Privacy policy

• Modhelm is a Discord bot with a web dashboard, a portal and a mobile app that teams of Roblox games use to manage reports, bans, appeals and verifications.
• We are the controller for the website, accounts, network-wide verification, billing, support, applications and the security of our systems.
• The team of each game is the controller for the moderation data of its community (reports, evidence, bans, appeals, notes). We process this data only on that team's behalf.
• All data is stored on our own server in a data centre in Frankfurt am Main, Germany. We use only necessary cookies, no analytics tools and no advertising.
• We do not sell data, we do not share it for advertising, and we do not use it to train AI.
• Bans are always decided by people, never by a machine.

The controller under the General Data Protection Regulation (GDPR) is:

Marlon Güttler, c/o Realisator Media GmbH, Bayernring 7, 12101 Berlin, Deutschland, email: info@modhelm.com

Realisator Media GmbH is only our postal address and has no access to Modhelm data. We have not appointed a data protection officer. For any privacy question, contact us directly at the email address above or open a privacy ticket in our support Discord.

We are the controller for data whose purpose we decide ourselves: visits to this website, logins and sessions, network-wide verification, payments, support, applications, notices under the Digital Services Act, records of consent, the mobile app and the security of our systems.

We are a processor for the moderation data that game teams manage with Modhelm: reports, evidence, decisions, bans, appeals, notes and the log of their server. The controller for this data is the owner of the Discord server or the team of the game. We conclude a data processing agreement under Art. 28 GDPR with every team.

You find a team's privacy notice in the game's portal at /g/<server>/privacy or on the team's own domain at /privacy. Every report and appeal form links to it. It is best to send requests about moderation data to the team. You can also contact us. We then forward your request to the team without delay and help it to answer.

Modhelm runs on our own server, which we rent from Hostinger International Ltd. (Larnaca, Cyprus) in a data centre in Frankfurt am Main, Germany. The database, the evidence files and the backups are stored there. Hostinger is our processor under Art. 28 GDPR and may use the data only to operate the server.

Our database is the open source software Supabase, which we run ourselves on this server. No data goes to Supabase Inc. or to any other cloud provider.

Fonts, graphics and scripts of the website are delivered from our own server. We do not embed Google services, advertising networks or analytics tools. The only exception are profile pictures and icons from Discord and Roblox, see "Images from Discord and Roblox".

When you open our website, the dashboard, the portal, the status page or the documentation, our server processes technically necessary data: IP address, date and time, the address requested, referrer, browser and operating system, and the status code of the response.

• Purpose: to deliver the page, find errors, and fend off attacks and abuse.
• Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is secure and stable operation, for example detecting and stopping overload attacks.
• Retention: 14 days. We keep individual entries longer if we need them to investigate a specific security incident.

We do not analyse these logs for statistics and do not combine them with other data. For limits against abuse (for example too many login attempts) we store the IP address only as an irreversible hash and only for the length of the respective time window.

We only set cookies that are strictly necessary for a service you explicitly use (§ 25(2) no. 2 of the German TDDDG). This does not require consent, so we do not show a cookie banner. We do not set analytics, advertising or third-party cookies.

If you install Modhelm as an app, your browser stores program files and an offline page so that the app starts quickly. They contain no personal data. The further processing is based on Art. 6(1)(b) GDPR (use of the service) and Art. 6(1)(f) GDPR (secure operation). Our cookie notice has more details.

In the dashboard, the portal and the app we show profile pictures, server icons and game images. Your browser loads some of them directly from the servers of Discord (cdn.discordapp.com, media.discordapp.net) or Roblox (rbxcdn.com). Discord or Roblox then receive your IP address, the address of the image and information about your browser. We learn nothing additional about you from this.

• Purpose: to show the images you know from Discord and Roblox, so that you recognise servers, players and team members at once.
• Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is a complete and familiar display. Images that belong to a report, however, are stored by us.
• Recipients: Discord and Roblox as independent controllers, also in the United States (see "Transfers to third countries").

