Privacy Policy

1. Data controller and contacts

Reforger Manager is the public name of the product, website and service.

Data controller: Manuel Pellizzaro.

Full address: Via Fiorita 19, 35010, Cadoneghe, PD, Veneto, Italy.

Contact for GDPR requests and exercising rights: privacy@reforgermanager.com. For general support you can write in the official Discord community.

2. Scope of this notice

Sales at launch are limited to Italy and the other European Union Member States.

Purchasing and contractually managing subscriptions is reserved for individuals aged 18 or older, or authorized representatives of organizations. Discord users may use the bot provided they meet Discord’s minimum age requirement in their country and comply with Discord’s Terms of Service; the 18+ purchase requirement does not automatically extend to server members. Discord age requirements.

Sales geography does not determine where providers process data. The service does not collect identity documents for automatic age verification.

This notice covers personal data processed through https://reforgermanager.com, https://dashboard.reforgermanager.com and the Reforger Manager bot.

Data comes from users, administrators, Discord events and APIs, Stripe communications and, for pre-existing operations, PayPal communications. Processing carried out independently by providers is also governed by their own notices. Each party’s role must be assessed for the specific activity; providers are not all treated indiscriminately as independent controllers.

3. Categories of data and source

• Account and access: Discord User ID, username, avatar, server list, Discord Guild ID and associated permissions through OAuth. Sessions hold authentication data and encrypted OAuth credentials to refresh the server list.
• Configurations: Guild ID, channel and role identifiers, permissions and module settings saved by administrators.
• Member activity: user identifiers, events handled by the bot, message content where the feature records it, moderation logs and actions, warnings, applications, tickets and transcripts, XP and levels. Processing depends on enabled modules and features used.
• Game Server Manager: game server configuration, hosts and ports, status, checks, events and metrics associated with the Guild. Any personally identifiable information and confidential parameters depend on configuration and are not intended for publication.
• Subscriptions: Guild ID, plan, amounts, currency, payment and subscription identifiers and status, paid periods, renewal cancellation and payment-provider events. Purchase attempts, payments, refunds, adjustments and processed events are recorded with dates, status and references. Manual reviews include audit notes and evidence, including Stripe Charge and PaymentIntent identifiers. The customer identifier associated with the Stripe subscription is used to open the Customer Portal.
• Technical data and correspondence: sessions, web server requests and data voluntarily sent to official contacts, limited to what is needed to handle the request.

4. Purposes and legal bases

• Access, sessions and configuration: GDPR Article 6(1)(b), for data necessary for the service requested by the individual contracting party or their pre-contractual steps. OAuth authorization is not general consent to data processing.
• Organization representatives and administrators: Article 6(1)(f), to verify access authority and manage the relationship with the organization. The interest is authorized service management; the organization’s contractual basis does not automatically extend to its representatives.
• Subscriptions: Article 6(1)(b), for payments, activation, renewal and cancellation of the individual’s contract and pre-contractual steps requested by the individual. The preceding distinction applies to representatives’ data. Necessary data is shared with Stripe and, for pre-existing operations, PayPal.
• Legal obligations: Article 6(1)(c), for actually applicable duties, including handling GDPR rights. Tax obligations do not entail indiscriminate retention of all service data.
• Security and protection of rights: Article 6(1)(f), to protect accounts, data and service availability, prevent abuse and establish, exercise or defend rights. Processing must be necessary and proportionate, taking individuals’ rights into account; it does not justify indiscriminate message archiving or unlimited retention.
• Support: Article 6(1)(b), for requests necessary for the individual’s contract or their pre-contractual steps; Article 6(1)(f), to answer general or representative requests while respecting their rights. Processing serves to respond to the received communication, not send marketing.
• Server features: moderation, archives, tickets, applications, XP and games involve different processing activities. The party determining their purposes and means must identify a legal basis for each activity and inform members. Reforger Manager acts as processor only for processing on that party’s behalf under documented instructions and a GDPR Article 28 agreement; for independently determined purposes it assumes controller responsibilities. Discord permissions and the administrator’s contract do not automatically justify every member-data use. Legitimate interests in moderation require necessity, proportionality and balancing, with particular attention to minors, and do not automatically extend to other features. General consent and withdrawal management is not available for these modules.

Data categories are described in section 3, recipients in sections 11–13 and retention in sections 8 and 14. The service does not use this data for marketing or commercial profiling.

5. Discord account data

We use it to recognize you, show the servers you can manage and verify your permissions before allowing changes. You can revoke the authorization at any time from your Discord account settings.

6. Servers, members and configurations

Configurations and operational data are associated with the Guild ID. The dashboard checks server management permissions; this does not give administrators ownership of all members’ personal rights or unrestricted access to other servers’ data.

