This Privacy Policy explains how Qloud Games Pty Ltd collects, uses, shares, and protects your personal information when you use Loftia, and the rights you have over that information.
It applies to the Loftia website (loftia.gg), the Loftia game and account system, and any beta or playtest programs we run (collectively, the “Service”). For how we deal with your personal data collected through our Discord Modmail bot, please see https://loftia.gg/discord-privacy.
This policy explains, plainly, what we do with your personal information. Where the law needs your permission, like advertising cookies or marketing emails, we ask for it separately, and you can change your mind at any time.
The data controller responsible for your personal information is:
Qloud Games Pty Ltd (ACN 658 781 885) Level 3, 55 Pyrmont Bridge Road, Pyrmont, NSW, Australia 2009
Email: [email protected]
References to “we,” “us,” and “our” mean Qloud Games Pty Ltd.
We collect only the information we need to run the Service, and for marketing, community management, and our business development and business protection purposes, as further specified below. The categories of personal information we collect are:
Account information: your email address, your chosen display name, the language you choose on our website and the language your browser is set to, and the country you signed up or first logged in from (worked out from your IP address) or other region that your platform reports, and the identifiers that link to your account and characters (including your platform account, such as Steam or Epic, and your character names).
In-game information: data tied to your account when you play: your characters and the gameplay data tied to your account; the messages you send in chat (including to facilitate sending them in-Game); and diagnostic and gameplay telemetry. If you link an email or make a purchase, we also hold that information (see Account information and Commercial information). If you report a problem or the game crashes, we may collect a screenshot and log files to help diagnose it.
Commercial information, including Kickstarter backer information: if you backed Loftia on Kickstarter, your name and pledge details, and (for backers who ordered physical rewards such as plush toys) the shipping address needed to deliver them. Otherwise, we may collect commercial information like your legal name and address, business number, bank account for the purpose of our commercial dealings with you.
Marketing list information: if you sign up for our mailing list, your email address.
Research survey information: if you choose to participate in a player survey, the information provided by you in that survey, which may include your email address, age, country, gender response, hobbies, and game purchasing and pricing preferences.
Support communications: if you contact us for support, primarily by emailing [email protected] or via our Discord server, the messages and information you share so we can help you.
Bug reports: if you report a bug through our website, what you tell us in the form (such as your platform, the part of the game affected and what went wrong), any screenshots, videos or log files you attach, your browser type and language, and, from your account, your email address and, if your account is linked to the game, your in-game account and character names, and, if your account is linked to Discord, your Discord user ID. Screenshots and log files can include other details from your device, such as its user name, so please check them and remove any personal information before you attach them. Parts of your bug report are posted publicly on our Discord server (see How We Share Your Information).
Technical and usage information: limited technical data collected automatically when you use the Service, such as your IP address, device and browser type, and basic diagnostic information, which we use to operate, secure, and troubleshoot the Service.
Advertising and analytics information: where you have accepted advertising or analytics cookies, or, in the regions where optional cookies run by default (see Cookies below), until you opt out: online identifiers stored by an advertising or analytics partner’s cookie, your IP address, the pages and actions you took on our site, and (for advertising partners only) a scrambled version of your email address (a “hash”) that cannot be turned back into your email address, used to measure whether our adverts work and to understand how the Service is used.
We do not directly collect payment or financial information. Payments for the game and for in-game purchases are handled by the relevant store or payment provider (such as Steam or the Epic Games Store), not by us.
We do not intentionally collect special categories of data (such as health, religious, or biometric data), and we ask that you do not share such information through the Service.
We generally collect your personal information directly from you. Where it is unreasonable or impractical to do so, we may collect your personal information from third parties, including game platforms and storefronts (like Valve and Epic Games), Discord, and players and other people who have dealings with you.
We use cookies and similar browser storage technologies in three categories:
Necessary: strictly necessary cookies that keep you logged in, maintain your authentication session, and remember your cookie choices. These are required for the account system to function and are exempt from consent requirements under EU/UK rules.
Analytics: used to understand how visitors use the Service so we can improve it. These include cookies set by Google Analytics and Microsoft Clarity.
Marketing: used to measure the effectiveness of our advertising. These include our advertising partners’ cookies (currently Meta and Google) and a session-storage record of which advert brought you here.
