privacy policy
LAST UPDATED Sep 29, 2025
Lobby9 is based in Ukraine, but we adhere to the European Union’s General Data Protection Regulation (GDPR), as well as other international privacy and data protection laws. We are committed to protecting your privacy, being transparent about how your data is collected and used, and ensuring you remain in control of your information.
We do not sell your personal data. However, we may use programmatic advertising solutions (such as Google AdSense) to support our services.
0. Data Collector
The data controller for Lobby9 is:
LIMITED LIABILITY COMPANY “BIOM STUDIO” (LLC “BIOM STUDIO”) Heroiv Kharkova Ave. 199D Kharkiv, 61044, Ukraine Contact: support@lobby9.com
1. Privacy Policy Updates
This Privacy Policy is current as of the “last updated” date. We may update it from time to time. Updates will become effective upon publication on lobby9.com/legal/privacy-policy.
If material changes occur, we will notify you by email (if available), in-app notices, or banners.
2. Definition of Personal Information
Personal Information “Personal Information” means any information relating to an identified or identifiable individual, including but not limited to your name, email address, username, IP address, location, payment details, or online identifiers.
Personal Information does not include:
Information that has been anonymized or aggregated, making it impossible to identify you.
Business contact information used solely for professional communications.
Sensitive Personal Information We do not intentionally collect sensitive data such as race, political opinions, health data, or criminal background, unless explicitly provided by you for a specific feature or legal reason.
Non-Personal Information Information that cannot be used to identify you directly, such as anonymized analytics, aggregated usage trends, or de-identified statistics.
3. Legal Basis for Processing
We process Personal Information under the following legal bases:
Contractual necessity: to provide and operate Lobby9’s services as described in the Terms of Service.
Legitimate interests: to secure and improve services, analyze usage, prevent fraud, and maintain community integrity.
Legal obligations: to comply with laws, regulations, and court orders.
Consent: for optional features such as cookies, personalized ads, or newsletters.
You may withdraw your consent at any time by adjusting your account or browser settings, or by contacting us at support@lobby9.com.
4. Data We Collect and Process
We collect, use, and disclose your Personal Information with your consent or as permitted by law. Consent may be express (e.g., through cookie banners) or implied (e.g., registering for an account).
You can withdraw consent at any time by contacting us at support@lobby9.com. Some withdrawals may limit access to certain features.
This section describes the categories of data we collect, the purpose of processing, and the legal basis under applicable data protection laws.
4.1 Personal Information Definition“Personal Information” means any data relating to an identified or identifiable natural person. This may include, but is not limited to:
Name, username, or nickname
Email address
Billing and payment details (if applicable)
IP address and geolocation
Device identifiers and browser information
Profile customization data (avatars, covers, preferences)
Gameplay data (game library, achievements, playtime, activity history)
Contributions (guides, posts, discussions)
Personal Information does not include aggregated or anonymized data that cannot reasonably be used to identify you.
4.2 Account RegistrationPurpose: To create and manage your Lobby9 account.
Data Collected: Username, email address, registration date, country.
Legal Basis: Contractual necessity.
Purpose: To sync gameplay data from external platforms.
Data Collected: Platform username, account region, library, achievements, playtime, authentication tokens.
Sources: Steam (Steam API), PlayStation (IGDB), Xbox, others.
Legal Basis: Contractual necessity; user consent for visibility preferences.
Purpose: To customize your Lobby9 profile.
Data Collected: Avatars, covers, frames, cosmetic preferences.
Privacy Settings: Public / Friends Only / Private.
Legal Basis: Contractual necessity; user consent for visibility preferences.
When you use Lobby9, we automatically collect technical and usage data, such as:
IP address and location (approximate)
Device type, operating system, browser version, and language
Referring pages and URLs visited within Lobby9
Timestamps, clicks, session duration, navigation paths
Error logs and crash diagnostics
Legal Basis: Legitimate interest (platform functionality, analytics, fraud prevention).
4.6 Leaderboards, XP, and LevelsPurpose: To provide rankings, progression, and community metrics.
Data Collected: Scores, leaderboard positions, points earned, XP level.
Legal Basis: Contractual necessity.
Purpose: To offer personalized guides, insights, and teammate suggestions.
Data Collected: Gameplay history, activity logs, browsing interactions.
Processing: AI models analyze aggregated data but do not make legally binding automated decisions.
Legal Basis: Legitimate interest.
Control: Users can disable AI recommendations in settings.
Purpose: To provide user-level and community-level statistics.
