Lost Gaijin — Privacy Notice
Effective date: September 5, 2026 · Version 1.2.0
This Privacy Notice explains what personal data Ten Turtle Games ("Ten Turtle", "we", "us") processes when you play Lost Gaijin (the "Game") and use its online AI features (the "AI Service"), why we process it, and the choices you have. It is part of the Game's End User License Agreement by reference.
The short version: the Game runs on your device and we collect no telemetry, analytics, or crash reports from it. We process your SteamID to sign you in and meter AI usage, fetch your public Steam display name and avatar for sign-in confirmation, cache them on your device, store the display name in our backend account record for account identification and support, and relay your prompts and game context to AI providers. We retain raw player input, generated responses, and limited request metadata in Langfuse in the United States for moderation, safety, abuse prevention, debugging, and quality improvement. Automated tools and authorized Ten Turtle Games staff may review flagged or sampled records. We do not sell these records or use them to train or fine-tune AI models. We never see your Steam password and do not take payments directly.
1. Who Is Responsible
Ten Turtle Games is the controller for the personal data described in this Notice. Contact: lostgaijin@tenturtle.games.
Valve Corporation is a separate and independent controller of your Steam account data (account details, billing, purchase history on Steam). Your use of Steam is governed by the Steam Privacy Policy (https://store.steampowered.com/privacy_agreement/), not this Notice. We do not receive your payment details, password, or billing information from Valve.
2. What We Process and Why
| Category | What it is | Why we process it | Where it lives |
|---|---|---|---|
| Steam identifier | Your SteamID (a numeric public identifier for your Steam account) | To sign you in, tie your AI allowance to your account, and prevent abuse | Our backend database (Cloudflare D1) |
| Public Steam profile | Your public Steam display name and full-size avatar URL | To show which Steam account signed in and identify the account for support | Fetched from Steam during sign-in; the display name is stored in our backend database (refreshed at each sign-in); both fields are also cached in the Game's local metadata database for that Steam account |
| Pseudonymized AI tag | A keyed, irreversible code derived from your SteamID (HMAC) | To attribute AI usage, investigate abuse, and respond to verified data requests without storing your SteamID with AI content | Transmitted to OpenRouter and stored with AI interaction records |
| Session records | Hashed session tokens and expiry times | To keep you signed in securely (only the hash is stored; the token itself stays in your device's OS keychain) | Our backend database |
| AI request context | The text you type, relevant parts of your game state, and conversation history needed to generate a response | To operate the AI features you are actively using | Processed by our backend and forwarded to AI providers; only the fields listed below are retained by us |
| AI interaction records | Raw player input, generated responses, model and provider, timestamp, and pseudonymized AI tag | To moderate content, prevent and investigate abuse, respond to reports, debug the service, evaluate output quality, and improve prompts and game quality | Langfuse (United States) |
| Usage metering | Per-request AI cost amounts and balance snapshots tied to your SteamID | To meter Story Credits accurately and display your balance | Our backend database |
| Purchase entitlement records | Steam order identifiers, items purchased, and amounts credited or reversed, tied to your SteamID | To grant what you bought on Steam, handle refunds/chargebacks honestly, and keep accounting records | Our backend database |
| AI access keys | Cryptographic keys that let our backend call AI providers on your behalf | To operate the AI Service; each player's key is stored encrypted (AES-256-GCM) and is never sent to your device | Our backend (encrypted at rest) |
| Service logs | Request logs generated by our hosting platform (e.g., IP address, timestamps, error rates) | Security, abuse prevention, and operating the service | Cloudflare (Workers observability) |
| Service incident notifications | An opaque error code and random support reference, without SteamID, profile data, player IP address, ticket, or token | To notify authorized staff of server-side sign-in failures | Sent to a private Discord incoming webhook; not stored in our backend database |
We do not collect telemetry, analytics, or crash reports from the Game, we do not track you across other websites or services, and we do not sell personal data. We do not use AI interaction records to train or fine-tune AI models.
Public Steam profile data is requested only after Steam validates the sign-in ticket. The Game stores the display name and avatar URL in its local metadata database so it can show the signed-in account across restarts. The backend stores only the display name, refreshed at each sign-in, as part of your account record for support identification; it does not store the avatar URL. Server-side sign-in failures may trigger a de-identified Discord notification containing only an opaque error code and random support reference. Discord receives and processes that notification; it receives no SteamID, display name, avatar, player IP address, ticket, or session token from this notification.
3. Where Your AI Data Goes
When you play, your input and the needed game context are sent from your device to our backend (hosted on Cloudflare), which forwards them to OpenRouter (https://openrouter.ai), which routes them to the underlying AI model providers (for example Google, DeepSeek, OpenAI, Mistral, or others we curate over time). Those providers process your prompts under their own privacy policies, which we do not control. Their policies govern issues such as retention and whether inputs may be used for model training or reviewed by humans. Review OpenRouter's privacy policy (https://openrouter.ai/privacy) and the applicable provider policies before entering anything sensitive.
