Shutter Island

Privacy policy

Version 1.3, as of 08.10.2026. This states what data is generated, why we need it, and how long it remains.

Controller

Controller within the meaning of the GDPR
Shutter-Island.eu
Scharn 7
32423 Minden
Contact
admin@shutter-island.eu
or via a ticket in the help centre

We have not appointed a data protection officer; the requirements for doing so are not met.

The short overview

If you only read one thing, read this:

What we process — and why

Account

What: Email address, password (only as a bcrypt hash — it never exists in plain text anywhere), display name, friend ID, player ID, the time of registration and of email confirmation, plus the language you last used (German or English) so that emails reach you in your language.

Why: So that an account can exist. Without an address there is no way back into the account; without a password, no login.

Legal basis: Art. 6(1)(b) GDPR — performance of the usage agreement.

How long: Until the account is deleted.

Friends and community profile

What: Your friends list: who is friends with whom, open requests, blocks and muting. On your community profile and with friend requests, other signed-in members see how many friends you have in common. Which ones they are, they only see if you allow it in the settings under “Privacy” (default: nobody; you can choose your friends or all members). The rest of your friends list is not visible to others.

Why: So that friends can find each other, chat and invite each other – and so that a request from someone you don’t know is easier to judge.

Legal basis: Art. 6(1)(b) GDPR — performance of the usage agreement.

How long: Until the friendship ends, a request is declined or the account is deleted.

Sessions and devices

What: One entry per session with IP address, browser identifier, the time of login, and the last activity. The session key itself is stored only as a hash in the database.

Why: So that login works — and so that under Devices you can see where you're signed in and end individual sessions or all of them. That's exactly what the IP address is for: it answers the question “was that my connection?” It's displayed truncated.

Legal basis: Art. 6(1)(b) and (f) GDPR — contract performance and our legitimate interest in the security of accounts.

How long: Browser sessions 30 days, launcher sessions 7 days — or until you end them.

Email confirmation and password reset

What: A one-time token, stored as a SHA-256 hash, with an expiry time. The token itself appears only in the email.

Why: So that no one can create an account using someone else's address, and so there's a way back if the password is lost.

How long: Confirmation 7 days, reset 1 hour. Used tokens are removed after 30 days.

Tickets in the help centre

What: What you write, plus subject, category, and your browser identifier. Without an account, additionally the email address you provide and the name we should address you by.

Why: To reply to you. We can't do that without an address.

Legal basis: Art. 6(1)(b) GDPR, for inquiries without an account Art. 6(1)(f) — our legitimate interest in answering inquiries.

How long: An account's tickets remain after its deletion, without any link to it; they also record what we answered and decided, and that can concern third parties — for example a report about someone else.

Verification requests

What: The requested identifier, your evidence in full, an optional address for follow-up questions, and the decision along with its reasoning.

Why: To check whether you're the person you're believed to be, and to keep the decision traceable.

Legal basis: Art. 6(1)(b) GDPR.

Bans

What: Scope, reason, duration, who imposed it, and who lifted it.

Why: To enforce them and to be able to explain them if asked.

Legal basis: Art. 6(1)(f) GDPR — our legitimate interest in a functioning community.

Purchases

What: Which games belong to your account, redeemed keys, timestamps.

Legal basis: Art. 6(1)(b) and (c) GDPR — contract performance and statutory tax retention obligations.

How long: Purchase receipts are subject to commercial and tax law retention periods of up to ten years. They remain even after an account is deleted, then without any link to your account.

Chat in the launcher

What: Messages are end-to-end encrypted – we cannot read them. The server holds: the public keys of your chat devices (plus computer name and last use, which only you see), one key per device with which it additionally locks its history, encrypted copies until your device picks them up, and for each message who wrote to whom and when, with a check value that reveals nothing about the content. Also your confirmation “at least 16 years old” with the time. The chat history is stored only by the launcher on your computer, encrypted, bound to your Windows account and locked with the key from the server: if you sign out or remove the device, we delete that key and the history there can no longer be read.

Why: To deliver messages to all of your devices and your friend’s, to limit spam and to open the chat only from age 16. If you report a message, you send its text to the moderators yourself; the check value shows it was sent exactly like this. If you try to send a blocked word, your launcher reports only the time – too many in a short time mute you automatically.

