Privacy Policy
Last Updated: October 2026
1. Who We Are (The Data Controller)
Bare Metal Gaming ([www.baremetalgaming.com](https://www.baremetalgaming.com)) is a trading name of The WiFi and Network People Ltd, a company registered in England and Wales under company number 17115691, with its registered office at 27 Pointers Close, London, E14 3AP, United Kingdom ("we", "us", "our").
For the purposes of the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the EU General Data Protection Regulation (EU GDPR), The WiFi and Network People Ltd is the Data Controller of the personal data you provide to us as a customer or website visitor.
If you have any questions about this Privacy Policy or how we handle your data, you can contact us at: [Insert Contact Email].
2. Our Role: Data Controller vs. Data Processor
Because we provide Platform as a Service (PaaS) virtual private servers (vPCs) managed via the CubeCoders AMP web interface, we handle two distinct categories of data:
2.1. Customer Account & Website Data (We are the Data Controller): We determine how and why your personal data is processed when you fill out our hardware advice forms, create an account, subscribe to a vPC tier (Ingot, Anvil, or Forge Series), or contact us for support.
2.2. In-Game & Player Data Hosted on Your vPC (You are the Data Controller): Once your vPC is provisioned and you deploy third-party game servers via your AMP panel, your game instances may log data belonging to the players who join your servers (such as player IP addresses, SteamIDs, Xbox/Microsoft UUIDs, or in-game chat logs).
Bare Metal Gaming acts strictly as a neutral infrastructure provider (Data Processor) regarding your server files.
We do not monitor, access, or harvest player data inside your game instances except where strictly necessary to resolve a technical support ticket at your request or investigate a breach of our Acceptable Use Policy.
You are responsible for managing your gaming community and player data lawfully.
3. The Personal Data We Collect
We collect and process only the data necessary to advise you, provision your server, and manage your billing:
Identity & Contact Data: Your name, email address, and Discord handle (collected when you submit our "Get Hardware Advice" form, open a support ticket, or place an order).
Pre-Sales & Configuration Data: Information you share with us regarding your target games, modpacks, and player counts so we can recommend the appropriate vPC tier.
Billing & Transaction Data: Your billing address, subscription history, invoices, and payment status. (Note: We do not store your full credit/debit card numbers on our servers; all payment card details are processed directly by our third-party payment processors).
Technical & AMP Access Data: Your IP address, browser type, login timestamps for your AMP control panel, and server resource usage metrics (CPU, RAM, disk space, and active instance counts).
4. How We Use Your Data and Our Lawful Basis
Under UK and EU data protection law, we must have a valid lawful basis to process your personal data. We rely on the following:
Purpose of ProcessingTypes of Data UsedLawful Basis (UK & EU GDPR)
Responding to "Get Hardware Advice" inquiries and pre-sales questions.
Name, Discord handle, email address, target game/modpack notes.
Legitimate Interests (or steps taken at your request prior to entering into a contract).Manual provisioning of your vPC, setting up your AMP panel, and delivering login credentials.Name, email address, Discord handle, subscription tier.Performance of a Contract (Article 6(1)(b)).Managing subscriptions, billing, collecting payments, and enforcing our 90-day minimum tie-in period.Identity, contact, and billing/transaction data.Performance of a Contract (Article 6(1)(b)).Accounting, tax compliance, and statutory record-keeping for UK HMRC.Invoices, transaction history, billing name and address.Legal Obligation (Article 6(1)(c)).Network security, DDoS mitigation, and enforcing our Acceptable Use Policy.IP addresses, network traffic logs, AMP access logs.Legitimate Interests (protecting our infrastructure and other customers).
5. Who We Share Your Data With (Sub-Processors)
We never sell your personal data to third parties. We only share relevant data with trusted service providers ("sub-processors") that are essential to delivering our Services:
Third-Party EU Data Center Providers: Your vPC and AMP environment are hosted within secure, enterprise-grade data centers located in the European Union.
Payment Processors & Banking Partners: Used to process your monthly or quarterly subscription payments, handle currency conversion, and issue invoices.
Communication & Support Platforms: If you request support or hardware advice via Discord or email, your messages pass through those respective platforms.
Legal & Regulatory Authorities: We may disclose information if required by UK or EU law, court order, or tax authorities (such as HMRC).
6. International Data Transfers (UK & EEA)
Because The WiFi and Network People Ltd is registered in the United Kingdom and our server infrastructure is located within the European Union (European Economic Area):
UK to EU Transfers: The UK government recognizes the European Economic Area (EEA) as providing an adequate level of data protection.
EU to UK Transfers: The European Commission has adopted an Adequacy Decision for the United Kingdom, meaning personal data can flow freely and securely between the EU and the UK without requiring additional complex transfer mechanisms.
If any third-party software tool we use transfers data outside the UK or EEA (for example, to the United States), we ensure it is protected by approved Standard Contractual Clauses (SCCs) and the UK International Data Transfer Addendum, or certified under the UK/EU-US Data Privacy Framework.
7. Data Retention (How Long We Keep Your Data)
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected:
Hardware Advice Inquiries (Non-Customers): If you fill out our website form but do not purchase a server, we delete your inquiry and contact details after 12 months.
Active Server Data & World Saves: Upon cancellation or termination of your vPC subscription (or if an invoice remains unpaid for more than 7 days past its due date), your virtual server and all associated game instances, world saves, and files are permanently wiped within 7 days.
Billing & Tax Records: Under UK tax and corporate law (HMRC regulations), we are legally required to retain invoices, payment records, and basic customer transaction details for 6 years plus the current financial year.
8. Your Data Protection Rights (UK & EU Residents)
Under the UK GDPR and EU GDPR, you have the following rights regarding your personal data:
Right of Access: Request a copy of the personal data we hold about you.
Right to Rectification: Request that we correct any inaccurate or incomplete personal data.
Right to Erasure ("Right to be Forgotten"): Request that we delete your personal data where there is no compelling legal reason for us to keep it (note that we cannot delete statutory billing/tax records before the 6-year HMRC retention period expires, nor can we erase active account billing obligations during your 90-day tie-in period).
Right to Restrict Processing: Request that we suspend the processing of your personal data in specific scenarios.
Right to Data Portability: Request the transfer of your personal data to you or a third party in a structured, machine-readable format.
Right to Object: Object to our processing of your personal data where we are relying on a "legitimate interest."
9. How to Exercise Your Rights or Make a Complaint
To exercise any of your rights, please contact us at [Insert Contact Email]. We will respond to all legitimate requests within one (1) month.
Supervisory Authorities:
UK Residents: You have the right to lodge a complaint at any time with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).
EU Residents: You have the right to lodge a complaint with your local national Data Protection Authority (DPA) in the EU Member State where you reside.
(We would, however, appreciate the chance to deal with your concerns directly before you approach a regulator, so please contact us in the first instance).
10. Cookies
Our website uses minimal cookies to ensure basic functionality and security. For detailed information on the cookies we use and how to manage your preferences, please refer to our separate Cookie Policy linked in our website footer.
06 / Legal