You log in to the dashboard, the app and the portal with Discord. Discord gives us your Discord ID, user name, display name, profile picture and language setting (scope identify). For the dashboard we also request the list of your servers (scope guilds) so that we can show which servers you may manage. We do not receive your email address or your messages.

We store the Discord access token encrypted (AES-256-GCM) so that we can check your permissions live on every request. We store your session only as a hash. We never receive a password.

• Purpose: login, checking your permissions, attributing your actions.
• Legal basis: Art. 6(1)(b) GDPR (you use the dashboard, app or portal) and Art. 6(1)(f) GDPR (security and traceability of decisions).
• Retention: sessions end after 30 days (dashboard and app) or 7 days (portal) or when you log out. Access tokens are deleted with the session. We keep your user profile (ID, name, picture) while you use Modhelm and delete it on request or after 24 months without a login, unless it is needed for the log of a server.

For appeals in the portal and for linking your Roblox account you log in with Roblox (OAuth 2.0, scopes openid and profile). Roblox gives us your Roblox user ID, user name, display name and the address of your profile picture. We never see your Roblox password. Roblox allows this login only from age 13.

We keep these details for at most one hour in a signed cookie (mh_rbx) and use them only for the appeal or the link you are making right now.

• Legal basis: Art. 6(1)(b) GDPR (you submit an appeal) or Art. 6(1)(a) GDPR (you link your account for verification).
• Retention: one hour in the cookie. After that only in the appeal (on behalf of the team) or in your verification (until you withdraw it).

When you verify through a verify panel, we store as controller: your Discord ID, if you wish your Roblox user ID, Roblox user name and display name, the version and time of your consent, and the servers in which you were verified, with method and time.

• Purpose: you verify once and are recognised in every server that uses Modhelm. These servers then give you their role and set your nickname in their format, which can include your Roblox name.
• Recipients: the servers you join that use Modhelm, and their teams. They see that you are verified and, if applicable, your linked Roblox account. They do not see reports, bans or notes from other servers.
• Legal basis: your consent (Art. 6(1)(a) GDPR). You can withdraw it at any time with /unverify or on your My data page. After that we no longer verify you automatically and delete the Roblox link immediately. The withdrawal applies to the future. Roles a server has already given you stay until that server removes them.
• Retention: until you withdraw. We keep the record of your consent for three more years after that (see "Records of consent").

Verification remains our own processing, even if you verify through a team's own bot or own domain.

We process this data on behalf of the respective game team (see above). For transparency, this is what it covers:

• Reported players: Roblox user ID, user name, display name, previous user names, profile picture, full body image and profile background, account age and other public profile data from Roblox
• Reporters: Discord ID and name, for reports from inside the game the Roblox user ID instead, the content of the report, answers to the team's questions, evidence such as videos, images and links
• Decisions: bans, temporary bans and acquittals with reason, duration, time and who decided, and the result at Roblox
• Appeals: text of the appeal, answers, Roblox user ID, Discord ID, status, attempt number and waiting periods
• Notes of the team about a player and the log of the server

Sources: reporters, the team's moderators, the game itself (reports from inside the game through Roblox Open Cloud) and the public interfaces of Roblox and Discord.

Before a report or an appeal is sent, the person explicitly agrees every time that their details and evidence go to the team of the game. We store a record of this.

We convert evidence videos on our server into a smaller format after upload and delete the original. We do not analyse the content of videos and images automatically. If a team books our moderation service, trained Modhelm moderators decide on reports according to the team's rules. Appeals always stay with the team.

There is no shared ban list across all servers. A moderator can ban a player in the games of other servers only where they have moderation rights themselves. Each of these servers then gets its own entry.

Default retention: reports without a penalty 180 days after the decision, otherwise until one year after the penalty ends. Appeals like the related penalty. The team can delete earlier. If a team removes its server data, we delete everything including the files.

If you were reported or banned in a Roblox game, you did not give us this data yourself. That is why we explain here what happens (Art. 14 GDPR). The controller is the team of the game, and we act on its behalf.

