Privacy Policy

Effective dateAugust 17, 2026

1. DATA CONTROLLER AND CONTACT DETAILS

Data Controller: The data controller responsible for the processing of your personal data under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation - GDPR) is:
Michał Majka, conducting business under the business name Michał Majka Neurogrine
Registered address: ul. Armii Krajowej 7/14, 30-150 Kraków, Poland
NIP (VAT ID): 6772308416 | REGON: 369467404
Contact Email: lhm@lexogrine.com
Scope of Application: Respecting your privacy rights is our fundamental obligation. This Privacy Policy sets out how we collect, process, store, and protect your personal data when you use the Lexogrine HUD Manager (LHM) desktop application, LHM Cloud, LHM Studio, LHM Network, and related websites (https://lhm.gg).
Applicable Laws: Data processing is conducted in strict compliance with the GDPR, the Polish Personal Data Protection Act of 10 May 2018, and other applicable data protection laws.
B2B Data Processing & DPA (Art. 28 GDPR): Where Users upload or process personal data of third parties (e.g., esports players, tournament participants, broadcast crew, or workspace members) within LHM Cloud, LHM Studio, or Enterprise Workspaces, Michał Majka Neurogrine acts as a Data Processor under Article 28 GDPR, processing such data on behalf of the User. Such data processing is strictly governed by our standard Data Processing Agreement (DPA), which forms an integral part of the Terms of Service and is accessible at https://lhm.gg/dpa.

2. SUMMARY OF DATA PROCESSING ACTIVITIES (ART. 13 GDPR)

To ensure full transparency, the following table summarizes why, on what legal bases, and for how long your personal data is processed:

Processing Purpose	Categories of Data	Legal Basis (GDPR)	Retention Period
Account Creation, Authentication & Security	Email, username, password hash, SSO IDs, Passkeys, TOTP, session tokens, login history, HMAC IP, User-Agent.	Art. 6(1)(b) (Contract) & Art. 6(1)(f) (Security)	Duration of active Account + 3 years security/audit retention post-deletion.
LHM Cloud Storage (User Content Hosting)	HUDs, player/team rosters, match history, overlays, replay metadata, configs, addons, custom CSS.	Art. 6(1)(b) (Contract performance)	Duration of active Subscription. Permanently erased within 30 days of Account deletion request.
Payments, Billing & Tax Compliance	Transaction IDs, full webhook objects (Stripe/Lemon Squeezy), billing details, last 4 digits of card, iFirma records.	Art. 6(1)(c) (Legal obligation under tax/accounting law)	5 years from the end of the tax year in which the transaction occurred.
Telemetry & Live Usage	App version, game title, workspace ID, active team/player observation details, Lexogrine & Scout usage time.	Art. 6(1)(f) (Legitimate interest in monitoring app performance)	Raw telemetry: 3 years.
Analytics, Hardware Limits & Audit Trail	Session counts, screen views (aggregated), MachineGuid (SHA-256), workspace audit actions, failure logs, MCP tool usage.	Art. 6(1)(f) (Legitimate interest in preventing abuse & verifying device limits)	Aggregated analytics & audit logs: up to 3 years post-account deletion.
Scout AI Analytics	Kills tracking metrics, match telemetry, XYZ coordinates, health/armor/economy data on failed requests.	Art. 6(1)(f) (Legitimate interest in AI model optimization)	Raw match state data: 3 years.
LHM Network Public Directory	Public profile name, bio, portfolio items, cover photos, contact info, social links, moderation logs.	Art. 6(1)(b) (Contract) & Art. 6(1)(a) (Consent for optional public details)	Retained until deleted by User, or unassigned/removed within 30 days of Account deletion.
Support Chat & Customer Services	Message content, timestamps, email, technical diagnostics attached by User.	Art. 6(1)(f) (Legitimate interest in resolving technical issues)	Retained for support resolution + 3 years for legal claims defense.
Legal Claims Defense, Security & Fraud Prevention	Account ID, deletion request timestamps, SHA-256 machine ID, HMAC IP/User-Agent, security audit trails, workspace activity logs.	Art. 6(1)(f) & Art. 17(3)(e) (Defense against legal claims & statutory compliance)	Exactly 3 years from Account deletion request (pursuant to Art. 118 of the Polish Civil Code).
Company Data Updates & Billing Audit	Timestamps of company data edits, new company details (NIP/VAT ID, address, name), invoices, tax records.	Art. 6(1)(c) (Tax/accounting obligation) & Art. 6(1)(f) (Audit trail)	5 years from the end of the tax year.
App Preferences & Localization	Selected application language, global default avatar, dark/light theme, UI layout preferences.	Art. 6(1)(b) (Contract performance)	Duration of active Account.

