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Privacy Policy

Effective Date: [EFFECTIVE_DATE]  |  Last Updated: [EFFECTIVE_DATE]


1. Introduction

1.1. This Privacy Policy ("Policy") describes how Frankenstein VTT ("Service", "we", "us", or "our"), accessible at https://frankensteinvtt.com, collects, uses, stores, and protects personal data of its users ("you", "User").

1.2. Data Controller:

1.3. This Policy is drafted in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR") and applies to all Users accessing the Service from the European Union, European Economic Area, or the United Kingdom.

1.4. By registering for and using the Service, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, you must discontinue use of the Service.


2. Definitions


3. Personal Data We Collect

3.1. Data Collected at Registration

DataDescriptionPurpose
Google OAuth identifier (sub)An opaque external ID from your Google account. This is not your email addressUser authentication
Display nameA pseudonym chosen by you during registrationIn-game identification
CountryISO 3166-1 alpha-2 country code (e.g., "DE", "FR"). Pre-filled via GeoIP at registration; you may override itDetermining data storage region; payment provider routing

Important: We do not store your email address. Authentication is handled exclusively through Google OAuth; we only receive and store the opaque "sub" identifier from Google. No passwords are stored or processed by the Service.

3.2. Game Data

During your use of the Service, the following data linked to your account is processed:

3.3. AI Feature Usage Data

When you use AI-powered features, we process:

3.4. Subscription and Payment Metadata

DataDescription
Payment providerName of provider (Stripe)
External customer IDIdentifier assigned by the payment provider
External subscription IDSubscription identifier in the provider's system
Subscription eventsCreation, payment success, payment failure, cancellation, refund

We do not store credit card or payment instrument data. Payment processing is handled entirely by the payment provider (Stripe) in compliance with PCI DSS. Your email address for receipts is collected by the payment provider directly and is not transmitted to us.

3.5. Technical Data

DataDescriptionStorage
IP addressesRecorded in web server logsServer logs only; not stored in the database
Session dataCurrent session informationTemporary storage in memory (Redis); deleted upon session expiry

3.6. Cookies

The Service uses only strictly necessary cookies:

CookiePurposeType
Session JWT tokenUser authentication (httpOnly; SameSite=Strict; Secure)Essential
Refresh tokenSession renewal without re-authentication (httpOnly; SameSite=Strict; Secure)Essential
User preferencesStoring interface preferencesEssential

We do not use advertising, analytics, or any other tracking cookies.


4. Purposes of Processing

We process your personal data for the following purposes:

  1. Service provision — authentication, authorization, and operation of game features
  2. AI feature operation — monster generation, voice command processing, token image generation
  3. Payment processing — subscription management, interaction with payment providers
  4. Security — preventing unauthorized access, fraud, and abuse
  5. Service improvement — analysis of anonymized usage statistics for product development
  6. Legal compliance — data retention in accordance with applicable legal requirements

5. Legal Basis for Processing (GDPR Article 6)

Legal basisData categoriesGDPR reference
ConsentRegistration data, AI usage data, cookiesArt. 6(1)(a)
Performance of a contractData necessary to provide the Service (game data, subscription data)Art. 6(1)(b)
Legitimate interestSecurity logs, abuse prevention, anonymized analyticsArt. 6(1)(f)
Legal obligationSubscription event audit trail, server logsArt. 6(1)(c)

You may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.


6. Data Storage

6.1. Storage Location

Phase 1 (current): All personal data, including data of EU Users, is stored on servers located in Moscow, Russia (hosting provider: TimeWeb Cloud). By registering for the Service during Phase 1, EU Users consent to the storage of their data in Russia. Russia is not on the European Commission's list of countries with an adequate level of data protection.

Phase 2 (planned): Personal data of Users whose registered country is outside Russia will be migrated to servers located in Amsterdam, Netherlands (EU). Russian user data will remain in Moscow. After migration, EU user data will be stored within the European Economic Area.

We will notify Users when the Phase 2 migration is complete.

6.2. Retention Periods

Data categoryRetention periodDeletion method
Account data (identifier, display name, country)Until deleted by UserAnonymization upon request (30-day grace period)
Game data (rooms, maps, shapes, notes)Until account deletionPreserved in anonymized form for other participants
AI usage statistics1 yearAutomated monthly deletion
AI call logsUntil monetization model is finalizedDeletion after analysis is complete
Saved monstersUntil account deletionCascading deletion with account
Subscription eventsIndefinitelyRetained for audit and compliance purposes
Subscription dataUntil account deletionCascading deletion with account
Processed webhooks30 daysAutomated daily deletion
Server logs (including IP addresses)90 daysAutomated rotation
Session data (Redis)Session lifetime (7 days max)Automated expiry

7. Your Rights Under the GDPR

7.1. Right of Access (Article 15)

You have the right to obtain confirmation as to whether your personal data is being processed and, if so, to request access to that data. Contact [DPO_EMAIL] to submit an access request.