• Which data: your Roblox user ID and public profile data, the report with evidence, decisions and penalties with reason and duration, the team's notes and your appeals. If your Discord account is linked to your Roblox account through verification, also your Discord ID.
• Where it comes from: players who reported you, the team's moderators, the game, and Roblox's public profile data.
• What for: to review reports, enforce the game's rules, apply bans at Roblox, handle appeals and protect the community.
• Legal basis: usually the team's legitimate interest in a safe community and in enforcing its rules (Art. 6(1)(f) GDPR). Your interests must be taken into account, especially if you are a minor. The team names the exact basis in its notice.
• Recipients: the team's moderators, Modhelm as processor, Roblox (the ban is applied in the game through Roblox Open Cloud, with your user ID, duration and reason) and Discord (the report appears in the team's Discord server). We do not tell you who reported you.
• Retention: as described above under "Default retention", unless the team sets shorter periods.
• Your rights: access, rectification, erasure, restriction and objection (Art. 15 to 18 and 21 GDPR) and a complaint to a supervisory authority. Contact the team through the privacy notice in its portal, or contact us and we will forward your request.

When you are banned, Roblox shows you the reason and the duration. If your Discord account is linked and the team has turned this on, you also get a message with the reason, the duration and the date from which you can appeal. If you delete your data at Roblox, Roblox can notify the game. If the team has set up this connection, we delete your data for this game automatically. An active ban stays stored at Roblox until the team or Roblox lifts it.

When you agree to a disclosure or to terms (for example with a report, an appeal, a verification, an application or when accepting the terms), we store a record: which text was shown in which version and language (as a SHA-256 checksum of the exact text), the time, the context (for example the report), the source (web or Discord), an irreversible hash of your IP address and a shortened description of your browser. You can see your records on the My data page.

• Purpose: to be able to prove that consent was given (Art. 7(1) GDPR).
• Legal basis: Art. 6(1)(c) GDPR in conjunction with Art. 7(1) GDPR, and Art. 6(1)(f) GDPR (proof towards authorities and courts).
• Retention: while the consent applies and three years after that (regular limitation period under § 195 of the German Civil Code).

You can buy paid plans on our website through Stripe or in Discord.

• Stripe (Stripe Payments Europe, Ltd., 1 Grand Canal Street Lower, Dublin, Ireland) processes your name, email address, billing address, VAT ID if any, and your payment details, and calculates taxes. We do not see card details. We store your Stripe customer number, the status of your subscription and the invoices.
• For the moderation service we send Stripe only a counter for each decision made by our team, so that the fee per 100 moderations can be calculated. No data about players goes to Stripe.
• For purchases in Discord, Discord handles the payment as the seller. We only receive which server has which plan for which period.

• Legal basis: Art. 6(1)(b) GDPR (contract) and Art. 6(1)(c) GDPR (tax and commercial law obligations).
• Retention: we keep invoices and accounting records for as long as the law requires, usually eight or ten years from the end of the calendar year (§ 147 of the German Fiscal Code, § 257 of the German Commercial Code).

When you write to us, by email or with a ticket in our support Discord, we process your details to answer you.

• Email: your email address, your name if given, and the content of your message.
• Support Discord: our support server uses Modhelm itself. To join, you verify with Discord and Roblox (see "Network-wide verification"). For a ticket we store your Discord ID and name, the topic you chose, your answers in the form, the conversation and your rating. When a ticket is closed, we create a transcript file, store it on our server, post it in an internal channel for our team and send you a copy by direct message. Messages in the support server are also stored by Discord.

• Legal basis: Art. 6(1)(b) GDPR if it concerns a contract or steps before one, otherwise Art. 6(1)(f) GDPR (legitimate interest in answering requests and improving the quality of our support).
• Retention: we delete ticket transcripts and emails twelve months after the request is closed, unless statutory retention duties apply, for example for business letters.

Partner programme

If you apply as a partner on our website or in the support Discord, we process your Discord ID, the type of partnership, your name or project, your links, your reach, the IDs of your Roblox games if you add them, your message and our decision. The application appears in an internal channel of our support Discord and in our staff panel.

Job applications

If you apply for a job, we process your Discord ID, name, email address, languages, experience, links, cover letter, CV as a PDF, your answers and the status of the process including our notes. Please only send us what matters for the job, for example no photo and no details about health or religion.

