This document maps V2 launch features to privacy, platform, AI, moderation, minor-safety, data-residency, wagering, cultural-review, rating, and parental dashboard obligations. It is an engineering control surface, not a substitute for jurisdiction-specific legal advice.
Product Surfaces#
- Profile and Settings expose Access, Rectification, Erasure, Portability, Restriction, Objection, consent management, Do Not Sell/Share, sensitive-data consent, data residency, AI transparency opt-out, and cookie preferences.
- First launch shows regional privacy defaults, Do Not Sell/Share where required, age confirmation, cookie or tracking defaults, and minor-account restrictions before optional processing begins.
- The web DSR form is linked from in-game settings, requires account 2FA, and
routes through
@themis/privacyand@oshun/data-residency. - Extended section 94 controls live in
V2/docs/legal/privacy-compliance-extended.mdand cover the privacy-by-design DPIA register, public sub-processor registry, California AADC minor defaults, Quebec Bill 96 / Bill 25, Brazil Marco Civil / LGPD, France product-placement disclosure, Italy and Belgium no-loot-box SKU disclosures, erasure audit scope, and privacy ops on-call.
GDPR And Data Residency#
V2 treats data-subject rights as an account feature. EU accounts can keep data inside the EU zone, currently Frankfurt and Stockholm. Japan routes to Tokyo, Korea to Seoul, LATAM to Sao Paulo, and the China SKU stores Chinese-region data on approved Chinese cloud infrastructure. Cross-region transfers require an approved mechanism such as Standard Contractual Clauses or Binding Corporate Rules.
US Privacy#
The US privacy registry covers CCPA/CPRA, CPA, VCDPA, CTDPA, UCPA, TDPSA, and MCDPA as named launch controls, with rolling updates for additional state laws. The registry updates at least every 30 days and drives settings defaults, request SLAs, sensitive-data consent, and Do Not Sell/Share availability.
DSA Moderation#
Moderation actions for decals, CAW outfits, lobby chat, profiles, replays, and reports publish a Statement of Reasons with action, policy, facts, automation role, appeal path, and out-of-court dispute route. Trusted Flaggers receive a priority queue. Transparency reports publish semi-annually.
EU AI Act#
Adaptive AI, chat moderation classifiers, anti-cheat and win-trading detection,
AI commentary, and generation pipelines stay in the AI use inventory. Model
Cards are hosted by @nous/safety; AI system records and conformity audit
exports are owned by @themis/accountability. Adaptive AI offers player
transparency and an opt-out to a static CPU profile.
Minors, Ratings, And Parental Controls#
Minor accounts use data minimization, no behavioral ads, no profiling, and parental restrictions. Platform integrations enforce Sony Family Management, Microsoft Family Safety, Nintendo Parental Controls, and Steam Family View. Per-mode rating variance is published in store-page metadata and enforced by parental controls.
Cosmetic And Cultural Review#
Cosmetics, fighter costumes, decals, religious iconography, sacred symbols, and culturally significant items require per-region sensitivity review and a community appeal path. User-generated culturally inappropriate content routes through the same report and DSA appeal workflow as other moderation actions.
Authority Sources Snapshot#
Last source review: 2026-05-18.
- GDPR: EUR-Lex Regulation (EU) 2016/679, including Articles 15-22, 33, and 46.
- DSA: European Commission DSA guidance and EUR-Lex Regulation (EU) 2022/2065, including Statement of Reasons, Trusted Flaggers, transparency reporting, and out-of-court dispute settlement.
- CCPA/CPRA: California Attorney General / CPPA guidance on consumer rights, Do Not Sell/Share, sensitive personal information, and response timing.
- EU AI Act: European Commission AI Act guidance and official implementation materials.
- Cookies: UK ICO cookie consent guidance and EU ePrivacy consent rules.
- Children: FTC COPPA business guidance plus per-region minor-protection rules.
- Wagering: UK Gambling Commission virtual item money-or-money's-worth guidance, Belgium Gaming Commission review, California gambling-law review, platform policy review, and local counsel signoff.
- Extended regional review: California AB 2273 bill text, Quebec CAI Law 25 guidance, Quebec Charter of the French Language, Brazil ANPD LGPD guidance, Brazil Marco Civil Law No. 12.965/2014, France Arcom product-placement guidance, and Italy/Belgium local-counsel gaming review.