Legal basis: Art. 6(1)(b) GDPR – the chat is part of the service and you switch it on yourself; for spam limits and moderation Art. 6(1)(f) GDPR.

How long: Read messages in the launcher for at most as long as the team allows (currently 48 hours after reading, your own after sending) – you can choose shorter in the settings. Encrypted copies on the server until picked up, at most 30 days. Who wrote to whom and when: 30 days. Times of blocked words: one day. Chat devices and their history key until you remove them, sign out or they go unused for 30 days. Reported messages up to 180 days after they were handled. The age confirmation as long as your account exists.

Echo, your test contact: Every account has Echo as a friend. Echo shows you your own status as your friends see it, sends invites back and answers in the chat with your own message. Unlike chats with people, Echo's keys are on our server: The server decrypts what you write to Echo in order to send it back to you. The content is neither stored nor logged. All that is stored is that Echo has greeted you and the session keys for your chat devices; who wrote to whom and when is kept for 30 days, as for every message. Legal basis: Art. 6(1)(b) GDPR. You can remove Echo from your friends list at any time.

Crash reports

What: Error message, program version, operating system — and, if you were signed in, the link to your account.

Why: To find bugs.

Legal basis: Art. 6(1)(f) GDPR.

Server logs

What: As usual, the web server records IP address, time, the address accessed, and browser identifier.

Why: Operation and defense against attacks.

Legal basis: Art. 6(1)(f) GDPR. How long: usually 14 days.

Cookies

We only set cookies that are necessary for login, the chosen language or your shopping cart:

The last two are set only by the shop, and only if you use it.

The login cookies are HttpOnly (JavaScript can't reach them), Secure (never sent over unencrypted connections), and SameSite=Lax. They contain only a random identifier, no data about you, and are deleted when you sign out. The language cookie contains only the language code. The cookie holding the number of cart items is deliberately NOT HttpOnly — that is the only way the header can show it without asking the shop on every page view. It contains a number and nothing else.

Because they are technically necessary or store a setting you made yourself (§ 25(2) TDDDG), they don't require consent — that's also why you don't see a cookie banner here. We don't set cookies for analytics or advertising purposes; there would be nothing for a banner to ask about.

Who else sees anything

Our hosting provider

The platform runs on rented servers in Germany. The provider processes data solely on our behalf; a data processing agreement under Art. 28 GDPR is in place for this.

The forum

The forum runs on the same servers. Display name, friend ID, and avatar are carried over from your account to it — in one direction: we manage the accounts, the forum displays them.

What you write in the forum is publicly readable. That's the point of a forum, but it's a decision you make with every post.

Game servers

When you connect to a game server, it receives your player ID, your display name, and your IP address — technically unavoidable, otherwise no connection could be made. Servers not operated by us are responsible for their own data.

Third countries

No transfer outside the EU takes place.

What remains after deletion

If you delete your account, it is removed — with three exceptions, and we'd rather name them than hide them:

Everything else — sessions, friends list, game ownership, bans, open tokens — goes with it.

Your rights

Access (Art. 15)

No request, no waiting time: download a file. It contains everything stored about your account — except the hashes of your password and sessions, which tell you nothing about yourself but would tell anyone who found the file something.

Rectification (Art. 16)

You change your display name, friend ID, and password yourself in your account. Everything else, a ticket is enough for.

Erasure (Art. 17)

Also yourself, immediately, no reason required — see above for what remains afterward.

Restriction, objection, portability (Art. 18, 20, 21)

The access file is machine-readable JSON, which also serves as data portability. For restriction and objection, write to us — for processing based on legitimate interests, we review your objection case by case.

Complaint (Art. 77)

You can file a complaint with a data protection supervisory authority, for example the one for the German federal state you live in. We'd prefer a ticket, but that's your choice, not a requirement.

Automated decisions

There are none. Bans and verifications are decided by a human. No profiling takes place.

Changes to this notice

If what we do changes, this page changes with it — and gets a new version number. If a change affects something substantial, we tell you, instead of hoping you'll check back.