• Purpose: to review your application, talk to you and decide.
• Legal basis: Art. 6(1)(b) GDPR (steps before a partnership, an employment or a freelance relationship). After a rejection, Art. 6(1)(f) GDPR (defence against possible claims, for example under the German General Equal Treatment Act).
• Recipients: only the people in our team who take part in the decision, and Discord for messages in the support Discord.
• Retention: six months after the process ends. If we become partners or work together, we keep the necessary details for the duration of the cooperation and after that only as far as statutory duties require.

Anyone can report illegal content through our notice form or by email. We process the name and email address (optional for notices about child sexual abuse material), the location and description of the content, the reason, your explanation, the time, the language, a hash of your IP address, a shortened description of your browser, and your Discord ID if you are logged in.

• Purpose: to review and handle the notice, inform you of our decision, handle complaints and provide proof to authorities.
• Legal basis: Art. 6(1)(c) GDPR in conjunction with Art. 16 and 17 DSA. For notices under the US DMCA, Art. 6(1)(f) GDPR (protection against liability and protection of third party rights).
• Retention: three years after the notice is closed.

We disclose your identity to the person concerned only where strictly necessary (Art. 17(3)(b) DSA). The exception are copyright notices under the DMCA: we forward them with name and contact details to the person who uploaded the content, so that they can respond. In case of criminal offences that threaten life or safety we inform the German Federal Criminal Police Office (Art. 18 DSA).

Our app at m.modhelm.com is a web app. You log in with Discord, just like in the dashboard. After 15 minutes without use it locks itself, and you unlock it again with a passkey.

Push notifications

You only get push notifications if you turn them on and your browser or device has asked for permission. We then store the address your browser gives us for notifications, the related keys, the servers and events you want messages for, and the time. Notifications are delivered through the push service of your browser or operating system, for example from Google, Apple or Mozilla. The content is end-to-end encrypted. The push service only sees that a message goes to your device, when, and how large it is.

• Legal basis: your consent (Art. 6(1)(a) GDPR and § 25(1) of the German TDDDG), which you give when you turn them on. You withdraw it by turning notifications off in the app or in your browser.
• Retention: until you turn them off or the push service tells us that the address is no longer valid.

Passkeys, Face ID and fingerprint

With a passkey you unlock the app or confirm your login, for example with Face ID, Touch ID or your fingerprint. Your biometric data never leaves your device. Your device checks it itself and only confirms to us cryptographically that the passkey was used. We store the passkey's identifier, the public key, a counter against copied keys, the supported transports, the name you give the passkey, and when it was created and last used. The private key stays on your device or in your password manager.

• Legal basis: Art. 6(1)(b) GDPR (you use this feature) and Art. 6(1)(f) GDPR (protecting your account). For our own team, passkeys are mandatory.
• Retention: until you delete the passkey or your account is deleted.

Our status page status.modhelm.com shows whether the bot, the website, login, the portal, the interfaces and the database are working. For this we automatically check our own components and the availability of Discord and Roblox every minute, and store the state, response time, error text and time. This contains no personal data of visitors or customers. We publish incident reports without names of staff members. Visits to the status page are covered by "Visiting the website".

• Legal basis: Art. 6(1)(f) GDPR (reliable operation and transparency about incidents).
• Retention: per-minute measurements 7 days, aggregated values 90 days.

If a team uses white label, we also process the application ID, bot token and client secret of its Discord application (encrypted with AES-256-GCM), the bot's name and picture, and the team's own domain with the result of the DNS check. For the own domain we obtain a TLS certificate from a certificate authority such as Let's Encrypt (Internet Security Research Group, USA). Only the domain name goes to the certificate authority, and like every certificate it is published in public Certificate Transparency logs.

On a team's own domain and in its own bot, the imprint and privacy notice of that team also apply, and the team is responsible for them.

• Legal basis: Art. 6(1)(b) GDPR (contract with the team).
• Retention: until the team ends white label. We then delete the token and secret immediately.

In the dashboard and the bot we log who carried out which action and when (for example a ban or a changed setting). This keeps every decision traceable. We store API keys, bot tokens and access tokens encrypted, and all connections use TLS.

