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Privacy Policy - Your Data & Privacy Rights

Last updated: January 2025

01 Introduction and Data Controller

This Privacy Policy explains how GuessTheLean, operated by Daniel Samer ("we", "us", or "our"), collects, uses, discloses, and protects your personal information when you play our free browser game.
GuessTheLean is a guessing game in which players estimate how the crowd rates a word, name, or topic on a left-to-right scale. To make this work, we aggregate players' guesses into the crowd distribution shown after each round.
We are committed to protecting your privacy and ensuring that your personal data is handled in accordance with applicable data protection laws, including the EU General Data Protection Regulation (GDPR).
Data Controller:
GuessTheLean
Operated by Daniel Samer
Am Alefskamp 50
47198 Duisburg
Germany
Email: blogs@samer.email
Phone: +49 15225669203
By using the game, you acknowledge that you have read and understood this Privacy Policy.

02 Data We Collect

We aim to collect as little personal data as possible. Depending on how you use the game, we may collect:
Gameplay Data:
- The guesses you submit during a round
- Your scores, streaks, and progress
- Which challenges you have played
Optional Account Data (only if you register):
- Username
- Email address
- Password (encrypted)
Technical Data:
- IP address
- Browser type and version
- Device and operating system information
- Cookies and similar technologies (see our Cookie Policy)
Usage Data:
- Pages and challenges visited
- Time spent in the game
- Referral source
We collect data directly from you and automatically through your use of the game. We do not require you to create an account to play.

03 How We Use Your Data

We use your data for the following purposes:
Running the Game:
- To show you challenges and record your guesses
- To calculate scores, streaks, and leaderboards
- To aggregate guesses, in anonymized form, into the crowd distributions shown to all players
Communication (only where relevant):
- To respond to your inquiries and support requests
- To send account-related notifications, if you have an account
Improvement and Security:
- To analyze usage patterns and improve the game
- To detect and prevent bots, cheating, and manipulation of results
- To comply with legal obligations
Legal Bases for Processing (GDPR):
- Contract Performance: Processing necessary to run the game for you
- Consent: Processing based on your explicit consent
- Legitimate Interests: Processing for our legitimate interests, such as preventing abuse and improving the game
- Legal Obligation: Processing required by law

04 Data Sharing and Disclosure

We do not sell your personal data. We may share your information in the following limited circumstances:
Service Providers:
We work with third-party companies that help us operate the game, such as:
- Hosting and cloud infrastructure providers
- Analytics services
- Email service providers (for account-related messages)
These providers are contractually bound to protect your data and use it only for specified purposes.
Legal Requirements:
We may disclose your data if required to comply with legal obligations or valid legal process, protect our rights, property, or safety, or investigate potential violations of our Terms.
Business Transfers:
In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity. We will notify you of any such change.
With Your Consent:
We may share your data for other purposes with your explicit consent.

05 Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected:
Anonymous Play:
- Aggregated and anonymized crowd data is retained to keep the game working, but it is not tied to your identity
Optional Accounts:
- Account data is retained while your account is active
- You can request deletion at any time
Specific Retention Periods:
- Account information: Duration of account plus 30 days
- Support correspondence: 3 years
- Server logs: 90 days
We regularly review our retention practices to ensure we don't keep data longer than necessary.

06 Your Rights Under GDPR

Under the General Data Protection Regulation (GDPR), you have the following rights:
1. Right of Access: You can request a copy of your personal data and information about how it's processed.
2. Right to Rectification: You can request correction of inaccurate or incomplete personal data.
3. Right to Erasure ("Right to be Forgotten"): You can request deletion of your personal data under certain circumstances.
4. Right to Restrict Processing: You can request that we limit how we use your data.
5. Right to Data Portability: You can request your data in a structured, commonly used, machine-readable format.
6. Right to Object: You can object to processing based on legitimate interests or for direct marketing purposes.
7. Right to Withdraw Consent: Where processing is based on consent, you can withdraw it at any time.
8. Right to Lodge a Complaint: You can file a complaint with a supervisory authority if you believe your rights have been violated.
To exercise any of these rights, please contact us at blogs@samer.email. We will respond to your request within 30 days.
Supervisory Authority:
Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW)
https://www.ldi.nrw.de

07 Cookies and Tracking Technologies

We use cookies and similar technologies to run the game and improve your experience. For detailed information about the cookies we use and how to manage them, please see our Cookie Policy.
Types of Cookies:
- Essential Cookies: Required for the game to function (for example, to remember your current round or streak)
- Analytics Cookies: Help us understand how visitors use the game
You can control cookies through:
- Our cookie consent banner
- Your browser settings
- The cookie settings page

08 Security Measures

We implement appropriate technical and organizational security measures to protect your personal data, including:
Technical Measures:
- Encryption of data in transit (TLS/SSL)
- Secure password hashing for any optional accounts
- Regular security updates and patches
- Firewall and intrusion detection systems
Organizational Measures:
- Limited access to personal data on a need-to-know basis
- Incident response procedures
- Regular security assessments
While we strive to protect your data, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security but are committed to taking all reasonable steps to protect your information.
If you suspect a security breach, please contact us immediately.

09 Children's Privacy

GuessTheLean is a general-audience game and is not directed at children. We do not knowingly collect personal data from children under 16 without the consent of a parent or guardian, in line with applicable law.
If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately. We will take steps to delete such information from our systems.

10 International Data Transfers

Your data is primarily processed within the European Union. If we transfer your data outside the EU/EEA, we ensure appropriate safeguards are in place:
- Standard Contractual Clauses approved by the European Commission
- Adequacy decisions by the European Commission
- Other legally recognized transfer mechanisms
By using the game, you understand that your information may be transferred to, stored, and processed in countries outside your country of residence.

11 Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons.
When we make changes:
- We will update the "Last Updated" date at the top
- For material changes, we will provide prominent notice on the platform
We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.
Your continued use of the game after changes become effective constitutes acceptance of the revised Privacy Policy.

12 Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:
Daniel Samer
Am Alefskamp 50
47198 Duisburg
Germany
Email: blogs@samer.email
Phone: +49 15225669203
For GDPR-related inquiries, you may also contact the supervisory authority:
Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen (LDI NRW)
Kavalleriestraße 2-4
40213 Düsseldorf
Germany
https://www.ldi.nrw.de

Last updated: January 2025