1. Who is responsible
The controller under the General Data Protection Regulation (GDPR) is:
Florian Nitzec/o Online-Impressum.de#3646
Europaring 90
53757 Sankt Augustin
Germany
Privacy and rights requests: service@battlelink.de. You may also use our external contact form. This is the controller’s contact address; it is not a representation that a formal data protection officer has been appointed.
2. The short version
- We need your email, an alias and a password to run your account. Other players do not see your email or password.
- Your opponent sees your trainer name, rating, results, filtered team sheet and messages. Signed-in players can see trainer names and statistics in the leaderboard.
- Chat is stored on our server. It is not end-to-end encrypted and can be reviewed by the operator when handling safety or support issues.
- The application has no advertising, analytics trackers or marketing cookies. Fonts are served from this site.
- Accounts are only available to people aged 18 or older who are legally adults where they live.
- You can ask us what we hold about you, ask for corrections, object where applicable, or request deletion. Contact us using the address above.
Use a nickname, not your real name, and do not share private information in chat.
3. Data, purposes and legal bases
| Data | Purpose | Legal basis |
|---|---|---|
| Email, trainer name, password hash, account status, age declaration and creation date | Create and provide an account; record the required declaration of legal adulthood. We do not collect a date of birth. | Article 6(1)(b) GDPR: the service agreement and steps to enter it. |
| Last used Poképaste link, saved in your account until replaced by a later search or removed on account erasure | Pre-fill your team link for future searches, including after signing in again or changing devices. This account preference is separate from temporary queue entries and previously shared chat messages. | Article 6(1)(b) GDPR: the requested matchmaking service. |
| Session and security-token hashes, expiry, last access and revocation information | Keep you signed in and protect your account. | Article 6(1)(b) GDPR for authentication; Article 6(1)(f) for preventing unauthorized access. |
| Password reset token hashes, expiry and encrypted outgoing reset messages | Deliver requested account recovery links; verify single-use resets and revoke previous sessions after a password change. | Article 6(1)(b) GDPR for account recovery and Article 6(1)(f) for account security and prevention of misuse. |
| Report reason and description, match identifiers, participant aliases, retained chat including team links, and one optional image | Preserve a bounded chat snapshot and sanitized image for operator review in the local admin dashboard, and send the complaint to support. The image is resized and re-encoded to remove embedded metadata; visible personal information may remain. | Article 6(1)(f) GDPR: proportionate handling of abuse and protection of participants. |
| Queue entries, hosting preferences, assigned lobby host, match participants, cancellation requests, game reports, timing, scores, rating and rating history | Find opponents, record results, resolve conflicting reports and calculate rankings. | Article 6(1)(b) GDPR; Article 6(1)(f) for investigating specific manipulation and maintaining fair results. |
| Chat text, manually submitted links, sender, match reference and message time | Deliver match chat and, when necessary, investigate a report or abuse. | Article 6(1)(b) GDPR for chat; Article 6(1)(f) for safety, proportionate moderation and protection of participants. |
| IP address and temporary request counters; technical connection data supplied by your browser | Deliver pages and real-time messages; limit automated attacks and abusive requests. | Article 6(1)(f) GDPR: availability, network security and prevention of misuse. |
| Terms version, acceptance time and declaration that the user is at least 18 and legally an adult | Document the agreement and the declaration of eligibility. | Article 6(1)(b) GDPR; Article 6(1)(f) for proportionate verification and evidence. Article 6(1)(c) applies where a specific legal duty requires a record. |
| Warnings, internal flags, temporary and permanent bans, reasons, review decisions and result correction history | Human review of reports, proportionate enforcement, appeals and correction of match statistics. Account decisions are made by the operator. | Article 6(1)(f) GDPR: account safety, prevention of abuse and fair results. |
| Support emails, complaints, contact details and information you provide | Answer your request, handle safety reports or exercise your rights. | Article 6(1)(b), 6(1)(f), or 6(1)(c) GDPR, depending on the request; rights requests are handled to meet GDPR obligations. |
For processing based on legitimate interests, our interests are account and service security, fair matchmaking, child protection and resolving concrete disputes. We consider the interests and rights of affected people, especially children, and limit access and retention accordingly. You have the right to object as explained below.
