Membership Privacy Policy

BY ORDER OF THE APOLLO EMPIRE

EMPEROR OF THE EMPIRE OF APOLLO

INSTRUCTION 26-101

01905 30 August 2025

Personnel

MEMBERSHIP PRIVACY POLICY

COMPLIANCE WITH THIS PUBLICATION IS MANDATORY

Accessibility: This instruction is accessible to all members past, present, and future of The Empire of Apollo.

https://www.apolloempire.com/aei26-101-privacy-policy

Releasability: There are no releasability restrictions on this publication.

Office of Primary Responsibility (OPR): HQ/A1

Certified By: Conor Evans, Emperor

Pages: 19

Summary of Changes: Initial release, establishing detailed Privacy Policy.

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1.1. Purpose. The Empire of Apollo (TEOA) is committed to protecting your privacy and managing your personal data in a transparent manner. This document, Apollo Empire Instruction (AEI) 26-101, Privacy Policy explains what information we collect from members and users, how we use and share that information, and the choices you have regarding your personal data.

We recognize that we operate globally, so this policy is designed as a global privacy policy — it aligns with key principles from multiple privacy laws around the world (such as the EU General Data Protection Regulation (GDPR) and the U.S. California Consumer Privacy Act (CCPA)) to ensure compliance and consistency.

"Personal information" (or "personal data") means any information that can be used to identify an individual, either on its own or when combined with other data. TEOA does not sell personal information to third parties. By using TEOA platforms or providing us your information, you agree to the data practices described in this instruction.

2.1. Personal Information We Collect.

2.1.1. Account Information: When you register or join The Empire of Apollo, we may collect your name (or chosen username/alias), email address, contact information, and a password. If our platforms require account profiles, you might also provide other details like an avatar image or a short bio.

2.1.2. Identifiers across Platforms: TEOA integrates multiple platforms (websites, game servers, forums, and Discord). We may collect unique identifiers that link your presence across these platforms — for example, your Discord username/tag, in-game character or Minecraft username, forum handle, or any other user ID relevant to TEOA services. This helps us create a central profile for you so that you receive your entitlements everywhere.

2.1.3. Contact and Communications: If you provide your email address or other contact info, we will collect it. We also collect the content of communications you send us or post publicly, including support tickets and public chat messages.

2.1.4. Transaction Information: If you make any payments or donations to TEOA, our payment processor will collect payment details. TEOA itself may receive records of your transactions (amount, date/time, items purchased) but we do not store sensitive payment account numbers. For specific transaction details, see Square's terms at squareup.com.

2.1.5. Usage Data: We automatically collect certain technical information when you use our websites or servers, including your IP address, device type, browser type, operating system, and general location (city/country) inferred from the IP. We also log activity information such as login times and actions performed in-game or on the site.

2.1.6. Cookies and Similar Technologies: Our websites may use cookies or similar tracking technologies. We use cookies for keeping you logged in (session cookies), remembering preferences, and collecting aggregate analytics. We may also use third-party analytics tools that set their own cookies.

2.1.7. Voluntary Data: Any other information you voluntarily provide, including feedback from surveys, contests, or beta programs.

2.2. How We Use Your Information.

We process and use the collected information for various legitimate purposes related to running The Empire of Apollo:

2.2.1. Providing and Improving Services: We use your information to operate TEOA platforms and personalize your experience, verify account ownership, authenticate logins, display your profile correctly, and deliver content or features you're entitled to.

2.2.2. Account Management: Information like your email and username are used to maintain your account and membership status. We may send service-related communications including welcome emails, verification codes, password reset links, or important notices.

2.2.3. Fulfilling Purchases and Rewards: Our central database links your transactions to your user IDs on each platform so that when you log into a game server, it knows what items or privileges to give you.

2.2.4. Communication and Customer Support: We may use your contact information to communicate with you about service updates, changes to terms/policies, or upcoming events. We may also send community newsletters; you will have the ability to opt out of promotional communications.

2.2.5. Enforcing Rules and Security: We process data to keep TEOA safe and fair. IP addresses and device identifiers are used to detect and prevent fraud, hacking attempts, or ban evasion.