Modhelm staff see a server's data only if the team has booked the moderation service, or during a support access with a reason and a time limit. Every support access appears in the server's log.

• Legal basis: Art. 6(1)(f) GDPR (security and traceability) and, for the logs of game teams, on behalf of the team.
• Retention: log entries at most 365 days, visible for 14 to 365 days depending on the server's plan.

Data we receive through the interfaces of Roblox and Discord is subject to fixed rules:

• We use it only for Modhelm's features.
• We do not sell it and do not pass it on to data brokers or advertising networks.
• We do not use it to train AI.
• We do not build profiles across servers or games and do not rate people, for example with a reputation score.
• If we lose access to the Roblox interfaces, we delete all data obtained through them.
• You can ask us at any time to change or delete your data: on My data, with /unverify or by email to info@modhelm.com.

We disclose data to authorities only where the law requires it, and to tax advisers only as far as needed for our accounting.

Our own server is in Germany. Discord and Roblox are based in the United States, and anyone who uses their platforms gives them data. When we send a ban to Roblox on behalf of a team, or the bot writes a message in Discord, data goes to these companies.

• Discord states that it bases transfers on the European Commission's standard contractual clauses and the EU-US Data Privacy Framework.
• Roblox states that it bases transfers on standard contractual clauses.
• Stripe is certified under the EU-US Data Privacy Framework and also uses standard contractual clauses.
• Push services and certificate authorities may process data in the United States. The content of push notifications stays encrypted.

Where a recipient is certified under the Data Privacy Framework, the European Commission's adequacy decision applies (Art. 45 GDPR), otherwise standard contractual clauses apply (Art. 46(2)(c) GDPR). You can get a copy on request.

You have the right to

• access your data (Art. 15 GDPR),
• rectification of incorrect data (Art. 16 GDPR),
• erasure (Art. 17 GDPR),
• restriction of processing (Art. 18 GDPR),
• data portability (Art. 20 GDPR),
• object to processing based on legitimate interests (Art. 21 GDPR, see below),
• withdraw consent with effect for the future (Art. 7(3) GDPR),
• lodge a complaint with a data protection supervisory authority (Art. 77 GDPR, see below).

Write to us at info@modhelm.com, open a privacy ticket in our support Discord or use the My data page. We answer within one month and free of charge. In complex cases we can extend this by two months, and we tell you so within the first month. If we have doubts whether the request comes from you, we may ask you, for example, to log in with the Discord or Roblox account concerned.

If your request concerns moderation data of a game team, we forward it to that team, which decides on it.

You can object at any time, on grounds relating to your particular situation, to processing based on Art. 6(1)(f) GDPR (Art. 21 GDPR). The processing then stops, unless there are compelling legitimate grounds that override your interests, or it serves the establishment, exercise or defence of legal claims.

For moderation data we process on behalf of a game team, please send the objection to the team. We forward it on request. We do not send advertising by email or direct message.

You can complain to any data protection supervisory authority, in particular in the country where you live or work. The authority responsible for us is:

Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit), Alt-Moabit 59-61, 10555 Berlin, Germany, www.datenschutz-berlin.de

We would prefer to sort out your concern directly with you first.

Discord may only be used from age 13, and the same applies to logging in with Roblox. Some countries require a higher minimum age. The dashboard and our paid plans are aimed at adults and businesses. We do not knowingly collect data directly from children under 13. If we learn of it, we delete that data. Parents can write to us about this at any time at info@modhelm.com.

Roblox is also played by children, so reported players can include children. Their data does not come from them but from reporters, the game or Roblox. That is why we keep moderation data minimal, show it only to the team of the game, delete it after fixed periods and never use it for advertising or profiles. Pages used by players have no tracking.

If you are under 16, please ask your parents before you verify or link your Roblox account.

Bans, temporary bans, acquittals and appeals are always decided by people. We do not use automated decision-making within the meaning of Art. 22 GDPR, no profiling and no AI to assess evidence or people.