What we do depends on where you are. In the UK, the EU/EEA, Norway, Iceland, Liechtenstein, Brazil, South Korea, Thailand and China, and wherever we cannot reliably tell where you are, nothing optional is stored or loaded until you accept it, and a consent banner asks you on your first visit. Everywhere else, optional cookies may run from the moment you arrive and you can switch them off at any time from Your Privacy Options, linked in the footer of every page.
Global Privacy Control. If your browser sends a Global Privacy Control (GPC) signal, we treat it as a valid request to opt out of optional cookies and of any sharing of your information for cross-context behavioural advertising, without you having to do anything else. The choice you make yourself on our site overrides the signal on that browser, and we tell you when we have seen it before you make that choice.
For full details, including the names and lifetimes of individual cookies, see our Cookie Policy.
We use your personal data for the following purposes. For users in the EU, UK, and other regions that require a legal basis for processing, we rely on the following bases:
To create and operate your account and run the game and beta (account and in-game information): performance of a contract.
To provide the Service and send you functional emails: performance of a contract.
To see how well our advertising works in each country (the country recorded on your account): our legitimate interests. We only count it in aggregate and never share it with our advertising partners. You can object at any time (see Your Rights).
To provide customer support (support communications and account information): performance of a contract and our legitimate interests.
To investigate and fix bugs you report (bug reports and account information): our legitimate interests in keeping the Service working.
To show the bugs you report to other players, so they can discuss them and tell us when they have the same problem (the parts of your bug report described under Bug reports posted on our Discord): our legitimate interests in fixing the bugs that affect the most players and being open with our community.
To fulfil Kickstarter rewards, including shipping physical items (backer name and shipping address): performance of a contract.
To secure and moderate the Service, prevent fraud and abuse and provide for a safe online gaming environment, and improve and troubleshoot the Service (technical and usage information, account information): compliance with a legal obligation and our legitimate interests.
To send marketing emails and game news (marketing list email): your consent, which you can withdraw at any time, or on the basis of our legitimate interest in keeping you informed about the Service you registered for. Every marketing email includes an unsubscribe link, and you can opt out at any time.
To conduct voluntary player research and inform product and pricing decisions (research survey information): your consent. Survey reporting is de-identified before it is made available to analysts.
To measure and improve our advertising (advertising and analytics information): your consent in the EU, UK and the other regions listed under Cookies, where the legal basis for storing or reading advertising cookies on your device is always consent. Elsewhere, our legitimate interests, subject to your right to opt out at Your Privacy Options.
To understand how the Service is used and improve it (including in-Game analytics information): your consent in the EU, UK and the other regions listed under Cookies, where the legal basis for storing or reading analytics cookies on your device is always consent. Elsewhere, our legitimate interests, subject to your right to opt out at Your Privacy Options. Comparing which version of a page or form works better is done on our own pages under our legitimate interests, reported only as aggregate counts and never shared; storing the version in your browser between pages requires your consent, and refusing it does not affect what you see.
To comply with legal obligations: compliance with a legal obligation.
Where we rely on legitimate interests, we have weighed those interests against your rights and concluded the processing is proportionate. You can object to this processing at any time (see Your Rights).
Automatic Checks
In some circumstances, automatic checks may be used in the Services for moderation or gameplay purposes – for example, to help us keep the game safe, text chat may be checked against a fixed list of offensive words.
We do not sell your personal information for money. We share information only in these limited circumstances:
Service providers. We use a small number of trusted providers who process data on our behalf, under contract and only on our instructions. These include our hosting and database infrastructure providers (eg. AWS), our email, marketing and advertising partners, and bug reporting partners (eg. Sentry).
Platform providers and business partners. We may disclose personal information to business partners with whom we jointly offer Services, which may include the companies that provide the platforms on which you play or through which you download or launch our games (eg. Epic Games, Valve).
These providers may also collect some information directly under their own privacy policies. The countries involved are described under International Data Transfers.
Bug reports posted on our Discord. When you report a bug through our website, we also post it in the bug forum on our Discord server, where anyone in the server can read it, reply to it and upvote it. The post shows the title and description you wrote, the part of the game affected, the type of bug, your platform, and any screenshots and videos you add in the main attachments field. Log files and the system information you give us are never posted. If your Loftia account is linked to your Discord account and you are a member of our server, the post mentions you; otherwise it shows no name. The form tells you this before you send a report. Discord is based in the United States, and what is posted there is also covered by Discord’s own privacy policy.