Administrators choose modules and settings within available technical limits. Retention is not configurable in the same way for every category.

7. Logs and moderation data

Depending on the modules enabled, the database actually stores: log entries with identifiers of the actor and target of an action, moderation warnings, whitelist applications (with username), tickets and transcripts, and, if enabled, an archive of edited or deleted messages for auditing.

For the message archive the administrator chooses the retention period (default 90 days, configurable from 1 to 3650 days), with automatic deletion of expired data. This rule does not apply to all other data. Administrators can delete log entries from the dashboard.

8. Cookies and sessions

The dashboard uses the technical session cookie connect.sid, HttpOnly, SameSite Lax and Secure in production. The default authenticated session duration is seven days; activity can update its expiry through the session renewal mechanism. This is not an absolute seven-day limit from initial sign-in.

Sessions are stored in the database. Expired sessions are not reused: they are deleted when read and through store cleanup scheduled every hour. The configured frequency does not guarantee an exact deletion time if the service stops or errors occur. Logout deletes the session concerned; it does not thereby erase all Guild data or backups.

The static website pages do not set profiling cookies.

The dashboard also uses browser sessionStorage to retain the selected Guild and the Guild and plan associated with a payment or subscription-management redirect. These are browser-side technical values, separate from the server-side authentication session; they do not establish acceptance of contractual terms.

9. Other tracking tools

The website pages and dashboard HTML do not embed analytics, tracking pixels, external fonts or scripts. Network services such as Cloudflare may process data separately: this description does not guarantee the absence of every upstream tool. The web server records IP address, request, date and time in shared technical logs. Rotation is daily, with 14 rotated copies and delayed compression; the active file and other copies are not included in the rotation count alone.

10. Subscriptions and Stripe

Public purchases use Stripe Checkout from the dashboard. Stripe collects the data needed for payment and the billing address. Reforger Manager does not store full card numbers.

Reforger Manager handles the identifiers and events needed to verify payment, activate a plan for a Guild ID, reconcile subscription status, paid periods and cancellation. The Customer Portal is provided by Stripe; customer identifiers may be used for authorized links to that service.

References and statuses of pre-existing PayPal purchase attempts or subscriptions may be retained to verify their outcome and handle any payments and requests. Direct PayPal is not available for new public purchases. A reference that cannot be retrieved from the provider does not, by itself, establish cancellation, expiry or absence of payments.

11. Hosting and providers

• Discord: accounts, OAuth, events and APIs. For data collected through its own services, Discord identifies Discord Netherlands BV as controller for EEA users; this does not determine Reforger Manager’s role for data received through the bot. Discord Privacy Policy.
• Stripe: payments, subscriptions, Checkout and Customer Portal. Stripe states controller and/or processor roles depending on the activity; it is not indiscriminately described as solely Reforger Manager’s processor. Stripe Privacy Policy.
• PayPal: verification and handling of pre-existing payment operations and any directly associated subscriptions. PayPal’s privacy notice also applies to processing through its own services.
• Contabo: Cloud VPS 4 hosting in the EU region, with an agreement covering data processing on the customer’s behalf. Confirmation of the physical VPS country is pending. Contabo DPA documentation.
• Cloudflare: domain, DNS, proxy and web protection. The DPA is incorporated into the applicable self-serve agreement and defines processor or sub-processor roles for customer data; processing for its own purposes is distinct. Cloudflare agreement; DPA.
• Zoho Mail EU: service email, including support, billing, legal and privacy. Signature of the account DPA is pending. Zoho distinguishes service data processed under customer instructions from processing for its own purposes. The Europe region includes data centers in Amsterdam and Dublin; this does not exclude access or transfers outside the EU. Zoho privacy notice and agreements; Data center locations.

The role of each provider depends on the activity performed. The sales territory and EU email routing do not establish that every processing operation takes place exclusively in the European Union.

12. Recipients of data

Data is accessible to the provider and the providers listed above within their respective roles, and to each server’s administrators for their own server’s data. We are not aware of any sale of personal data.

Management of the VPS, database and service mailboxes is entrusted solely to the service provider. Access by infrastructure providers and Discord administrators within their respective roles remains distinct.

13. International transfers

Providers may involve infrastructure, group companies and sub-processors outside the European Economic Area, including through remote access. Hosting, email and processing are not represented as exclusively European.

The Cloudflare DPA incorporated into the applicable agreement provides for transfers outside the EEA and EU standard contractual clauses, with different modules depending on the customer’s role. Zoho describes transfers within its group and to third parties and protective agreements based on EU clauses; signature of our account DPA remains pending and it is not represented as already signed.

