1. Data controller
The controller of your personal data is:
Maurice Hurdebise, independent entrepreneur (natural person), operating under the trade name "Jack & Mani". Company number (BCE): 0805.203.037 (not subject to VAT). Address: Rue Chaumont 9, 4970 Stavelot, Belgium. Email: info@jackandmani.com.
Jack & Mani offers an artificial-intelligence-powered investigation game, available as a web version (playable from your browser) and as a downloadable app on the app stores. The game includes a classic "digital" mode and a location-based "outdoor" mode, which guides you through real places in a city.
This policy is governed by Belgian law and by the General Data Protection Regulation (GDPR). The competent supervisory authority is the Data Protection Authority (DPA) in Belgium.
Note: the web version and the mobile app may involve different processing. This policy mainly describes how the web version works; some features (such as continuous location tracking) may go further on the native mobile app.
2. Data we process
We process the following categories of data, depending on how you use the service.
Account and authentication data: email address and password (the password is hashed and managed by our authentication provider, never stored in plain text by us), email verification status, technical account identifier (UID), display name (username) and profile picture if you provide them or if you sign in with Google, as well as the creation and last login dates. You can also play in guest mode (anonymous account), without providing an email.
Game profile and progress: username, avatar, last city played, daily streak, game preferences (automatic voice playback, notifications, academic mode), unlocked features, status of the dialogues seen with the character Mani, as well as your game statistics (experience, score, distance traveled, badges, progress per investigation). This data is stored locally on your device; for permanent (non-anonymous) accounts, progress statistics are also synced to our servers.
Content of conversations with the AI: the text of the messages you send to the game characters (free input), the recent conversation history and the context of the current investigation. In academic mode, the text you enter is also analyzed for spelling and grammar correction.
Location data (outdoor mode only): your GPS coordinates (latitude, longitude) and, where applicable, your heading, updated during the game. The city inferred from your location is kept. Your IP address is, in effect, shared with our mapping provider when the map loads and when the city name is looked up.
Technical and security data: your technical identifier (UID) is used as a rate-limiting key (anti-abuse) and is sent to our AI provider as an end-user identifier. Your IP address and technical headers may be logged by our hosting provider.
Activity data (fitness tracking, optional): only if you turn on fitness tracking in your account options, we keep, per day, the distance covered during outdoor investigations, the time spent playing outdoors and the number of outings. These aggregates are used to show your fitness indicator, your estimated steps and an estimate of calories. No movement trace is recorded, and tracking stays off by default.
We do NOT collect a company name, postal address or phone number, contrary to what our previous policy stated.
3. Purposes and legal bases
We only process your data for specified purposes and on a precise legal basis (Article 6 of the GDPR).
Providing the game and managing your account (account creation, sign in with email/password including verification and reset, sign in with Google, guest mode, linking a guest account to a permanent account, saving progress): performance of the contract (art. 6.1.b).
Running the chat with the AI characters (generating the characters' replies from your messages): performance of the contract (art. 6.1.b), since this conversational mechanic is the core of the service you are requesting.
Correcting your messages in academic mode (spelling, grammar): performance of the contract (art. 6.1.b), an educational feature that you activate.
Making the characters "speak" (voice synthesis of the text of the game dialogues): performance of the contract (art. 6.1.b).
Offering the location-based outdoor mode (displaying the map, determining the city, locating your position): your consent for enabling location tracking (art. 6.1.a), collected through the permission prompt of your browser or system, then performance of the contract (art. 6.1.b) for providing the mode once enabled. Location tracking is never triggered automatically: it is triggered only after an explicit click on your part.
Ensuring security and preventing abuse (automated content moderation, chat rate limiting, cost control, protection of minors): legitimate interest (art. 6.1.f), and where applicable compliance with a legal obligation (art. 6.1.c) for certain moderation obligations.
Audience measurement, product analytics, session replay and error tracking: your consent (art. 6.1.a), collected through the cookie banner. These processing activities are only enabled after your agreement. See the Cookies section.
Managing purchases (freemium model: three free investigations, then paid content by the unit or by season): performance of the contract (art. 6.1.b) and accounting obligations (art. 6.1.c) for keeping invoices. The subscription offer is not yet available.
Account and authentication
Data
Email, password (hashed by the provider), verified email, technical identifier (UID), username and picture (if provided or via Google), creation/login dates. Guest mode possible without an email.
Purpose
Create and manage the account, sign you in (email/password, Google, or guest), link a guest account to a permanent account.
Legal basis
Performance of the contract (art. 6.1.b GDPR).
Recipients
Google / Firebase Authentication (processor).
