Privacy Policy.

This Privacy Policy sets forth the privacy practices and data protection principles of Alteran Platforms (formerly operating as Creative Duo Group), hereinafter referred to as the "Data Controller," "we," "us," or "our." This document outlines the collection, processing, storage and protection of Personal Data provided by users ("Data Subjects" or "you") who access our services, including Project Cryolity, Project Warp and associated community forums.

All data processing is conducted in strict compliance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and the corresponding Czech national legislation, specifically Act No. 110/2019 Coll., on Personal Data Processing (Zákon č. 110/2019 Sb., o zpracování osobních údajů).

In the course of providing our services, we may collect and process the following categories of Personal Data:

• Technical and Connectivity Data: Including Minecraft Universally Unique Identifiers (UUIDs) and Internet Protocol (IP) addresses. This data is essential for user authentication, routing connections through our localized proxy infrastructure and ensuring platform security.
• Contact Information: Including email addresses provided during registration or support inquiries.
• Account and Profile Data: For users engaging with our Community Forums or support ticketing systems, we may collect full names, telephone numbers, country of residence and universal identifiers.

“We treat your data with the same defense protocols that we use to protect our own server infrastructure.”

We process your Personal Data relying on the following legal bases under the GDPR and Act No. 110/2019 Coll.:

• Performance of a Contract (Art. 6(1)(b) GDPR): To provide, maintain and operate our services; authenticate user access via Minecraft UUIDs; and route traffic efficiently.
• Legitimate Interests (Art. 6(1)(f) GDPR): To analyze user behavior for service improvement, personalize user experiences and deploy localized proxy solutions and DDoS mitigation services to ensure network security and stability.
• Legal Obligations (Art. 6(1)(c) GDPR): To comply with applicable statutory retention requirements and respond to lawful requests from Czech regulatory or judicial authorities.

Alteran Platforms has completed a structural migration of its data storage facilities. User data previously processed and stored on edge infrastructure located in the Netherlands and Germany has been entirely migrated to centralized facilities within the jurisdiction of the Czech Republic.

Currently, all Personal Data is stored exclusively within the European Union at the following locations:

1. 01 Proprietary, on-premise server infrastructure located in Aš, Czech Republic.
2. 02 Secure, third-party data center facilities located in Prague, Czech Republic.

We do not sell your Personal Data. We may disclose your information strictly under the following circumstances:

• Data Processors: We share necessary network data (e.g., IP addresses) with contracted third-party DDoS protection providers to safeguard our infrastructure. These entities act as Data Processors and are bound by Data Processing Agreements (DPAs) that enforce strict compliance with the GDPR and Czech data protection laws.
• Corporate Restructuring: In the event of a merger, acquisition, reorganization, or sale of assets, Personal Data may be transferred to the successor entity, subject to continued adherence to this Policy or an equivalent privacy framework.
• Legal Compliance: We reserve the right to disclose Personal Data when compelled by valid legal processes, such as subpoenas, court orders, or statutory obligations mandated by the authorities of the Czech Republic.

Alteran Platforms retains Personal Data only for the duration necessary to fulfill the purposes for which it was collected. Upon the termination or voluntary deletion of a Cryolity Community account by a user, we will permanently erase or anonymize the associated Personal Data within thirty (30) days, in accordance with the principles of data minimization and storage limitation under the GDPR and Act No. 110/2019 Coll.

Under the GDPR and Czech law, you possess the following actionable rights regarding your Personal Data:

1. 01
   Right of Access and Rectification: The right to request a copy of the Personal Data we hold about you and to demand the correction of any inaccuracies.
2. 02
   Right to Erasure ("Right to be Forgotten"): The right to request the deletion of your Personal Data from our systems, subject to the 30-day processing window mentioned in Section 6.
3. 03
   Right to Data Portability: The right to receive your data in a structured, commonly used and machine-readable format.
4. 04
   Right to Withdraw Consent: The right to revoke previously granted consent for specific processing activities at any time.
5. 05
   Right to Lodge a Complaint: If you believe your data privacy rights have been violated, you have the right to lodge a formal complaint with the supervisory authority of the Czech Republic: the Office for Personal Data Protection (Úřad pro ochranu osobních údajů - ÚOOÚ).

The Data Controller implements robust technical and organizational measures (TOMs) - including our in-house Alteran Sentinel AI verification and database shielding architecture - designed to protect Personal Data against unauthorized access, accidental loss, alteration, or unlawful disclosure. However, Data Subjects acknowledge that no electronic transmission or digital storage system can be guaranteed to be completely secure.

Pursuant to Section 7 of Act No. 110/2019 Coll., which establishes the age of digital consent in the Czech Republic, our services are not directed toward individuals under the age of fifteen (15). We do not intentionally collect or solicit Personal Data from children under this age threshold. Should we become aware of such data collection, we will execute immediate deletion procedures.

We reserve the right to amend this Privacy Policy periodically to reflect changes in legal, regulatory, or operational requirements. Substantive modifications will be communicated via our website or Discord server, accompanied by a revised "Effective Date."

For inquiries, the exercise of data rights, or matters relating to data privacy, please contact our designated privacy team at: