Privacy policy
Who is responsible
The controller is the publisher of Handler: Mathieu Vigne, sole proprietor (EI), trading as Wavify, SIREN 898 183 504.
Contact for any question about your data: [email protected]
Handler has no data protection officer: the contact above answers these requests.
Handler plays two roles. For members' accounts, billing, the security of the service and the shared anticheat network, it is a controller. For player data collected from an organization's servers, it is a processor for that organization, which is the controller: the data processing agreement describes this framework.
Members' data
You are a member when you have a Handler account. We process:
- your account: email address, display name, language, date of creation and of email verification, hashed password (never in clear text);
- your place in organizations: membership, roles, permissions, email and notification preferences;
- your security: sessions (hashed token, device type such as “Chrome on macOS”, dates, IP address fingerprint), two-factor authentication (encrypted secret, hashed backup codes), passkeys (public key), single-use tokens, security log (sign-ins, password or settings changes, with an IP address fingerprint);
- your linked accounts: Steam or Discord identifier and name, if you link them;
- the mobile app: the device's notification token, platform, app version, language, quiet hours; device attestation key (Apple App Attest);
- your actions in an organization: an audit log that keeps who did what, when, with the before and after values and an IP address fingerprint;
- your exchanges with us: the messages you send to the contact address.
We do not store your IP address in clear text in the database: only a fingerprint computed with a secret key is kept, which allows comparing and limiting abuse without recovering the address. The IP address is still visible, for the duration of the request, to the servers and network providers that carry the traffic.
Billing
For a paid plan, we process: the billing country, the VAT number if you give one, the Stripe customer and subscription identifiers, the subscription status, invoices and refunds.
Bank card data is entered at Stripe. Handler does not receive or keep it.
Contact requests
When you write from the migration form on the site, we process: your name, your email, your community's name, the tool you use, the number of servers, your message and a fingerprint of your IP address. This data is used to answer your request and to prepare the migration.
The request is emailed to the platform administrators, and an acknowledgement is sent to you. Your message is not read automatically.
Players' data
When an organization connects a server, Handler collects for it the data the game exposes:
- game identity: SteamID, nicknames used, dates and number of sessions on each server;
- activity: kills, deaths, weapons, distances, factions, cash, ping, match events, presence readings;
- moderation: sanctions (kicks, bans, reasons, durations), team notes, anticheat cases and detections, votes and polls the player takes part in;
- tickets: messages, evidence links, an optional email address that the player gives and confirms to be told about replies;
- public Steam profile: nickname, avatar, declared country, account age, VAC and game bans, retrieved from Steam.
Handler does not collect players' IP addresses on game servers.
The organization decides what it publishes. A public page shows only what it turns on: server status, leaderboard, matches, profiles. Players appear there by nickname; a profile has a random address with no computable link to the SteamID.
A player can sign in with Steam on a public page, without a Handler account. We then keep their SteamID and a hashed session token for 30 days. This sign-in lets them remove themselves from public pages, open a ticket, vote and appeal a report.
Why and on what basis
- Providing the service (account, organizations, servers, tickets, API, app): performance of the contract or of pre-contractual measures.
- Answering a contact or migration request: pre-contractual steps taken at your request, and legitimate interest in answering the people who write to us.
- Securing accounts and the service (sessions, two-factor authentication, rate limits, bot check, security log, abuse detection): legitimate interest in protecting the service and its users.
- Invoicing and bookkeeping: performance of the contract and legal obligation.
- Sending essential emails (verification, security, billing): performance of the contract. Optional emails (automations, ticket replies) can be turned off from a link in the email or in your settings.
- Sending mobile notifications: your consent, given in your device's system and withdrawable at any time.
- Anticheat and shared network: legitimate interest of organizations and of Handler in protecting servers against cheating and abuse, with the safeguards described below.
- Providing a moderation service to an organization: on behalf of the organization (processing).
Anticheat, shared network and automated decisions
The anticheat computes statistical clues from gameplay activity, which open cases. By default no sanction is automatic: a human reviews the case.
An organization may turn on automatic actions (kick, ban). They apply only if at least two independent signal families exceed their threshold, are capped by an hourly circuit breaker, and remain subject to a human review within an adjustable delay. In that case the organization is responsible for the decision. The player can always ask for human intervention, state their view and appeal the sanction.
The shared network is optional and turned on organization by organization, with three separate consents: sharing anonymized kill statistics, publishing reports, receiving others' reports. A report starts from a case confirmed by a human or from an active ban, with a category and a short summary. Organizations that receive it see a reputation, a number of organizations and a date, never the organization that published it. Only platform moderators can see it.
If an organization chooses to apply a network report automatically, at least two independent organizations are required. When a report is withdrawn or overturned, the bans it caused are lifted.
