings, an installation identifier and, if you turn the option on, saved single-player games stay on your own device and are not sent to us. On a Mac the default name in offline games is your computer account's name. It is used only on your device.

What we do not do

We use no analytics, advertising, tracking or crash-reporting services. We do not collect your location, contacts or device identifiers for advertising. We make no automated decisions with legal or similarly significant effects on you. The website sets no cookies and runs no scripts.

Who receives the data

• Hetzner Online GmbH hosts our servers in Falkenstein, Germany and Helsinki, Finland, as our data processor.
• Postmark (ActiveCampaign, LLC, USA) delivers the moderation emails described above, as our data processor.
• Apple and Valve provide sign-in and purchase verification. To verify a Steam sign-in we send your sign-in ticket and Steam ID to Valve, and receive your Steam display name back. Apple and Valve process your data under their own privacy policies, as independent controllers.

We do not sell or share your data with anyone else, except where the law requires it.

Transfers outside the EEA

Our own servers are in the EEA. Postmark, Apple and Valve are in the United States. Transfers to Postmark are based on the EU–U.S. Data Privacy Framework or the European Commission's standard contractual clauses. Data you exchange with Apple and Valve is governed by your own agreements with them.

How long we keep it

• Account and purchase data: while your account exists. Ask us and we delete it.
• Running games: until the game ends, or 7 days after the last activity.
• Game records, recordings and game chat: 30 days after the game ends. A game with a report that is still being handled is kept until the report, and any appeal, is closed.
• Direct messages: only in the game server's memory, until that server restarts, unless they are part of a report.
• Blocks: until you unblock the player, or your account is deleted.
• Reports: as long as needed to handle the report, any appeal, and to recognise repeated abuse by the same account.
• Logs: for a limited time, after which they are deleted automatically as they rotate.
• Backups: the account database is backed up so it can be restored after a failure. Backups are kept for up to 90 days, so deleted data disappears from them within 90 days.

Your rights

You have the right to:

• see the personal data we hold about you and get a copy of it;
• have incorrect data corrected. Your display name comes from Game Center or Steam, so changing it there updates it here the next time you sign in;
• have your data deleted;
• restrict our processing, or object to processing based on our legitimate interests;
• receive the data you gave us in a machine-readable format.

To use any of these rights, email support@countervalue.game from the game's Feedback screen or include your display name, so we can find your account. We answer within one month.

If you think we process your data unlawfully, you can complain to the Norwegian Data Protection Authority (Datatilsynet), www.datatilsynet.no, or to the data protection authority where you live.

Changes to this policy

If we change how we process personal data, we will update this page and the date at the top.