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Join the DiscordPortentum Privacy Policy
Last updated: October 5, 2026
1. Who We Are and What This Policy Covers
1.1. This Privacy Policy explains how Firelight Games LLC, a Utah limited liability company doing business as Snowfall Games ("Snowfall", "we", "us"), collects, uses, shares, and protects personal data when you:
- (a) play Portentum (the "Game") on Steam or in a web browser at play.portentum.game;
- (b) use your Snowfall Account, which is the account you use to sign in to the Game and which may also be used with other Snowfall games (this Privacy Policy covers its use with the Game; other Snowfall games have their own privacy policies); or
- (c) visit portentum.game or wiki.portentum.game (the "Sites"), sign up for our newsletter, or submit a form on the Sites.
Together, these are the "Services".
1.2. Snowfall is the controller of your personal data for the Services. Our contact details are in Section 16.
1.3. When you sign in with Steam, Google, or Discord, or buy through Steam, those companies process your data under their own privacy policies: Valve, Google, and Discord.
1.4. Your Snowfall Account is also used if you play other Snowfall games. Your sign-in data (Section 2.1) is shared by those games. Other Snowfall games have their own privacy policies. If you delete your Snowfall Account, you will lose access to all Snowfall games that use it.
1.5. Fan projects permitted by our Terms of Service after the Game's online features end are not operated by us, and this Privacy Policy does not apply to them.
2. Personal Data We Collect
2.1 Data from your sign-in provider
| Provider | Data we receive |
|---|---|
| Steam | Steam ID, Steam profile name, avatar, whether you own the Game and its downloadable content, and, for in-game purchases, the transaction details Steam provides, such as your country and currency. Steam does not provide your email address. |
| Name, email address, profile picture, and the sign-in credentials Google issues to us (see Section 2.6). | |
| Discord | Discord user ID, username, email address, avatar, the sign-in credentials Discord issues to us (see Section 2.6), and whether you are a member of the Snowfall Discord server. |
2.2 Data created when you play
- Profile: your display name, your player ID, wins, losses, ratings, and account creation date. Your display name is first set from the name on the sign-in account you used or, if that account has none, is a randomly generated name. It is shown publicly (see Section 4), and you can change it at any time in Settings. Our staff can also change a display name that breaks our Terms of Service.
- Game data: your collection, decks, currencies and their transaction history, runs, battles (including each action taken), the boards you build, card pack openings, including your progress toward guaranteed outcomes, achievements, quests, Journal progress, rankings, tournament participation, and settings (such as volume, equipped cosmetics, and your time zone offset).
- Activity data: when you start and stop playing and how long you play; and, while the Game is open and in focus, your current activity (for example, which menu or mode you are in, and the round, wins, and lives in your current run). We keep only your current activity and clear it when your play session ends. Our team can view which players are online and what they are currently doing in the Game, to monitor the health of the Game.
- Purchase records: what you bought, the price and currency, the date, and whether the purchase was completed, refunded, or charged back, as reported by Steam. We do not receive your card number or other payment details.
2.3 Data from your device
- The Game's version, your operating system and its version, and your language setting.
- When you sign in on play.portentum.game: your IP address and browser user agent, stored with your sign-in session.
- Our hosting and network providers receive your IP address when you connect to the Services and keep it in their request logs for a limited period (see Section 7). We do not keep our own server request logs.
2.4 Data you give us
- Messages you send us, such as support requests, bug reports, and appeals.
- On the Sites, if you choose to: your email address for the newsletter, and, on the press swag form, your name, outlet or publication, and postal address. Press swag form submissions are shared with our staff through internal collaboration tools to arrange shipping, are not stored in our game databases, and are deleted after your swag ships or within 90 days of submission.
2.5 Data collected on the Sites
- If you accept analytics cookies: usage data collected by Google Analytics 4 (see Section 11).
