Cleanops BO3 Patch - GDPR Policy

Last Updated: July 05, 2025

This document outlines the privacy practices of the Cleanops BO3 Patch ("the Patch") with regard to the collection, processing, and storage of personal data from its users, in compliance with the General Data Protection Regulation (GDPR) (EU) 2016/679.

1. Introduction

The Cleanops BO3 Patch processes personal data as described in this policy.
By using the Patch, you acknowledge the terms outlined herein.

2. Data Controller

For the purposes of the GDPR, the data controller responsible for your personal data collected through the Cleanops BO3 Patch is:

Krashgamer
privacy@cleanops.dev

3. Personal Data Collected

The Cleanops BO3 Patch collects the following types of personal data:

4. Purpose and Legal Basis for Data Collection

The personal data listed above is collected and processed for the following purposes, based on identified legal bases under GDPR:

Purpose: Analytical Purposes and Service Integrity

To monitor and analyze the performance, stability, and usage patterns of the Cleanops BO3 Patch, including understanding user numbers, tracking adoption, and detecting technical issues or misuse. This processing also supports the detection and prevention of cheating or malicious activity to maintain fair gameplay and the integrity of the Patch.

Legal Basis: Legitimate Interests (Article 6(1)(f) GDPR)

We process your Steam ID and IP address to fulfill our legitimate interest in understanding how our Patch is used, identifying and resolving technical issues, preventing abuse, and maintaining fair gameplay. This processing is necessary to operate and enhance the Patch, and our interests are balanced against your fundamental rights and freedoms.

5. Processing of SteamIDs for Anti-Cheat Blacklist

Cleanops maintains an anti-cheat blacklist containing SteamIDs of individuals identified as cheaters, for which a comprehensive Legitimate Interests Assessment (LIA) has been conducted.

Purpose: The legitimate interest for this processing is to maintain a fair, stable, and equitable multiplayer gaming environment for players in lobbies where the Cleanops BO3 Patch is active, by actively identifying and mitigating cheating behaviors. This directly addresses the significant disruption and negative experience caused by cheaters.

Legal Basis: This processing is based on our legitimate interests (Article 6(1)(f) GDPR).

Data Processed and Impact: Only SteamID64s are retained in this blacklist. The primary negative impact on a data subject included in this blacklist is the automatic disconnection from multiplayer lobbies where the Cleanops BO3 Patch is active, which restricts their ability to participate in certain online games.

Data Retention: SteamIDs on this blacklist are retained indefinitely to ensure persistent mitigation of cheating behavior.

Safeguards and Mitigation Measures:
Despite the intrusive nature of automated disconnections, Cleanops has implemented measures to protect the rights of data subjects, including providing a clear "Appeal a Ban" process available on the Cleanops Discord server. This allows data subjects to challenge their inclusion on the blacklist and present evidence for reconsideration.

6. Data Retention

Your personal data (Steam ID and pseudonymized IP address) collected for the stated purposes (analytical and service integrity when using the patch) will be retained for a period strictly necessary to fulfill those purposes, or as required by applicable law. This data is retained for a maximum of 3 days. After this period, the data will be securely deleted or anonymized. SteamIDs included in the anti-cheat blacklist (as detailed in Section 5) are retained indefinitely.

7. Data Sharing and Disclosure

We may share your personal data in the following limited circumstances:

8. International Data Transfers

Your personal data may be transferred to, and processed in, countries outside of the European Economic Area (EEA), specifically the United States, through our service provider Cloudflare. Where such transfers occur, appropriate safeguards are in place to protect your data, such as Standard Contractual Clauses approved by the European Commission as detailed in Section 6. As our Oracle Cloud VM server is based in Germany, data processed through Oracle remains within the EEA and does not constitute an international transfer for GDPR purposes.

9. Children's Privacy

The Cleanops BO3 Patch is not intended for use by individuals under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that personal data from a child under 16 has been collected without parental consent, we will take steps to delete that information promptly. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at privacy@cleanops.dev.

10. Your Data Protection Rights

Under the GDPR, you have the following rights regarding your personal data:

To exercise these rights, please contact us using the details in Section 2. We may require proof of identity.

11. Security Measures

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include the pseudonymization of data, such as hashing IP addresses with a salt.

12. Data Breach Notification

In the unlikely event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will make reasonable efforts to inform affected users through our designated public channels (e.g., Discord server, GitHub Pages) and notify the relevant supervisory authority without undue delay, in accordance with our legal obligations under the GDPR. We will communicate the nature of the breach, the likely consequences, and the measures taken or proposed to be taken to address it.

13. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. Material changes will be communicated through our designated channels. Continued use of the Patch after modifications constitutes acknowledgment of the updated policy.

14. Contact Us

For questions or concerns about this Privacy Policy or our data processing practices, please contact us at:

privacy@cleanops.dev