Privacy Policy

We are the controller for processing data under this Privacy Policy unless we tell you otherwise in the individual case. You may contact us for data protection concerns and to exercise your rights as follows:

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• email addresses
• accounts with other game platforms
• game data
• other data provided or saved

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe, Apple and Google. You may find their privacy notice link(s) here: https://stripe.com/en-ch/privacy, https://www.apple.com/legal/privacy/data/en/apple-pay/ and https://payments.google.com/payments/apis-secure/u/0/get_legal_document?ldo=0&ldt=privacynotice&ldl=en-GB.

Game Platform Login Data. We may provide you with the option to register with us or connect your account using your existing account with other game platforms (currently Lichess and Chess.com). If you choose to do so, we will receive certain profile information about you from the game platform provider, as described in the section called ‘HOW DO WE HANDLE YOUR CONNECTION WITH OTHER GAME PLATFORMS?’ below.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’), and hardware settings).

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We process the personal information for the following purposes listed below. We may also process your information for other purposes only with your prior explicit consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see ‘WHAT ARE YOUR PRIVACY RIGHTS?’ below.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

We may rely on the following legal bases to process your personal information:

• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
  • Send users information about special offers and discounts on our products and services
  • Analyse how our Services are used so we can improve them to engage and retain users
  • Support our marketing activities
  • Diagnose problems and/or prevent fraudulent activities
  • Understand how our users use our products and services so we can improve user experience
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Subcontractors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (‘third parties’) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows:

• Cloud Computing Services
• Data Analytics Services
• Payment Processors
• User Account Registration & Authentication Services

We also may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

As explained in section 5 above, we disclose data to other parties. These are not all located in Switzerland. Your data may therefore be processed both in Europe and in any country in the world.

If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses, which can be accessed here: https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.

Many countries outside of Switzerland or the EEA currently do not have laws that ensure an adequate level of data protection under the DPA or the GDPR. The contractual arrangements mentioned compensate for this weaker or missing legal protection to some extent. However, contractual precautions cannot eliminate all risks (namely of government access abroad). You should be aware of these remaining risks, even though they may be low in an individual case, and we take further measures (for example pseudonymization or anonymization) to minimize them.

Please note that data exchanged via the internet is often routed through third countries. Your data may therefore be sent abroad even if the sender and recipient are in the same country.

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

Where our website asks for your consent, you can accept or decline non-essential cookies via the cookie banner. In addition, you can refuse or remove cookies through your browser settings (see ‘CONTROLS FOR DO-NOT-TRACK FEATURES’ below). If you wish to object to the use of online tracking technologies for advertising, you can also contact us as described in ‘WHAT ARE YOUR PRIVACY RIGHTS?’.

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, ‘AI Products’). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies

We provide the AI Products through third-party service providers (‘AI Service Providers’), including Amazon Bedrock. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in ‘WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?’ You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

• AI automation

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data’s safety.

In Short: If you choose to register or log in to our Services using a connection with your account with other game platforms, we may have access to certain information about you.

Our Services offer you the ability to register, log in or connect your account using your account with other game platforms (currently Lichess and Chess.com; further platforms may be added). Where you choose to do this, we will receive certain data about you from your other game platform provider. The profile information we receive may vary depending on the provider concerned, but will often include your name, user name, email address and game data.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party game platform provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We process your data for as long as our processing purposes, the legal retention periods and our legitimate interests in documentation and keeping evidence require it or storage is a technical requirement. If there are no contrary legal or contractual obligations, we will delete or anonymize your data once the storage or processing period has expired as part of our usual processes.

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

To help you control the processing of your personal data, you have the following rights in relation to our data processing, depending on the applicable data protection law:

• The right to request information from us as to whether and what data we process from you;
• The right to have us correct data if it is inaccurate;
• The right to request erasure of data;
• The right to request that we provide certain personal data in a commonly used electronic format or transfer it to another controller;
• The right to withdraw consent, where our processing is based on your consent;
• The right to receive, upon request, further information that is helpful for the exercise of these rights;

If you wish to exercise the above-mentioned rights in relation to us, please contact us in writing, at our premises or by e-mail; you will find our contact details in Section 1. In order for us to be able to prevent misuse, we need to identify you (for example by means of a copy of your ID card, unless identification is not possible otherwise).

Depending on your location of residence, you also have the right to lodge a complaint with the competent data protection supervisory authority in your country. You can reach the Swiss supervisory authority here: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html. You can find a list of authorities in the EEA here: https://edpb.europa.eu/about-edpb/board/members_en. You can reach the UK supervisory authority here: https://ico.org.uk/global/contact-us/.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated ‘Revised’ date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.