Data processing agreement

Controller: the server administrator, meaning the owner of the Discord server or the person who adds Ganyu to the server and configures it, from the dashboard or through commands. If they act on behalf of an association, a company or a community, they declare that they have the authority to bind it.

Processor: VSK, a SARL with variable capital whose registered office is at 47, rue Vivienne, 75002 Paris, France, registered with the Paris RCS under number 105 185 789, reachable at [email protected], which publishes and operates Ganyu.

The administrator accepts this agreement by adding Ganyu to a server or by configuring it. The agreement applies for as long as the bot is installed on the server, then until the data is deleted as described in the "End of processing" section.

If this agreement and the Terms conflict regarding the data processed on behalf of the administrator, this agreement prevails.

VSK processes the data of the server's members for the sole purpose of providing the features the administrator enables and configures. The purposes are those the administrator pursues with these features: moderation and safety of the server, member support, community engagement and server management. VSK does not decide who is sanctioned or why.

The processing consists of collecting this data from Discord, recording, organising and displaying it in Discord channels and on the dashboard, modifying it on instruction, then deleting it. It covers the following features:

• Server logs (edited or deleted messages, joins and leaves, voice, bans, role and channel changes) and attachment logging.
• Sanctions, warnings, automoderation, its infractions and excerpts of the messages it deletes.
• Tickets, answers to their forms, events and transcripts.
• Member onboarding and management: verification, welcome and goodbye messages, auto roles and reaction roles, birthdays announced on the server, temporary voice channels, command rules, channel templates and history.
• Giveaways and their entries, drops, sticky messages and custom messages, custom commands and automations.
• Server levels, economy, quests and mini-games according to the administrator's settings, and tracking of the game accounts they add.
• Automatic translation of messages, when the administrator enables it.

Other processing related to Ganyu (account and dashboard, payments and billing, global XP and economy, activity statistics, security, audit log, command and virtual currency transaction logs, dashboard action log, audience measurement) is carried out by VSK on its own account, as controller, and is described in the privacy policy.

Depending on the features enabled, the data processed is the following:

• Discord ID, username, nickname, avatar, roles and server join date.
• Content of edited or deleted messages and of attachments, when the logs are set up to record it.
• Sanctions, warnings, automoderation infractions and their reasons.
• Answers to ticket forms, messages and transcripts.
• Activity tied to the server's features: joins and leaves, voice presence, giveaway and drop entries, levels, balances and progress in the server's quests and mini-games.

Data subjects: the members of the server, the people who interact with it (ticket authors, people mentioned in a logged message), and its moderators and administrators.

Ganyu is not designed to process special categories of data (GDPR article 9) or data relating to criminal convictions and offences (article 10). The administrator refrains from asking for such data, for example in ticket forms.

VSK processes this data only on the administrator's documented instructions. These instructions are the bot configuration (dashboard and commands), the commands issued on the server and this agreement. They also cover the transfers of data outside the European Union described in the "Sub-processors" section.

VSK does not use this data for any other purpose, does not sell it and does not use it for advertising. If Union or Member State law requires it to carry out other processing, VSK informs the administrator before processing, unless that law prohibits it.

VSK immediately informs the administrator if, in its opinion, an instruction infringes the GDPR or other Union or Member State data protection provisions.

Only the members of the Ganyu team who need it for their role (operations, support, security) can access this data. VSK undertakes that the persons authorised to process this data are bound by an obligation of confidentiality.

VSK implements the following technical and organisational measures:

• Encrypted connections to the website and the dashboard.
• Production and backup servers hosted in the European Union, by Contabo.
• Ticket transcripts encrypted (AES-256-GCM) with a key specific to each server, itself encrypted by a master key kept outside the database.
• Discord session access tokens and custom bot tokens encrypted in the database. Session tokens are stored there only as a hash.
• Secrets masked in technical logs and in the dashboard action log.
• Access to servers and data restricted to the Ganyu team.
• Backups encrypted on the production server before being copied to a separate backup server. Their rotation aims at a retention of about one week.
• Automatic deletion of data at the end of its retention periods. Logged attachments are not stored: they only pass through memory.

