Privacy Policy

1. Who is responsible

The controller of your personal data is Serhii Romanenko, an individual entrepreneur (FOP) registered in Ukraine on 13 July 2020, based in Odesa, Ukraine, the publisher of Dareboard. Contact: privacy@dareboard.app.

For every privacy question or request write to privacy@dareboard.app. For general questions: support@dareboard.app.

We have not appointed a representative in the EU or the UK. You can contact us directly at privacy@dareboard.app about any privacy matter, and you can complain to the data protection authority in your country. We have not appointed a data protection officer, as none is required for our size and kind of processing.

2. What we collect

Account and sign-in. You sign in with Apple or Google; there is no password. We hold the stable identifier that Apple or Google gives us for you, the sign-in method, the e-mail address if the provider shares it (Apple may give a private relay address), the time you were last active and a technical identifier of the app installation on your device. For Sign in with Apple we also keep the token needed to revoke the sign-in when you delete your account. You can try part of the app as a guest, without signing in.

Subscription and purchases. Apple and Google take every payment. We receive only the store's purchase record: a purchase reference, the plan (week, month, year or forever), its status and dates, including the free trial. We never receive your card or payment details. Our server also keeps a history of purchase and subscription events (a trial starting or converting, a renewal, an expiry, a refund: plan, store, status and date), kept with the purchase record, which loses any link to you when your account is deleted, and adds them up into totals so we can see how the app is doing. It also sends anonymous trial counts (converted or lapsed; store, plan and environment only, no account ID) to PostHog in the EU. These counts are sent even if you turn off usage counts in the app, because they cannot be tied to you.

Age confirmation. The age check runs on your device. We keep only the fact that you passed it. Your date of birth, or the age range your phone shares, is used once on the device and is not sent to us.

Crash reports and usage counts. Both are on by default, and you can turn either off at any time in the app's settings; turning one off stops it at once, and the usage counter also deletes the identifier it stored. We receive technical data about your device and about crashes (Sentry, EU) and counts of how features are used (PostHog, EU). Inside the EEA (and when we cannot tell where you are) the usage counter keeps no identifier on your device: it uses a new random one each time you open the app and stores nothing. Elsewhere, the UK included, it keeps one random anonymous identifier on the device so that we can count returning users; it is never linked to your account, name or e-mail address. Crash reports carry no name or e-mail address and do not track sessions; the crash reporter's SDK keeps a technical installation identifier on your device, which we strip from the reports.

Server logs. Our servers record technical data about each request, including the IP address, the time and the result, to keep the service secure and to find faults. Logs are kept for 30 days and then deleted.

The website. The website dareboard.app is hosted on Cloudflare Pages. When you visit it, Cloudflare processes your IP address and request data to deliver the pages and protect the site, and keeps its own logs under its own policy. The site sets no cookies and uses no local storage, loads no third-party fonts, and has no sign-in or forms. Cloudflare Web Analytics counts visits in aggregate: a small script from Cloudflare records page views, the page, the referring site, country, browser and device type, and page load performance. It sets no cookies, does not fingerprint you or build a profile of you across sites, and we see only aggregated counts. E-mails you send to privacy@dareboard.app pass through Cloudflare Email Routing, which forwards them, and are stored in the publisher's Gmail mailbox (Google).

Notifications. The first release sends no push notifications. If we add news or offers later, we will ask for your consent first and keep a push token for that purpose only.

3. The players you type in, and your own tasks

When you host a game you may type in the names and genders of the other players, whom they may be paired with, how many times each has owned up in Never Have I Ever…, and your own tasks. This information is shown on the shared screen, so everyone present can read it. In an adult category it can reveal details of a person's private life, which the law treats as sensitive.

The players' details stay on the host's phone and are never sent to us. Players being set up are kept until the game starts (then they belong to that game), until the host removes them, or until the host signs out or deletes the account. A started game's details are deleted when it ends or when you decline to resume it. Because we never receive them, we cannot look them up or correct them for you; the host controls them.

Your own tasks are different. Writing them needs an account, and we keep them on our service, linked to your account, so they are the same on every device you sign in on; the app also keeps a copy on your phone for playing offline. You can change or delete them in the app at any time. Signing out removes the copy from the phone, and deleting your account erases them from our service.

Tell the players before you start that their names are shown on the shared screen. A player can ask the host to remove them at any time.

4. What we do not collect

• No payment card data.
• No photos, video or audio of anyone: tasks are text only.
• No precise location, contacts or advertising identifier.
• Nothing about a player's name or the category played when you use the share button at the end of a game: the shared text names the game, the awards and a link to the app.