- If you accept analytics cookies: clicks on wishlist, Discord, and press-kit links. We record each click with a random identifier stored in your browser, which is not linked to your name, email address, or Snowfall Account, and an approximate city and country derived from your IP address. Your IP address is sent to our location provider for that lookup and is not stored by us. This information is shared with our team through internal tools.
- For press swag form submissions: an approximate city and country derived from your IP address.
2.6 Data we do not collect
We do not collect sensitive personal data such as health, biometric, or precise geolocation data, or payment card details. When you sign in with Google or Discord, the provider also issues sign-in credentials to us. We use them when you sign in to receive the information listed in Section 2.1. Our authentication system keeps them with your account, and we do not use the stored credentials to access your Google or Discord account. The Game does not contain third-party advertising or analytics software, and we do not use anti-cheat software that scans your device; battles and random outcomes are determined on our servers.
3. How We Use Personal Data and Our Legal Bases
3.1. We use personal data for the purposes below. Where the EU or UK General Data Protection Regulation ("GDPR") applies, we rely on the legal basis shown.
| Purpose | Data used | Legal basis (GDPR) |
|---|---|---|
| Create and maintain your Snowfall Account and sign you in | Sign-in provider data, device data, web session data | Performance of our contract with you |
| Provide the Game: save progress, run battles, match you with opponents, present your boards to other players, show rankings | Profile, game data | Performance of contract |
| Deliver purchases and maintain your Virtual Items | Purchase records, game data | Performance of contract |
| Automatically remove Virtual Items when Steam reports that a purchase was refunded or charged back | Purchase records, game data | Performance of contract; legitimate interests (preventing fraud) |
| Process refunds and chargebacks and prevent purchase fraud | Purchase records, game data | Legitimate interests (protecting the Services and our revenue) |
| Keep the Services secure and fair: detect cheating, exploits, abuse, and unauthorized access; enforce our Terms of Service | Profile, game data, activity data, device data, web session data | Legitimate interests (a safe and fair game for all players) |
| Monitor the live service and diagnose problems | Activity data, profile | Legitimate interests (running a reliable online game) |
| Show your current activity to your Steam and Discord friends (rich presence), which you can turn off in Settings | Activity data | Legitimate interests (letting players see what their friends are playing) |
| Provide Snowfall community features, such as not asking members of the Snowfall Discord server to join it again; we check membership with Discord | Discord user ID, Discord server membership | Legitimate interests (running our community) |
| Understand and improve the Game: fix bugs, balance cards and modes, measure how many people play and which features they use | Game data, activity data, device data | Legitimate interests (improving the Game) |
| Show battle replays, share links, and battle videos; feature battles in promotional material | Display name, profile, game data | Legitimate interests (letting players share battles and promoting the Game) |
| Respond to your messages, support requests, and appeals | Messages, profile | Performance of contract; legitimate interests |
| Send service emails, such as notices about changes to our Terms of Service | Email address | Performance of contract; legitimate interests |
| Send the newsletter | Email address | Consent |
| Website analytics (Google Analytics 4) and website click counts | Sites analytics data, click records | Consent |
| Press swag forms, including detecting fake submissions | Form data, approximate location | Legitimate interests (fulfilling your request, preventing abuse) |
| Keep purchase and accounting records | Purchase records | Legitimate interests (meeting our tax and accounting obligations under US law) |
| Comply with law and respond to lawful requests; establish, exercise, or defend legal claims | Any relevant data | Legal obligation, where EU or UK law requires it; otherwise legitimate interests (complying with other laws that apply to us, and protecting our legal rights) |
3.2. No generative AI training. We do not use your personal data or content to train generative artificial intelligence models.
3.3. Automated decisions. Matchmaking uses game data, such as your rating, to select opponents. When Steam reports that a purchase was refunded or charged back, our systems automatically remove the Gems or items from that purchase, which may make your Gem balance negative. You can contact us if you think this was a mistake. We do not make decisions about you based solely on automated processing that produce legal or similarly significant effects. Decisions to suspend or terminate an account are made by our staff, and you can appeal them as described in our Terms of Service.