Data Collected: Game comparisons, achievements by rarity, hours played, contributions.
Legal Basis: Legitimate interest.
Purpose: To allow creation of guides, discussions, reviews.
Data Collected: Content, user ID, media uploads, timestamps.
Legal Basis: Legitimate interest.
Purpose: To maintain technical stability and prevent abuse.
Data Collected: IP addresses, device/browser data, security logs.
Processor: Cloudflare (retention up to 124 days).
Legal Basis: Legitimate interest.
Purpose: To monitor traffic, improve services, generate usage reports.
Data Collected: IP, browser info, session behavior.
Processor: Google Analytics.
Legal Basis: Legitimate interest.
Purpose: To deliver relevant ads and measure effectiveness.
Data Collected: IP address, cookie identifiers, device info, browsing activity, approximate location.
Partners: Google AdSense, Google Ad Exchange, Index Exchange, OpenX, Rubicon/Magnite, PubMatic, and other advertising partners (full list available in the Advertising Partners section).
Legal Basis: Consent (via cookie banner) and legitimate interest.
Control: Users may opt-out of targeted ads through browser settings or industry opt-out tools (e.g., YourAdChoices, Google Ads Settings).
5. How We Use Your Information
We use your information to:
Provide and manage your Lobby9 account.
Sync achievements, stats, and progress from linked gaming platforms.
Enable participation in leaderboards, competitions, and community discussions.
Personalize your profile and feed.
Deliver AI-powered recommendations, guides, and insights.
Improve platform functionality, monitor performance, and enhance security.
Display relevant ads if you consent to programmatic advertising.
Comply with legal and regulatory requirements.
Profile Privacy Settings: You control the visibility of your profile:
Public – Visible to all users.
Friends Only – Visible only to approved friends.
Private – Visible only to you.
6. Data Sharing
We do not sell your Personal Information. We may share it in the following cases:
Service Providers: Hosting, analytics, customer support, and security providers (e.g., Cloudflare, Google).
Advertising Partners: If you consent, we may allow programmatic partners such as Google AdSense, PubMatic, Rubicon/Magnite, Teads, OpenX, and Index Exchange to use cookies for targeted advertising.
Legal Requirements: When disclosure is required by law, regulation, or court order.
With Consent: For any other purpose you approve explicitly.
7. Cookies and Tracking Technologies
A cookie is a small piece of data stored on your device that helps us provide and improve Lobby9. Cookies allow us and our partners (for example, advertisers, analytics providers, and social media platforms) to track how you use Lobby9 for purposes including security, analytics, personalization, and advertising.
Types of Cookies We Use
Essential Cookies These are required for the basic operation of Lobby9. They include cookies that allow you to log in, maintain your session, and secure your account.
Functionality Cookies These help us remember your preferences (such as language, themes, or profile customization) and personalize your experience.
Analytics and Performance Cookies These allow us to understand how Lobby9 is used. They collect statistical and technical information (such as page views, time spent, click patterns) to improve platform performance.
Social Media Cookies These enable interactions with content shared on external social media platforms (e.g., “liking” or sharing a guide). Depending on your settings with those networks, your activity may be visible on your profile there.
Advertising and Targeted Advertising Cookies These cookies collect information about your browsing behavior (such as pages visited, ads clicked, and approximate location) to deliver more relevant ads. They may also be used to measure ad performance and prevent the same ad from being shown too often. For details, see the Advertising Partners section.
Shared ID Cookies These cookies store a unique user ID in the Lobby9 domain and may be shared with trusted ad partners to improve audience matching, especially for ads delivered on iOS and MacOS browsers. You may opt out of Shared ID tracking at any time.
Control and Opt-Out
You can manage cookies in your browser settings and choose to disable some or all cookies. Please note that disabling essential cookies may limit your ability to use certain features of Lobby9.
8. Log Files
Like most platforms, we use log files for analytics and security. These may include:
IP addresses
Browser type and version
ISP
Referring/exit pages
Date/time stamps
Session lengths and click counts
We use this data to administer the platform, analyze usage trends, prevent abuse, and improve services.
9. Pixel Tags
We use pixel tags (also known as web beacons, clear GIFs, or tracking pixels), which are small graphic files embedded in our platform or communications. Pixel tags allow us and our trusted third-party partners to collect information about how you interact with Lobby9.
