Draft
Privacy policy
Working version dated 2026-11-14
DRAFT AWAITING LEGAL REVIEW (BLO-46). This is a working translation of the Polish draft. It is not legal advice and not a document ready for publication. If the two versions differ, the Polish version prevails. Fields marked [like this] need completing or confirming by a lawyer.
1. Who is the controller
The data controller is [full name, address, tax ID and company register number of IT360] (“IT360”). Contact on data matters: [privacy e-mail address, to be set; until then the contact form on the home page].
2. Scope
The BlobIQ website and the BlobIQ game in its test version available in the browser (the TV screen and players' phones). Phone and TV apps are not available yet; we will extend this policy when they appear.
3. What data we process and why
| Data | Purpose | Legal basis | How long |
|---|---|---|---|
| Beta sign-up: e-mail address, selected site language, date and time of sign-up, version of the consent text | Informing about beta tests, apps and the BlobIQ launch | Consent (Art. 6(1)(a) GDPR), which you can withdraw at any time | Until consent is withdrawn or the project ends [set a maximum period] |
| Player name or nickname, blob appearance, room code, answers and scores in the game | Running the game | Contract for the service (Art. 6(1)(b) GDPR) [to be confirmed] | Until the room ends or the server restarts; the game state is in server memory [confirm whether anything is stored permanently] |
| Session identifier in the phone browser's memory (in the game, not on this website) | Returning to the game after a phone goes dark | Strictly necessary for the service, no consent [legal assessment: Art. 173 of the Polish Telecommunications Law] | Until the user deletes it or the session expires [period] |
| Technical connection data: IP address, time, browser type (server logs) | Security and diagnostics | Legitimate interest (Art. 6(1)(f) GDPR) | [period, e.g. up to 30 days] |
| Cookie-free visit statistics: page address, referrer, device and browser type, country; nothing stored on the device, no profiling [enabled only if analytics is configured; confirm provider, location and legal basis] | Understanding which content is read and whether the path to the game works | Legitimate interest (Art. 6(1)(f) GDPR) [legal assessment, including Art. 173 of the Polish Telecommunications Law] | [period per provider] |
| A message from the contact form (name, e-mail address, text) or e-mailed to us | Replying to the message | Legitimate interest (Art. 6(1)(f) GDPR) | [period] |
Please use a first name or nickname in the game. We do not ask for a surname, address or phone number. You give an e-mail address only if you sign up for the beta or write to us.
4. Cookies, video and fonts
- The website sets no cookies and has no cookie banner. Fonts are hosted by us, not by a third-party provider.
- The video (if present) loads from YouTube in enhanced privacy mode (youtube-nocookie.com) only after you click the play button. YouTube (Google) may then receive your IP address and browser data and may store data on your device under its own policy. [confirm transfers outside the EEA and the legal assessment]
- We do not sell data and we run no advertising on the website.
- Player names are not sent to the services that generate the host's voice: the lines and the names from the pool are pre-recorded. [confirm technically]
5. Recipients
Data is processed by our infrastructure providers (server hosting: [provider and location]) under data processing agreements. The beta list is stored on our server and is not passed to external mailing tools. [update when we choose a mailing tool; list of providers and any transfers outside the EEA]
6. Your rights
You have the right of access, rectification, erasure, restriction of processing, objection and data portability, the right to withdraw consent at any time (without affecting the lawfulness of earlier processing), and the right to lodge a complaint with the President of the Polish Personal Data Protection Office (UODO) or another supervisory authority. To exercise your rights or to remove your address from the beta list, write to the address in section 1. Player data is linked to a room, so we may ask for the room code and name.
7. Children
The game in its first version is intended for people aged 16 and over. [verify the age of consent under Art. 8 GDPR, Polish law and app store rules]
8. Changes
When we change how we process data (for example by adding accounts, payments or game statistics), we will update this policy and give the date of the change.