The administrator gives VSK a general authorisation to engage sub-processors. The providers with which VSK has signed a contract or accepted data processing terms, and which may process server data, are the following:

• Contabo GmbH (Germany): hosting of the production servers, databases and backups, in the European Union.
• Cloudflare: content delivery network and protection of the website and the dashboard.
• DeepL: translation of messages, when the administrator enables automatic translation.

Stripe, the payment provider, receives no data processed on behalf of the administrator: it is only involved in payments and billing, for which VSK is the controller.

VSK imposes on these sub-processors (Contabo, Cloudflare and DeepL), by contract or through their data processing terms, data protection obligations equivalent to those of this agreement, and remains liable to the administrator for their performance. Transfers outside the European Union rely on the safeguards described in the privacy policy (adequacy decision or standard contractual clauses).

Discord and Riot Games are not sub-processors of VSK: they are independent controllers and data sources, which VSK does not bind by contract on behalf of the administrator. Discord is the platform on which the bot runs: the data comes from it and the features run through its API, under Discord's terms. Riot Games provides the game statistics for the accounts tracked on the server, when the administrator enables account tracking.

DuckDuckGo is not bound to VSK by any contract. When the origin server refuses to serve an image because it receives too many requests, Ganyu retries that download once through DuckDuckGo's public image relay. DuckDuckGo then receives the address of the image (the address of a Discord avatar contains the member's Discord ID), from the IP address of Ganyu's server. No other data is sent to it.

VSK informs administrators of any intended addition or replacement of a sub-processor by updating this page and announcing it on Ganyu's official Discord server, with reasonable notice before the change. The administrator may object by writing to [email protected]. If no solution is found, they may end the agreement by removing the bot from their server.

Taking into account the nature of the processing, VSK assists the administrator, through appropriate technical and organisational measures, in answering requests from their members to exercise their rights (access, rectification, erasure, restriction, portability, objection):

• Each member can export their data, delete their account and object to activity tracking from the My data page of the website, and manage that tracking with the /privacy command on Discord. The export and the deletion also apply to the member's data processed for the server, as described in the section "Member tools and server data".
• The administrator has their own tools: the moderation commands and the dashboard let them view and remove warnings, lift sanctions and disable a feature at any time.
• When VSK receives by another channel (e-mail, Discord) a request about a server's data, it forwards it without undue delay to the administrator concerned as soon as it can identify them, and does not answer the substance of the request in their place. Only the tools of the My data page apply without the administrator stepping in, on their instruction described in the next section.
• On written request to [email protected], VSK helps the administrator find, extract or delete a member's data when their own tools cannot.

By adding or configuring the bot, the administrator instructs VSK to also apply to their server's data the requests that each member makes themselves from the My data page: access and portability (GDPR articles 15 and 20) through the export, erasure (article 17) through the account deletion. VSK carries out these requests without consulting the administrator beforehand.

The export given to the member contains the server data about them, including the sanctions, warnings and automod infractions that target them, with their reasons, and the transcripts of the tickets they opened. The IDs of other people stored in the records (the moderator who issued a sanction, the person who handled a ticket) are masked in it. Ticket transcripts are provided as they are, with the messages and names of the other participants.

