Privacy policy

Status

DRAFT – not legal advice. To be reviewed by a lawyer before launch.

Covers the EU GDPR and the UK GDPR / Data Protection Act 2018, and the UK Age Appropriate Design Code. [TO CHECK: US state laws and Canadian PIPEDA before opening those countries.]

In short

No account, no phone number, no date of birth, no geolocation, no access to your contacts or chats. We never ask for your email to play. One exception: if you get Premium, we keep the email you entered on Stripe, only to find your subscription again.

Private groups, anonymous votes, nothing is posted automatically. Your images are never sold, used to train AI models or used commercially.

High privacy by default: nothing is public, and nothing leaves the group without the OK of the people concerned.

Controller

[TO COMPLETE: name or company name of the operator], reachable at [TO COMPLETE: contact email address].

[TO COMPLETE: UK representative if required.]

Data we process and why

Nickname, self-declared age range, acceptance of the rules: to create your participation and apply the protections for under-18s (legal basis: performance of the service).

Country you select when creating a group: to apply the right minimum age and currency.

Votes: to compute the results. Nobody can see who voted for who. In a very small group, the numbers in the results can still give hints about some votes.

Lore Dump entries (text, stickers, images) and sharing permissions: to build the group's awards, only with the required OKs.

One technical session cookie per group, needed to recognize you without an account.

Internal audience measurement: anonymous event types (e.g. "group created", "card downloaded") linked to a truncated technical reference, without IP address, nickname or content. No advertising tools, no behavioural targeting.

Payment: handled by Stripe. We never see your card details; we keep the status, amount and dates of your subscription (accounting obligations).

Payment email: the address you enter on Stripe for Premium is kept by FriendWrap, only to restore your Premium on another device (legal basis: performance of the service). It is not used for advertising or marketing.

Premium sign-in link: if you enter your email on the Premium page, we send you a magic link by email (valid for 1 hour, single use). It is sent through our email provider (see "Processors").

Premium cookie (fw_premium): a signed technical cookie set on the device that paid, to recognize your Premium without an account. It lasts 400 days at most and is used for nothing else.

Age

The service is for people 18 and over. By ticking the box, you certify that you are.

Images

Images are re-encoded and their metadata (location, device, date) removed. They are stored privately and only shown to authorized group members through temporary links.

An image is only visible to the group after everyone recognizable in it agrees and the organizer approves it. It can only be used on a shareable card with the OK of the author and of everyone recognizable.

Important limit: an image or card someone already downloaded can't be erased from their device remotely.

How long we keep data

A group and all its data are deleted automatically 60 days after it was created, or at the latest 30 days after the reveal. Unused draft images are deleted after 24 hours.

Payment records are kept as long as the law requires: [TO COMPLETE].

Your payment email is kept as long as your subscription exists, then for the length of the accounting obligations: [TO COMPLETE: duration, to check with a lawyer]. Magic links expire after 1 hour. The Premium cookie expires after 400 days at most.

Your rights

You can delete an entry, withdraw a permission, leave a group (your votes, lore and images are deleted) or, as organizer, delete the whole group, at any time from the app.

For any other request (access, correction, objection): [TO COMPLETE: contact email address]. In the UK you can also complain to the ICO (ico.org.uk). [TO COMPLETE: other supervisory authorities.]

Processors

[TO COMPLETE: application host, database / storage (e.g. Supabase, region), Stripe for payments, international transfer safeguards.]

Brevo (Sendinblue SAS, France): sends the Premium magic-link emails. It receives your email address and the link, nothing else. [TO CHECK: international transfer safeguards.]