1) Who We Are (Data Controller)
Controller: Federico Figone (registered company in Italy)
Contact: alpha@hordesofthefallen.com
For all requests about your personal data (access, deletion, objection, etc.) please contact us by email.
2) What Data We Collect
Data you provide
- Email address (required for waitlist and program communications).
- Optional questionnaire answers (e.g., preferred modes, favorite games, feedback).
- Age confirmation (checkbox confirming you are 16+ or have parental authorization).
- Marketing consent (optional, separate checkbox).
Data we generate/collect automatically
- Recruit/Referral ID we assign to you (e.g., HFT-XXXXXX).
- Referrer code (if you arrived via a referral link like
?ref=HFTXXXX). - Technical metadata during signup (e.g., IP address and user-agent for security and consent records).
3) Purposes and Legal Bases
Game programs (Alpha/Beta) & Development
We use your data to administer access keys, organize testing waves, collect feedback, and communicate essential updates about the testing process and the Game’s development lifecycle.
Legal basis: our legitimate interests in developing and improving the Game and operating testing programs; and/or steps taken at your request prior to entering into an agreement regarding participation.
Marketing communications (optional)
If you tick the optional box, we use your email to send news, dev updates, launch information, promotions and community content.
Legal basis: your consent (you may withdraw at any time).
4) Referral System (No Third-Party Email Submission)
We provide a personal referral link (e.g., https://hordesofthefallen.com/?ref=HFTXXXX). If someone signs up using your link, we record your Recruit ID as their referrer. We do not allow you to submit other people’s email addresses to us.
5) Where We Store & Process Data (International Transfers)
Our site is currently hosted with Namecheap in the United States. This involves transferring personal data outside the EU/EEA to a country that may not provide the same level of protection as in the EU/EEA.
When such transfers occur, we rely on appropriate safeguards, including Standard Contractual Clauses (SCCs), and implement additional measures where necessary. You may request information about these safeguards via alpha@hordesofthefallen.com.
We may consider migrating to an EU-based hosting provider to minimize cross-border transfers. This policy will be updated accordingly if that occurs.
6) Data Sharing (Processors & Recipients)
- Hosting provider: Namecheap (USA) – infrastructure, storage, security.
- Email service provider (if/when integrated): we may connect to a mailing platform (e.g., Brevo or Mailchimp) to send transactional and/or marketing emails. The provider and country of processing will be disclosed in this policy once integrated and a Data Processing Agreement is in place.
- Legal/Compliance: where required by law, court order, or to protect our rights.
We do not sell your personal data.
7) Retention
- Game lifecycle communications (Alpha/Beta/updates): retained while the Game remains in active development and the communication remains relevant; we periodically review and remove outdated records.
- Marketing (with consent): up to 24 months from your last interaction (e.g., opening an email or participating), or until you withdraw consent, whichever occurs first.
- Consent records / security logs: retained as necessary to demonstrate compliance (typically aligned with statutory limitation periods).
- You may request deletion at any time (see “Your Rights”).
8) Your Rights (EU/EEA & UK)
Subject to legal conditions and exemptions, you have the right to:
- Access your personal data and obtain a copy.
- Rectify inaccurate or incomplete data.
- Delete your data (“right to be forgotten”) (Click Here)
- Restrict or object to processing (including objection to processing based on legitimate interests).
- Portability of data you provided to us.
- Withdraw consent at any time for marketing (this does not affect processing before withdrawal). (Click Here)
To exercise your rights, contact us at alpha@hordesofthefallen.com. We will respond within one month (extendable in complex cases).
You also have the right to lodge a complaint with your local supervisory authority. In Italy, this is the Garante per la Protezione dei Dati Personali (garanteprivacy.it).
9) Security
We implement technical and organizational measures appropriate to the risk, including HTTPS/TLS, access controls, unique referral IDs, and minimization of collected data. No online service can be 100% secure; risks remain inherent to Internet transmission.
10) Children
Our services are intended for individuals aged 16+. If you are under the relevant age of consent in your country, you should obtain parental authorization. If we learn we have collected data from a child without proper authorization, we will delete it.
11) Cookies & Analytics
We do not currently use analytics or non-essential cookies. If we later enable analytics (e.g., a privacy-friendly EU provider) or other tracking technologies, we will update this policy and, where required, request consent via a banner.
12) Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be posted on this page with an updated “Last updated” date. If changes materially affect your rights or the way we process your data, where appropriate we will notify you by email.
13) Contact
If you have questions or requests regarding this policy or your personal data, contact:
Email: alpha@hordesofthefallen.com
Website: https://hordesofthefallen.com/
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