Through OpenRouter's observability integration, an AI interaction record for each request is mirrored to Langfuse (https://langfuse.com), an AI observability platform. Our Langfuse workspace is hosted in the United States. The record contains the raw player input and generated responses, the model and provider, a timestamp, and the pseudonymized AI tag. It does not contain your SteamID. Langfuse processes these records on our behalf as a service provider.
OpenRouter Guardrails may inspect requests for prompt-injection patterns and sensitive information, and may block or redact a request before it reaches an underlying model. However, the Developer's relay receives your raw input before OpenRouter performs those checks. The copy retained in Langfuse may therefore contain sensitive information even when OpenRouter later blocks or redacts the request.
Automated systems periodically analyze AI interaction records for policy violations, abuse, safety issues, and output-quality problems. Within Ten Turtle Games, access is limited to authorized staff, who may review flagged records, reports, or limited samples for those purposes. We do not engage contractors to review AI interaction records.
Do not enter sensitive personal, medical, financial, confidential, or secret information into the Game. Your input and the resulting AI responses may be retained and reviewed as described above.
4. Legal Bases (GDPR)
Where the EU/UK GDPR applies, we rely on: performance of a contract (sign-in, metering, and delivering the AI features you use); legitimate interests (content moderation, security, abuse prevention, investigating reports, debugging, evaluating output quality, improving the Game and AI Service, and billing integrity); and legal obligation (tax, accounting, and legally required records). You may object to legitimate-interests processing as described in Section 7. Some processing, including creating AI interaction records, is necessary to provide the AI Service safely; if it cannot be performed, we may be unable to provide AI features to you.
5. Retention
- Session records: deleted when they expire (up to 30 days after sign-in).
- Public Steam profile: the display name is kept in our backend account record while your account is active (deleted with account data below); name and avatar are cached per Steam account in the Game's local metadata database until that local Game data is deleted.
- Service incident notifications: not stored in our backend database; Discord's retention applies to webhook messages.
- Usage metering details: recent per-request costs are pruned within 24 hours; aggregate balance figures are kept while your account is active.
- AI interaction records: retained only for as long as reasonably necessary for moderation, safety, abuse prevention, report investigation, debugging, quality evaluation, service improvement, enforcement, and applicable legal obligations. We periodically review whether continued retention is necessary and delete or de-identify records when it is not. Records relevant to an investigation, security incident, dispute, enforcement action, or legal claim may be retained while the matter is active and for as long as reasonably necessary afterward.
- Other AI request context: conversation history and game-state fields sent as context are not copied into our Langfuse interaction record unless the same information appears in the raw player input or generated response. Retention by OpenRouter and the underlying model providers is governed by their policies (Section 3). Your full conversation history also remains in your local save file on your device.
- Purchase records: retained as long as required for accounting, tax, and Steam-mandated billing reconciliation (typically up to 7 years), then deleted or aggregated.
- Account data (SteamID, display name, keys, entitlements): retained while your account is active. Deleted within 30 days of a verified deletion request (Section 7), except purchase records we must keep by law.
6. Security
Session tokens are stored only as hashes; per-player AI keys are encrypted at rest (AES-256-GCM) with keys held in a managed secrets store; transport uses TLS throughout. AI interaction records are stored in our Langfuse workspace (United States region) using Langfuse's encryption at rest and access controls. We restrict workspace access to authorized Ten Turtle Games staff under least-privilege permissions. Langfuse stores the pseudonymized AI tag rather than your SteamID.
No system is perfectly secure, and we cannot guarantee absolute security. Because AI interaction records contain raw text, do not enter sensitive or confidential information. The sign-in token on your device lives in your operating system's credential store — see the EULA (Section 4.2) for device-sharing risks.
7. Your Rights
Depending on your jurisdiction, you may have rights to access, correct, delete, or export your personal data, to object to or restrict certain processing, and to lodge a complaint with a supervisory authority. California residents may exercise CCPA/CPRA rights (know, delete, correct, opt out of "sale/sharing" — we do not sell or share personal data as those terms are defined). To exercise any right, email lostgaijin@tenturtle.games and complete reasonable account verification. We can use your verified SteamID to derive the pseudonymous AI tag and locate associated interaction records without storing your SteamID in Langfuse. We respond within the timeframes the law requires.
A verified deletion request includes associated AI interaction records unless continued retention is reasonably necessary for an active investigation, security, enforcement, legal, tax, or accounting purpose. Deleting your account data does not refund purchases or delete Valve's records of your Steam transactions.
8. Children
The Game is intended for adults (18+). We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us personal data, contact us and we will delete it.
9. Changes to This Notice
We may update this Notice as the Game evolves. Material changes will be presented in the Game (and the version and effective date above will change). Continued use after notice constitutes acceptance of the updated Notice.
10. Contact
Ten Turtle Games — lostgaijin@tenturtle.games