Privacy Policy

1. Who is responsible

Criminaler is operated by IT Sebastian Domagała, a Polish sole proprietorship. The operator is the controller of personal data processed for the Criminaler service.

For privacy requests—including access, deletion, correction, or objection—contact privacy@criminaler.com.

2. Information we process

• A generated anonymous device identifier, game progress, attempts, scores, ticket balance, streaks, and quiz-session history.
• AI Investigation messages and the replies generated for the quiz. Please do not enter personal or sensitive information.
• Feedback you voluntarily send, including any text and contact details you choose to include.
• Rewarded-ad verification and anti-fraud records.
• Technical and security data in API, hosting, and infrastructure logs.
• Cookieless website analytics and pseudonymous mobile product analytics, as described below.

3. Location

If you choose “my location” in the Case Atlas, the app asks the device for location access only to position the map. Criminaler does not intentionally include precise coordinates in product-analytics events. Device, network, infrastructure, analytics, and advertising providers may still process technical location signals such as an IP-derived approximate location under their own roles and policies.

4. Why we use information

Depending on the processing, the proposed legal bases are performance of the service, consent for third-party AI processing where requested, legitimate interests in service security and proportionate analytics, and compliance with legal obligations. These bases remain subject to final legal review.

• To provide quizzes, save progress, calculate scores, operate tickets, and prevent duplicate or fraudulent rewards.
• To answer AI Investigation messages and keep the investigation transcript available to you.
• To provide support, review corrections, secure the service, diagnose faults, and meet legal obligations.
• To understand product use and improve Criminaler through limited analytics.

5. Analytics

The website uses the existing PostHog EU service only when its optional analytics key is configured. Website analytics are cookieless, do not identify visitors, respect Do Not Track, and use explicit page-view and App Store conversion events only. We disable automatic capture, session replay, surveys, heatmaps, dead-click capture, and feature flags.

The mobile app uses a generated anonymous identifier for first-party product analytics. It is not used for cross-company advertising or Apple-defined Tracking. Before release, Settings must provide a control to disable future mobile analytics. Disabling analytics will not itself erase historical events.

6. Advertising and AI recipients

Before release, rewarded ads must use Google AdMob with Google’s consent tools. Initial ads will be requested as non-personalized, subject to the consent and limited-ad choices available in your region.

Before release, AI Investigation must send messages through OpenRouter to AI model providers only after the in-app disclosure is accepted. Criminaler requires routes that deny provider data collection and support Zero Data Retention; if no compliant endpoint is available, the AI feature may be unavailable. Operational metadata may still be handled under the providers’ documented policies.

7. Other recipients and transfers

We use service providers for infrastructure and hosting, analytics, advertising and consent, AI processing, and operational support. Criminaler’s primary API and database are intended to be hosted in the EU, subject to final dashboard verification. Some providers may process data outside the EEA; applicable contractual and legal safeguards must be verified before launch.

We do not sell personal data and do not use Criminaler analytics for cross-company advertising.

8. Retention

These are the launch targets. Automated deletion jobs, provider settings, and backup rotation must be verified before publication.

• Gameplay records and AI custom-quiz history: until deletion or 24 months after inactivity.
• Feedback and PostHog analytics: 12 months.
• API and infrastructure logs: 30 days.
• Backups containing deleted or expired records: expire within 30 days.
• Rewarded-ad anti-fraud records: 24 months, with the user link removed earlier where practical.

9. Your choices and rights

You may have rights to access, correct, delete, restrict, or object to processing, and to withdraw consent without affecting earlier lawful processing. You may also complain to the Polish data-protection authority or another competent supervisory authority.

The app’s Delete My Data action is intended to delete or de-identify server records linked to the current anonymous ID, address historical analytics deletion, clear local app data, and create a fresh ID only after server confirmation. Until that flow is verified, do not treat Reset local data as server-side deletion.

10. Children, security, and changes

Criminaler is intended only for adults aged 18 and over and is not directed to children. We use proportionate technical and organizational safeguards, but no online service can guarantee absolute security.

Material policy changes will appear in the change history. The app will provide a notice when a material change affects users and will request permission again if a consent-based purpose or recipient category materially changes.