Privacy Policy

What penaltybluff.com and the browser version of Penalty Bluff keep, send and share, and the choices you have.

Effective date: 6 November 2026 · Last updated: 6 November 2026

This Privacy Policy explains how Artem Podrushniak ("we", "us", "our"), an independent developer in Indonesia, handles data when you visit penaltybluff.com and play the browser version of the Penalty Bluff game at penaltybluff.com/play/ (together, "the site"). It applies to the site only; phone versions of the game, once released, will have their own policy. Related documents: Terms of Use and Contact.

In short. There are no accounts. The game never asks for your e-mail address, your location or your contacts; the only thing you can type in is an optional player name. Your progress and settings are kept in your own browser. Online play sends our server only what a match needs, and a room is deleted an hour after it goes quiet. We run no analytics or tracking tools of our own. We show or may show ads from Google AdSense: Google and its partners use cookies for them, and where the law requires it you are asked for consent first (section 2.5).

1. Who we are and how to contact us

The site is run by Artem Podrushniak, an independent developer, who decides how the data described here is used (the "controller" under data protection laws such as the GDPR).

Privacy contact e-mail: artem.podrushnyak@gmail.com (the subject "[Penalty Bluff] Privacy" helps us find your message)
Country: Indonesia

2. What data is processed

2.1. Data kept in your browser

The game saves its data in your browser's local storage for penaltybluff.com (the game's storage library, shared_preferences, uses the browser's localStorage on the web). This data stays on your device. It is not a cookie, it is not attached to requests, and it is not sent to us or to anyone else, except the two items marked "used for online play" when you choose to play online (2.2). It contains:

Settings: sound, vibration, slow motion, "Clean frame for filming", the language if you picked one, and whether the how-to-play sheet has already been shown.
Match setup: the player names you typed for two-player and online games, the rules you last chose (zones, format, tricks) and the last computer level you played.
Progress: a ledger of the coins and experience each match earned, with its time and kind; the Locker room items you bought and the ones you wear; and the career rivals you have beaten.
The computer's memory of you: your most recent picks — up to 200 as the shooter and 200 as the keeper — each with its zone, the number of zones, whether it was a trick, and the result. Computer opponents learn your habits from it, and the scout report after a match is read from it. Picks from online matches are added too. It contains nothing about who you are.
An install identifier (used for online play): a random code created the first time you open the online menu. It is not derived from your device or browser, it is never shown on screen, and it is not linked to your name.
Your seat in an online match (used for online play): the room code, the player id and the secret token our server issued for your seat, so that you can return to the match after reloading the page. It is removed when you leave the match. A note of the last online match you were paid coins for is kept so that a match is paid only once.

Your browser may also keep copies of the game's files in its cache so that the game starts faster next time. Data in local storage is separate for each browser and each device. In a private or incognito window it is usually deleted when you close the window.

2.2. Online play (optional)

Nothing reaches our game server until you open the online menu and start or join a match. Then the server (api.penaltybluff.com, run on Cloudflare) receives and keeps for the life of the room:

A name. When you play a friend, the name you entered (optional, up to 16 characters), which is shown to the other player in the room. When you play a random opponent, your own name is not sent: the server gives both players a generated name such as "Keeper 4821".
The room record: the six-character room code, the rules, the two seats (name, player id and secret token), the kicks played, the score, rematch votes and timestamps.
Your actions in the match: your pick for each kick (the zone, and whether you used a trick), when you have seen the reveal, and whether you are connected. Your pick is sealed on the server and is not sent to your opponent until both players have picked. If time runs out, the server picks a random zone for you.
Your install identifier (2.1), sent when you create or join a room and when you join the random-opponent queue. It is used for the per-device request limits (2.3) and so that the queue never pairs you with yourself. It is not stored in the room.

The other player sees your name (in a friend room) or your generated name, your picks once they are revealed, the score and whether you are connected. There is no chat. An invite link contains the room code: anyone who has it can take the free seat until the room is full, so send it only to the person you want to play.

While you wait for a random opponent, the queue keeps your install identifier and the time you joined. That is gone as soon as you are paired or leave the queue. If you choose to play a bot instead, the bot runs in your browser and the match does not use our server.

2.3. Request limits and server logs

Request limits. To protect the game server from abuse, it counts requests per network address (an IPv4 address, or the /64 block of an IPv6 address) and, where a request includes it, per install identifier within that address, over windows of one minute or one hour. The counters are stored under your network address (the per-device ones also under your install identifier) and are deleted within a few hours.
Our log lines. The server writes a short log line for events such as a room being created or joined, a match starting or ending (with its score), a dropped connection or an error. These lines contain room codes, seat numbers and match results. In the queue they contain an eight-character fragment of a one-way hash (SHA-256) of your install identifier, never the identifier itself. They contain no names, no secret tokens and no IP addresses.
Cloudflare's request records. Cloudflare keeps a record of each request to the game server, with its time, the address requested and technical details of the request and the response. For the random-opponent queue, the address requested includes your install identifier.