3. DETAILED SCOPE OF PROCESSED DATA & SPECIFIC MODULES

3.1 Authentication & Security Credentials

To manage your Account, control access, and safeguard against unauthorized breaches, we process:

Account Credentials: Email address, username, cryptographic password hash, external identity provider IDs (Google, LinkedIn, Steam, GitHub SSO), Passkey credentials (WebAuthn), TOTP secret keys, and backup recovery codes.
Security & Tokens: Email verification/reset tokens, email change authorization tokens, session expiration timestamps, and session revocation statuses.
Network Signatures: HMAC-hashed IP addresses and User-Agent strings stored to detect credential stuffing and session hijacking without retaining raw IP addresses permanently.

3.2 LHM Cloud Storage (User-Generated Content Disclaimer)

IMPORTANT LEGAL DISCLAIMER: All data stored within LHM Cloud constitutes User-Generated Content (UGC) created, uploaded, or configured by the User. The Data Controller acts strictly as an automated technical hosting infrastructure provider under Article 6(1)(b) GDPR. The User retains full responsibility for the lawfulness and accuracy of any third-party personal data (e.g., player names, photos, social links) uploaded to LHM Cloud. All Cloud items contain the User's unique Account Identifier to link files to the owner.

HUDs & Overlays: Visual layout files, configurations, unique HUD IDs, target game, keybind mappings, and display settings panels.
Player Directory: First name, last name, nickname, SteamID/in-game identifier, nationality, assigned team, photo, custom social media URLs (for Studio mode), and user-attached custom metadata.
Team Directory: Team name, short tag, country, logo graphic, and user-attached custom metadata.
Match Directory: Participating teams, overall series score, map veto sequence (bans/picks, starting sides), per-map scores, match date, status (scheduled, live, completed), round-by-round delta history, and League of Legends champion draft history.
Tournament Directory: Name, group stage / playoff formats (Swiss, brackets), logo, participating rosters, match schedule, and results.
App & Functional Assets: App settings, custom addons, X-Ray team color assignments, Steam API Key, default global avatars, and mid-game team swap states.
Replay Metadata: Local network IP addresses, hostnames, user & workspace identifiers, and replay configuration parameters.
Enterprise Workspaces: Workspace names, user membership lists, and role permission matrices.
HUD Sharing Records: Recipient email addresses, timestamps, authorization status (sent, accepted, rejected, expired).

3.3 WebRTC Camera Signaling (Transient In-Memory Processing)

When using LHM Cameras for direct peer-to-peer (P2P) WebRTC video transmission:

Transient Signaling Data: LHM servers temporarily act as a signaling broker transferring network metadata, including local/public IP addresses, network ports, ICE candidates, supported media codecs, and DTLS certificate fingerprints.
Zero Storage Guarantee: Signaling data is processed exclusively transiently within volatile RAM and communication buffers. It is never written to disk, stored in databases, or analyzed. Audio and video streams pass directly between participants (P2P) and are never recorded, intercepted, or stored by LHM.

3.4 Telemetry & Live Usage Data

We collect background usage statistics during active application execution:

Execution Telemetry: Active game title, User ID, Workspace ID, application version.
Observed Match Telemetry: Names, logos, countries, and live scores of observed teams; usernames, real names, SteamIDs, countries, and photos of players actively tracked on screen.
Live Feature Usage: MachineGuid, unique session ID with timestamps, active Lexogrine HUD and Scout tools usage duration, active theme names, and custom color selections.