Retention
For as long as the account exists; no automatic purge to date (to be confirmed).
Game progress and statistics
Data
Username, avatar, experience, score, distance, badges, progress per investigation, preferences, last city, daily streak.
Purpose
Save your progress and preferences, display your statistics, feed the leaderboards.
Legal basis
Performance of the contract (art. 6.1.b GDPR).
Recipients
Local storage on your device; for permanent accounts, syncing to Cloud Firestore (Google).
Retention
Local: until the browser is cleared or you sign out. Server: for as long as the account exists; weekly per-city leaderboards expire after ~15 days.
Conversations with the AI
Data
Text of your messages, recent history (last 10 messages), investigation context, technical identifier (UID) sent as an end-user identifier. For the help assistant: your question and technical information about your device (browser, platform) sent for troubleshooting.
Purpose
Generate the replies of the game characters and of the help center assistant (conversational mechanic).
Legal basis
Performance of the contract (art. 6.1.b GDPR).
Recipients
OpenAI (United States).
Retention
Messages not kept by us (transit), and on OpenAI's side per its policy. Questions the help assistant could not resolve are kept in a non-identifying form (without your identifier) for up to 12 months, to improve the FAQ.
Automated moderation
Data
Raw text of your message, before the reply is generated.
Purpose
Detect and filter out inappropriate content (in particular protection of minors) and prevent abuse.
Legal basis
Legitimate interest (art. 6.1.f GDPR), where applicable a legal obligation (art. 6.1.c).
Recipients
OpenAI (United States), moderation API.
Retention
Not kept by us (the result is used then discarded).
Academic correction
Data
Text of your message (only when academic mode is enabled).
Purpose
Correct spelling, grammar and clarity for educational purposes.
Legal basis
Performance of the contract (art. 6.1.b GDPR).
Recipients
OpenAI (United States).
Retention
Not kept by us; the correction is returned then saved locally with the message.
Voice synthesis (character voices)
Data
Text of the character dialogues to be voiced, voice identifier, language (not the personal content of your messages).
Purpose
Make the game characters "speak".
Legal basis
Performance of the contract (art. 6.1.b GDPR).
Recipients
ElevenLabs (United States), via a server function in the EU; audio cache at Google.
Retention
Audio cache ~7 days; daily quota per user.
Location tracking (outdoor mode)
Data
GPS coordinates (latitude, longitude), heading if available, IP address in effect, name of the inferred city.
Purpose
Display the map, determine the city where you are playing, locate your position during the game.
Legal basis
Consent for enabling it (art. 6.1.a) then performance of the contract (art. 6.1.b GDPR).
Recipients
Mapbox (United States).
Retention
Coordinates not persisted (in memory during the game); city name kept.
Security and rate limiting
Data
Technical identifier (UID) used as an anti-abuse counter key; IP address/logs on the hosting side.
Purpose
Prevent abuse, control costs, ensure the availability and security of the service.
Legal basis
Legitimate interest (art. 6.1.f GDPR).
Recipients
Google / Firebase Realtime Database; hosting provider for the logs.
Retention
Chat counter ~60 s; daily voice quota; logs according to the hosting provider (to be confirmed).
Friends and social sharing
Data
Your username, your avatar and your score, shared with the players you add as friends; signed, temporary invitation token encoded in a QR code or a link.
Purpose
Allow you to add friends (by scanning a QR code in person or through a link), display your friends list and compare your scores.
Legal basis
Performance of the contract (art. 6.1.b GDPR).
Recipients
Google / Cloud Firestore (processor) and the other players you add as friends.
Retention
For as long as the friendship exists, until you or your friend removes it.
Multiplayer games
Data
When you play an investigation together on site: your nickname and score shared with the other players in the game, and the temporary association of participants in the same game (who plays with whom).
Purpose
Let several people play the same investigation together in person, and show the live ranking and the end-of-game ranking.
Legal basis
Performance of the contract (art. 6.1.b GDPR).
Recipients
Google / Cloud Firestore (processor) and the other players in the same game.
Retention
Transient data, deleted automatically when the game expires (a few hours). Nothing is kept after the outing.
Push notifications
Data
Device token for notifications (FCM token) and preferred language.
Purpose
Send you game-related notifications (for example a friend request or its acceptance), when you have allowed them.
Legal basis
Consent (art. 6.1.a GDPR).
Recipients
Google (Firebase Cloud Messaging).
Retention
For as long as the permission remains active; the token is deleted when you disable notifications.
Error tracking and stability
Data
Technical diagnostic data and error logs (device and session information), without identifiable personal data.
