DRAFT – have this reviewed before launch (GDPR; for users in Japan and the US possibly APPI and
US state law). Placeholders in [brackets].
Privacy Policy
1. Controller
[Provider as stated in the imprint], email: team@bangouro.com
2. What we process
- Account: email address, password (stored only as a hash by our sign-in provider), time of registration and confirmation.
- Beta applications: email address, the name you give us, how you play, favourite leader and your message – only to review your application and email you your beta key. Deleted [6] months after the closed beta ends, or earlier on request.
- Beta access: the beta key you redeemed and when.
- Games: time, decklists, bot version, every decision, the result, and whether you used take-backs, the advisor or a winnable start. This powers your match history, statistics and reports.
- Analyses: which game you analysed and when (for the monthly allowance).
- Share links: a random key per shared game; the shared page does not name you.
- Technical data: IP address and time in server logs, only for security and troubleshooting, deleted after [14] days. Cookies only for signing in (strictly necessary). No tracking, no advertising.
3. Purposes and legal bases
- Providing the game, your account, history and reports: contract (Art. 6(1)(b) GDPR).
- Reviewing beta applications and emailing beta keys: your consent in the application form (Art. 6(1)(a) GDPR), which you can withdraw at any time by email.
- Improving and evaluating our bots with pseudonymised games (without any link to your account): legitimate interest (Art. 6(1)(f) GDPR). You can object at any time (team@bangouro.com); deleting your account removes the link to you.
- Security of the service: legitimate interest (Art. 6(1)(f) GDPR).
4. Service providers (processors)
- Supabase Inc. – sign-in, database and storage, hosted in the EU ([region, e.g. Frankfurt]).
- Hetzner Online GmbH, Germany – servers for the game and this website.
- mailbox.org (Heinlein Hosting GmbH), Germany – sending and receiving email.
- [Payment provider for Premium, once introduced.]
5. Retention
We keep account and game data as long as your account exists. When you delete your account, we delete your email address, history and share links; pseudonymised games without any link to you may be kept to train our bots. [Add retention duties for payment data.]
6. Your rights
Access, rectification, erasure, restriction, data portability and objection (Art. 15–21 GDPR) by email to team@bangouro.com, and the right to lodge a complaint with a data protection authority.