2.4. Hosting, delivery and the game engine

Cloudflare (Cloudflare, Inc.) hosts the site and the game server and processes data for us as our service provider. Every visit passes through Cloudflare's network, which processes your IP address and request details (such as your browser type and language) to deliver pages and protect the site from attacks. For this, Cloudflare may set strictly necessary security cookies, for example to tell people from automated traffic. For visits to the site's pages, Cloudflare gives us only aggregated traffic statistics, such as the number of requests and the countries they come from.
The game engine. The game is built with Flutter, Google's open-source toolkit. When the game starts, your browser may download part of the Flutter engine from Google's server www.gstatic.com and, if some text needs characters the game's own fonts do not have, a fallback font from fonts.gstatic.com. Like any download, this shows your IP address and browser details to Google. The site's pages use fonts served from penaltybluff.com itself.
Sharing a result or an invite. When you share a result card or an invite, the game hands it to your browser's or device's share feature. It goes wherever you send it; we do not receive a copy.

2.5. Advertising (Google AdSense)

We show or may show ads from Google AdSense, a Google service, on the pages of penaltybluff.com and in the browser game, for example between matches. When this policy took effect, we had applied to AdSense and no ads were shown yet; from the moment ads appear, this section applies in full. If we add another advertising provider, we will update this policy first.

Third-party vendors, including Google, use cookies to serve ads based on a user's prior visits to this website or other websites.
Google's use of advertising cookies enables it and its partners to serve ads to our users based on their visit to this site and/or other sites on the Internet.
You may opt out of personalised advertising by visiting Google's Ads Settings. You can also opt out of some third-party vendors' use of cookies for personalised advertising at www.aboutads.info.
Google can allow other ad technology providers it has approved to serve or measure ads on the site. In the European Economic Area, the United Kingdom and Switzerland, these vendors are listed, with links to their privacy policies, in the consent message (open "Manage options"). Where a vendor offers its own opt-out, you can use it on that vendor's website.

When an ad is requested, Google and its partners receive the address of the page, your IP address (from which an approximate location can be estimated), information about your browser and device, identifiers stored in cookies or similar technologies, and how you interact with ads (for example views and clicks). They use this to serve and measure ads, to limit how often you see the same ad, to prevent fraud and, where allowed, to personalise ads. How Google uses this data is explained in How Google uses information from sites or apps that use our services.

Consent in the EEA, the UK and Switzerland. Visitors from these regions are shown a consent message from a consent management platform certified by Google and integrated with the IAB Transparency and Consent Framework, before advertising cookies are used. You can accept, refuse, or choose purpose by purpose and vendor by vendor. You can change your choice at any time with the "Privacy and cookie settings" link that appears at the bottom of the page once ads are active. If you do not consent to personalised ads, Google shows non-personalised ads, chosen from the content of the page and your general location rather than your history; if you allowed cookies, these may still use them for limiting repeats, aggregated reporting and fighting fraud. If you do not allow cookies at all, Google may show limited ads that work without them.

Elsewhere, ads may be personalised unless you opt out using the links above, your browser's settings or, in some US states, the opt-out described in section 7.

2.6. Cookies and similar technologies at a glance

We set no cookies of our own. This is what may be stored in your browser when you use the site:

What	Set by	Why	How long
Game data in local storage (2.1)	The game	Settings, progress, the computer's memory, your online seat	Until you clear it; seat until you leave the match
Security cookies	Cloudflare, if needed	Protecting the site from attacks and automated traffic	Short-lived
Your consent choice	Google's consent tool, in the EEA, UK and Switzerland	Remembering what you chose	Set by the tool
Advertising cookies and identifiers	Google and its partners, once ads are shown	Serving, measuring and, where allowed, personalising ads; fighting fraud	Under their policies

2.7. If you write to us

If you e-mail us, we receive your e-mail address and whatever you write, and use them only to answer you and to fix what you reported. Our mailbox is hosted by Google (Gmail).

2.8. What we do not collect

No account, password or e-mail address (unless you write to us), no precise location, no contacts, no photos, no camera or microphone, and no analytics, tracking pixels or social media plugins of our own.

3. Why we use data, and on what legal basis

Where data protection laws such as the EU or UK GDPR require a legal basis, each use rests on the one given with it:

to keep your settings and progress in your browser (2.1) — needed to provide the game you asked for (performance of a contract). Because this storage is needed for the game to work as you asked, we do not ask for separate consent for it;
to run online matches (2.2) — performance of a contract;
to protect the site and the server, apply request limits and keep logs (2.3, 2.4) — our legitimate interest in a working, safe service. You can object at any time (section 6);
to deliver the game engine and fonts quickly (2.4) — our legitimate interest in a game that loads reliably;
for ads (2.5) — in the EEA, the UK and Switzerland, your consent for storing or reading information on your device for ads and for personalised ads, which you can withdraw at any time; for non-personalised and limited ads, our legitimate interest in funding a free game; and our legal obligations, to ask for and respect your choices;
to answer your messages (2.7) — your request and our legitimate interest in answering it;
to comply with the law — our legal obligations.

