Privacy Policy

Anarchy Control Center (ACC) Effective date: 14 September 2026 Version 1.0

1. Who We Are

Anarchy Control Center ("ACC", "we", "us" or "our") is operated by Mario Aquilina, trading as Anarchy Esports, Malta.

For questions about this Privacy Policy, our processing of personal data, or to exercise your data-protection rights, contact:

Email: support@anarchymt.com

For the personal data processed in connection with operating ACC, Mario Aquilina trading as Anarchy Esports acts as the data controller where we determine the purposes and means of processing.

2. Scope of This Policy

This Privacy Policy explains how personal data is processed when you:

• use the Anarchy Control Center desktop application;
• use ACC's online and team features;
• use AI Coach;
• activate or validate an ACC licence;
• visit the ACC website; or
• contact Anarchy Esports for support.

ACC is designed so that a substantial amount of gameplay and demo-analysis data remains on your own computer.

3. Data Stored Locally on Your Computer

ACC processes a significant amount of information locally.

This may include:

• CS2 demo files;
• parsed demo information;
• player names and identities;
• Steam IDs;
• player positions and coordinates;
• heatmaps;
• tactical evidence;
• Match Brief positional evidence;
• opponent scouting information;
• locally generated analysis;
• local application settings and history; and
• locally cached information.

Demo files and the principal data parsed from those demos are stored locally and are not uploaded to Anarchy Esports.

ACC may also store locally:

• your ACC licence key and licence instance identifier;
• your FACEIT username;
• an Anthropic API key if you choose to provide one; and
• team-room credentials.

Sensitive credentials stored by ACC are protected locally using Windows Data Protection API (DPAPI) under the current Windows user account where implemented by the application.

Some interface state is also retained locally by ACC's application WebView.

4. Licence Activation and Device Identification

ACC uses Lemon Squeezy for licence activation and validation.

When activating ACC, the application sends:

• your licence key; and
• a pseudonymous machine fingerprint.

The machine fingerprint is generated by applying SHA-256 to information derived from the Windows MachineGuid and system-drive volume serial number. ACC uses this identifier to bind a licence activation to a device.

The underlying raw hardware values used to generate the fingerprint are not sent as part of this process.

Although the fingerprint is hashed and is not intended to reveal the underlying hardware values, it is a persistent device identifier and we therefore treat it as pseudonymous personal data, not anonymous data.

For subsequent licence validation and deactivation, ACC may send the licence key and the instance identifier issued for the activation.

Lemon Squeezy also processes information associated with purchases and payments in its capacity as merchant of record. Payment-card information is handled through Lemon Squeezy's checkout environment rather than by ACC.

5. Anarchy Online Services

Certain ACC features communicate with online infrastructure operated for Anarchy Esports.

Cloudflare Worker

ACC may communicate with an Anarchy-operated Cloudflare Worker.

Depending on the feature being used, the Worker may receive:

• a randomly generated installation identifier;
• your ACC licence key;
• your licence instance identifier;
• your IP address;
• FACEIT player identifiers;
• FACEIT match identifiers; and
• AI Coach prompt content when the hosted AI path is used.

The installation identifier is a random UUID generated for an ACC installation. It is used primarily for operational purposes such as rate limiting.

IP addresses may also be processed by Cloudflare and the Worker as part of providing, securing and rate-limiting the service.

Supabase and Team Rooms

If you use ACC's team-room functionality, information may be stored using our Supabase backend.

Depending on how you use the feature, this may include:

• team name;
• player nickname;
• role;
• FACEIT nickname and player identifier;
• scrim opponent;
• maps;
• server information;
• free-text scrim notes;
• player availability;
• team statistics;
• strategy-board information; and
• FACEIT match identifiers.

Where required to provide features such as Match Brief or team-related analysis, Anarchy-operated services may retrieve relevant team-room information from our Supabase backend, including roster and match information.

Information shared within a team room may be visible to other members of that room.

You should therefore avoid entering unnecessary personal or sensitive information into free-text fields such as scrim notes.

6. FACEIT

ACC uses FACEIT information to provide features such as player statistics, match history and match-related analysis.

By default, FACEIT requests are routed through Anarchy Esports' Cloudflare Worker. These requests may contain FACEIT player identifiers and match identifiers.

If the application's Worker endpoint is manually replaced with a direct endpoint, requests may instead be sent directly to FACEIT.

ACC may cache information obtained from FACEIT where necessary for application functionality and performance.