Transfers must rely on an applicable adequacy decision or GDPR Article 46 safeguards, with necessary assessments and supplementary measures. The EU region of the VPS does not exclude possible access from other countries. For information about safeguards and how to obtain a copy, contact privacy@reforgermanager.com; credentials and confidential security details are not disclosed.

14. Retention

Retention differs by data category. Removing the bot, cancelling a subscription and erasing personal data are separate actions. Removing the bot does not trigger complete automatic erasure.

• Configurations and other operational data: configurations can remain available for reinstallation. There is no general automatic expiry applying to all moderation data, warnings, applications, XP, tickets, transcripts and history. Closing a ticket does not mean all its data is erased.
• Message archive: the default period is 90 days, configurable by the administrator from 1 to 3650 days, with periodic cleanup. This is distinct from other moderation records. Fifteen-minute statistical aggregates have a 45-day cleanup rule.
• Sessions: renewable expiry and cleanup as described in section 8; seven days is not an absolute deletion deadline measured from first authentication.
• Application log files: the logger uses thresholds of 14 days for application logs and 30 days for warnings, errors and billing logs, with cleanup at startup and every six hours. These settings do not cover every system log or copied file.
• Web server logs: Nginx is configured for daily rotation with 14 rotated copies and delayed compression. The active log and other copies mean this is not a guaranteed maximum retention period of 14 days.
• Backups: scheduled creation is active. The configured retention plan uses 30 days for daily copies, eight weeks for weekly copies, three calendar months for monthly copies and 30 days for code/configuration copies. Scheduled creation only calculates expiry candidates; it does not automatically delete expired archives. Historical and release copies are not covered by that expiry plan. These thresholds are not enforced maximum retention periods. No external cloud backup copy is represented as active.
• Billing and correspondence: these are handled separately from operational data and technical backups. Assessment of erasure requests considers applicable accounting obligations and documented needs. No general fixed period is stated for these categories.

The retention criterion is whether the data is necessary for its specific purpose: managing the requested service, responding to a received communication, complying with an applicable obligation or documented protection of a right. The mere possibility of reinstalling the bot does not justify unlimited retention. Where automatic expiry is not provided, duration must be assessed by category and necessity, not treated as indefinite retention.

Deletion in the active database does not by itself delete backups or email. Requests are handled manually through privacy@reforgermanager.com, considering copies and applicable retention obligations. The thresholds above describe the available technical rules; they do not guarantee automatic erasure of all copies or replace that assessment.

15. Security measures

We adopt reasonable measures, including HTTPS encrypted connections, protected session cookies, encryption of Discord OAuth access and refresh tokens stored in the server-side session, server-side permission checks on every management operation, and data separation by Guild ID. No system is entirely free of risk.

16. Your rights

Where and to the extent provided by applicable law, individuals may request access, rectification, erasure and restriction of processing. They may object to processing based on legitimate interests; portability applies when legal conditions are met, particularly to data provided and processed automatically on the basis of consent or contract.

Where processing is based on consent, it may be withdrawn without affecting the lawfulness of previous processing. Withdrawal is not presented as applicable to processing that does not depend on consent.

An individual member’s rights are distinct from a Guild administrator’s powers; administrators may not obtain or erase other users’ data indiscriminately. Privacy requests are handled individually by the provider through the contact in the next section.

17. How to exercise your rights

Send requests to privacy@reforgermanager.com, distinguishing Guild data deletion from rights concerning your own personal data. Specify the scope and, where relevant, the Guild ID; do not send passwords, tokens or full payment details.

Identity and authority must be verified for the specific scope. Knowing the Guild ID is insufficient. Personal requests require verification of the individual, not merely an administrator role; where the bot is absent, adequate documented verification is needed.

Assessment separates configurations, operational data, administrative records and infrastructure copies. Any exceptions must be justified by applicable obligations or needs, limited and reviewed: an active subscription alone does not justify retaining every item of data. Data deletion does not cancel subscription renewal.

Requests are handled manually, verifying identity and authority for the specific scope, keeping servers separate and protecting other users’ data.

The GDPR requires a response without undue delay and normally within one month of receipt. Any extension by up to two further months because of complexity or number of requests must be communicated within the first month with reasons. A refusal must give reasons and indicate applicable remedies.

Complete automatic erasure of all historical copies is not available. A change in the active database does not by itself guarantee that the same data is absent from a backup or subsequent restoration. These limitations do not remove applicable erasure or restriction obligations and must be considered when handling a request.

18. Right to lodge a complaint

You have the right to lodge a complaint with the competent supervisory authority, for example that of the country where you live or work.

19. Updates and effective date

Version 1.0. Effective date: 2026-11-07.

This notice may be updated to reflect changes to the service and its processing of personal data. Updates do not remove the rights of data subjects.