Advertising partners. Where you have accepted marketing cookies, or in the regions where optional cookies run by default, until you opt out: online identifiers, your IP address and the pages you viewed are disclosed to our advertising partners (currently Meta and Google) so that we can measure whether our adverts work. Under California law this counts as “sharing” for cross-context behavioural advertising, even though no money changes hands. You can stop it at any time at Your Privacy Options, and we instruct our partners to apply limited-data-use mode where a Global Privacy Control signal is present. When you complete a sign-up, we also share a hashed version of your email address with our advertising partners so they can measure that their advert led to your registration. Hashing converts your email into a coded string before it leaves us, so we do not share it in readable form; it is used only to check whether an advert worked. We do this only where you have accepted marketing cookies, and we never share your readable email, your account identifier, or anything you do inside the game.
Legal and safety reasons. We may disclose information where we believe in good faith it is necessary to comply with a legal obligation, enforce our terms, protect the rights, property, or safety of Loftia, our players, or the public, or investigate possible wrongdoing.
Business transfers. If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.
International Data Transfers
We are based in Australia, and many of our service providers, platform providers and business partners are located in the United States, including Amazon Web Services, Epic Games and Valve (which operate Epic Online Services and Steam), and our error-reporting and email providers. Our game-server hosting provider runs servers that may be located in the region nearest you. This means that if you are located in the EEA, the UK, or elsewhere, your personal information may be transferred to and processed in the United States and Australia, and handled by game servers located in regions around the world that are run for the purpose of reducing player latency and improving the player experience.
We keep personal information only as long as we need it for the purposes described in this policy, or as required to meet legal obligations, resolve disputes, and enforce our agreements. In more detail, as at the date of this Privacy Policy:
Your account and in-game data. We keep your account and in-game information (such as your characters, items, progression, and linked email) for as long as your account exists. When you ask us to delete your account, we delete this information within 30 days, except for the limited records described below that we are required or permitted to keep for longer, such as purchase records and safety records.
Gameplay telemetry and diagnostics. Diagnostic and gameplay telemetry is kept for up to 24 months, after which we delete it or keep it only in a form that no longer identifies you.
Chat. We may collect and retain in-game chat messages for a limited period for moderation, player safety and legal compliance purposes, and for longer where a message is part of a player report or where we are required to preserve it by law.
Player reports and moderation. We keep player reports, and the moderation and ban records related to them, for up to 24 months, or longer where we need them to keep the Service safe. We may keep ban and safety records even after an account is deleted, so that a banned player cannot simply create a new one.
Support communications. We keep support conversations, including in-game support chat, email, and messages through our Discord server, for up to 24 months after your request is resolved.
Purchases. We keep records of purchases and in-game currency transactions for 7 years to meet our tax, accounting, and other legal obligations, and we keep these even if you delete your account. We never see your payment card details, as they are handled by the relevant store or payment provider, not by us.
Crash and error reports. Crash reports and in-game feedback sent to our error-reporting provider are kept for up to 90 days.
Marketing list. We keep your email on our marketing list until you unsubscribe.
Research surveys. Identifiable survey responses are retained for up to 24 months. De-identified aggregate or response-level research data may be retained for longer to preserve the validity of product research.
Bug reports. We keep a bug report for 24 months after you send it, and the files you attach for 180 days, then delete them automatically.
We also copy your report into our internal bug tracker, and we may post it as a public thread on our Discord server for players to discuss and upvote. Screenshots or videos you attached can appear in that post. The bug tracker copy (the description of the bug and any files copied to it) may be kept for as long as we need it to fix the bug, but your character name or email address is removed from it when the report is deleted.
After a report or your account is deleted, the Discord thread and its discussion stay, as do any screenshots or videos you attached, but the mention of you is removed. Email [email protected] if you want the post, or your attachments in it, taken down.
Advertising and analytics. Advertising cookies last up to 90 days and analytics cookies up to 2 years (see our Cookie Policy), or until you opt out. We keep user-level analytics data for up to 14 months after your last visit, and aggregated statistics that do not identify you may be kept longer. Our advertising and analytics partners keep the data they receive under their own privacy policies.
Where the law requires it (including in the EEA and UK), the legal basis for storing or reading advertising and analytics cookies on your device is your consent, and nothing optional is stored on your device before you give it. Elsewhere, we rely on our legitimate interest in understanding and promoting the Service, and optional cookies run until you opt out. You can withdraw consent or opt out at any time from Your Privacy Options without affecting anything we did while it was in force.
When information is no longer needed, we delete or anonymise it.
We take reasonable technical and organisational measures to protect your information, including secure hosting and restricted access. However, no method of transmission over the Internet or method of electronic storage is completely secure, and we cannot guarantee its absolute security.
Loftia’s core audience is 18+, although you may create an account or otherwise use the Service (with parental agreement, if applicable) if you are 13 years old or older (or such higher age as applicable in your jurisdiction). The Service is not directed to children under 13, and we do not knowingly collect personal information from them.
If you are a parent or guardian and believe a child under 13 has provided us with personal information, please contact [email protected] and we will delete it.
Where additional protections apply to users under 18, we will comply with those requirements, including any applicable age-assurance and child-protection measures.
You have rights over your personal information. How to exercise them, and the specific rights available, depend on where you live. In all cases, contact us at [email protected] to make a request. We may need to verify your identity before we act, and we will respond within the timeframes required by applicable law.
Subject to your jurisdiction, you will generally have the right to:
Access a copy of the personal information we hold about you;
Rectify inaccurate or incomplete information;
Withdraw consent at any time, where we rely on consent (although this will not affect the lawfulness of our processing of your personal data prior to consent being revoked); and
Lodge a complaint with your local data protection authority (in the UK, the Information Commissioner’s Office).
In some jurisdictions, including the EEA and the UK, you have the right to:
Erase your information (“right to be forgotten”);
Restrict or object to certain processing, including direct marketing;
Data portability, the right to receive your information in a structured, machine-readable format;
We will respond to your request within one month, extendable by up to two further months for complex requests, in which case we will tell you within the first month.
These rights are not absolute. For example, we may keep some information where we are required to by law (for example, financial records) or where we have an overriding legitimate interest (for example, safety and moderation records), as described under How Long We Keep Your Information.
California and Other US States
We do not sell your personal information for money. We do “share” personal information as California law defines that term: online identifiers and information about your activity on our site are disclosed to an advertising partner for cross-context behavioural advertising, unless and until you opt out. The categories involved are identifiers (including cookie identifiers, IP address, and a hashed form of your email address) and internet activity information.
You may have the right to opt out of that sharing, and you can exercise it in three ways: from Your Privacy Options, linked in the footer of every page; by sending a Global Privacy Control signal from your browser, which we honour as a valid opt-out request without further action from you; or by emailing [email protected]. You may also have other rights enshrined in law.
We will not discriminate against you for exercising any of these rights. Your account, rewards and access to the Service are unaffected. We do not sell your personal information. Where we “share” it for cross-context behavioural advertising (as described above), we do not knowingly do so for anyone under 16. We do not process sensitive personal information for the purposes that would trigger a right to limit its use. We will respond to verifiable requests within 45 days, extendable where permitted.
Australia
If you are in Australia, and you have a concern about how we handle your information, please contact us first. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.
As noted in the International Data Transfers section, we disclose personal information overseas (to the United States), consistent with APP 8.
Marketing Communications
You may exercise your right to opt out of marketing emails at any time by clicking the “unsubscribe” link contained in each email. Unsubscribing does not stop essential service or account-related messages.
Third Party Services
The Service may contain links to other websites or services that are not operated by us (such as our social media pages, third party gaming platforms or other partners). This Privacy Policy doesn’t and can’t cover all such third parties, and we encourage you to review their terms and privacy settings before engaging with them.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will post the updated version on this page and update the “Last updated” date. For material changes, we will take additional steps to notify you where required. You are advised to review this Privacy Policy periodically for any changes.
Contact Us
If you have any questions about this Privacy Policy or how we handle your information, you can contact us:
Qloud Games Pty Ltd Level 3, 55 Pyrmont Bridge Road, Pyrmont, NSW, Australia 2009
Privacy Officer: [email protected]