Providing account fields is necessary to use an account. Without them we cannot provide matchmaking. A Poképaste share link is required to search for a match. Our server fetches its contents and saves only Pokémon, Item, Ability, Nature and moves as a fixed match snapshot. EVs, IVs, nicknames, paste titles, authors and notes are not saved in that snapshot or delivered to the opponent; the original link is not automatically shared. Additional chat and support submissions are voluntary; avoid sensitive data about health, beliefs or other private matters. Merely visiting the legal pages does not require an account.
We calculate Elo ratings automatically from confirmed match outcomes and use ratings to find suitable opponents. These recreational calculations do not themselves make decisions with legal or similarly significant effects within Article 22 GDPR. Contact us to request a human review of a disputed outcome. We do not use advertising profiles or automated content scanning.
4. Age declarations and minors
Battle Link is intended only for people aged 18 or older who have reached the age of legal majority where they live. We collect a required declaration of adulthood and record it with the accepted terms version and time. We do not routinely collect dates of birth, parental email addresses or identity-document copies.
The declaration is not independent age verification. If you believe an account belongs to a minor, contact us. We assess credible reports, restrict access where appropriate and remove data that we have no lawful reason to retain. A parent may contact us about a child’s data even though no parental-approval account option is offered. We verify requests proportionately to avoid disclosing information to an unauthorized person.
Article 8 GDPR contains specific rules for certain consent-based online services offered to children. These rules do not establish a universal minimum age for making every contract independently. Our service uses the adulthood requirement described in the Terms of Service and does not rely on a blanket privacy-consent checkbox.
6. Hosting, email and international transfers
Hosting and infrastructure
STRATO GmbH, Otto-Ostrowski-Strasse 7, 10249 Berlin, Germany, provides the VPS and network infrastructure as our processor. The operator has selected a server location in Germany. Application, database and Redis run on that VPS; administrative access is limited to authorized administrators.
Email and support delivery
STRATO GmbH, Otto-Ostrowski-Strasse 7, 10249 Berlin, Germany, provides our operational mailbox service@battlelink.de for verification, recovery, support and reports. SMTP authentication may use the associated primary mailbox. The operator has confirmed a STRATO processing agreement, most recently concluded on 20 January 2026. Support-mailbox copies require separate operator deletion.
Transfers outside the EEA
Primary application storage and operator-controlled NAS backups are in Germany. This is not a blanket promise that all recipients operate only in the EEA. STRATO lists applicable subprocessors and transfer safeguards in its processing agreement (https://www.strato.de/agb/avv/); EEA processing is the contractual baseline, with service-related exceptions under GDPR Chapter V. Email is delivered to the provider chosen by the recipient, potentially outside the EEA. To import a submitted team, our server requests its public identifier from Pokepaste; it does not send account credentials, email or the player browser IP. Browser visits to external links are processed by their providers. Contact the operator for the recipients and safeguards applicable to your request.
Before a provider processes production data on our behalf, the required contractual and security arrangements must be in place. Where data is transferred outside the EEA, an applicable GDPR Chapter V mechanism is required, such as an adequacy decision or appropriate safeguards, with additional measures where necessary. You may request details and a copy of applicable safeguards, subject to lawful redactions, using our privacy contact.
8. Storage and deletion
Account information and acceptance records are kept while needed for the account and its agreement. You can request account closure or erasure by email. Requests are reviewed and carried out by the operator; there is no self-service deletion button at present. We erase or anonymize data that is no longer necessary, unless a specific legal duty or concrete legal claim justifies restricted retention. We explain any refusal or limitation and do not apply a blanket retention exception.
- Chat messages, including manually submitted links: 30 days after sending.
- Completed or cancelled match records and their rating ledger: 180 days after completion or cancellation. Current account ratings remain until account closure or correction. Unfinished matches expire after two hours; unresolved results have a 15-minute resolution deadline. On erasure, direct account identifiers and the user’s chat messages are removed; shared results may remain under a new, unlinked alias until their retention deadline to preserve opponents’ match records. This is pseudonymization, not a promise that every shared record is immediately anonymous. Requests for earlier removal are assessed individually.
- Routine audit and abuse-report records, including captured chat and images: 90 days. Moderation history is ordinarily removed after 90 days; records for an active ban are retained while it remains active. Current bans, the latest warning and internal flags remain until expiry or operator correction, removal or account erasure. Match correction history follows the match retention period.
- Expired or revoked sessions: removed by the retention job.