2.2.6. Analytics and Metrics: We use aggregated usage data to understand how members engage with TEOA, track login rates, popular game modes, and feature usage. Where possible, we use anonymized or aggregated data that does not directly identify individuals.

2.2.7. Legal Compliance: We may need to process and retain certain data to comply with legal obligations including financial records for accounting and tax purposes.

2.3. Cookies and Tracking Technologies.

2.3.1. Essential Cookies: Necessary for the website to function properly (e.g., session cookies to keep you logged in). These do not require consent.

2.3.2. Preference Cookies: Used to remember your settings and preferences such as language selection or display options.

2.3.3. Analytics Cookies: Collect information about how users interact with our website. We currently use squareup.com which sets cookies to gather usage data.

2.3.4. Third-Party Integrations: If our site integrates content from third parties (such as embedded YouTube videos or social media share buttons), those third parties might set their own cookies.

2.3.5. Do-Not-Track Signals: Our systems do not currently respond differently to DNT signals. We instead provide you with direct control via cookie consent tools or account settings.

2.3.6. Opt-Out: You can manage cookies through your browser settings. You have the ability to delete or block cookies, but doing so might impact your ability to use certain features.

2.4. Data Sharing and Disclosure.

TEOA does not sell your personal information to third parties. We do share certain information with third parties in the following contexts:

2.4.1. Service Providers: Trusted third-party companies that help us operate TEOA services or perform functions on our behalf, including cloud hosting providers, payment processors, email service providers, and analytics services.

2.4.2. TEOA Staff: Members of our administrative team may access personal information on a need-to-know basis. All such personnel are bound by TEOA Form 3B-003, Non-Disclosure Agreement.

2.4.3. Other Members (limited): By the nature of a community, some of your information (username, avatar, profile info you choose to share) is visible to other members. We urge you to be mindful that any information you make public in the community can be seen and used by others.

2.4.4. Legal Requirements: We may disclose personal information if required by law or in response to valid requests by public authorities (court orders, subpoenas, government demands).

2.4.5. Business Transfers: If The Empire of Apollo undergoes a significant change (merger, acquisition, or transfer of assets), your personal data might be among the assets transferred. We will ensure the new entity continues to honor your privacy rights.

2.4.6. With Consent: Outside the scenarios above, if we would like to share your information with a third party, we will obtain your consent before doing so.

2.5. International Data Transfers.

The Empire of Apollo operates a global community. Personal data collected from members around the world may be transferred to and stored on servers in different countries. Our central database and primary servers are currently located in the United States.

2.5.1. Privacy and Data Protection: When we transfer data from users in the European Economic Area (EEA), United Kingdom, or other regions with strict data laws, we take steps to ensure compliance with those laws through Standard Contractual Clauses (SCCs) or other appropriate mechanisms.

2.5.2. Central Database Benefit: We have implemented security measures on this central repository to guard your information. Access to personal data is restricted to authorized personnel and service processes.

2.5.3. Your Acknowledgment: By using TEOA and providing personal information, you acknowledge that your data may be transferred to, stored in, and processed in the United States and other jurisdictions.

2.6. Data Security Measures.

TEOA takes data security very seriously. Our security measures include:

2.6.1. Encryption: All network communications involving personal data are protected via HTTPS/TLS encryption. Sensitive data like passwords is stored in encrypted or hashed form — passwords are never stored in plain text; they are salted and hashed using strong algorithms.

2.6.2. Access Controls: We limit access to personal data strictly to TEOA staff and service providers who need it. Accounts with access to the database or administrative interfaces are protected by strong authentication and two-factor authentication where possible.

2.6.3. Monitoring and Auditing: Our systems are monitored for suspicious activities. We keep logs of access to personal data and regularly review these logs to detect any unauthorized access attempts.

2.6.4. Secure Hosting: We host our infrastructure with reputable providers that have strong physical and network security. Regular encrypted backups of data are performed.

2.6.5. Staff Training: All TEOA team members with access to personal data receive guidance on data privacy and security protocols.

2.6.6. Testing and Improvement: We periodically test our security measures, including vulnerability scanning and penetration testing where resources allow.

2.7. Data Retention.

We will retain your personal information only for as long as necessary to fulfill the purposes outlined in this instruction, or as required by law:

2.7.1. Active Account: For as long as you have an active account with TEOA, we keep the information associated with your account.