4. Who receives data

We do not sell personal data for money. Data reaches others only:

Cloudflare — hosting, delivery, security, the game server's storage and its request records (2.2–2.4);
Google — the downloads of the game engine and fallback fonts (2.4); ads and the consent message (2.5); and our mailbox, if you write to us (2.7);
the other player in an online room — your name or generated name, your revealed picks, the score and whether you are connected (2.2);
authorities, when the law requires it.

Under some US state laws, letting advertising partners use cookies for targeted ads can count as "selling" or "sharing" personal information even when no money changes hands; section 7 explains how to opt out.

5. How long data is kept

Game data in your browser: until you clear the site data or the browser removes it. Your seat in an online match: until you leave the match.
An online room, with everything in it: deleted one hour after the last activity in the room. The queue keeps your entry only while you wait.
Request-limit counters: deleted within a few hours.
Server logs and Cloudflare's request records: up to 7 days.
Cloudflare keeps a recovery history of the game server's storage for up to 30 days, so deleted data, such as a room, can remain in it for up to 30 days after deletion. We would use it only to repair a fault.
E-mails: as long as needed to deal with your request.
Data that Google, its partners and Cloudflare process on their own account: under their own retention policies.

6. Your rights and choices

Depending on where you live, you may have the right to access your data, to correct or delete it, to restrict or object to its use (including, at any time, use based on our legitimate interests), to receive it in a portable form, and to withdraw consent. To make a request, write to artem.podrushnyak@gmail.com. If you are in the EU, the UK or another country with similar law, you can also complain to your local data protection authority.

Deleting the game's data. Everything in 2.1 is in your browser, and you can delete it yourself: open the site settings for penaltybluff.com in your browser (in most browsers, the icon to the left of the address) and delete the site's data, or clear cookies and site data in the browser's privacy settings. This also resets your coins, items and career, and a new install identifier is created the next time you play online.
Data on our server. There are no accounts, so we can only find data by its room code and time, and rooms are deleted an hour after they go quiet. If you write to us soon after a match, tell us the room code, or for a random opponent the names shown and the time.
Ad choices. Use the "Privacy and cookie settings" link (EEA, UK and Switzerland), Google's Ads Settings, www.aboutads.info, or your browser's cookie settings.

We answer requests within the time the applicable law sets. We may ask for details that help us find the data, but no more than that.

7. Privacy rights in US states

If you live in a US state with a consumer privacy law, such as California, you may have the right to know what personal information we collect and how we use it, to access, correct and delete it, to opt out of its "sale" or "sharing" for targeted (cross-context behavioural) advertising, and not to be treated differently for using these rights.

What is collected, by us or by our providers and ad partners: identifiers (IP address, the install identifier, cookie identifiers used by ad partners), internet activity (pages visited on the site and interactions with ads), approximate location estimated from the IP address by our providers, and the name you type for a friend room. We collect no sensitive personal information.
Opting out. Where these laws apply and ads are shown, Google's US state privacy message places a "Do Not Sell or Share My Personal Information" link on our pages. Using it tells Google to limit how it uses your data for ads. You can also opt out by writing to us.
We do not knowingly sell or share the personal information of anyone under 16.
You may use an authorised agent. If we turn down a request, you can appeal by replying to our answer.

8. Children

Penalty Bluff is a general-audience game. It is not directed at children under 13, and we do not knowingly collect personal information from children under 13. The game asks for nothing about anyone beyond an optional player name. If you are under the age at which you can consent to data processing where you live (up to 16 in some EU countries), ask a parent or guardian before agreeing to personalised ads. If you believe a child under 13 has given us personal information, for example by typing their real name as a player name online, write to us and we will delete what we can find.

9. International transfers

We are based in Indonesia: when you write to us, or when we look at server logs, the data is read from there. Cloudflare processes data in data centres around the world, usually one close to you. Google processes data in many countries, including the United States. These providers protect such transfers with legal safeguards, such as the European Commission's standard contractual clauses, as described in their privacy policies (section 12).

10. Security

The site and the game server are reached only over encrypted connections (HTTPS and secure WebSockets). The secret token for your seat travels in a connection header rather than in the web address, so it does not end up in request records, and our logs carry only a short hash fragment of your install identifier. No method of storage or transmission can be guaranteed fully secure.

11. Changes to this policy

We may update this Privacy Policy, for example when ads start to appear or when the game changes what it keeps. We publish each new version on this page and update the dates at the top. If a change significantly affects how your data is used, we will also say so on the site.

12. Third-party privacy resources

13. Contact

Questions about this policy or your data: artem.podrushnyak@gmail.com, subject "[Penalty Bluff] Privacy". See also the contact page.