Privacy policy

1. Controller

Maël Picornell
c/o POSTFLEX PFX-384-194
Emsdettener Straße 10
48268 Greven
Germany

Please do not send parcels or packages to this address.

Email: kontakt.volksvertreter@protonmail.com

2. Website hosting through Cloudflare

This website is provided as a static website through Cloudflare. The provider is Cloudflare, Inc., 101 Townsend Street, San Francisco, CA 94107, USA.

When the website is accessed, technically necessary connection data is processed, in particular IP address, date and time of access, requested file, amount of data transferred, browser and operating system information, and server log data. Processing is necessary to deliver the website securely, reliably and quickly.

The legal basis is Art. 6 para. 1 lit. f GDPR. The legitimate interest lies in the secure and reliable provision of this website. Further information is available in Cloudflare's privacy policy: https://www.cloudflare.com/privacypolicy/

3. No cookies, no tracking, no external fonts

This website itself does not use cookies, its own tracking, web analytics, advertising trackers, tracking pixels or externally loaded fonts, and it does not store anything in your browser.

If analytics features, contact forms, newsletters, embedded videos or external content are added later, this privacy policy must be updated first.

4. Contact by email

If you contact me by email, the data you provide is processed in order to answer your request. This usually includes your email address, the content of your message and the technical metadata of the email.

The legal basis is Art. 6 para. 1 lit. f GDPR. For precontractual or contractual matters, Art. 6 para. 1 lit. b GDPR may apply. Emails are deleted once they are no longer required for processing and no legal retention obligations prevent deletion.

5. Anonymous gameplay statistics in the app

The Demagogue app collects anonymous gameplay statistics by default through a minimal TelemetryDeck interface (provider: TelemetryDeck GmbH, Augsburg) in order to improve balancing, stability and player experience. You can turn off these statistics at any time in the app settings under "Anonymous statistics".

The regular TelemetryDeck SDK is not initialized for this, so no automatic device, operating system, language, session or user identifier data is sent.

The app sends balancing data only for a randomly selected local 50% sample group. A random group number is generated once and stored locally in the app settings. This sampling bucket is not a unique identifier; neither the bucket nor an installation identifier is transmitted. Rare technical anomalies and savegame compatibility problems may be collected regardless of the sample group, but still only while Anonymous Statistics is enabled. A few onboarding milestones are also collected regardless of the sample group, for example campaign started or first term completed; each is sent at most once per installation and contains nothing but the name of the milestone.

Only explicitly allowed gameplay and technical data is transmitted, such as difficulty, game mode, legislative period progress, broad run count buckets, app version, static catalog IDs for game content such as selected laws, ChoiceEvent impressions, ChoiceEvent options, election promises and triggered lead crises, flat dashboard buckets, broad playtime and activity buckets, aggregated election and balancing values, anonymous onboarding milestones, anonymous paywall events (paywall shown and CTA tap with an anonymous entry point), and technical savegame compatibility counts.

The telemetry payload does not include device model, operating system version, language, region, locale, time zone, screen data, session IDs, user IDs, run IDs, continuous run numbers, player names, party names, dynamic sandbox party IDs, lead crisis titles, article or news text, exact lead crisis spawn ticks, save files, game states, file paths, advertising IDs, store or RevenueCat customer identifiers, transaction or receipt IDs, store tokens, prices or currency data. With every internet connection, the sender IP address is technically visible to the server; the app does not send it as a data field and does not store it.

More information: https://telemetrydeck.com/privacy/

6. In-app purchases

The app offers optional in-app purchases through the relevant app store. Payments are processed by Apple or Google. Payment data such as credit card numbers, bank details or app store account information is not transferred to the provider of this app.

For use of the app through the Apple App Store, Apple's standard EULA also applies unless a separate EULA is configured in App Store Connect. Purchases through the Apple App Store are processed through Apple's in-app purchase system; RevenueCat is used for technical management and verification of purchases and unlocks. Refunds for Apple in-app purchases are handled by Apple.

The app uses RevenueCat (RevenueCat, Inc., USA) to verify purchases, manage purchase status, unlock purchased content and restore purchases. Technical purchase data may be processed, such as product ID, purchase status, transaction or receipt information, store purchase token, app-specific user identifier, platform, app version and country or region. RevenueCat processes this data as a service provider on behalf of the app provider.

Further information: https://www.revenuecat.com/privacy/

7. Suggestions and feedback in the app

If you submit a law suggestion, event suggestion or feedback as a full version user in the app, the content you voluntarily enter is transmitted to Supabase and stored there. The provider is Supabase, Inc. (USA); the data may be processed in the United States.

In addition to your input, technical metadata is sent: app version, build number, the app language you have set, the internal product ID of the full version, the place in the app you submitted from, a timestamp, and a random identifier for the submission. This metadata is used only to categorize the submission; no device, account, or user identifiers are transmitted. As with any internet connection, the sender's IP address technically arises at the server.