5. Why we use it, and on what basis

• Providing your account and sign-in: performance of our contract with you (Art. 6(1)(b) GDPR).
• Keeping your own tasks and syncing them between your devices: contract (Art. 6(1)(b)).
• Selling and honouring your subscription and purchase: contract (Art. 6(1)(b)) while the account exists; keeping purchase records afterwards: legal obligation under tax and accounting law (Art. 6(1)(c)).
• Checking your age before adult content: legal obligation where the law requires the check (Art. 6(1)(c)); otherwise our legitimate interest in keeping adult content from minors (Art. 6(1)(f)).
• Crash reports and usage counts: our legitimate interest in keeping the app stable and in understanding, in aggregate, how it is used (Art. 6(1)(f)); they are on by default, and you can object at any time by turning them off in the app's settings.
• Server logs, server error reports (Sentry, sent without IP addresses or request contents), security and abuse prevention: our legitimate interest in running a secure service (Art. 6(1)(f)).
• Website visit counts (Cloudflare Web Analytics, no cookies): our legitimate interest in knowing how the website is used and keeping it fast (Art. 6(1)(f)).
• Answering your requests and keeping records of them: legal obligation and our legitimate interest (Art. 6(1)(c), (f)).
• Player details typed on the host's device: processed only on that device, by the host, for the host's own game — a purely personal activity outside the GDPR (Art. 2(2)(c)). We never receive them, so we are not their controller.

Where we rely on legitimate interests you may object; see section 9.

6. Who receives your data

We use service providers who process data on our behalf, each under a data processing agreement:

• Amazon Web Services, Frankfurt (eu-central-1): hosting of the service.
• Sentry, EU region: error alerts of the service and crash reports of the app (for the app: on by default, can be turned off in the app).
• PostHog, EU cloud: usage counts (on by default, can be turned off in the app) and anonymous purchase counts sent by our server (not linked to you, and not affected by the app switch).
• Cloudflare: hosting and delivery of the website, anonymous visit counts (Cloudflare Web Analytics), and forwarding of e-mails sent to our address.
• Google (Gmail): the mailbox where e-mails sent to privacy@dareboard.app arrive.

Apple and Google act as independent controllers for Sign in with Apple, Google Sign-In, App Store and Google Play billing and the age signals of your phone. Their own privacy policies apply to what they do.

We may disclose data if a law or a binding order of a public authority requires it. We do not sell your personal data, we do not share it for advertising, and we do not use it for automated decisions with legal effect.

7. Where your data is held and transfers

The service runs in the AWS region in Frankfurt, Germany, and Sentry and PostHog are used in their EU regions. The publisher works from Ukraine, which the EU has not found to provide adequate protection; when we access data of EU/EEA, UK or Swiss users from there, or when a provider moves data outside the EEA, we rely on the EU Standard Contractual Clauses (and the UK addendum where needed), on the EU-US Data Privacy Framework for certified US providers, or on another safeguard the law recognises. You can ask us for a copy of the safeguard at privacy@dareboard.app.

8. How long we keep it

• Account: until you delete it in the app, or automatically after 24 months without using the app while signed in; erased within 30 days of that day.
• Players' details: on the host's device only. Players being set up are kept until the game starts, the host removes them, or the host signs out or deletes the account; a started game's details are deleted when it ends.
• Your own tasks: until you delete them or your account.
• Purchase records: kept without any link to your account for 3 years, as Ukrainian tax and accounting law requires, then erased.
• Server logs: 30 days.
• Backups: erased data is never restored into the live service, and backups holding it expire within one month of the erasure.
• Crash reports and usage counts: up to 90 days at Sentry and 12 months at PostHog; they carry no name or e-mail address.

9. Your rights

Depending on where you live (for example under the GDPR, the UK GDPR, the Swiss FADP or Ukrainian law), you may ask us for access to your data or a copy of it, correction, erasure, restriction, portability, and to object to processing based on legitimate interests; you may also withdraw a consent at any time. Withdrawing a consent does not affect what was done before.

Write to privacy@dareboard.app. We may ask you to prove who you are. We answer within one month; where the law allows, we may extend this by two months and will tell you within the first month. Requests are free unless they are clearly unfounded or excessive.

To delete your account, go to Account → Delete account in the app. Without the app, follow the steps at https://dareboard.app/delete-account. Deleting the account does not cancel a subscription: cancel it in the App Store or Google Play.

You may complain to the data protection authority of your country or place of work or residence. In Ukraine this is the Ukrainian Parliament Commissioner for Human Rights. Residents of California and other US states with privacy laws have the same rights of access, deletion and correction; we do not sell or share data for advertising.

10. Age

Dareboard is for adults. Where your phone's own age signal says you are under 18, or you do not confirm that you are 18 or older, the app does not open. We do not knowingly collect data from anyone under 18. If you believe a minor has an account, write to privacy@dareboard.app and we will delete it.

11. Security and breaches

We protect data in transit (TLS) and at rest and limit who can reach it. If a personal-data breach puts people at risk, we notify the supervisory authority within 72 hours where the law requires it and tell the people affected without undue delay.

12. Changes

If we change this policy in a way that matters, we will update the date at the top and, where the law requires, tell you in the app before the change applies. Earlier versions are available on request.