MCDM

Draw Steel Codex Privacy Policy

Last Modified on December 12, 2025

We are MCDM (“MCDM”, “we”, or “us”). This Privacy Policy applies to the “Draw Steel Codex” online platform and related software applications and content (we’ll refer to this as the “Service”).

By using the Service, you agree to the terms of this Privacy Policy. Please read our Terms of Service as well, for general guidance about your use of the Service.

What’s in this Privacy Policy?
In this Privacy Policy, we will explain what personal information we collect about you and how we use and share that information. We’ll also explain your rights and choices about the personal information that we collect. 

What Information Do We Collect?
We collect and process different types of personal data depending on how you interact with our Service. Here’s an overview of the information we collect:

Account and Profile Information
When you create or update an account with us, or connect a third-party account (such as a Steam, Patreon, or other third-party sign-in service that we make available), we collect certain information to manage your account, including your email address.

We use this information to create and manage your user account on the Service.

Service Usage Information
As you use our Service, we may automatically collect information about your interactions, including your login times and frequency, as well as your activities on the Service.

We use this information to provide core Service functionality, to analyze user behavior and preferences, and to correct errors and make updates to the Service.

Device and Behavior Information
We may automatically collect certain technical and analytic information from you and your device when you use our Service, including your device type, model, operating system version, and web browser.

We use this information to ensure Service compatibility and performance, and to fix errors and make updates to the Service.

Transaction Information
When you make purchases or other transactions through our Service, we may collect certain payment and transaction information necessary to process that transaction (or to allow our third party payment processor to do so). This may include your payment method (last 4 digits only) and other required information. 

Please note that we do not store complete payment card information - this is handled by our secure payment processors.

We use this information to process transactions and subscriptions on the Service.

User Communication and Content
If you choose to use communication or content sharing features on the Service, including sharing any game content, interacting with other users, or publicly posting on the Service’s forums and other communication and discussion channels, we may collect any content and communications that you transmit to us or other users through the Service.

We use this information to enable core Service features, such as content sharing and user-to-user interactions.

How Do We Share Your Information?

  • Technical Service Providers: We may share certain personal data with trusted service providers who help us operate and improve our Service, including our software developers and hosting providers, email newsletter providers, analytics service providers, and others.

  • Platform Partners: We share data with third-party platform partners to allow for third-party sign-in and account creation.

  • Payment Processors: We share data with our third-party payment processors partners to process payments and transactions.

  • Social Platforms: When you utilize social functionality of the Service, we share data with social networks and other third parties to enable sharing of content to social platforms.

How long do we keep your data?
We only keep your personal data as long as it’s required to provide you with the Service. Sometimes a longer period might be required by law. 

After that, we will delete your personal data within a reasonable time.

Please note that we may retain some data, if necessary to: 

  • resolve disputes, 

  • enforce our user agreements, 

  • follow any technical and legal requirements related to the Service.

Children’s privacy rights
We don’t knowingly collect any personal data from children under the age of 13. We also don’t knowingly allow them to create accounts, sign up for newsletters, make purchases, or use the Service. 

We may also limit our personal data processing for EU users between 13 and 16.

We take children’s privacy seriously and encourage parents to play an active role in their children’s online experience. If you have any concerns about your child’s personal data, please contact us at hello@mcdmproductions.com.

“Do Not Track” Signals
Because there’s not yet a consensus on how companies should respond to web browser-based or other “do not track” mechanisms yet, we do not respond to web browser-based do not track signals.

Your Rights and Choices
We believe in giving users control over their personal data. This section outlines your rights (some of which may be based on where you reside) and how to exercise them.

All Users:
Regardless of your location, you have the right to:

  • Request deletion of your personal data

  • Opt out of marketing communications

  • Access and update your account information

  • Control cookie settings through your browser

  • Manage notification preferences

If you would like to exercise any of those rights, please email us at hello@mcdmproductions.com. We may ask for additional info to verify that you’re the owner of that data. 

EU and UK Residents:
We are regulated under the General Data Protection Regulation (GDPR), which applies across the European Union. We are responsible as a controller of personal data for GDPR purposes.

Additionally, UK residents have similar rights to the above under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. 

Legal Basis for processing your personal data:
In accordance with the General Data Protection Regulation (GDPR) and UK data protection law, we process your personal data based on the following legal grounds:

  • Consent. For personal data collected when you provide it to us directly, such as when you sign up for an email list or either create an account directly or connect a third-party account with the Service, we may rely on your explicit consent. In these situations, you have the right to withdraw your consent at any time (see “How to Contact Us” below).

  • Contractual Obligations. We process specific sets of your data to fulfill our contractual obligations to you. This encompasses actions like account maintenance, operating payment processing on the Service, providing Service communications and content sharing functionality, and general Service operations and delivery.