Account deletion acts on every server where the member has data, including servers they have left:

• Deleted, in particular: the sanctions, warnings and automod infractions that target them, their server member record, their levels, balances, inventory and roles stored for the server, their premium profile on the server, their quests, their birthday role grants, their giveaway entries and their temporary voice channel lists.
• Detached from them, in particular: in the server logs, they no longer appear as the author or the target of an action, and their name and avatar are removed. In the tickets they opened, they no longer appear as the author and the form answers are erased. In the tickets they handled, the sanctions and warnings they issued and the ticket events, they no longer appear as the author. They are removed from giveaway winners and from the list of members protected against voice moves in the moderation configuration, their ID is replaced in the server's automations, incidents and notifications, and their personal permissions are removed from channel templates and channel history.
• Kept: the content of log entries (messages, nicknames, avatar addresses), the reasons they wrote about other members, ticket transcripts, the command rules that target them and the temporary voice channels they own, as detailed in the privacy policy.

Consequence for moderation: the member's disciplinary history on the server disappears. The count of their warnings and automod infractions restarts from zero, and the configured escalation thresholds apply again from the beginning. Messages already posted in the Discord log channels are not changed.

Taking into account the nature of the processing and the information available to it, VSK assists the administrator in meeting their obligations under articles 32 to 36 of the GDPR: security of processing, notification of a breach to the supervisory authority and communication to data subjects, data protection impact assessment and prior consultation. To that end, it provides the relevant information about the processing and the measures described in this agreement.

VSK notifies the administrator of any personal data breach affecting their server's data without undue delay after becoming aware of it. The notification goes through the available contact channels: a Discord direct message to the server owner, the email address linked to their Ganyu account if they have one, or an announcement on Ganyu's official Discord server.

It describes, where possible, the nature of the breach, the categories and approximate number of people and records concerned, its likely consequences, the measures taken or proposed to address it and the contact point at VSK. Information not yet known is provided as soon as possible.

When the bot is removed from a server, that server's data is deleted automatically 30 days after the removal, unless the bot comes back in the meantime or the server still has a paid subscription, whether active, paused or in collection. In the latter case, the data is kept until the server's subscription has returned to the free plan. Ticket transcripts are deleted together with the key that encrypts them.

The following are kept. VSK processes them from the moment they are collected on its own account, as controller (accounting, service security, fighting cheating, install tracking), or is required to keep them by law:

• The server record (ID, name, owner, person who added the bot), to recognise the server if it installs the bot again.
• The install history (13 months) and its attribution, whose referring page is erased after 13 months; the person who installed the bot remains recorded.
• Subscriptions, payments, shop purchases and billing data, kept for at least 10 years as accounting records.
• The virtual currency transaction log (about 14 months at most), which VSK keeps to check balances and fight cheating.
• Growth contests, their winners, their participants and the servers credited (12 months after the end of the contest), and the log of direct messages about subscriptions (1 year).
• The feature settings enabled for the server, the Ganyu team audit log (13 months) and the dashboard action log (about 14 months at most), which VSK keeps for the security of the service.

Deleted data then disappears from the backups as they rotate, a rotation that aims at a retention of about one week. While the bot is installed, data follows the retention periods set out in the privacy policy.

VSK does not offer a full export of a server's data. Messages already posted in the log and ticket channels stay on Discord, under the administrator's control. The administrator may ask in writing at [email protected] for a copy of their server's data or for its early deletion.

VSK makes available to the administrator the information needed to demonstrate compliance with this agreement: this page, the privacy policy and its answers to written questions sent to [email protected].

The administrator may request an audit, carried out by themselves or by an auditor they appoint who is bound by confidentiality. VSK first answers in writing, with its documentation. If that is not enough, an audit is arranged on an agreed date with reasonable notice, without access to other servers' data, no more than once a year except after a data breach, and at the administrator's expense.

The administrator undertakes to have a lawful basis for the processing they set up, to inform the members of their server about it (for example in the rules or an information channel, with a link to Ganyu's privacy policy), to restrict access to the log and ticket channels to the people who need it, and to answer their members' requests.

For any question about this agreement, write to [email protected]. VSK has not appointed a data protection officer.

VSK may amend this agreement to keep up with changes to the service or to the law. The date at the top of the page shows the latest revision, and significant changes are announced on the website or on Ganyu's official Discord server. This agreement is governed by French law.