Privacy Policy

Data Controller

The data controller is Zero Softworks di Peretto Alex, European VAT number IT04514000241. Contact: info@zerosoftworks.it, telephone +39 0424 017669.

Data Processed

• Account data, such as email address and authentication identifiers.
• Session and security data, including technical cookies and server-side security signals.
• Anonymous usage-limit data, including a technical anonymous identifier and hashed network-derived signal.
• Local game data stored in the browser, such as score statistics.
• Subscription data, such as Stripe customer, subscription, price, and status identifiers.
• Transactional email metadata needed to send sign-in, account, and subscription emails.
• Support data voluntarily sent by users by email or other contact channels.
• Optional leaderboard data, only when a signed-in user chooses to publish it: public nickname, mode, grade, play type, score, solved cards, time, consent version, and publication timestamp.
• Aggregate website analytics processed through Umami, such as page views, referrers, browser/device type, and country-level traffic information, without publishing user identities.

Purposes and Legal Bases

• Provide accounts, authentication, learning features, and Plus access: performance of a contract or pre-contractual measures.
• Process subscriptions and payments: performance of a contract and legal obligations.
• Issue invoices and keep accounting records: legal obligations under Italian and tax law.
• Prevent abuse, protect security, and enforce anonymous usage limits: legitimate interest and service security.
• Respond to support, invoice, bug, and malfunction requests: performance of a contract, legal obligations, or legitimate interest depending on the request.
• Send transactional emails: performance of the service and legitimate interest in account/security communications.
• Publish optional leaderboard results: explicit user choice/consent and performance of the requested leaderboard feature.
• Measure aggregate usage and improve the service through privacy-friendly analytics: legitimate interest in understanding site performance and usage without advertising or profiling.

The service does not use advertising networks, behavioral analytics, tracking pixels, or marketing profiling. Umami is used for aggregate privacy-friendly analytics and is configured to respect Do Not Track.

Processors and Third Parties

The service uses selected providers to operate the app:

• Vercel for hosting and delivery.
• Supabase for authentication and database services.
• Stripe for payments, subscriptions, invoices/receipts, and billing portal.
• Resend for transactional email delivery.
• Umami for aggregate privacy-friendly analytics.

These providers may process data outside the European Economic Area under their applicable transfer mechanisms, such as Standard Contractual Clauses, adequacy decisions, or other lawful safeguards.

Retention

• Account data is kept while the account exists and for the time needed to complete deletion workflows.
• Subscription and payment records are kept as needed to provide Plus access, handle disputes, and comply with legal/accounting obligations.
• Anonymous usage events are intended to be retained only for the operational window needed to enforce fair-use limits and diagnose abuse.
• Support communications are kept for the time needed to resolve the request and protect legal interests.
• Accounting and invoice-related data is retained for the period required by Italian law.
• Leaderboard entries are retained while the user chooses to keep them public and can be removed from the game screen while signed in.

User Rights

Users may request access, rectification, erasure, restriction, portability, or objection where applicable under GDPR. Users may also lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) or another competent EU supervisory authority.

Requests can be sent to info@zerosoftworks.it.

Leaderboard publication is optional. Users can remove their published leaderboard entries directly from the app while signed in, or request removal by contacting support.

Children

The service is not intended to sell subscriptions to children. Paid subscriptions must be purchased by adults or with appropriate parental/guardian involvement where required by law.

Cookies and Local Storage

See the Cookie and Storage Policy for technical browser storage used by the app.