Privacy policy

1. Who is responsible

DOROBANTI NETWORK S.R.L., trading as Dorobanti Media, is the controller of personal data processed through this website and our support service. Use the contacts below for questions or requests about your data.

2. In the app

Secret Subject has no accounts, ads, analytics tools or game server. Player names, assigned identities, candidates, answers and scores are processed in device memory only for the current session. You can use a pseudonym. Each screen shows the other player’s assigned identity. The Host’s device holds complete game state while the other device receives only the information needed by its player.

The app does not send game data to us or save it to disk or the cloud. Local Network permission enables discovery and an encrypted connection on the same Wi-Fi. Discovery advertises the Host’s chosen in-game name and a temporary game identifier to devices browsing this app’s local service. After selecting a game, both chosen names are exchanged over the encrypted pending connection. Game data is withheld until the players compare the displayed code and both approve. Temporary encryption identities, approvals and reconnection state remain in session memory; a new game starts a new connection approval.

Secret Subject does not access the camera, microphone, contacts or GPS location. There is no access code to copy or paste, and the app does not read the clipboard automatically. The displayed comparison code is checked by the two players; it is not a password, account or proof of a person’s identity. Use a nickname suitable for local discovery and hide names and comparison codes in support screenshots.

Website links open the browser without game data. The visit involves the processing described in the next section. For beta versions, we do not download or separately archive TestFlight feedback and crash reports; data in Apple’s service is managed under that service’s rules.

Secret Subject + uses StoreKit for purchases, restoration and access checks. The app uses verified transaction and subscription evidence in memory, including identifiers, purchase dates and expiry, to decide access. Apple handles the purchase and payment processing; the app does not receive card or payment-method details. The game does not save a subscription database. Apple may separately provide the publisher with receipts and subscription reports. These records are distinct from the app’s local access check; their availability does not establish that the publisher exports or retains them. Actual publisher access, exports and retention periods remain to be confirmed before this draft is approved.

The language preference (System, Romanian or English) is saved locally and can be changed in the app. Separately, custom theme titles and names remain on the device: you save them only on the device where you create them, in system-protected files excluded from app backups. There is no contacts import, account, cloud sync or list publishing. The app does not send the library to the publisher. The Host keeps the full list; the Guest receives the theme title and the game projection for their own screen over the encrypted local connection, without saving the Host’s library.

3. When you visit the website

Vercel hosts this website and receives your IP address, requested page and technical information sent by your browser to deliver pages. The provider’s exact security and error log categories are still being verified.

The website code includes no advertising, visitor analytics, forms or embedded third-party widgets. It sets no cookies or preferences in browser storage. The page address selects the language. The hosting provider may process technical data for delivery and security; this is separate from game-session data.

Vercel Pro with Observability Plus is enabled. Vercel documents 30-day retention for observability data and runtime logs. No drains are configured. Other provider records and recovery copies have separate retention.

4. When you contact us

Our shared address for support and privacy requests is listed in the contact section. When you write, we receive your email address, your name if provided, your message and any attachments. Telephone contact may disclose your number and the information you share. We do not automatically receive game data. We use the details you send to support only to handle your request, with no marketing, tracking or profiling.

Contact is optional. To help, we need details of the problem and a way to reply. Avoid player names and remove unnecessary personal data from screenshots. Do not send passwords or identity documents without a justified request.

The developer personally handles support and privacy requests. We use Apple iCloud Mail for email and do not record support calls. Only the developer has access to the mailbox. Support mail is not forwarded. The provider-controlled account and recovery arrangements still require review.

5. Why we use this data

For delivering and protecting the website and answering support questions, this draft proposes legitimate interests: operating a secure website and providing the help you request (GDPR Article 6(1)(f)). The assessment of necessity and privacy impact is still in progress.

Data-rights requests are handled under our legal obligation in the GDPR (Articles 6(1)(c) and 12–22). We do not use data for marketing, profiling or automated decisions with legal or similarly significant effects.

6. Providers and transfers

Vercel hosts the website and Apple iCloud Mail provides email. The contracting entities, roles and actual configuration of these services must be confirmed before this draft is approved. Apple also manages app distribution and system permissions under its own terms; the game has no cloud service.

Vercel’s published DPA covers processor handling on Pro and Enterprise and includes international-transfer clauses. Apple’s Privacy Policy describes international processing and Standard Contractual Clauses for EEA transfers. These published frameworks do not establish our exact account arrangements or promise EU-only storage. Account-specific roles, recipients and applicable safeguards still require review. You can request recipient details and a copy of applicable safeguards.

7. How long we keep data

The language preference remains saved locally between launches, until you change it or the app’s data is removed. Game session data stays in memory and is not saved for a later launch. Completely closing the app loses the session. Saved custom themes remain separately on the device until you delete them under Temele mele. You can view, edit and delete them even after Plus expires. Deletion removes the theme from the app’s library. The publisher holds no account or round archive. Local Network permission is managed separately in iOS/iPadOS Settings.

We delete routine support emails, attachments and necessary call notes 90 days after the request is resolved. At the same deadline, we empty the trash for these messages and delete associated downloaded attachments and exports. Records required for legal obligations or disputes have separately justified retention for each category and situation; the 90-day period does not automatically apply to them.

Support mail is not forwarded. Only the owner accesses the devices that receive it. Neither mail nor downloaded support files are included in local or device backups. Retention of hosting records outside the documented Plus window and rights-request records, and the handling of provider-controlled copies and backups, still require verification. Deleting a message does not establish immediate deletion from provider backups.

8. Your rights

Under the GDPR’s conditions, you can request access, correction, erasure or restriction. Portability applies when its legal conditions are met. We have no database of your games to search or export.

You can object to processing based on legitimate interests on grounds relating to your situation. We must stop that processing unless a GDPR exception applies.

Use the contacts above for requests. We reply without undue delay, within one month of receipt. If the number or complexity of requests justifies an extension of up to two months, we notify you within the first month and explain why. Requests are generally free of charge, subject to the GDPR’s exceptions.

You can complain to ANSPDCP or the supervisory authority in the EU country where you live, work or believe the infringement occurred. ANSPDCP’s procedure is linked below. You also have the right to go to court.

9. Updates and document status

This is a draft for the operator’s review, with no effective date or legal approval. Unconfirmed information is explicitly identified. Legal rights apply throughout this period. Once facts are completed and approved, we publish the version and update date; feature or provider changes require a new review.