4. What Other Players and the Public Can See
4.1. In the Game. Your display name, wins, losses, rating, and the boards you build are shown to other players when they play against you, and in rankings and tournaments, including to tournament spectators. We do not show other players your email address or your Steam, Google, or Discord account identifiers. Unless you change it, your display name may be the name from your sign-in account, so people who know that account may recognize you.
4.2. Outside the Game. Rankings and player profiles (a player ID, display name, wins, losses, rating, and account creation date) are available only to signed-in players. A battle can be viewed without signing in only through a share link. When a player shares a battle, we create a link (play.portentum.game/?battleId=...) and a video of the battle showing both players' display names. The video is stored as a public file on our content delivery network. Anyone with the link or the file address can view it, and it can appear in link previews on other websites and apps, where it may be copied or indexed. If we release an Offline Version of the Game under our Terms of Service, it may include boards built by players as opponents, without display names or any other personal data.
4.2A. Steam and Discord rich presence. While you play, the Game shows your current activity (for example, the menu or mode you are in, and the wins and lives in your current run) to your Steam friends through Steam and, if Discord is running on your device, to your Discord friends through Discord. This is on by default. You can turn it off in Settings.
4.3. Promotion. We may feature battles, including display names and boards, in trailers, videos, and social media posts. If you would prefer not to be featured, tell us at snowfall.games/contact and we will not use your battles in promotional material we create after your request.
4.4. You can change your display name at any time in Settings. We may change a display name that breaks our Terms of Service.
5. How We Share Personal Data
5.1. Service providers. These providers process personal data on our behalf, under contracts that limit them to providing their service to us:
| Provider | Purpose |
|---|---|
| Railway | Hosting of our servers and databases |
| Cloudflare | Network security, content delivery, and storage of game assets and battle videos |
| Website analytics (only with your consent) | |
| MailerSend | Sending service emails |
| MailerLite | Sending the newsletter (only if you sign up) |
| An IP geolocation service | Deriving approximate city and country from an IP address for Site click counts and forms |
| Our email provider | Hosting our email inbox, including messages you send us |
| An AI service provider | Tools our staff use to operate and analyze the Services, under terms that do not allow the provider to train its models on that data |
5.1A. Other companies. Valve (Steam), Google, and Discord exchange data with us when you sign in or buy through them, and use it as independent controllers under their own privacy policies (Section 1.3). When rich presence is on, Valve and Discord also receive your current activity in the Game (Section 4.2A). We also use collaboration tools provided by other companies to share information within our team, such as Site click information, press swag form submissions, and service alerts; those companies process that information under their own terms. The trailer on the Sites is embedded from YouTube, which processes data under Google's privacy policy.
5.2. Other players and the public, as described in Section 4.
5.3. Legal and safety. We may disclose personal data where required by law, legal process, or a lawful request by public authorities, or where necessary to protect the rights, property, or safety of Snowfall, our players, or others, including to prevent fraud or cheating.
5.4. Professional advisers. We may share personal data with our lawyers, accountants, and auditors under duties of confidentiality.
5.5. Business transfers. If Snowfall is involved in a merger, acquisition, financing, or sale of all or part of its business or of the Game, personal data may be transferred to the buyer or successor, which will be bound to use it in line with this Privacy Policy.
5.6. With your direction. We may share personal data with others when you ask us to.
5.7. No sale. We do not sell personal data, and we do not share it for targeted or cross-context behavioral advertising.
6. International Data Transfers
We are based in the United States, and we collect and process personal data there. Our service providers process personal data in the United States and other countries. Where a provider processes personal data of people in the European Economic Area, the United Kingdom, or Switzerland outside those regions, we rely on the European Commission's Standard Contractual Clauses (with the UK Addendum and Swiss amendments where applicable) in that provider's data processing terms, or on the provider's certification under the EU-U.S. Data Privacy Framework and its UK and Swiss extensions. You may request a copy of the relevant safeguards by contacting us.