3.5 Application Analytics, Audit Logs & Hardware Limits

To enforce subscription seat limits, debug system errors, and improve product performance:

Screen Analytics: Application screen view counts (e.g., "Players tab opened 33 times"). Exact event timestamps are discarded immediately after daily aggregation.
Session Counts & Devices: Number and timestamps of application/module launches. Device identification is performed using a stable SHA-256 hash of the system hardware ID (and legacy UUID). We do not collect hardware specifications - only the fact that a login occurred on Device X vs Device Y to enforce Plan session limits (e.g., Personal Plan 1-device active limit, which automatically resets after 12 hours).
System Failure Diagnostics: Server and desktop error logs triggered by user actions (timestamp, error code, stack trace).
Workspace & Administrative Audit Trails: Timestamps and action types (add, edit, delete, user_invite, permission_change) for Enterprise workspaces, seat purchases, and team assignments.
In-App Messaging & Tools: Display logs of System Messages, and daily aggregated call counts for local MCP (Model Context Protocol) tools.
User Preferences & Device Data: Application language setting, app version, stable SHA-256 system identifier, HMAC IP address, and User-Agent.

3.6 Scout AI Telemetry

For accounts utilizing Scout AI capabilities:

Performance Metrics: Played map, count of observed kills, missed kills, and total API request counts.
Failed Response Telemetry: In cases where the Scout server cannot render a response, diagnostic game-state telemetry is collected to improve model accuracy: match score, player XYZ coordinates, health, armor, money, weapons, ammo, view vectors, velocity, bomb state, and detailed player statistics.

3.7 Payment Processing, Billing & Tax Records

Transactions are handled directly by the Data Controller or through authorized Merchants of Record (Stripe, Lemon Squeezy) and invoiced via iFirma:

Transaction Records: Payment process initiation and confirmation timestamps, user account ID, selected plan, billing period, seat count, upgrade/downgrade flags, net/gross amounts, currency, applied discounts, tax amounts, and exchange rates.
Payment Processor Webhooks: LHM archives full raw webhook message payloads received from Stripe and Lemon Squeezy for tax, accounting, and anti-fraud auditing. This includes payment processor customer IDs, subscription/invoice IDs, payment status, card brand, last 4 digits, expiry date, issuing country, and fraud risk scores.
Card Security: LHM never receives, sees, or stores full payment card numbers or CVC/CVV security codes.
Invoicing Data: Company name, billing address, VAT ID (NIP), invoice generation timestamps, and direct request/response payloads exchanged with iFirma.
Company Data Edits: When a User updates company details assigned to their Account, LHM logs the timestamp of the modification alongside the newly provided company attributes (company name, VAT ID/NIP, registered address, tax region) for legal compliance and audit verification.

3.8 LHM Network (Public Directory)

Public Profile Data: Title, bio description, uploaded portfolio graphics, MIME types, file sizes, creation/approval dates, tag selections, external website URLs, contact details, public email, social media profiles, and owner ID.
Moderation Audit: Moderation status, rejection reasons, and admin log entries.

4. ACCOUNT DELETION

Account Deactivation (Soft Delete): Upon requesting Account deletion via settings, your Account enters an immediate "Soft Delete" state. Public profiles (including LHM Network entries) are unassigned, and access permissions to paid features are revoked.
Erasure of Cloud Content (30 Days): User-Generated Content hosted within LHM Cloud (saved HUDs, custom CSS, asset libraries, team/player rosters) is permanently deleted from active operational databases within thirty (30) days of the deletion request.
Archival Retention for Legal Claims & Authorities (3 Years):
- Pursuant to Article 6(1)(f) and Article 17(3)(e) GDPR, core Account records, security audit logs, unique machine identifiers (SHA-256 hashes), session histories, workspace activity logs, and system error events are archived for three (3) years from the date of Account deletion.
- This retention period aligns with the statutory statute of limitations for commercial legal claims under the Polish Civil Code (Art. 118 KC) and ensures the Data Controller can fulfill statutory duties to cooperate with law enforcement agencies, courts, or regulatory authorities upon legal request.
Statutory Tax Retention (5 Years): Billing details, invoice records, and Merchant of Record transaction payloads are retained for five (5) years from the end of the tax year in which the transaction occurred, in compliance with statutory tax obligations (Art. 6(1)(c) GDPR).
Hard Erasure: Upon the expiry of the respective statutory retention periods (3 years for claims/logs and 5 years for tax documents), all remaining archived data is permanently and irreversibly destroyed or anonymized.