2.7.2. Inactive Accounts: If you stop using TEOA or ask for your account to be deleted, we will delete or anonymize your personal information after a certain period, unless we need to keep it for legitimate reasons. We may define an inactivity threshold (e.g., 2 years of no login) after which we proactively delete or anonymize accounts.

2.7.3. Transaction Records: We may retain certain financial or transaction data for longer periods if required for legal compliance.

2.7.4. Communications: If you've communicated with us (support emails, dispute resolutions), we may retain those records as long as necessary to protect our legal interests.

2.7.5. Backup Copies: Even after deletion, residual copies of your data might remain in our backups or archival systems for a brief period until those backups are cycled out.

2.8. Your Rights Over Your Data.

As a user of The Empire of Apollo, you have certain rights regarding your personal data:

2.8.1. Right to Access: You have the right to request a copy of the personal data we hold about you (Data Subject Access Request).

2.8.2. Right to Rectification: If any personal information we have is inaccurate or incomplete, you have the right to request that we correct or update it.

2.8.3. Right to Deletion: You can request that we delete your personal data (Right to be Forgotten). We will delete or anonymize the personal information we have about you, provided that we do not need to retain it for legal or legitimate business purposes.

2.8.4. Right to Restriction of Processing: In some cases, you have the right to ask us to limit the processing of your data while the accuracy of the data or the basis for processing is under review.

2.8.5. Right to Data Portability: For data that you provided to us and that we process by automated means based on consent or contract, you have the right to request that data in a structured, commonly used, machine-readable format.

2.8.6. Right to Object: You have the right to object to certain types of processing, especially if we are processing your data based on legitimate interests or for direct marketing.

2.8.7. Right to Opt-Out of "Sale"/Sharing (California residents): We do not sell personal data. If any sharing qualifies as a "sale" or "sharing" under the CCPA/CPRA, California residents have the right to opt out.

2.8.8. Right to Withdraw Consent: In cases where we rely on your consent to process data, you have the right to withdraw that consent at any time.

2.8.9. Right not to be Subject to Automated Decisions: TEOA does not make any significant decisions about members purely by automated means without human involvement.

2.8.10. Right to Lodge a Complaint: If you believe we have infringed your privacy rights, you have the right to complain to a data protection authority. For EU users, this would be your national supervisory authority.

2.9. Children's Privacy.

TEOA is not intended for children under the age of 13. We do not knowingly collect or solicit personal information from anyone under 13 years old. If we discover that we have collected personal data from a child under 13 without proper parental consent, we will take immediate action to delete that information.

2.10. Changes to This Instruction.

TEOA may update this instruction from time to time. When we make material changes, we will post the updated instruction on our website with a new effective date and may provide additional notice such as an announcement on Discord or an email to registered users. Continued use of TEOA services after the new instruction becomes effective indicates acceptance of the changes.

3.1. Contact Details:

Contact Email: teoa.a1@apolloempire.com

Mailing Address: PO BOX 256, Bowling Green, Ohio, 43402

Discord Support: Help Ticket System on our Discord server

Data Protection Officer (HQ/A8/CISO): Deputy Chief of Staff for Strategic Plans, Programs and Requirements, and Chief Information Security Officer of the Empire of Apollo.

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References:

AEI 26-1, Membership Terms of Use

AEI 28-2, A Staff Structure

TEOA Form 3B-003, Non-Disclosure Agreement

Acronyms and Abbreviations:

AEI — Apollo Empire Instruction

API — Application Programming Interface

CCPA — California Consumer Protection Act

COPPA — Children's Online Privacy Protection Act

CPRA — California Privacy Rights Act

DDOS — Distributed Denial of Service

GDPR — General Data Protection Regulation

HTTPS — Hypertext Transfer Protocol Secure

HQ/A1 — Deputy Chief of Staff for Manpower, Personnel, and Services

HQ/A8/CISO — Deputy Chief of Staff for Strategic Plans, Programs and Requirements,

and Chief Information Security Officer

ICO — Information Commissioner's Office

OPC — Office of the Privacy Commissioner of Canada

TEOA — The Empire of Apollo

TLS — Transport Layer Security

2FA — Two Factor Authentication