7.2. Right to Data Portability (Article 20)

You may export your personal data in a structured, commonly used, machine-readable format (JSON) through the Service interface:

7.3. Right to Rectification (Article 16)

You may correct your display name through the profile settings in the Service. To request correction of other data, contact [DPO_EMAIL].

7.4. Right to Erasure ("Right to Be Forgotten") (Article 17)

You may request deletion of your account and associated personal data:

After anonymization, the remaining game data contains no information that could identify you. This renders the data anonymous and outside the scope of the GDPR.

7.5. Right to Restriction of Processing (Article 18)

You have the right to request restriction of processing of your personal data in the following circumstances:

Contact [DPO_EMAIL] to submit a restriction request.

7.6. Right to Object (Article 21)

You have the right to object to processing of your personal data based on legitimate interest (Article 6(1)(f)). Upon receiving an objection, we will cease processing unless we demonstrate compelling legitimate grounds that override your interests.

Contact [DPO_EMAIL] to submit an objection.

7.7. Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority. If you are in the EU/EEA, you may contact the data protection authority in your country of residence. A list of EU data protection authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en

7.8. Response Timeline

We will respond to all data subject requests within 30 calendar days of receipt. In complex cases, this period may be extended by a further 60 days, in which case we will inform you of the extension and the reasons for the delay within the initial 30-day period, in accordance with GDPR Article 12(3).


8. International Data Transfers

8.1. Phase 1 (Current)

During Phase 1, all data (including data of EU Users) is stored in Moscow, Russia. Russia does not benefit from an adequacy decision under GDPR Article 45. The legal basis for this transfer is your explicit consent (GDPR Article 49(1)(a)), given at registration. You are informed of and consent to this arrangement by agreeing to this Privacy Policy.

8.2. Phase 2 (Planned)

Upon completion of Phase 2, personal data of non-Russian Users will be stored on servers in Amsterdam, Netherlands (within the EEA). No international transfer of EU user data will occur after migration.

8.3. AI Processing

When you use AI features, text prompts (without personal data) may be transmitted to third-party AI model providers. These prompts do not contain your identifier, display name, or any other personally identifying information.


9. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage:


10. Third-Party Data Processing

Third partyRoleData sharedLegal basis
Google (Google Ireland Limited)Authentication provider (OAuth)"sub" identifier (received from Google; email address is not requested or stored)Consent (signing in with Google)
Stripe (Stripe Payments Europe, Limited)Payment processingPayment data is processed by Stripe directly; we receive only the external customer ID and subscription eventsPerformance of a contract
AI model providersContent generationText prompts without personal dataConsent (use of AI features)

We require all third-party processors to process data in accordance with the GDPR and have appropriate data processing agreements in place.


11. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:


12. Children's Data

The Service is not intended for individuals under the age of 16. By registering, you confirm that you are at least 16 years of age. We do not knowingly collect personal data from children under 16. If we become aware that a User is under 16, we will delete their account and associated data.


13. Automated Decision-Making

The Service does not engage in automated decision-making or profiling that produces legal effects or similarly significantly affects you, within the meaning of GDPR Article 22. AI features (monster generation, voice commands) generate game content and do not make decisions about you as a person.


14. Changes to This Policy

14.1. We may update this Policy from time to time. The current version is always available at https://frankensteinvtt.com/privacy.

14.2. For material changes, we will provide notice through the Service interface at least 14 days before the changes take effect.

14.3. Continued use of the Service after the changes take effect constitutes your acceptance of the updated Policy. If you do not agree with the changes, you should discontinue use of the Service and may request deletion of your data.


15. Contact Information

For any questions or requests regarding this Privacy Policy or the processing of your personal data:

We are committed to resolving any concerns about your privacy. If you believe that we have not adequately addressed your concern, you have the right to lodge a complaint with your local data protection supervisory authority.


16. Governing Law

This Policy and any disputes arising from it shall be governed by the laws of the European Union (GDPR) as they apply to the processing of personal data. For matters not covered by the GDPR, the laws of [GOVERNING_LAW_JURISDICTION] shall apply.