5. DATA RECIPIENTS AND INTERNATIONAL TRANSFERS

5.1 Subprocessors and Service Providers

We share necessary personal data strictly on a need-to-know basis with trusted third-party subprocessors bound by Data Processing Agreements (DPAs) under Article 28 GDPR:

https://lhm.gg/subprocessors

5.2 Third-Country Data Transfers (Outside the EEA)

Some of our subprocessors (such as AWS, Stripe, Google, Meta, or Lemon Squeezy) are based in or operate infrastructure within the United States:

Transfers to US entities participating in the EU-U.S. Data Privacy Framework (DPF) adequacy decision are conducted under Article 45 GDPR.
Where DPF certification is inapplicable, data transfers are protected under European Commission Standard Contractual Clauses (SCCs) pursuant to Article 46(2)(c) GDPR, alongside technical transport encryption (TLS 1.3).

6. COOKIES AND LOCAL BROWSER STORAGE

We use small text files ("Cookies") and local storage items to operate the Website and Application.

Managing Cookies: You can disable or wipe analytical and marketing cookies at any time using our Cookie Banner or via your browser's security settings. Disabling essential technical cookies may prevent logging into your Account.

You can find more information about cookies here: https://lhm.gg/cookies

7. YOUR DATA SUBJECT RIGHTS (GDPR)

Under Articles 15 through 22 of the GDPR, you possess the following statutory rights regarding your personal data:

Right of Access (Art. 15 GDPR): Right to receive confirmation as to whether your data is processed and obtain a copy of all held data.
Right to Rectification (Art. 16 GDPR): Right to correct inaccurate or incomplete personal details.
Right to Erasure / "To Be Forgotten" (Art. 17 GDPR): Right to request permanent account erasure (executed following our 30-day Soft Delete protocol).
Right to Restriction of Processing (Art. 18 GDPR): Right to restrict data processing under specific legal disputes.
Right to Data Portability (Art. 20 GDPR): Right to receive your personal data in a structured, machine-readable JSON/CSV format.
Right to Object (Art. 21 GDPR): Right to object to processing based on legitimate interests (Art. 6(1)(f) GDPR) or direct marketing.
Right to Lodge a Complaint: You have the right to lodge a formal complaint with a European data protection supervisory authority. In Poland, the relevant authority is:
Prezes Urzędu Ochrony Danych Osobowych (PUODO)
ul. Stawki 2, 00-193 Warsaw, Poland
Website: https://uodo.gov.pl

8. AUTOMATED DECISION-MAKING & AI TRANSLATIONS

No Automated Profiling: We do not subject your personal data to automated decision-making or profiling that produces legal or similarly significant effects under Article 22 GDPR.
AI Language Translations: Translations of our Website, application interface, or terms generated using Large Language Models (LLM / AI) are executed on generalized static text. No personal user data is ever transmitted to or processed by third-party AI models for language translation purposes.

9. CHANGES TO THIS PRIVACY POLICY

Right to Update: We reserve the right to modify or update this Privacy Policy at any time to reflect changes in our legal obligations, software features, technology infrastructure, or data processing practices.
Notification & Grace Period (14 Days):
1. Registered Users will be notified of proposed material changes to this Privacy Policy at least fourteen (14) days prior to their effective date in-app notice banner upon launching LHM.
2. During the 14-day grace period, Users may acknowledge the proposed changes or defer the decision ("NO") while retaining standard access to the application and services.
Login Suspension Post-Grace Period:
1. Upon the expiration of the 14-day grace period, access to the User Account, LHM Cloud, LHM Studio, and the desktop application will require explicit confirmation of the revised Privacy Policy.
2. Users who have not confirmed the updated Policy will be unable to complete the authentication process or bypass the login screen until explicit acceptance is submitted via the presented prompt.
3. If a User chooses not to accept the revised Privacy Policy upon the expiry of the 14-day window, they may request complete Account deletion in accordance with Section 4 of this Policy.