Privacy Policy

1. Controller and scope

Munk Studios, trading as Peer (“Peer”, “we”, “us”, or “our”), is the data controller for the personal data described in this Privacy Policy. This policy applies to Peer Network, Peer Accounts, Peer Store, Peer Client, Peer Community, connected first-party games, and related websites, support, software, and online services (the “Services”). A game or optional feature may provide a supplemental notice where it has additional data practices.

Controller

Munk Studios (trading as Peer)

CVR

40786902

Registered address

Odinsgade 109, Denmark

Privacy contact

privacy@peerclient.com

Support contact

support@peerclient.com

2. Personal data we collect

Please do not place sensitive information—such as health, political, religious, sexual-life, precise identity-document, or financial information—in a public profile, forum post, chat, voice note, or upload unless it is genuinely necessary and appropriate. If you disclose information about another person, you must have a lawful reason and any permission required.

3. Where personal data comes from

• From you: registration, profile edits, purchases, messages, uploads, support requests, settings, and gameplay inputs.
• Automatically from your device and use: IP address, authentication events, client version, service logs, presence, game activity, security and anti-cheat signals, and essential cookies.
• From other users: messages, friend requests, reports, group membership, gifts, mentions, votes, and content involving your account.
• From connected first-party games and Peer services: entitlement, presence, playtime, server context, gameplay/account events, moderation, and technical records.
• From service providers: Xsolla payment confirmations, refunds, chargebacks and fraud status; hosting, security, and delivery diagnostics; and support-provider information where used.

4. Purposes and legal bases

Where we rely on legitimate interests, we consider necessity, proportionality, your reasonable expectations, and the effect on your rights. You may object as described below. Providing registration and payment information is necessary to create an account or complete a purchase; without it, we cannot provide that feature. Optional profile fields and public contributions are voluntary.

5. Payments and Xsolla

When you start a purchase, Peer creates an order and sends Xsolla the information needed to open hosted checkout, including a Peer account identifier, order/product information, price and currency, and transaction-routing parameters. Xsolla and its payment partners collect and process payment details such as card or alternative-payment information, billing details where required, IP/device and fraud-prevention data, and transaction information.

Peer receives provider notifications needed to validate and fulfil the purchase, including the Peer account, provider transaction ID, amount, currency, payment status, and refund or chargeback status. Peer does not receive or store your full payment-card number. Xsolla describes whether it acts as an independent or joint controller or as a processor for a particular service in the Xsolla Privacy Policy. Its checkout terms and privacy practices apply separately to data it controls.

6. Who receives data and international transfers

We disclose personal data only as needed for the purposes above:

• Other users receive profile, presence, community, message, voice, gameplay, and group information according to the feature and your settings.
• Xsolla and payment providers receive order and account-routing information to process payments, refunds, disputes, fraud checks, and legal obligations.
• Hosting, storage, content-delivery, email, security, anti-cheat, crash-diagnostic, and support providers may process the minimum data needed to supply their services under appropriate terms.
• Professional advisers, auditors, insurers, and transaction counterparties may receive data where reasonably necessary and subject to confidentiality and legal safeguards.
• Authorities or affected parties may receive data when required by law or reasonably necessary to protect rights, safety, the Services, or the public; establish or defend legal claims; or respond to lawful process.

Some recipients may process data outside Denmark or the European Economic Area. Where Peer is responsible for such a transfer, we use an available legal safeguard such as an adequacy decision, the European Commission’s standard contractual clauses, or another lawful mechanism, and apply supplementary protections where required. Xsolla’s own policy describes transfers it controls.

Peer does not sell personal data. We do not currently share platform activity for cross-context behavioral advertising.

7. Public, social, and communication features

Your username, display name, avatar, biography, status, public community posts, poll choices where displayed, reputation, and certain game/presence information may be visible to other users or the public depending on the feature. Direct and group communications are visible to their participants and may be reported to moderators. Other users can copy or reshare information they can see, so choose public content carefully.

Messages and uploads are associated with participants and conversation membership so the service can deliver history, unread state, moderation, quotas, and integrity checks. Deleted messages or posts may be soft-deleted or retained for a limited period where necessary for safety, abuse prevention, disputes, backups, or legal compliance.

8. Cookies and similar local storage

peerclient.com currently uses only technologies needed to provide requested functions, such as a session cookie to keep you signed in, a cross-site-request-forgery token to protect forms, and temporary session state for navigation and age gates. These are used for authentication, security, load continuity, and settings needed for the service to work.

We do not currently use third-party advertising or analytics cookies on peerclient.com. If we introduce non-essential analytics, personalization, or marketing technologies, we will update this policy and request prior consent where required. You can block cookies in your browser, but blocking essential cookies may prevent sign-in, checkout initiation, forms, or account features from working.

9. How long we keep data

We keep personal data only for as long as needed for the purpose collected, including to provide an active account and persistent game/social history, comply with law, resolve disputes, prevent fraud and abuse, and enforce agreements. Retention depends on the record:

• account, profile, library, social, and connected-game records are generally kept while the account is active and then deleted, anonymized, or restricted when no longer needed;
• presence and live voice-state records are operational and refreshed or expire as service state changes; live voice audio is relayed rather than stored unless you deliberately create and send a voice note;
• messages, community content, uploads, moderation, and safety records remain while needed for the feature, participants, rule enforcement, and disputes, subject to deletion requests and the rights of others;
• order, payment, refund, entitlement, and accounting records are kept for the periods required by tax, bookkeeping, consumer, fraud-prevention, and legal-claims rules—often five years or longer where a dispute or specific law requires;
• security logs, IP/device identifiers, diagnostics, and support records are kept for a period proportionate to the security, support, or legal need; and
• backup copies are removed or overwritten on the applicable backup cycle unless preservation is legally required.

Account closure does not necessarily delete public content already forming part of a discussion, transaction records, anti-fraud evidence, or data that must be retained by law. Where appropriate, we detach or minimize the account identity instead.

10. Children and age controls

Peer accounts are not available to children under 13. We collect date of birth to enforce account and content age controls. Users below the age of legal majority should involve a parent or legal guardian in account creation and purchases. Games, forums, and content may have higher minimum ages.

If you believe a child below the minimum age has created an account or personal data was provided without required parental authorization, contact privacy@peerclient.com. We will investigate and take appropriate action. We do not knowingly use children’s data for behavioral advertising.

11. Your privacy rights

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

• receive information about processing and access a copy of your personal data;
• correct inaccurate or incomplete data;
• request deletion or restriction of processing;
• object to processing based on legitimate interests or to direct marketing;
• receive data you provided in a structured, commonly used, machine-readable format and transmit it to another controller where the portability right applies;
• withdraw consent at any time, without affecting processing that was lawful before withdrawal;
• not be subject to a decision based solely on automated processing that has legal or similarly significant effects, where that right applies; and
• complain to a data-protection authority.

Send a request to privacy@peerclient.com. Describe the account and request clearly. We may ask for proportionate information to verify identity and protect the account. We normally respond within one month under GDPR, subject to lawful extensions or exceptions. Requests are generally free, although the law permits a reasonable fee or refusal for manifestly unfounded or excessive requests.

You may complain to the Danish Data Protection Agency (Datatilsynet), Carl Jacobsens Vej 35, 2500 Valby, Denmark, or to the supervisory authority where you live or work. We encourage you to contact us first so we can address the issue.

12. Security, automated systems, and policy changes

We use technical and organizational measures intended to protect confidentiality, integrity, and availability, including password hashing, authenticated sessions/tokens, access controls, payment-webhook validation, upload limits and integrity metadata, logging, moderation controls, and service separation. No online system is perfectly secure, so protect your credentials and report suspected compromise to support@peerclient.com.

Peer may use automated signals to support age gates, security, anti-fraud, anti-cheat, abuse detection, content prioritization, and service operation. Where a decision would produce legal or similarly significant effects and applicable law grants safeguards, we will provide required information and access to human review.

We may update this policy when the Services, providers, law, or processing changes. We will post the current version here and update the date above. Material changes will also be communicated through the site, client, account email, or another reasonable channel where required.

Privacy questions and requests may be sent to privacy@peerclient.com or by post to Munk Studios, Odinsgade 109, Denmark.