Privacy policy

Last updated: [date]. Highlighted passages must be completed; have this document reviewed by a lawyer before going live.

Data controller

[Company name], [address in Hong Kong], [registration number]. Contact: [email address].

The General Data Protection Regulation (GDPR) applies to users located in the European Union, wherever the company is established.

Data we collect

• Account: username, password (stored only in encrypted, irreversible form), activation keys used, access rights and remaining usage time.
• Connection and usage log: date and type of event (login, failed login, key activation, start and end of analysis), truncated IP address (last octet removed), browser and system type.
• Analysis results: for each analysed cargo, the merchant, the cargo size, the recognised sound group and, if you provide it, the item actually found; and the layout of the merchant's cargos. This data contains no image or sound; it is used to improve results for all players.
• Payments: plan purchased, amount, date, PayPal order and transaction numbers, the email address of your PayPal account. Payment is processed by PayPal: we never receive your card details.
• Session cookie: a single technical cookie, needed to stay logged in. No advertising or analytics cookies.

What we do not collect: the game image and sound shared during analysis are processed only in your browser. They are never sent to our servers or recorded; only the results described above are.

Purposes and legal bases

• Providing the service and managing your access (performance of the contract).
• Collecting payments, handling refunds and disputes, keeping accounts (performance of the contract, legal obligation).
• Improving the accuracy of the service from analysis results (legitimate interest).
• Preventing fraud, account sharing and abuse, securing the service (legitimate interest).

Retention

• Connection and usage log: 90 days, then deleted automatically.
• Analysis results: as long as the service is operated; deleted with the account on request.
• Sessions: deleted after 30 days of inactivity.
• Payments: [period required by accounting obligations].
• Account: until deleted, on request or after [duration] of inactivity.

Recipients and hosting

Data is hosted by [hosting provider, country]. It is neither sold nor shared for commercial purposes. [If hosted outside the EU: describe the safeguards for the transfer (standard contractual clauses…)].

Payments are processed by PayPal, which acts as a controller for its own purposes (see its privacy policy).

Your rights

You can request access to your data, its correction, deletion or portability, or object to processing, by writing to [email address]. You can also contact the data protection authority of your country.