The information collected through pixel tags may include:
Pages you visit within Lobby9
Features you click on or interact with
Time spent on each page
The next page or feature you access
Whether you open or interact with email communications from us
Purpose: Pixel tags are used for analytics, performance monitoring, fraud prevention, and advertising measurement. They help us understand how users engage with Lobby9 and whether ads, content, or emails are effective.
Third Parties: Some pixel tags are placed by our advertising, analytics, or social media partners to track engagement across platforms. Data collected via these pixels may be combined with other information by those partners in accordance with their own privacy policies.
Control: You may restrict the use of pixel tags by disabling images in your email client or adjusting your browser’s privacy settings. However, doing so may reduce the quality of your experience on Lobby9 or limit certain features.
10. Data Retention
Account Deletion: When you delete your account, all data is permanently erased within 30 days. Backups may exist for up to 4 weeks.
Unlinked Gaming Platforms: Related data is deleted unless you opt to retain history.
Analytics Logs: Retained up to 24 months.
Legal Obligations: Some records may be stored longer if required by law.
11. Your Rights
As a data subject under GDPR/CCPA and similar laws, you may:
Access your data
Correct inaccurate data
Request deletion (“Right to be Forgotten”)
Restrict processing
Request portability
Object to processing (including targeted ads)
Withdraw consent
Requests: support@lobby9.com. We respond within 30 days.
12. Data Security
We take the protection of your Personal Information seriously and have implemented technical, organizational, and contractual safeguards to prevent loss, misuse, unauthorized access, disclosure, alteration, or destruction.
Our measures include:
Compliance with ISO 27018 (best practices for Personal Information in the cloud).
Encryption of data in transit and at rest where applicable.
Role-based access control, ensuring only authorized personnel with a legitimate business need can access your Personal Information.
Continuous monitoring and regular security testing of our systems.
If we become aware of a security breach, unauthorized access, or disclosure of Personal Information, we will take immediate action and notify affected users and regulators as required by law.
13. Age Restriction
Lobby9 is not intended for children under 16. If we learn we have collected data from someone under 16 without parental consent, we will delete it promptly.
14. International Data Transfers
Your data may be transferred outside your country, including to the United States or EU. Such transfers are protected by Standard Contractual Clauses (SCCs) or equivalent safeguards.
15. Advertising Partners
We work with trusted partners who may collect data for ads, measurement, and personalization:
Google AdSense / Ad Exchange
Sovrn
Others (full updated list available upon request)
Each partner applies its own privacy policies.
16. Sensitive Personal Information
Lobby9 does not intentionally collect or process any sensitive personal information , including but not limited to:
Government-issued identifiers (e.g., social security numbers, passport numbers)
Racial or ethnic origin
Political opinions
Religious or philosophical beliefs
Health, biometric, or genetic information
Trade union membership
Criminal background or history
In rare cases, we may ask optional questions (e.g., user surveys) that touch on such topics. Participation is voluntary, and you may decline to answer.
We request that you do not share sensitive personal information with us unless strictly necessary. If you do, it will be processed only with your explicit consent or as otherwise required by law.
17. Legal Disclaimer
We make every effort to preserve your privacy. However, we may be required to disclose Personal Information if we have a good-faith belief that such action is necessary to:
Comply with a current judicial proceeding, court order, or other legal process served on Lobby9;
Respond to requests from public or governmental authorities, including authorities outside your country of residence;
Enforce our Terms of Service or other agreements;
Protect the rights, property, or safety of Lobby9, our users, or the public.
Such disclosures will only occur to the extent permitted or required by applicable law.
18. Online Accounts and Services
If you choose to participate in or register for any of our services — including, but not limited to, user accounts, discussion forums, commenting features, surveys, newsletters, or other interactive content — we may request and process certain Personal Information such as your:
Name and username
Email address
Login details (including password or authentication provider)
Other contact details you may provide
This information is processed in accordance with this Privacy Policy and is necessary to deliver the services you have registered for.
We may also use this information to:
Improve the functionality and security of Lobby9 services;
Prevent abuse, fraud, or unauthorized use of accounts;
Personalize your experience across different Lobby9 features.
Unsubscribing and Account Deletion
You may opt out of newsletters or other communications at any time by using the “unsubscribe” link included in such emails.
For account deletion requests (e.g., discussion/forum accounts), you can contact us directly at support@lobby9.com.
Please note that if you have multiple registered emails or accounts, you must unsubscribe or delete each individually.
19. Contact Information
For any privacy inquiries, requests, or complaints, contact:
Email: support@lobby9.com
Address: Lobby9 Technologies, Kyiv, Ukraine