A player can appeal a report after signing in with Steam on a public page. The organization that published it answers within 7 days. After that, a platform moderator confirms or overturns it. An organization cannot republish on the same player and category for 90 days after an overturn, or 30 days after a withdrawal.
Who receives the data
Data is not sold. It is accessible to the publisher, to the members of an organization according to their permissions, and to the following providers, which process it on our behalf:
- OVH SAS: hosting of the servers and the database (Italy (OVHcloud datacenter), in the European Union).
- Cloudflare, Inc.: network, protection and Turnstile bot check (United States).
- Stripe Payments Europe, Ltd and Stripe, Inc.: payment and billing (Ireland, United States). Stripe is also a controller for its anti-fraud and anti-money-laundering obligations.
- Brevo (Sendinblue SAS, France) or another transactional email provider: email address and content of the emails sent (delivery).
- Apple (APNs, App Attest) and Google (FCM, Play Integrity): mobile notifications and verification of the app's authenticity (United States).
- Valve (Steam): Steam OpenID sign-in and public profiles (United States). Valve acts on its own behalf.
- Discord Inc.: if you link your Discord account or your organization installs the bot (United States). Discord acts on its own behalf.
We may also disclose data to an authority if the law requires it.
Transfers outside the European Union
Cloudflare, Stripe, Apple, Google, Valve and Discord may process data in the United States. These transfers rely on the European Commission's adequacy decision for the Data Privacy Framework, when the provider is certified under it, or on the Commission's standard contractual clauses, with supplementary measures where needed.
The host processes data in Italy (OVHcloud datacenter), in the European Union: no transfer outside the European Union for hosting.
To get a copy of the applicable safeguards, write to the contact address.
For how long
- Account: as long as it exists. On deletion, the email, name, password, two-factor authentication, passkeys, linked accounts, devices and memberships are erased. The account row remains, anonymized, so that organizations' audit history stays readable.
- Sessions: inactive after 14 days, 90 days at most; an expired or signed-out session is deleted 30 days later. Email verification tokens: 24 hours. Password reset: 20 minutes. Email change: 1 hour. Invitations: 7 days.
- Handled contact requests: 365 days after they were handled, then deleted. A request that is not handled yet is kept until it is.
- Security log: 365 days, then deleted. Audit log: as long as the organization exists, then anonymized with it.
- Proof of acceptance of the terms (document, version, date, hash of the IP address): as long as the account exists, then in anonymized form.
- Disabled notification devices: 30 days. Unused device attestation keys: 180 days.
- Player session on the public site: 30 days.
- Detail of game events (kills, readings, match events): currently kept without a time limit, like the aggregates. A retention period may be set for the Free plan; it will be announced by email and on the Pricing page, with notice before it applies, and will only apply going forward.
- Statistical aggregates (totals, leaderboards, player histories): kept without a time limit while the organization exists.
- Automation run logs and webhook deliveries: 30 days.
- Sanctions, notes, tickets and cases: as long as the organization keeps them, and at the latest until the end of the contract with it.
- Network reports: while they are active. A withdrawn or overturned report stops counting.
- Invoices and accounting records: 10 years (legal obligation).
- Server technical logs: 1 month.
- Requests sent to the contact address: the time needed to handle them, then 1 year.
At the end of the contract with an organization, its data is deleted or returned as set out in the data processing agreement.
Your rights
You can ask for access to your data, its rectification, its erasure, restriction of processing and portability, and object to processing based on legitimate interest. You can withdraw a consent at any time and give instructions about what happens to your data after your death.
To exercise these rights, write to [email protected]. We answer within one month, extendable by two months if the request is complex. We may ask for reasonable proof of identity.
You can delete your account and download a copy of your data (JSON file) yourself from the settings, once a day, after confirming your identity.
If you are a player, you can contact the organization that runs the server, which is the controller for your game data, or contact us: we point you to the right place and help the organization answer. For the shared network, contact us directly. You can also remove yourself from public pages by signing in with Steam.
If you think your rights are not respected, you can complain to the CNIL (cnil.fr, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07).
Security
Handler protects data with proportionate measures: encrypted connections, passwords and tokens stored hashed, two-factor secrets and RCON passwords encrypted, IP address fingerprints, two-factor authentication and passkeys, data separated by organization, rate limits, logs with cookies and authentication headers masked.
In case of a data breach likely to create a risk for you, we notify the CNIL within 72 hours and inform you if the risk is high.
Minors
You must be 15 to create an account. A younger player may appear on an organization's server; the organization is then responsible for their data. If you are a parent and think a child created an account, write to us: we delete it.
Changes
We update this policy when our processing changes. The version and date are at the top of the page. An important change is announced in the service or by email.