Privacy Policy

1st Cavalry Division (“we”, “us”, or “the Division”) is a gaming and milsim community. This Privacy Policy explains how we handle personal information on our website and related community systems (including linked PERSCOM features where you use them).

1. Information We Collect

We collect information you provide directly to us, such as when you create an account, link community services, donate, participate in operations, or contact us for support.

Personal Information

• Account Information: Username, display name, email address, password, country or region where we collect it for compliance, and date of birth when you create an account (used only to verify you meet our minimum age requirement and for account security; we do not publish your date of birth on the public site)
• Security factors: Whether you have enabled two-factor authentication or passkeys, and related device/credential metadata needed to operate those features (we do not store your authenticator secrets or passkey private keys in a form you or we can recover as passwords)
• Profile Information: Profile pictures and other information you choose to provide
• Discord: Discord username or Discord user ID when you link Discord or when it is stored via a linked PERSCOM personnel profile
• Steam: Optional Steam ID 64 on PERSCOM-linked profiles for community and game identity
• PERSCOM link: A linked personnel identifier (perscomId) and related personnel, assignment, training, and operations data when your website account is linked to PERSCOM
• Donations: Records of donations or subscriptions you make through our donate flows (amounts, status, and identifiers needed to show goals and history—not full payment card numbers)
• Communication Data: Messages sent through our contact form or messaging system
• Usage Data: Information about how you use our website and services

Automatically Collected Information

• Log Data: IP address, browser type, pages visited, time spent on pages
• Cookies: Small data files stored on your device (see Cookies and Tracking Technologies below)
• Device Information: Device type, operating system, and browser version
• Abuse-prevention signals: Data collected by Google reCAPTCHA when you use protected forms such as login or registration (see Third-Party Services)

2. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our community website and related services
• Operate accounts, authentication (including 2FA and passkeys), and PERSCOM linking / single sign-on
• Run community features such as roster, campaigns, gallery, messaging, forms, and notifications
• Process donations and subscriptions and record related status
• Prevent abuse and automated attacks (including reCAPTCHA)
• Send technical notices, updates, security alerts, and support messages
• Respond to your comments, questions, and requests
• Monitor and analyse trends, usage, and activities (including optional analytics cookies)
• Detect, investigate, and prevent fraud and other harmful activity
• Comply with legal obligations

3. Legal Basis for Processing (GDPR)

Under the UK GDPR / GDPR, we process your personal data based on the following legal grounds:

• Consent: When you have given clear consent for us to process your personal data for specific purposes (for example certain cookies)
• Contract: When processing is necessary to provide the account and community services you request
• Legitimate Interest: When we have a legitimate interest in processing your data (for example securing the service, moderating the community, or improving the site), balanced against your rights
• Legal Obligation: When processing is necessary to comply with a legal obligation

4. Information Sharing and Disclosure

We do not sell your personal information. We share information only as described in this policy, including:

• Service providers and platforms: Trusted third parties that help us run the website and community (see Third-Party Services below)
• Community administrators: Trusted members with AdminCP or similar permissions may access personal data only as needed for moderation, support, safety, or compliance, under access controls. AdminCP is not a public directory of your private data
• Legal Requirements: When required by law or to protect our rights, property, safety, or that of our members
• Consent: When you ask us to share information or give explicit consent

Date of birth and age: Your date of birth is not shown on public or member-facing pages. It may be used internally to derive age for eligibility checks. A very limited set of authorised staff may view date of birth or age in our admin tools only when their role explicitly includes the relevant permission (for example account support, safety, or legal compliance). Those accesses are subject to organisational access controls.

5. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest where we control the systems
• Regular security assessments and updates
• Access controls and authentication mechanisms (including optional 2FA and passkeys)
• Staff and admin training on data protection expectations for the community

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When we no longer need your information, we will securely delete or anonymize it.

7. Your Rights (GDPR)

Under the GDPR, you have the following rights regarding your personal data:

• Right of Access: Request copies of your personal data
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data
• Right to Restrict Processing: Request limitation of processing of your data
• Right to Data Portability: Request transfer of your data to another service
• Right to Object: Object to processing of your personal data
• Right to Withdraw Consent: Withdraw consent at any time where we rely on consent

To exercise these rights, use the account or GDPR request tools we provide on the site where available, or contact us using the information in the “Contact Us” section below.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to run the site and improve your experience. Cookies help us:

• Keep you signed in and protect forms (for example session and CSRF cookies)
• Remember your preferences and settings
• Analyse website traffic and usage patterns (where analytics cookies are enabled)
• Improve website functionality and performance

You can control cookie settings through your browser preferences or our cookie consent banner. Disabling certain cookies may affect website functionality (especially login and security cookies).

Website analytics

We use analytics to understand how the site is used and to improve our services. Analytics are hosted internally by Rawhost UK Ltd (our hosting provider) for the sole purpose of site analytics. Data is held by Rawhost UK Ltd in that capacity. Participation is on an opt-out basis: analytics are enabled by default, and you may disable them at any time via the “Analytics Cookies” setting in our cookie preferences.

9. Third-Party Services

We use the following third parties and platforms in connection with the website. Their own terms and privacy policies also apply when you use their services.

PayPal

Donations and subscription payments are processed by PayPal. PayPal handles payment credentials according to its own policies. We store donation and subscription status and related identifiers needed to operate donate pages, goals, and your donation history. We do not store full payment card numbers on our systems.

Steam

If you choose to add a Steam ID 64 on a PERSCOM-linked profile, we store that identifier for community and game identity. Using Steam itself is governed by Valve / Steam’s terms and privacy policy.

Discord

We use Discord as a community channel (including invite links from this site). If you link Discord or a Discord user ID is associated with your account or PERSCOM profile, we may use it for identity, support, and notifications. Activity on Discord is also subject to Discord’s terms and privacy policy.

Google reCAPTCHA

We use Google reCAPTCHA (typically v3) on login, registration, and similar flows to reduce bots and abuse. Google may receive device and browser signals as described in Google’s Privacy Policy and Terms of Service.

PERSCOM single sign-on (SSO)

You may link your website account to PERSCOM so roster, campaigns, combat records, courses, and related personnel features work. Linking uses short-lived SSO tokens and stores a personnel link (perscomId). Personnel and operations data for linked members is held in PERSCOM and related API systems operated for the same community. Outbound SSO may require website two-factor authentication to be completed first.

Other links

Our website may contain links to other third-party websites. We are not responsible for their privacy practices or content. Review their policies before providing personal information.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your own (for example when a provider such as PayPal, Discord, Google, or Steam processes data). Where we control the transfer, we aim to comply with applicable data protection laws and use appropriate safeguards.

11. Children's Privacy

Our services are not intended for children under 16 years of age. At registration we collect date of birth so we can apply this rule: we do not knowingly allow accounts for users under 16. This site is also not directed at children under 13 under the U.S. Children’s Online Privacy Protection Act (COPPA). If you are a parent or guardian and believe your child has provided us with personal information, please contact us and we will take appropriate steps.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of changes by posting the updated policy on this page and revising the “Last updated” date. We encourage you to review this page periodically.

13. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

• Through our contact form
• On Discord
• By email at: privacy@1stcavalry.org