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Privacy Policy

Version 1

1 Data controller

The publisher of 2-12-10. For any question about your data: hello@2-12-10.com.

2 Data we collect

  • Profile: nickname, color, avatar (optional), language, notification preferences, date and version of the Terms of Use you accepted.
  • Email (optional): only to recover your account, with a link or a 6-digit code sent to that address.
  • Game content: photos played, clues, round discussion messages, reactions to photos, votes, points and statistics, groups and party-mode games joined, and the time zone of a party-mode game’s host (for its automatic end).
  • Game activity: the time slots of the day (in 4-hour blocks) when you open a group in the app, the time the “your turn” and “clue given” notifications addressed to you were sent, and a per-group activity score, calculated on demand from this data and your play over the last 7 days (photos and clues sent and how quickly, votes, reactions and messages, clues given when you were the storyteller over 30 days). The score is not stored and is not visible to any player.
  • Notifications: tokens provided by Apple or Google to send you notifications, and device type (iOS or Android); history of the notifications addressed to you (type, group, title, text, whether it was sent and why not), viewable only by the 2-12-10 team to diagnose delivery problems.
  • Security: IP address, used to limit abuse (repeated attempts, mass sending). For emails sent to an address entered in the app or on our pages, a fingerprint of that address (not the address itself), used to limit the number of emails sent to the same address.
  • Blocked addresses: if an email we send is permanently rejected by the recipient’s mail server or marked as spam by the recipient, a fingerprint of the address (not the address itself), the reason and the date, so we stop writing to it.
  • Reports: reported content, reason and comment, author of the report, moderation decision.
  • App error reports: when the app hits an error, the technical description of the error, the last actions before it (screens visited and buttons tapped, without their content), the screen concerned, the app version, the device and system type, and the phone’s language and time zone. These reports contain neither your identifier, nickname, email, IP address nor photos; codes, tokens and secret links are masked.
  • Server error reports: when the server hits an error, the technical description of the error, the address called (without its parameters or secret codes and links), the last technical operations before it (database queries without their values, technical messages without their context) and the server version. These reports contain neither your identifier, your IP address nor the content of your requests (text, photos, email).

Photos are chosen in your phone’s photo picker: the app only accesses the photos you select, never your whole library, and does not use the camera. They are re-encoded on our servers, and their metadata (EXIF, including GPS location) is removed.

Our web pages (invitations, Terms of Use, this page) set no cookies and use no analytics or tracking tools.

3 Purposes and legal bases

  • running the game (account, groups, rounds, party-mode games, discussion and reactions, votes, ranking, history) and sending you the round notifications you turned on: performance of a contract (the Terms of Use you accept);
  • choosing the storyteller each day from the group’s members, taking each member’s activity into account, to reduce rounds lost because the storyteller does not give their clue within 2 hours: legitimate interest in rounds taking place for all members of the group. This selection has no effect on your points or ranking, and no member is ever excluded from the draw;
  • letting you recover your account by email: performance of a contract, at your request, if you add an address;
  • limiting repeated attempts and emails sent, no longer writing to an address that rejects our emails, moderating reported content and suspending accounts that break the rules: legitimate interest in keeping the service secure, preventing abuse, protecting players and enforcing the rules of the service.
  • detecting and fixing app and server errors: legitimate interest in keeping the service working and stable.

Right to object: you can object at any time, on grounds relating to your particular situation, to processing based on legitimate interest, by writing to hello@2-12-10.com. We will then stop that processing, unless there are compelling legitimate grounds (for example, handling a pending report).

No advertising, no ad profiling, no sale of data.

4 Who sees your content

Your photos, clues and votes are only visible to members of the groups or the party-mode game where they are played, and only when the game rules allow it: the storyteller and the author of each photo stay secret until the results. Photos are served through private, temporary links: at most 48 hours for a game photo, at most 7 days for a profile picture or a challenge image. A link stops working as soon as the photo is deleted (removal by moderation, deletion of your account, new profile picture). The app keeps a cached copy of these images on your device to display them faster.

Your messages in a round’s discussion and your reactions to photos, with your nickname, are visible to the group’s current members, including those who join it later; in a party-mode game, your reactions are visible to its players. A message you sent cannot be edited or deleted by its author: to have it erased, write to us at hello@2-12-10.com or delete your account.

The invitation link to a party-mode game shows anyone who opens it the host’s nickname and avatar and the number of players, while the game is ongoing. During a party-mode game and on a group’s screen, the app stays connected to our server to follow the game live: this connection carries no content and no nickname, only a signal that the game or its discussion has changed.

The service’s administrators have access, in a secure tool, to the data needed to run and moderate it, including the content of games.

The moderation team is alerted to each new report by an email that only gives its type and reason: not the reported content, the comment or the nicknames involved.

If a moderation measure concerns you (photo or clue removed, group name replaced, profile reset, account suspended), you are informed by email if your address is confirmed, otherwise by notification, with its reason. This message only names the item concerned (for example “your photo from October 12”), without the reported content or the author of the report.

The content of the notifications you turn on (group name, a new member’s nickname, the owner’s nickname when they change the group’s schedule or delete it, the nicknames of the month’s ranking winners, and the nicknames of the authors of new discussion messages) is sent to Apple’s notification service (APNs) or Google’s (Firebase Cloud Messaging) so it can be delivered to your device. These services may temporarily keep an undelivered notification so it can be delivered.