7. AI Coach

ACC provides optional AI-assisted analysis.

There are two possible processing paths.

Using Your Own Anthropic API Key

If you provide your own Anthropic API key, AI Coach requests are sent directly from your computer to Anthropic.

Your API key is stored locally using Windows DPAPI and is not sent to Anarchy Esports.

Prompt content may contain match information and player names extracted from analysed gameplay.

Your use of Anthropic in this configuration is also subject to the terms and privacy arrangements applicable to your own Anthropic account.

Using ACC's Hosted AI Service

Where the feature is available and you have not configured your own Anthropic API key, ACC may route the AI Coach request through an Anarchy-operated Cloudflare Worker.

In this case, the prompt passes through infrastructure operated for Anarchy Esports before being submitted to Anthropic.

An AI Coach request may reach Anarchy Esports infrastructure for entitlement or availability checks even where the request is subsequently declined and is not forwarded to Anthropic. A declined request is not processed by Anthropic.

The prompt may contain:

• match information;
• gameplay-derived information; and
• player names.

Raw CS2 demo files are not transmitted to Anarchy Esports or Anthropic as part of AI Coach.

ACC does not use AI Coach to make decisions that produce legal or similarly significant effects concerning you.

8. Network Diagnostics

ACC's network-diagnostic functionality may request your public IP address from ipify.org.

Your IP address is returned to ACC and displayed as part of the diagnostic information.

ACC does not intentionally persist the returned public IP address in its local database or separately transmit that result to Anarchy Esports.

Your request to ipify necessarily exposes your IP address to that service.

9. Website Data

The ACC website does not currently use:

• analytics;
• advertising trackers;
• tracking pixels;
• third-party scripts;
• non-essential cookies; or
• browser storage for tracking.

The website is hosted using Cloudflare Pages. As with ordinary website hosting, Cloudflare may process technical request information such as IP addresses and request metadata when delivering the website.

Links to third-party services, including Lemon Squeezy, take you to those services and their own privacy practices apply after you leave our website.

Because the current ACC website does not use non-essential cookies or similar tracking technologies, ACC does not currently display a cookie-consent banner.

10. Support Communications

If you contact us at support@anarchymt.com, we process the information you provide, which may include:

• your email address;
• your name;
• licence or account information you choose to provide;
• technical information;
• attachments; and
• the content of your correspondence.

We use this information to respond to your request, investigate technical problems, prevent abuse where necessary and maintain appropriate support records.

Support correspondence is normally retained for up to 24 months after the last interaction, unless a longer period is reasonably necessary to resolve an ongoing dispute, comply with a legal obligation, or establish, exercise or defend legal claims.

11. No Analytics, Telemetry or Gameplay Monitoring

ACC does not currently contain analytics, advertising tracking, crash-reporting or telemetry systems.

ACC does not capture your screen.

ACC does not continuously monitor your gameplay.

ACC does not upload your raw CS2 demo files.

This does not mean that ACC processes no personal data. Online features described elsewhere in this Policy necessarily process limited information required to provide those features.

12. Why We Process Personal Data

Where GDPR applies, we rely on an appropriate legal basis for each processing activity.

Performance of a contract

We process information where necessary to provide ACC and functionality you request, including:

• licence activation and validation;
• entitlement checks;
• requested online features;
• team-room functionality; and
• support necessary to provide the service.

Legitimate interests

We may process limited information where necessary for our legitimate interests in:

• protecting ACC against abuse and unauthorised use;
• enforcing licence restrictions;
• rate limiting;
• maintaining the security and reliability of our services;
• diagnosing technical problems; and
• establishing, exercising or defending legal claims.

Where we rely on legitimate interests, we consider the necessity of the processing and its impact on users.

Legal obligations

We may retain or process information where necessary to comply with applicable legal obligations.

Where an optional feature requires a different legal basis, we will provide appropriate information when the feature is introduced or used.

13. Service Providers and Third Parties

ACC currently interacts with or relies upon services including:

Lemon Squeezy — merchant of record and licence services. It processes purchases, payments and associated transaction information and provides ACC's licence activation infrastructure.

Cloudflare — website hosting, Workers, networking, security, rate limiting and email-routing infrastructure.

Supabase — backend infrastructure used for team rooms and related shared data.

Anthropic — AI processing for AI Coach, either directly using your own API key or through ACC's hosted AI path where available.