Purpose
Detect and fix crashes and technical problems to ensure the stability and security of the service.
Legal basis
Legitimate interest (art. 6.1.f GDPR).
Recipients
Sentry (United States).
Retention
Up to 90 days.
Audience measurement and analytics
Data
Usage data, events, session replay.
Purpose
Measure the audience, analyze and improve the product.
Legal basis
Consent (art. 6.1.a GDPR).
Recipients
Google Analytics 4 (USA), PostHog (EU), after your consent.
Retention
According to the retention settings of each measurement tool.
Purchases
Data
Customer identifier, subscription/transaction identifier, amount, currency, dates, invoice. No card data stored by us.
Purpose
Process the freemium model payments and billing.
Legal basis
Performance of the contract (art. 6.1.b) and accounting obligation (art. 6.1.c GDPR).
Recipients
Stripe (USA) for payment processing; purchase record kept at Google (Firestore, EU).
Retention
Belgian legal accounting period (approx. 7 years) for invoices.
Fitness tracking (optional)
Data
Distance covered per day, time spent on outdoor investigations per day, number of outings per day, and the values derived from them (estimated steps, estimated calories, fitness indicator). No movement trace is kept.
Purpose
Show you a fitness indicator and your activity statistics in your account, if you have turned this option on.
Legal basis
Consent (art. 6.1.a GDPR), withdrawable at any time in your account options.
Recipients
None. Data kept with Google (Firestore, EU) in a private sub-document, not shared with third parties.
Retention
Rolling 14 days, automatically purged. Deleted immediately and entirely if you withdraw your consent.
4. Recipients and processors
We do not sell your data and we do not use any advertising network. Your data is shared only with the technical providers (processors) strictly necessary for the service to work, acting on our instructions.
Google / Firebase (Google Ireland Limited and Google LLC): authentication (Firebase Authentication), sign in with Google, game database (Cloud Firestore), real-time database (Realtime Database, for the anti-abuse counters), server functions (Cloud Functions, europe-west1 region), audio file storage (Cloud Storage) and site hosting. Your email address stays confined to the authentication service and is not copied into the game database.
OpenAI (OpenAI, L.L.C., United States): generating the characters' replies, automated content moderation and academic correction. OpenAI receives the text of your messages, the recent conversation history and your technical identifier (UID), sent as an end-user identifier.
ElevenLabs (United States): voice synthesis. ElevenLabs receives the text of the character dialogues to be voiced (and not the personal content of your messages). The call is relayed by a server function hosted in the European Union, then the audio is cached at Google.
Mapbox (Mapbox, Inc., United States): mapping and geocoding for the outdoor mode. Mapbox receives your GPS coordinates (to determine the city name) and your IP address (when the map tiles load).
Measurement stack (enabled after your consent): Google Analytics 4 (audience measurement), PostHog hosted in the European Union (product analytics, session replay, A/B testing, surveys) and Sentry (error tracking). These tools are described in our cookie policy.
Stripe (Stripe, Inc., United States): payment processing. Your card data is entered and processed directly by Stripe and is never received or stored by us; we only keep a purchase record (amount, date, transaction identifier, invoice).
If players' usernames were ever to appear in public leaderboards, this would be clearly indicated to you.
5. Transfers outside the European Union
Some of our processors are established in the United States or may access your data there. Transfers outside the European Union therefore take place:
Google / Firebase: Firestore, the Realtime Database and the Cloud Functions are hosted in the European Union (europe-west1, Belgium); however, Firebase Authentication is a global Google service and your login credentials may be processed outside the EU, with Google (a US company) also being able to access the data remotely; OpenAI (United States): transfer of the content of your messages and of your identifier; ElevenLabs (United States): transfer of the text of the dialogues to be voiced; Mapbox (United States): transfer of your GPS coordinates and of your IP address; Stripe (United States): transfer of the data necessary to process the payment.
These transfers are governed by the safeguards provided for by the GDPR: the European Commission's standard contractual clauses and, where applicable, membership of the EU-US Data Privacy Framework.
Our PostHog instance is hosted in the European Union and does not involve a transfer outside the EU in this respect. Google Analytics 4 and Sentry, on the other hand, may process data in the United States. These measurement processing activities are only enabled after your consent.
6. Retention periods
Account and synced progress data: kept for as long as your account exists; an account that remains inactive for 36 months is deleted or anonymized. Weekly per-city leaderboards automatically expire after about 15 days.
Data stored locally (progress, preferences, game saves, in-game conversations): kept in your browser until you erase it (clearing the browser). On sign-out, local game data is removed from your browser; in guest mode, it is stored for the duration of the session and erased when the tab is closed.
