Privacy Policy

1. Introduction

SafeNet ("we", "our", or "us") is committed to protecting your privacy and complying with applicable data protection laws including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), and other relevant regulations.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Discord bot. For detailed information about data processing, please also refer to our Data Processing Agreement.

Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not use SafeNet.

2. Owner & Administrator

SafeNet is a security and moderation tool operated by:
RJO Innovation & Consultancy (“RJO I&C”)

Contact may be established through the internal support system provided in the bot, or through the official Discord community of RJO I&C.

3. Types of Data We Collect

SafeNet collects and processes the following categories of personal data:

3.1 Automatically Collected Data

• Discord User IDs and usernames: Unique Discord identifiers
• Server IDs: Discord server (guild) identification numbers
• Server membership information: Your participation in Discord servers using SafeNet
• Message history: When necessary for moderation purposes
• IP address information: For anti-VPN detection and security purposes
• User behavior analytics: Activity patterns for security assessment
• Timestamps: Event timestamps for security events and verification attempts
• Server Configuration: Bot settings and preferences configured by server administrators

3.2 User-Provided Data

• Support Inquiries: Information you provide when contacting our support team
• Verification Information: Data submitted during verification processes

Note: We do not collect sensitive personal data such as financial information, health data, or racial/ethnic origin without explicit consent.

4. Data Retention & Legal Exceptions to Erasure

SafeNet retains personal data only as long as necessary to fulfill the purposes stated in this Privacy Policy. However, under GDPR Article 17(3)(b) and (e), the Right to be Forgotten has important exceptions that SafeNet lawfully applies:

4.1 GDPR Exceptions to Erasure

Erasure does not apply when processing is necessary for:

• Security, fraud prevention & abuse mitigation: Preventing ban evasion, detecting malicious actors, and maintaining community safety
• Legal obligations or legal claims: Establishment, exercise, or defense of legal claims as per Article 17(3)(e)

4.2 What SafeNet Deletes Upon Erasure Request

When you request deletion, SafeNet immediately erases:

• Full user profiles and personal metadata
• Discord IDs and usernames (in clear text)
• IP addresses in raw form (except where legally required)
• Analytics and enrichment data

4.3 What SafeNet Lawfully Retains for Security

For the legitimate interests of community safety and fraud prevention (Article 6(1)(f)), SafeNet retains only minimal, security-critical data:

• Hashed identifiers (salted, irreversible): Cannot be reverse-engineered to identify you
• Pseudonymised risk flags: e.g., "Previously malicious" – without personal profile data
• Security event records: Timestamp, event type, and outcome only (no personal data)
• Abuse-prevention fingerprints: Non-reversible patterns used only to detect coordinated harm

These retained records are:

• Pseudonymised and cannot directly identify you
• Proportional to SafeNet's security mission
• Retained only as long as the security threat exists
• Not used for profiling, marketing, or any purpose beyond fraud/abuse prevention

4.4 Transparency on Retention

SafeNet maintains transparency about this approach:

• We do NOT claim "never to delete data"
• We DO erase personal-identifiable information where possible
• We RETAIN only minimal security-critical identifiers
• This distinction is GDPR-compliant under established case law and EDPB guidance

5. Your Data Subject Rights

Under applicable data protection laws (including GDPR, CCPA, and other regulations), you have the following rights:

• Right of Access: Request access to your personal data processed by SafeNet
• Right to Rectification: Correct inaccurate or incomplete personal data
• Right to Erasure (Right to be Forgotten): Request deletion of your personal data (subject to legal exceptions for security and fraud prevention as described in Section 4)
• Right to Data Portability: Receive your personal data in a structured, machine-readable format
• Right to Object: Object to processing for direct marketing and certain other purposes
• Right to Restrict Processing: Request limitation of how your data is used

5.1 How to Exercise Your Rights

To exercise any of these rights, contact us at:

• Email: info@rjo-web.nl
• Discord: Join our support server

We will verify your identity and respond within 30 days (or within the timeframe required by applicable law).

5.2 Data Access

Only authorized RJO Innovation & Consultancy staff have access to stored data. We implement strict access controls and security measures to protect your information.

6. Legal Basis for Processing

SafeNet processes personal data based on the following legal grounds:

• Consent: Where you have explicitly agreed to data processing by using SafeNet's services
• Legitimate Interests (GDPR Art. 6(1)(f)): To maintain server security, protect against abuse, prevent fraud, spam, harassment, and other harmful behavior on Discord servers
• Legal Obligation: Where required by law or court order
• Performance of Contract: To provide SafeNet services to server administrators

Important Note: By using SafeNet or servers that use SafeNet, you acknowledge and agree to this data processing. If you do not agree, please do not use servers that utilize SafeNet.

7. Data Sharing and Third Parties

SafeNet does not sell personal data to third parties. We may share data with:

• Discord Inc.: As required for bot functionality
• Service providers and hosting partners: Under data processing agreements
• Law enforcement: When legally required by valid legal order
• Server administrators: For moderation purposes

All third parties are subject to strict confidentiality agreements and data protection obligations.

8. Data Security

SafeNet implements comprehensive security measures to protect personal data:

• End-to-end encryption for data in transit
• Industry-standard encryption at rest
• Regular security audits and penetration testing
• Access controls and authentication mechanisms
• Employee data protection training
• Incident response procedures

9. Data Storage Location

SafeNet's services and data infrastructure are physically located and operated in the Netherlands. All personal data processed by SafeNet is stored on servers situated within the Netherlands.

This ensures that your data benefits from:

• GDPR protection as an EU member state
• Dutch data protection authority oversight
• Compliance with Dutch cybersecurity standards
• EU data residency requirements

By storing data exclusively in the Netherlands, SafeNet minimizes cross-border data transfers and ensures strong legal protections under EU data protection law.

10. International Data Transfers

Because SafeNet's primary data storage is in the Netherlands (an EU member state), most personal data does not require international transfers. However, in limited cases where data must be transferred outside the EU/EEA for technical or legal reasons, SafeNet ensures such transfers comply with applicable data protection laws through:

• Standard Contractual Clauses (SCCs)
• Adequacy decisions by relevant authorities
• Explicit user consent where required

11. Third-Party Services

SafeNet operates on Discord's platform and is subject to Discord's Terms of Service and Privacy Policy. We recommend reviewing Discord's policies:

• Discord Terms of Service
• Discord Privacy Policy

12. Children's Privacy

SafeNet does not knowingly collect information from children under 13 years of age (or the minimum age required in your jurisdiction). If you believe we have collected information from a child, please contact us immediately so we can delete such information.

13. Changes to This Privacy Policy

RJO I&C may update this Privacy Policy from time to time. We will notify you of any material changes by updating the "Last Updated" date and, where appropriate, by providing additional notice through the Bot or our website.

Your continued use of SafeNet after changes are posted constitutes acceptance of the updated Privacy Policy.

14. Contact Information

For questions about this Privacy Policy or to exercise your data subject rights, contact:

We will respond to your inquiry within 30 days (or within the timeframe required by applicable law).

15. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Netherlands. Any disputes arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the Dutch courts.