Privacy Policy

1. Who is responsible

Toni Lukkaroinen, Finland, runs Hiili as a private individual and is the controller of your personal data. Contact us about privacy at toni.lukkaroinen@gmail.com. We have not appointed a data protection officer.

2. What we collect

We do not ask for your real name, email address (unless you write to us), precise location or contacts, and we do not seek out special categories of personal data. Please do not share such details in chat or on boards.

3. What stays on your computer

The game creates these files next to itself and does not send them to us. You can delete them, though deleting a wallet file without your recovery phrase means losing access to your funds:

When you use the wallet, the game asks a public Hoosat service (proxy.hoosat.net) for balances and sends transactions through it. That service sees your IP address and wallet addresses.

4. Why, and our legal bases

If the GDPR or UK GDPR applies to you, these are the purposes we use your data for, and the legal basis for each:

You need to give a name, a password and a date of birth to create an account; without them we cannot provide one.

Automated decisions. The server works out your age from your date of birth, and refuses the wallet if you are under 18. If you think your date is wrong, contact us and a person will look at it. We make no other automated decisions with legal or similarly significant effects, and do no profiling.

5. Who sees it

We do not sell personal data, share it for advertising, or show ads.

6. How long we keep it

7. International transfers

Our game server is in Finland. Players connect from around the world, and other players, wherever they are, receive your name and chat as part of the game. If you turn on the itch.io widget, your browser connects to itch.io, which is based in the United States; that happens on your explicit consent (GDPR Art. 49(1)(a)). The Hoosat network is a global network of independent computers. If we use a provider outside your country that receives your data from us, we use a lawful transfer mechanism such as an adequacy decision or standard contractual clauses, and you can ask us for a copy.

8. Security

Please read this. The connection between the game client and the game server is not encrypted at the moment. That includes your password when you log in, your date of birth when you register, and your chat. Anyone who can watch the network between you and the server could read them. We are telling you this so you can protect yourself: use a password you use nowhere else. We will update this section when that changes.

What we do: passwords are stored only as salted, repeatedly hashed values; repeated wrong passwords slow down login attempts; and the server checks game actions rather than trusting the client. Wallet keys are encrypted on your own computer and are never sent to us.

If a breach puts your data at risk, we will notify the authorities and affected players as the law requires. Because we do not have your email address, we would tell you in the game and on this website.

9. Children

Hiili is not for children under 13, and we do not knowingly keep their data. If you are under the digital consent age where you live, up to 16 in some countries, a parent or guardian must agree for you. If you believe a child under 13 has an account, contact us and we will delete it. Parents and guardians can use the rights below for their child. Young players: keep your real name, address, school and photos out of chat.

10. Your rights and how to use them

Depending on where you live, you may have the right to:

How to ask. Email toni.lukkaroinen@gmail.com and tell us your player name and what you want. Never send your password. To check that the account is yours, we will give you a one-time code to type into the in-game chat while logged in. If you can no longer log in, tell us and we will find another way. We answer within one month (45 days where US state law applies), and for free unless a request is clearly unfounded or excessive.

What deleting does. We delete your account, date of birth and character, and remove your player name from what you built. The builds themselves can stay in the shared world. Chat that other players have already seen cannot be recalled, logs expire as in section 6, payment records stay as long as accounting law requires, and blockchain transactions cannot be removed. Parcels you own would be released, so read the Wallet, Land and Market Terms first.

11. Rules for particular places

European Economic Area, United Kingdom and Switzerland

You can complain to the data protection authority where you live or work, or where you think the problem happened. You do not need to contact us first, though we would welcome the chance to help. We are based in Finland, so our lead authority is the Office of the Data Protection Ombudsman.

California and other US states

In the last 12 months we collected these categories, for the purposes in section 4 and from you directly: identifiers (player name, IP address, wallet addresses), age, commercial information (land and coin purchases, market sales), internet or network activity (gameplay and logs), and account login details, which are sensitive personal information and are used only to let you log in. We do not sell or share personal information as California law defines those words, including that of anyone under 16. There is nothing to opt out of, so browser signals such as Global Privacy Control have no further effect. You or an authorised agent can use the rights in section 10, and if we refuse a request, you can appeal by replying to our answer.

Brazil

You have the rights in Article 18 of the LGPD and can complain to the ANPD. Our legal bases are those in section 4, read as their LGPD equivalents.

Canada, Australia, New Zealand, Japan, South Korea and elsewhere

You can use the rights in section 10 wherever you live, and complain to your national privacy regulator. If you play from outside the country our server is in, your information is sent there, where the law may differ from yours.

12. Changes

When the game starts collecting something new, or we change how we use data, we will update this page before it happens and tell you in the game if the change is significant.