GPS coordinates: not kept persistently. They only live in memory during the game and are lost when the page reloads. Only the name of the inferred city is kept.
Anti-abuse counters (rate limiting): ephemeral. The chat counter expires after about 60 seconds; the voice synthesis quota is daily (600 requests per day per user). The audio cache is kept for about 7 days.
Content sent to OpenAI and ElevenLabs: we do not keep it on our side (it only passes through). Any retention by these providers is governed by their own policy (generally a temporary retention for abuse-prevention purposes).
Activity data (fitness tracking): kept for 14 days at most, as daily aggregates, then purged automatically. It is deleted immediately and entirely if you turn fitness tracking off.
Invoices and payment records: kept for the legal accounting period applicable in Belgium (generally 7 years).
7. Your rights
In accordance with the GDPR, you have the following rights over your personal data:
Right of access: obtain confirmation that data concerning you is being processed and receive a copy of it; Right to rectification: have inaccurate or incomplete data corrected; Right to erasure: request the deletion of your data, under the conditions provided for by the GDPR; Right to restriction of processing; Right to object, in particular to processing based on our legitimate interest; Right to data portability: receive your data in a structured format, or have it transferred to another controller; Right to withdraw your consent at any time, for the processing that depends on it (location tracking, audience measurement, product analytics), without this affecting the lawfulness of the processing carried out before the withdrawal.
To exercise these rights, write to us at info@jackandmani.com. We generally respond within one month.
Account deletion: the service does not yet offer a self-service account deletion button. To have your account and the associated data deleted, send us your request by email at info@jackandmani.com; we will act on it within a maximum of 30 days.
You also have the right to lodge a complaint with the Data Protection Authority (DPA) in Belgium: Rue de la Presse 35, 1000 Bruxelles (www.autoriteprotectiondonnees.be).
8. Protection of minors
Our game is aimed at a family audience, which may include children.
In Belgium, the age from which a minor can consent on their own to the processing of their data in the context of information society services is set at 13. Below that age, processing is only lawful with the consent of the holder of parental authority.
We draw the attention of parents and guardians to the fact that the game lets you have free-text conversations with characters powered by an artificial intelligence hosted in the United States (OpenAI), with voice synthesis (ElevenLabs, United States), and that the outdoor mode relies on location tracking. We have set up automated moderation of messages in order to detect and filter out inappropriate content, in particular content involving minors.
We recommend that parents accompany and supervise their children's use of the game, especially in outdoor mode (moving around real places). If you believe that a child has sent us data without the required consent, contact us at info@jackandmani.com so that we can carry out the necessary checks and, where applicable, delete it. The indoor mode is accessible from around age 9, under the responsibility of a parent or guardian, and parental consent is required for those under 13, as detailed in our terms of use; the technical arrangements for collecting this consent are being put in place.
9. Cookies and trackers
The service uses trackers strictly necessary for it to work (in particular your browser's local storage for sign-in and saving your progress, and the session persistence of the authentication). These trackers do not require your consent.
The other trackers (audience measurement, product analytics, session replay, error tracking) are only enabled after your consent, collected through a banner on your first visit. You can change or withdraw this consent at any time.
Location tracking is not a cookie but a device permission, requested separately at the moment you launch the outdoor mode.
The details of cookies and trackers, the providers concerned and the ways to manage your consent are set out in our cookie policy, available at /legal/cookies.
10. Security
We implement appropriate technical and organizational measures to protect your data: encryption of exchanges (HTTPS), password management through a specialized authentication service (hashing, never plain-text storage on our side), request authentication using secure tokens, rate limiting of calls (anti-abuse) and automated content moderation.
GPS coordinates are not kept persistently and remain, by design, on your device during the game. Game conversations are saved locally on your device.
Since no measure can guarantee absolute security, we encourage you to choose a strong password and not to reuse it elsewhere.
11. Changes to the policy
We may update this policy, in particular to reflect new features (for example public leaderboards or the subscription offer) or legal developments.
Any change will be published on this page and will take effect as soon as it is published. In the event of a substantial change, we will make our best efforts to inform you by an appropriate means. We encourage you to check this page regularly.
12. Contact
For any question relating to this policy or to the exercise of your rights, you can write to us at:
Maurice Hurdebise (Jack & Mani) Rue Chaumont 9, 4970 Stavelot, Belgium Email: info@jackandmani.com
You can also lodge a complaint with the Data Protection Authority (DPA) in Belgium: www.autoriteprotectiondonnees.be.