7. How Long We Keep Personal Data
7.1. We keep personal data only for as long as necessary for the purposes described in this Privacy Policy, including:
| Data | Retention |
|---|---|
| Snowfall Account, profile, and game data | While your Snowfall Account exists. Deleted within 30 days after you delete your Snowfall Account in the Game or we verify a deletion request you send by email, except as stated below. |
| Play sessions and playtime | While your Snowfall Account exists. |
| Activity data (current activity) | Only the most recent state is kept; it is replaced with each update and cleared when your play session ends. Playtime totals are kept while your Snowfall Account exists. |
| Battles you took part in with other players | Kept as part of the other players' battle history. When your Snowfall Account is deleted, we replace your display name in those records with a placeholder, unlink them from your account, and delete shared battle videos that show your display name. Promotional material published before your deletion request is not recalled. |
| Battle videos for share links | Kept while the battle record exists; deleted when a player shown in the video deletes their Snowfall Account, as described above. |
| Purchase records | For 7 years after the purchase, to meet tax and accounting obligations, including after account deletion. |
| Web sign-in session records (IP address, user agent) | Until 30 days after the session expires or you sign out. |
| Hosting and network request logs (IP address) | Kept by Railway and Cloudflare for the limited periods set by those providers. |
| Messages you send us | For up to 3 years after the matter is resolved. |
| Newsletter email address | Until you unsubscribe. After that, we keep your email address on a do-not-email list so we do not email you again. |
| Website click records | 13 months, then deleted. |
| Google Analytics data | 14 months. |
| Press swag form submissions | Until your swag has shipped, and no longer than 90 days after submission. |
| Aggregated or de-identified statistics | May be kept indefinitely, as they do not identify you. |
7.2. We may keep data for longer where required by law or where necessary to establish, exercise, or defend legal claims. Deleted data may remain in database backups until those backups expire under our hosting provider's backup schedule.
8. Security
We use reasonable technical and organizational measures designed to protect personal data, including encrypted connections, access controls limited to staff who need access, and sign-in through Steam, Google, or Discord so that we do not receive or store the passwords for those accounts. No system is completely secure. If we become aware of a security incident affecting your personal data, we will notify you and the relevant authorities as required by applicable law.
9. Your Rights and Choices
9.1. Your rights. Wherever you live, you may ask us to: (a) confirm whether we process your personal data and give you access to it; (b) correct inaccurate personal data; (c) delete your Snowfall Account and personal data, subject to Section 7; (d) provide your personal data in a portable format; (e) restrict or object to our processing of your personal data, and we will stop unless we need that processing to provide the Game to you, to keep the Services secure and fair, to comply with law, or to establish, exercise, or defend legal claims; and (f) withdraw consent at any time, where we rely on consent, without affecting processing before the withdrawal. You can change your display name yourself in Settings, and you can delete your Snowfall Account yourself in the Game's Settings.
9.2. How to make a request. Email [email protected] with the subject "Privacy request". We will verify that the request comes from the account holder before acting on it:
- (a) for accounts with an email address (Google or Discord sign-in), by asking you to send the request from, or confirm it through, that email address; and
- (b) for Steam accounts, which have no email address with us, by asking you to confirm details only the account holder would know, or to make a temporary, specified change to your in-game display name or your Steam profile.
You may use an authorized agent, who must provide your signed permission, and we may still verify your identity directly.
9.3. Timing. We respond within one month of receiving a verified request (extendable by two further months for complex requests where GDPR applies), or within 45 days where US state law applies (extendable by 45 days where permitted). We may decline requests that are manifestly unfounded or excessive, or where an exception under applicable law applies, and we will explain why.
9.4. Appeals and complaints. If we decline your request, you may appeal by replying to our decision, and we will respond within 45 days. If you are in the EEA, UK, or Switzerland, you also have the right to complain to your local data protection supervisory authority (in the UK, the Information Commissioner's Office).