Only one rule runs automatically: an appeal submitted before the waiting period has ended is rejected with the date of the next possible appeal. This is purely a deadline check, does not count as an attempt and does not replace a decision on the appeal.

California (CCPA/CPRA)

The California Consumer Privacy Act only applies above certain revenue and user thresholds. Regardless of that, we grant people in California the following rights.

The purposes, retention periods and recipients are described in the sections above. We do not use sensitive personal information to infer characteristics about you.

• No sale, no sharing: we do not sell personal information and do not share it for cross-context behavioural advertising ("sale" or "sharing" under the CCPA), including that of people under 16. We honour signals such as Global Privacy Control, but they change nothing for us because we do neither.
• Your rights: to know the categories and specific pieces of personal information we hold about you, to delete, to correct, and not to be discriminated against for using your rights.
• How to use them: by email to info@modhelm.com or on My data. We verify your identity, for example by asking you to log in with the account concerned, and answer within 45 days. An authorised agent can make the request for you if they provide written permission.
• We do not disclose personal information to third parties for their direct marketing (California Shine the Light law).

Other US states

If you live in another state with its own privacy law, for example Virginia, Colorado, Connecticut, Utah, Texas or Oregon, you have the same rights. If we decline a request, we tell you why. You can appeal to us and get an answer within 60 days. If we still decline, you can contact the Attorney General of your state.

Children under 13 (COPPA)

Our service is not directed to children under 13, and we do not knowingly collect personal information directly from them. Reports from inside a game can contain the Roblox user ID of the reporting player. We use it only to handle the report and never for advertising, profiles or contacting the player. If we learn that we received data directly from a child under 13, we delete it. Parents can reach us at info@modhelm.com.

For people in the United Kingdom, the UK GDPR and the Data Protection Act 2018 apply. You have the same rights as described above. Transfers to the EU are covered by the UK's adequacy regulations, transfers to the United States by the UK Extension to the Data Privacy Framework where the recipient is certified, and otherwise by the International Data Transfer Addendum.

We design pages used by players following the principles of the Age Appropriate Design Code: no profiling, no advertising and privacy-friendly default settings.

You can complain to the Information Commissioner's Office: ICO, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, ico.org.uk.

For people in Switzerland, the Federal Act on Data Protection (revFADP) applies. In particular, you have the right to access, to receive and transfer your data, to rectification and erasure, and you can object to processing. According to the Federal Council, Germany and the EU provide adequate data protection. Transfers to the United States are based on the Swiss-US Data Privacy Framework where the recipient is certified, and otherwise on standard contractual clauses.

The supervisory authority is the Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern, www.edoeb.admin.ch.

For people in Brazil, the Lei Geral de Proteção de Dados (LGPD) applies. We process your data to perform a contract, based on legitimate interests, to comply with legal obligations, to exercise rights or with your consent (Art. 7 LGPD), as described in the sections above.

You have the rights under Art. 18 LGPD: confirmation that we process data, access, correction, anonymisation, blocking or deletion of unnecessary data, portability, information about recipients, information about the consequences of refusing consent, withdrawal of consent, and objection. Transfers abroad are based on the mechanisms under Art. 33 LGPD, in particular standard contractual clauses. Our communication channel for LGPD requests is info@modhelm.com. You can also contact the Autoridade Nacional de Proteção de Dados (ANPD), www.gov.br/anpd.

For people in Canada, the Personal Information Protection and Electronic Documents Act (PIPEDA) applies and, where relevant, provincial laws such as Québec's Law 25. The person responsible for the protection of personal information at Modhelm is Marlon Güttler, reachable at info@modhelm.com.

Your data is stored in Germany and may also be processed by the recipients listed above in the United States. Courts and authorities there may demand access under local law. You can request access to and correction of your data and withdraw consent at any time. We may then be unable to offer some features. You can file complaints with the Office of the Privacy Commissioner of Canada, www.priv.gc.ca.

If you live in another country, the rights in this privacy policy apply to you as well. Mandatory rights under the law of your country remain unaffected. Write to us at info@modhelm.com if you want to use them.

We update this privacy policy when our service or the law changes. The version on this page applies. We inform customers about significant changes in the dashboard.