Effective date / version: [EFFECTIVE DATE] (draft, version [VERSION])
[LEGAL ENTITY NAME], [REGISTERED BUSINESS ADDRESS], [COUNTRY], is the controller of personal data processed to operate Don Quack, subject to confirmation of applicable legal roles. Privacy contact: [PRIVACY CONTACT]. Representative/DPO if required: [DATA CONTROLLER CONTACT/REPRESENTATIVE IF REQUIRED].
We use account, forecast, preference and subscription data to deliver the requested service and fulfil purchases (contract/performance at your request); sign-in/security records to prevent abuse and secure systems (legitimate interests, balanced against your rights); and payment/accounting records for legal obligations where applicable. Support processing may be necessary for contract performance, legitimate interests or legal compliance according to the request. Any optional marketing or non-essential tracking would need a separate lawful basis and, where required, consent; this draft does not authorize either. We do not describe sports forecasts as automated decisions producing legal or similarly significant effects about you.
Access is limited to authorized operators and service providers as needed, subject to [PROCESSOR CONTRACTS AND LOCATIONS]. Source identifies:
We may disclose data to competent authorities when legally required or to protect legitimate rights subject to applicable safeguards. No advertising sale or new ad-pixel integration is part of this draft. Third-party sites/checkout have their own policies; review them before use.
The inspected web app uses localStorage dq_token for the sign-in session token and dq_lang for your language preference. The source default session lifetime is 30 days, configurable; token expiry does not necessarily physically remove the stored item. Signing out removes the token from that browser; language preference persists until changed or cleared. Clearing site storage removes local copies and may sign you out but does not delete server records. These are not described as one single storage item or as sessionStorage-only. The inspected product has no authorized analytics/advertising pixels in this scope; do not add them without a separate review and required notice/consent. Hosting and request logs are distinct from ad tracking.
We minimize retention according to service, security and legal needs. Inspected cleanup normally deletes forecasts older than 30 days; this is not a promise that every type of personal data is deleted after 30 days. Unrelated Top Picks and sent markers normally have a seven-day cleanup rule, but picks referenced by pending accumulators are preserved and can persist longer. Retention can therefore affect displayed performance history.
Accounts/preferences: [ACCOUNT RETENTION]. OTP/database request records: [OTP RECORD RETENTION] (default sign-in code validity is 10 minutes, not a deletion policy). Payment, subscription and accounting records: [PAYMENT AND TAX RECORD RETENTION]. Logs: [SERVER AND SECURITY LOG RETENTION]. Support: [SUPPORT RETENTION]. Backups: [BACKUP RETENTION AND DELETION CYCLE]. Legal holds may require longer retention, restricted to that purpose. Owner must establish and test these schedules; no automatic full-account deletion or immediate purge from backups is claimed.
Contact [PRIVACY CONTACT] to request access, correction, deletion, restriction, objection or portability where applicable, or to withdraw consent for any consent-based processing without affecting prior lawful use. We may need proportionate identity verification and may retain records required by law or for legitimate claims. Rights workflow: [RIGHTS REQUEST HANDLER AND VERIFICATION PROCESS]. The app does not currently provide a verified self-service full-account deletion button; clearing localStorage or signing out is not account deletion. You may complain to [SUPERVISORY AUTHORITY] or the relevant authority where you live/work when applicable. Statutory response deadlines apply; this draft does not invent a different period.
Source includes hashed one-time codes, expiring signed sessions, authenticated ownership-scoped account/payment access and signed payment-callback checking. No system is risk-free; these design measures are not an independent security certification or assurance that all deployment settings are correct. Security/incident contact/process: [SECURITY/INCIDENT CONTACT AND PROCESS]. Processing may occur outside your country through the providers above. Destinations and appropriate safeguards: [INTERNATIONAL TRANSFER SAFEGUARDS]. Do not assert EU-only storage or adequacy/standard clauses until confirmed.
The service is intended for adults aged at least 18 or the higher applicable minimum; we do not knowingly offer it to children. Contact [PRIVACY CONTACT] if you believe a child has supplied data so that the responsible operator can assess and take appropriate action. Material changes to processing will be reflected here and notified where required. This draft is not consent to undisclosed future processing.