We explain what data we collect, how we use it and your rights under GDPR. Your privacy is taken seriously.
Important note
By using our services, you confirm that you have read, understood and agree to all the terms set out here.
1. Controller
- Tuga Army — contact: [email protected]
2. Data we process
- Identifiers: SteamID, nickname, avatar, session identifiers, IP and user agent.
- Account/Transactions: order_id, payment status (PayPal/EuPago), timestamps, TAC Coins balance/history, VIP/unban.
- Support and auditing: support communications, relevant activity logs (e.g. webhooks).
- Cookies/Analytics: Google Analytics identifiers (after consent). See the Cookie Policy.
3. Purposes and legal bases (GDPR art. 6)
| Purpose | Legal basis | Main data |
|---|---|---|
| Authentication and Account management | Performance of a contract (6(1)(b)) | SteamID, session |
| Payment processing | Performance of a contract (6(1)(b)); legal obligation (6(1)(c)) | order_id, status, timestamps |
| Granting VIP, TAC Coins, unban | Performance of a contract (6(1)(b)) | account, balance, history |
| Security and fraud prevention | Legitimate interest (6(1)(f)) | IP, logs, patterns |
| Analytics and improvement | Consent (6(1)(a)) | GA identifiers |
| Legal compliance (authority requests) | Legal obligation (6(1)(c)) | requested data |
- DPIA note: a Data Protection Impact Assessment will be carried out if we introduce extensive profiling or new high-risk processing.
4. Retention (periods and justifications)
| Category | Period | Justification |
|---|---|---|
| Transactions/receipts | 10 years | Accounting/tax obligations |
| Authentication and security logs | Up to 12 months | Security and defence of interests |
| Consent logs (cookies) | 5 years | Proof of compliance |
| Webhooks/anti-fraud | Up to 24 months | Legitimate interest (fraud) |
| Inactive accounts | Deletion or anonymisation after 12 months | Data minimisation |
| Support data | 24 months | Incident handling and defence |
- After the period, we delete or anonymise the data.
5. Sub-processors and international transfers
- Sub-processors: Steam (Valve), PayPal, EuPago, Google (Analytics), Cloudflare, AWS, Vercel.
- Typical locations: EU and/or USA.
7. Changes
- We will publish the update date; material changes may be communicated by email/in-app.
8. Contact
- Questions or requests: [email protected]
For legal questions or to exercise your rights