9.5. Other choices. You can decline or withdraw website analytics consent (Section 11), unsubscribe from the newsletter through the link in every newsletter email, and change your display name in Settings.
9.6. We will not discriminate against you for exercising your privacy rights.
10. Children
The Services are not directed to children under 13, and you must be at least 13 to create a Snowfall Account (or older, if the law where you live requires it for using online services without parental consent). We do not knowingly collect personal data from children under 13. If we learn that we have collected personal data from a child under 13, we will delete it and close the child's Snowfall Account. If you believe a child under 13 has given us personal data, tell us at snowfall.games/contact. If you are under 16, or under the age of digital consent where you live, you need a parent's or guardian's permission to sign up for our newsletter or to accept analytics cookies on the Sites.
11. Cookies and Similar Technologies
11.1. We use the following cookies and local storage:
| Name | Where | Purpose | Type |
|---|---|---|---|
| Sign-in session cookies | play.portentum.game | Keep you signed in | Strictly necessary |
| Browser storage used by the Game | play.portentum.game | Keep your settings, keep you signed in, and store game files so the Game loads faster | Strictly necessary |
| sf_analytics_consent | Sites | Remember your cookie choice | Strictly necessary |
| Cloudflare security cookies, where set (for example, __cf_bm) | Sites and play.portentum.game | Protect the Services from bots and attacks | Strictly necessary |
| sf_session_id | Sites | Random identifier for counting link clicks | Analytics; set only after you accept |
| sf_press_engaged | Sites | Count a press page view once per visit | Analytics; set only after you accept |
| Google Analytics cookies (for example, _ga) | Sites | Usage analytics | Analytics; set only after you accept |
11.2. Google Analytics and our click counting are enabled only if you select "Accept" in the cookie banner. You can change your choice at any time with the "Cookie settings" link at the bottom of every page on the Sites.
11.3. The trailer on the Sites is embedded from youtube-nocookie.com. When the video player loads, Google receives your IP address and browser information, and YouTube may store data on your device when the player loads or when you play the video. Google's privacy policy applies to that data.
12. Emails
We send the newsletter only to people who sign up for it, and every newsletter includes an unsubscribe link. Our newsletter provider records whether newsletter emails are opened and which links are clicked, so we can see which news interests players. Service emails that you need in order to use the Services are not marketing.
13. Notice to US Residents
13.1. Depending on the state where you live, you may have the right to know, access, correct, delete, and obtain a copy of your personal data, and to opt out of its sale, its use for targeted advertising, or certain profiling. You can exercise these rights as described in Section 9.
13.2. We do not sell personal data, "share" it for cross-context behavioral advertising, or use it for targeted advertising, and we do not engage in profiling that produces legal or similarly significant effects. We do not use or disclose sensitive personal information.
13.3. In the past 12 months, we collected the categories of personal information described in Section 2 (identifiers, commercial information, internet or other electronic network activity information, approximate geolocation derived from IP address, professional information (the outlet or publication you give on the press swag form), inferences about game performance such as ratings, account log-in credentials (the sign-in credentials described in Section 2.6), and whether you are a member of the Snowfall Discord server), from the sources and for the purposes described in Sections 2 and 3, and disclosed them to the categories of recipients described in Section 5.
14. Notice to EEA, UK, and Swiss Residents
14.1. The legal bases for our processing are set out in Section 3. Where we rely on legitimate interests, we have balanced those interests against your rights, and you may object at any time as described in Section 9.
14.2. Providing your data is necessary to create a Snowfall Account and play the Game; without it, we cannot provide the Game. Providing data on the Sites is optional.
15. Changes to This Privacy Policy
We may update this Privacy Policy. We will change the date at the top when we do. If we make a material change, we will notify you in the Game, by email, or on the Sites before the change takes effect. If a change requires your consent under applicable law, we will ask for it. Previous versions are available on request.
16. Contact
Firelight Games LLC, a Utah limited liability company doing business as Snowfall Games Postal address: available on request by email to [email protected] Email: [email protected]
See also our Terms of Service.