The purpose is exclusively review and possible further development of Demagogue. Submitted suggestions and feedback are not displayed publicly. The legal basis is your consent given by actively submitting (Art. 6 para. 1 lit. a GDPR).

Further information: https://supabase.com/privacy

8. Duel mode (optional)

Duel mode is an optional online feature. Only if you voluntarily create or join a duel, a randomly generated match code, the game configuration (starting seed, difficulty, enabled expansions, term limit, deadline and chosen victory conditions) and anonymous game statistics of your run (scores, aggregated game values, chosen bonus and sabotage effects, decisions as static catalog IDs, and your party color and symbol) are transmitted to Supabase and stored there. The provider is Supabase, Inc. (USA); the data may be processed in the USA. For duel mode itself, no names, contact details or device identifiers are transmitted; the display name of your opponent is stored exclusively locally on your own device and is never transmitted. As with any internet connection, the sender IP is technically received by the server.

The sole purpose is running the duel, i.e. exchanging the game states between both participants and determining the result. The data is deleted automatically: invitations that are not accepted expire 7 days after they are created and are deleted after another 7 days. Joined duels retain their normal deadline and are stored for 30 days after they end. Legacy duels without a deadline are ended after 90 days without activity. The legal basis is the performance of the feature you actively use (Art. 6 (1) (b) GDPR).

Further information: https://supabase.com/privacy

9. Duel notifications (optional)

If you turn on notifications in duel mode, Google creates a delivery address for this device and hands it to the app. That address is transmitted to Supabase and stored there, together with the duel's game code, your role in it, the platform, the language set in the app and whether this is a test build or a store build. When an event occurs, the server sends the title and text of the message along with the game code, the current legislative term and an identifier for the event to your device via the Firebase Cloud Messaging service. The providers are Google Ireland Limited and Google LLC (USA); the data may be processed in the USA. No names, contact details, saved games or advertising identifiers are transmitted. As with any internet connection, the sender IP arrives technically at the servers involved.

Without your consent the service is not started at all: as long as notifications are switched off, no delivery address is created and there is no connection to Google. You can switch them off again at any time in the settings; the stored delivery address is then deleted. It is also deleted once the corresponding duel ends and its data is removed after the periods stated above. The legal basis is your consent (Art. 6(1)(a) GDPR), which you may withdraw at any time with effect for the future.

More information: https://firebase.google.com/support/privacy

10. Backup of achievements and career (optional)

The game can back up your unlocked achievements and your career statistics so that they survive a reinstall: on iPhone and iPad to your personal iCloud, on Android through your device backup at Google. The backup can be turned off in the settings, and the stored profile can be deleted there. Only achievement IDs, progress counters, your career figures, a randomly generated identifier for this installation so that several devices can be combined, plus the name of the game edition, the app version and the time of the last backup are stored. Save games, names, contact details and advertising identifiers are not backed up.

The data stays in your own account in each case: at Apple in the key-value store of your Apple ID, at Google in your device backup. It is not transferred to the developer or to third parties, and the developer has no access to it. Apple and Google process it under your agreement with them. The legal basis is the performance of the function you are using (Art. 6(1)(b) GDPR).

Further information from the providers: https://www.apple.com/legal/privacy/ and https://policies.google.com/privacy

11. Advertising

Whether the app shows ads depends on the installed app version:
Google Play: Up to and including version 1.1.0 the app showed ads; from version 1.1.1 onwards it is ad-free.
Apple App Store: Up to and including version 1.0.4 the app showed ads; from version 1.1.1 onwards it is ad-free.

In the ad-free versions (1.1.1 and later), no ad networks, advertising identifiers, or ad-related tracking are used.

In the older versions that still show ads, ads were served via Google AdMob (provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland). Only non-personalized ads were shown. In this context, in particular the IP address, approximate location, and device and app information as well as interactions with ads were processed. Consent was obtained through Google's consent management (User Messaging Platform, UMP). No cross-app or cross-device tracking for advertising purposes took place. The legal basis was your consent (Art. 6 para. 1 lit. a GDPR) and Art. 6 para. 1 lit. f GDPR.

Further information on data processing by Google: https://policies.google.com/privacy

12. Your rights

To the extent that personal data arises from voluntary submissions or technically necessary connection data, you may contact kontakt.volksvertreter@protonmail.com by email at any time for access, correction or deletion requests.

Deletion requests may be made by email. All data that can be assigned to the request will be deleted. Fully anonymized statistical data cannot be individually assigned and therefore cannot be deleted individually.

You also have the right to lodge a complaint with a data protection supervisory authority.

13. Changes

This privacy policy may be updated when necessary, for example when new website or app features are added. The current version is available on this website.