5 Processors and transfers

  • Hosting of the API, the database and the real-time server: Laravel Cloud (Laravel Holdings Inc., United States), EU Central region (Frankfurt, Germany). Laravel is certified under the EU–US Data Privacy Framework.
  • Photo storage: Cloudflare R2 (Cloudflare, Inc., United States), in a storage space restricted to the European Union: photos are stored in the European Union. Cloudflare is certified under the Data Privacy Framework and also applies the European Commission’s standard contractual clauses.
  • Email delivery (sign-in and verification codes and links, report alerts to moderators, moderation notices): Resend (Resend, Inc., United States), certified under the Data Privacy Framework, which also tells us about rejected emails and emails marked as spam; its data processing agreement also provides for the standard contractual clauses.
  • Notifications: Google Firebase Cloud Messaging (Google LLC, United States), certified under the Data Privacy Framework. Google may process this data in any country where it or its subprocessors have facilities.
  • Notifications on iPhone: Apple Push Notification service (Apple), under the terms Apple applies to app developers.
  • App and server error monitoring: Sentry (Functional Software, Inc., United States), in its European Union region: error reports are stored in the European Union. Sentry applies the European Commission’s standard contractual clauses.

6 Security

We implement appropriate technical and organizational measures to protect your data against unauthorized access, loss, alteration or disclosure, including encrypted communications, access control and temporary links for photos.

7 Retention periods

  • Inactive account: an account you have not used for one year is automatically deleted, along with its data, as described in the “Deleting your account” section;
  • Account without a group: an account that belongs to no group and creates or joins no party-mode game for one month (since it was created, since it left its last group or since its last party-mode game) is automatically deleted, along with its data, in the same way;
  • Profile and email address: as long as your account exists;
  • Game content: according to the retention rules for groups, rounds and party-mode games described below. A photo uploaded but never played is deleted after 24 hours;
  • A group’s rounds (clues, photos, votes, points, discussion messages, reactions): as long as the group exists. If you leave or are removed from a group, all the photos you played in it are deleted, including the one in the current round, except a photo targeted by a pending report (see below): they disappear from the group’s history. Your clues, messages, reactions, votes and points remain;
  • Read markers (round stage viewed, round results opened, last reading of the discussion): deleted every day, except those of the last two rounds of each group;
  • Inactive group: a group with no activity for two months (no new member, clue, submitted photo or vote) is automatically deleted, along with its rounds, photos, messages, reactions, votes and points;
  • Reported photo in a group: a photo targeted by a pending report is not deleted when its author leaves the group, when the round is cancelled or when the group is deleted. It is kept for moderation until the report is handled, then deleted;
  • Party-mode games: when a party-mode game ends (at the host’s request, when the host leaves, or automatically at 6 a.m. the next day), all the photos played in it are deleted, including those of players who left before the end, except those of a reported round (see below). The final ranking stays visible to its players for 24 hours, then the game is deleted entirely (rounds, clues, votes, points, list of players). If at least one round was started, only statistics attached to the host remain: the game’s dates and duration, the time and day it was started, the number of players, new accounts, rounds played and cancelled, the average round durations and the number of reports, with no information about the other players. They are deleted with the host’s account. A round targeted by a pending report (photo, clue or player) is kept, with its clue, photos and participants, until the report is handled, then deleted;
  • Sign-in codes and links: valid for 15 minutes, then deleted within 24 hours after they expire (an automatic deletion runs every day). App session: expires after one year without use;
  • Notifications: notification tokens are kept as long as your account exists and the token remains valid. A token that Apple or Google reports as invalid is deleted. Turning notifications off in the app stops sending, without deleting the token, so they can be turned back on later. The notifications themselves may be kept temporarily by Apple or Google to allow delivery, according to their own retention mechanisms;
  • Game activity: opening time slots, notification send times and the notification history are kept for 60 days, then deleted, and immediately with your account (the nickname of a player who deleted their account may remain for up to 60 days in the text of a notification addressed to another player). Each storyteller draw is recorded with every member’s weight at that moment, with no time limit while the group exists;
  • IP address: anti-abuse counters (your IPv4 address, or the start of your IPv6 address) valid for one hour at most, then deleted within 24 hours after they expire. Host’s technical logs: 7 days;
  • Fingerprint of an email address: 24-hour sending counter. Blocked addresses: with no time limit, so we never write again to an address that rejects our emails; you can ask for yours to be removed by writing to hello@2-12-10.com;
  • Reports: deleted one year after they are handled;
  • App and server error reports: 90 days at most at Sentry.

8 Deleting your account

You can delete your account at any time from the app (Profile) or from the Delete my account page, once you have handed your groups over to other players. If you host an ongoing party-mode game, it ends. An account left unused for one year, or that goes one month without a group or a party-mode game, is also deleted automatically, in the same way. Your avatar, photos, round discussion messages, the clues of the games you told, email and notification tokens are erased, and your color is replaced by a neutral gray; your photos and clues also disappear from the groups’ history, except a photo (avatar included) targeted by a pending report: it is kept for moderation until the report is handled, then deleted. Likewise, the text of a reported message or clue, and the nickname copied when a profile is reported, remain in the report (reported_text): while it is open, then 12 months after it is handled. Your nickname disappears: in other players’ history, you appear as “Deleted player”. Your points, in the groups’ ranking and statistics, your votes and your reactions to photos remain, attached to “Deleted player” instead of your nickname; the statistics of the party-mode games you hosted are deleted.

9 Your rights

Under the GDPR, you have the right to access, rectify, erase, restrict, object to and port your data. To exercise them: hello@2-12-10.com. You may also lodge a complaint with your data protection authority (in France, the CNIL: cnil.fr).

10 Minimum age

2-12-10 is intended for people aged 13 or over.

11 Changes

If this policy changes significantly, the app asks you to accept it again before you keep playing. The current version is shown at the top of this page.