FACEIT — source of player, match and statistics information requested by ACC.

ipify — used by the optional network-diagnostic feature to determine your public IP address.

These organisations may process information under their own terms and privacy documentation or, where applicable, as service providers acting on our behalf.

We do not sell your personal data.

We do not share personal data with advertisers for behavioural advertising.

14. International Data Transfers

Some service providers used by ACC operate internationally and may process personal data outside Malta or the European Economic Area.

Where Anarchy Esports is responsible for an international transfer of personal data, we will rely on a lawful transfer mechanism required by applicable data-protection law, where such a mechanism is required.

Some processing may also occur directly between you and an independent third-party service, such as when you use your own Anthropic API credentials.

Further information about a provider's locations and safeguards can be obtained from that provider's privacy documentation.

15. Retention

We aim to retain personal data only for as long as necessary for the purpose for which it is processed.

Current retention arrangements include:

• Match-session records: automatically expire after approximately 12 hours.
• Support correspondence: normally retained for up to 24 months after the last interaction.
• Local demo and analysis information: remains on your device until you delete it or remove the relevant application data.
• Local credentials/settings: generally remain until cleared, removed or the relevant local application data is deleted.
• Team-room and other shared Supabase information: may remain until deleted through available team functions or following a valid deletion request. Some categories do not currently have an automatic expiry period.
• Licence and transaction records held by Lemon Squeezy: retention is determined by Lemon Squeezy and applicable legal requirements.

Platform-level logs, backups and security records maintained by infrastructure providers may be retained according to those providers' applicable retention schedules.

16. Your Data-Protection Rights

Subject to the GDPR and any applicable exceptions, you may have the right to:

• request access to personal data we hold about you;
• request correction of inaccurate or incomplete personal data;
• request erasure of your personal data;
• request restriction of processing;
• object to processing based on legitimate interests;
• receive certain information you provided in a portable format where the right to data portability applies; and
• withdraw consent at any time where processing is based on consent, without affecting processing carried out before withdrawal.

To exercise your rights, contact:

support@anarchymt.com

We may request reasonable information to verify your identity before fulfilling a request.

We will respond without undue delay and normally within one month, as required by applicable data-protection law. This period may be extended where permitted by law for complex or numerous requests.

Some rights are not absolute and may be subject to exceptions under applicable law.

17. Deleting Your Data

ACC provides controls for deleting or clearing certain local information and some team information.

However, ACC does not currently provide a single self-service function that deletes every piece of information held across all online services.

If you want personal data held by Anarchy Esports to be deleted, contact:

support@anarchymt.com

We will assess and action valid erasure requests in accordance with applicable data-protection law and will inform you if information must be retained for legal or other permitted reasons.

Uninstalling ACC removes application data from the affected installation but should not be relied upon as a method of deleting information already stored by online services.

18. Security

We use technical and organisational measures intended to protect personal data appropriate to the nature of the service.

Examples implemented within ACC include local DPAPI protection for sensitive application credentials, pseudonymous identifiers, restricted backend access and minimisation of remote processing by keeping raw demo analysis local where possible.

No method of electronic storage or transmission is completely secure, and we cannot guarantee absolute security.

If you believe you have identified a security or privacy issue, please contact support@anarchymt.com.

19. Children's Privacy

ACC is not designed to collect personal data from children as a dedicated children's service.

If you believe a child has provided personal data to Anarchy Esports in circumstances requiring parental or guardian involvement under applicable law, contact us at support@anarchymt.com so that we can investigate and take appropriate action.

20. Complaints

If you believe that our processing of your personal data infringes applicable data-protection law, you may contact us first at:

support@anarchymt.com

You also have the right to lodge a complaint with the competent supervisory authority.

For Anarchy Esports in Malta, the supervisory authority is the:

Office of the Information and Data Protection Commissioner (IDPC), Malta

You may also have the right to complain to another competent supervisory authority, particularly in the EU/EEA country where you live, work or where the alleged infringement occurred.

21. Changes to This Privacy Policy

We may update this Privacy Policy when ACC's functionality, service providers, legal requirements or data-processing practices change.

When we make material changes, we will update the effective date and version shown at the beginning of this Policy and, where appropriate, provide additional notice through the website or application.

Previous versions may be retained where appropriate for accountability purposes.

22. Contact

For privacy enquiries or to exercise your data-protection rights:

Mario Aquilina trading as Anarchy Esports Malta Email: support@anarchymt.com