  • Legitimate Interests. For certain data processing activities, we rely on our legitimate business interests. This includes activities like Service error correction, updates, and improvements, and ensuring a safe user environment.

  • Legal Compliance. There are instances where we’re legally mandated to process your data. This could be due to regulatory requirements, legal requests, or for the prevention of fraud and illegal activities.

Your rights under GDPR and UK GDPR:
Under the GDPR, EU and UK residents have several important rights: 

  • You can request a copy of your personal data

  • You can ask us to correct that personal data, delete it, or request that we use it only for certain purposes. 

  • If you’ve consented to our processing, you can change your mind and ask us to stop using your personal data. For example, you can unsubscribe from our mailing list at any time – just click the link in each marketing email. 

  • In some circumstances, you can ask us not to use automated processing or profiling about you.

If you would like to exercise any of those rights, please email us at hello@mcdmproductions.com. We may ask for additional info to verify that you’re the owner of that data. 

Also, in some cases where the law requires it, we may not be able to help with the above requests.

US Residents - State-Specific Privacy Rights:
For residents of states with comprehensive privacy laws (including California, Virginia, Colorado, Connecticut, Utah, Texas, and Oregon), you may have additional rights, depending on your state’s law. These include:

Access and Control Rights

  • Request a copy of your personal data

  • Correct inaccurate personal information

  • Request deletion of your personal data

  • Receive your data in a portable format

Right to Opt Out of:

  • Targeted advertising

  • Sale of personal data

  • Profiling and automated decision-making

Important Notes
In addition to the above rights, we also agree to the following with respect to US users’ personal data:

  • We will not discriminate against you for exercising your rights

  • We do not sell personal data as defined by state privacy laws

  • We do not engage in automated decision-making that produces legal effects

  • We protect sensitive personal data with additional safeguards

California Resident Rights
In addition to the above rights, for California residents under the California Consumer Privacy Act (CCPA), you have the right to designate an authorized agent to make requests on your behalf.

If you would like to exercise any of those rights, please email us at hello@mcdmproductions.com. We may ask for additional info to verify that you’re the owner of that data. 

Canadian Residents:
For Canadian residents, we are committed to protecting your personal information in accordance with the Personal Information Protection and Electronic Documents Act (PIPEDA). PIPEDA’s ten fair information principles include accountability, identifying purposes, consent, limiting collection, limiting use, disclosure and retention, accuracy, safeguards, openness, individual access, and challenging compliance.

Under PIPEDA, you have certain rights regarding your personal information. These rights include:

  • Right to Access: You have the right to access the personal information we hold about you and request a copy of that information.

  • Right to Rectification: If you believe that any of the personal information we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it.

  • Right to Withdraw Consent: If you have previously provided your consent for the collection, use, or disclosure of your personal information, you have the right to withdraw that consent at any time. Please note that withdrawing your consent may affect our ability to provide certain services to you.

  • Right to Object: You have the right to object to the collection, use, or disclosure of your personal information for certain purposes, such as direct marketing.

  • Right to Erasure: In certain circumstances, you have the right to request the deletion or removal of your personal information from our records.

  • Right to Data Portability: You have the right to request a copy of your personal information in a structured, commonly used, and machine-readable format, and to transmit that information to another organization.

If you would like to exercise any of those rights, please email us at hello@mcdmproductions.com. We will respond to your request or inquiry within a reasonable timeframe and in accordance with applicable laws. We may ask for additional info to verify that you’re the owner of that data.

Please note that there may be limitations on these rights as set out in PIPEDA or other applicable laws.

International Data Transfers
Our headquarters is in the United States. 

No matter where you live, by using the Service you consent to the processing and transfer of your personal data in and to the United States. This processing will be under the privacy policies of third parties that we share personal data with. 

If you would like more information, please contact us (see “How to contact us” below).

Security Measures
We have taken steps and put security measures in place to prevent the accidental loss or misuse of personal data. 

For example, we limit access to those who have a genuine business need. Those processing your information will do so only in an authorized manner. 

We have procedures in place to deal with any suspected data security breach. We’ll notify you and any applicable regulator of a suspected data security breach when legally required.

Resolving Disputes
We hope that we can resolve any questions or concerns you raise about our use of your personal data. 

Please contact us at hello@mcdmproductions.com to let us know if you have questions or concerns. We will do our best to resolve the issue.

For EU residents, the GDPR also gives you right to lodge a complaint with a supervisory authority. You may do this in the EEA state where you live, work, or where any alleged infringement occurred. 

Changes to This Privacy Policy
We last updated this Privacy Policy on December 12, 2025

We may make further updates from time to time, which will be reflected in the latest version posted on the Service. For major changes, we will post a message on the Service and send you a message through your account on the Service about the change.

How to Contact Us
Please contact us if you have any questions about this Privacy Policy or your personal data.

You can do so using the following contact info: