Privacy PolicyYour data, with full transparency

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.

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.

Origin of your visit (Teacher offer): if you have accepted audience measurement, we store in your browser how you arrived on the site on your first visit, namely the campaign parameters in the page address, the Google Ads click identifier, the name of the site you came from, the landing page and the date. If you then subscribe to a Teacher offer, this information is attached to your subscription at Stripe.

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.

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.

Knowing where Teacher subscribers come from (which channels, for example a search engine, an ad or a partner site, bring in teachers): your consent to audience measurement (art. 6.1.a), collected through the cookie banner. Without this consent, nothing is stored or attached to your subscription.

Managing purchases (freemium model: one free investigation, 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 Teacher offer is available as a subscription, annual or monthly.

We do not sell your data and we do not show any advertising in the service. If you have accepted audience measurement, a Google Ads tag only measures sign-ups that come from our own Google ads, and is never used to build ad retargeting audiences. 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). For Teacher offer subscriptions, Stripe also receives the origin of your first visit described above, only if you have accepted audience measurement.

If players' usernames were ever to appear in public leaderboards, this would be clearly indicated to you.

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, Google Ads and Sentry, on the other hand, may process data in the United States. These measurement processing activities are only enabled after your consent.

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.

Origin of your first visit (Teacher offer): in your browser, until you withdraw your consent to audience measurement, which erases it, or until you clear your browser. At Stripe, kept with the subscription concerned, for the same period as purchase data.

Invoices and payment records: kept for the legal accounting period applicable in Belgium (generally 7 years).

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).

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.

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.

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.

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.

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.