- Password reset links: single use, valid for 15 minutes; a new request invalidates earlier links. Expired token records are removed by the mail worker, normally within one minute while it is running.
- Encrypted outgoing mail: reset messages expire after 15 minutes, verification messages after 30 minutes, and report messages after 24 hours if not sent. Message bodies, chat copies and images are removed from the outgoing queue after the mail server accepts them, or after final failure or expiry. Non-content delivery records are kept for up to seven days, checked by the mail worker. Retries may occasionally produce duplicate emails.
- Report emails and images already delivered to the support mailbox are separate copies. The operator reviews and deletes them when no longer needed, normally within 90 days, unless a documented complaint or legal claim requires restricted retention. The application does not automatically delete messages from the mailbox. Account erasure also requires reviewing those mailbox copies.
- Queue entries, including the submitted Poképaste link and hosting preference: removed on cancellation, pairing, loss of the last valid connection, or server restart. Authentication rate-limit entries expire within approximately two hours; socket rate counters last about one minute.
The application checks these routine deletion deadlines at startup and hourly. Removal can therefore occur up to about one hour after a deadline, or when service resumes after downtime.
Infrastructure logs
Operator-controlled VPS application and system diagnostic/security logs are retained for at most seven days during normal operation, using a shorter journal retention window, bounded journal files and hourly cleanup. After downtime, cleanup resumes on startup. We do not enable routine Caddy request access logs or intentionally log passwords, session tokens or chat bodies. Provider-held infrastructure records follow the provider arrangements and applicable obligations; this limit does not silently delete provider records.
Backups
The operator stores one encrypted, successful backup on an operator-controlled UGREEN NAS in Germany. A new backup is scheduled daily at 03:00 Europe/Berlin and replaces the previous backup only after successful validation. Failed backups preserve the previous successful copy until a successful replacement or operator review; this is not a guaranteed 24-hour deletion deadline. Temporary staging is cleared after a run. Authorized access is limited, the decryption key is retained separately for recovery, and erased accounts must not be reactivated after restore. Manual migration dumps and mailbox copies are reviewed separately for deletion; verified erasure requests require a new sanitized backup or separate justified handling of affected copies.
Where records are held for a concrete complaint or legal claim, only the necessary records may be preserved separately with restricted access until the matter and applicable retention obligation end. Support correspondence is reviewed when a request is resolved and deleted when no longer needed, subject to those same criteria. Backup error notifications use our operational mailbox and contain job information, not player data or credentials. The operator must document the reason and duration of any exceptional retention. Restore procedures must reapply completed erasure requests so that deleted accounts do not become active again.
9. Your rights and complaints
Subject to the conditions in the GDPR, you may request access and a copy (Article 15), correction (Article 16), erasure (Article 17), restriction (Article 18), and portability of data processed automatically on the basis of consent or a contract (Article 20). These rights also apply to children. We may need proportionate information to confirm your identity or a representative’s authority and protect other people’s data.
Right to object: where we rely on Article 6(1)(f), you may object on grounds relating to your particular situation (Article 21). We then stop that processing unless we demonstrate compelling legitimate grounds or need it for legal claims. You may object to direct marketing at any time without giving reasons; we do not currently carry out direct marketing.
If processing is based on consent in a particular case, you may withdraw that consent at any time without affecting earlier lawful processing. Necessary account processing described here is not based on optional consent.
Contact service@battlelink.de. We normally respond without undue delay and within one month. If a lawful extension is necessary because of complexity or the number of requests, we will explain it within that month. Requests are generally free; any exception is governed by Article 12 GDPR.
You may complain directly to a supervisory authority, particularly where you live, work or believe an infringement occurred. You do not have to contact us first. The North Rhine-Westphalia authority is the Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW), Kavalleriestraße 2–4, 40213 Düsseldorf, Germany; poststelle@ldi.nrw.de. This does not restrict access to another competent authority or the courts.
10. Security
Passwords are stored as Argon2id hashes, not plain text. Session secrets are hashed in the database. Access checks, input validation and request limits help protect accounts and matches. Public operation must use HTTPS. No internet service can promise absolute security; use a unique password and tell us if you suspect misuse. Do not send passwords or session tokens in a support request.
11. Changes to this notice
We update this notice when purposes, providers or practices change and provide any further notice or consent opportunity required by law before a materially different use. This page is information about processing, not a request for blanket consent. See also the Terms of Service and Legal Notice.