App and website
Privacy at Santa Dice Game
This privacy notice applies to the Santa Dice Game / Pakjesavond app on iOS and Android, the browser demo, and pakjesavond.com.
Your game on your device
You do not need an account. Preferences, game progress, custom rules, and player names for Gift Chain are stored locally on your device so you can resume your game. The mobile app uses shake sensor data on your device only. Player names, custom rule texts, and sensor readings are never sent with usage counters.
You share custom rules yourself by copying text and sending it through another app. There is no automatic cloud sync. Your device may include app data in a system backup, which you manage through your device or platform account.
Limited usage counters
Usage statistics are enabled in our production build. Under Privacy & statistics in the app you can see whether your installed build sends measurements. When enabled and you play online, we count:
- Started games: game or rule variant, sound effects on/off, and for the dice game the duration category.
- Actual changes to rule variant, duration category, or sound effects.
- Completed games: the variant and whether the timer expired, someone ended the game manually, or all gifts were unwrapped.
Measurements are sent over HTTPS to Cloudflare and added to separate daily totals. The database stores no individual events or combined record of all your choices. Player names, player counts, gift details, custom rule texts, and sensor values are never included. We do not use user, session, installation, or advertising IDs, analytics cookies, fingerprinting, or player profiles. We do not measure individual dice rolls or Spotify usage.
There is no separate statistics toggle in the app, but you can play offline. Offline or failed measurements are not queued or sent later. We do not sell this data or use it for advertising.
Website and hosting
The marketing website uses no analytics of its own, no tracking cookies, no accounts, and no forms. Images and fonts are served from the website itself. The website does not read game data from the app.
Cloudflare provides hosting and the statistics service. During network traffic, Cloudflare receives technical data such as your IP address, the requested URL, and browser information for operation and security. That data is not stored in our statistics database. The daily counters are stored in an EU database; this does not mean all network processing remains inside the EU.
Cloudflare and our email provider Zoho Mail may process data internationally, including outside the European Economic Area. Their documentation describes processing and transfer safeguards, including Standard Contractual Clauses: Cloudflare Privacy, Cloudflare Data Processing Addendum, and Zoho Privacy. For questions about data they process on our behalf, you can contact us.
Support and third-party services
Danilo Verhaert is the data controller responsible for this processing. For privacy questions and requests, email support@pakjesavond.com.
If you email us, we process your name, email address, message, and any attachments via Zoho Mail to answer your question. Do not send passwords, payment card details, or unnecessary personal data about other players.
Downloads and payments are handled by the App Store or Google Play. The app itself never asks for payment card details. The Spotify button only opens an external playlist link when you tap it, without passing player names or game progress. We have no access to your listening history. These services are governed by their own privacy policies: Apple, Google, and Spotify.
Purposes and retention
Local storage enables the requested game features and resuming a saved session. When support is necessary for providing the app, the legal basis is performance of a contract. For other inquiries, security, and the limited usage counters to improve the app, we rely on legitimate interests. A statutory retention obligation is the basis where mandatory retention applies.
- Local game data: kept on your device until you replace or delete it. You manage device/browser storage and any system backups yourself.
- Daily totals: counters older than 24 months are deleted daily from the active statistics database.
- Support emails: within 6 months after resolution we delete messages and attachments from active correspondence, including sent items and trash. Only where required by law or an ongoing dispute do we retain relevant data longer, for as long as necessary.
Technical recovery backups have separate retention periods. Cloudflare D1 has a Time Travel recovery window of up to 30 days, or 7 days on the free plan. Zoho describes a 30-day recovery period after deletion from trash for individual emails. Cloudflare retains other technical network data as needed for service delivery, security, and legal obligations as described in its privacy policy.
Your rights
You may request access to, rectification, erasure, or restriction of your personal data, object to processing based on legitimate interests, and where applicable request data portability. We handle requests in accordance with applicable legal requirements and deadlines.
We cannot remotely view or erase your local game data, and we cannot identify an individual player from the daily counters. This does not limit your rights regarding data that can be linked to you, such as a support email. You have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) or the competent supervisory authority in your country.
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