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LEGAL INFORMATION

Privacy policy

A game session, a website visit and a support message are different things. This policy explains each one separately.

Version: 2026-09-21-draft.1

Draft · Not yet in effectThis page is a publicly accessible, incomplete draft under review. It is not a final approved notice and does not limit your legal rights.Revised for completion: September 21, 2026

On this page

Who is responsible for this informationA. Data in the native appB. Visiting the websiteC. Email and telephone supportPurposes and legal basesRecipients and international transfersHow long data is keptYour rightsAutomated decisions and sensitive informationChildren and family useUpdates and external links

1. Who is responsible for this information

Cine sunt? is presented by DOROBANTI NETWORK S.R.L., trading as Dorobanti Media, tax identifier (CUI) 51010254, Trade Register number J2024047810002. For questions about personal data or to exercise your rights, contact contact@dorobantimedia.com or +40 730 000 064.

Registered office: Aleea Tomești nr. 9, bl. 15, sc. 2, et. 7, ap. 63, Sector 4, București, 042144, România

2. A. Data in the native app

The app temporarily uses player-chosen names, assigned identities, answer options, confirmed guesses, scores and technical session and reconnection data. These enable two players to connect, play rounds and determine results.

Game data is exchanged between the two nearby devices using Apple’s Wi-Fi Aware and networking features. The Host’s device manages the game state. During a round, each player sees the other player’s identity; the results can reveal both identities and submitted answers.

The app does not send the session to an operator backend. It has no accounts, analytics, advertising SDKs, purchases or app-level crash-upload mechanism. It does not use the camera or microphone. Players have their conversation outside the app.

Session data stays in app memory, without saving to files, databases or preferences. A new game resets scores and identity history. Ending the app process loses the session, which cannot be restored. Pairing and other operating-system-managed data are separate from app storage.

You can use a nickname; we do not ask for your legal name. Choose a name different from the other player’s, with at most ten characters. The other participant can see that name.

3. B. Visiting the website

To deliver a page, its server receives your IP address, the requested address and technical information sent by your browser. This can include your browser type, operating system and referring page. These requests are separate from game data in the app.

The website code has no analytics, tracking pixels, advertising, embedded third-party media or external fonts. It sets no cookies or browser-storage preferences; the page address determines the language. Your browser may cache files needed to display pages. This is separate from user tracking. Hosting and website protection services must be assessed separately.

The website is hosted on a Vercel Pro account. Hosting and protecting the site involve processing the technical requests described above.

4. C. Email and telephone support

When you contact us, you voluntarily provide your email address or phone number and the contents of your message or conversation. You may also provide your name, app version, device model, OS version and a description of the issue. We use this information to understand your request, communicate with you and investigate the reported problem.

There is no website contact form. Email and telephone links open your own apps for those services. Do not send passwords, access codes, sensitive information or unnecessary information about other people. Without a way to contact you or relevant technical details, our ability to help may be limited.

Our mailbox provider is Apple iCloud Mail and our telephone provider is Vodafone. Within our organization, support correspondence is accessible only to authorized personnel.

5. Purposes and legal bases

The purposes described here are operating the local game, delivering website pages and handling support requests and personal-data enquiries. An app without an operator backend does not mean the company processes no data through its website or support channels.

Visiting the website, reading this policy or sending a message does not provide consent for every use of data. Operating-system permissions for connecting devices are separate from personal-data information.

Handling requests to exercise your data-protection rights is based on compliance with the legal obligations in GDPR Articles 12–22, under Article 6(1)(c). That basis does not automatically extend to every support message or technical log.

6. Recipients and international transfers

In the game, the other participant’s device receives the data needed for the session. Operating-system services and App Store distribution have their own Apple terms and privacy information. Email and telephone services also involve processing by their providers.

Vercel hosts the website, Apple iCloud Mail provides the support mailbox, and Vodafone provides telephone service. We do not promise that this processing takes place exclusively in the European Economic Area.

7. How long data is kept

For the app, retention is determined by the session’s lifetime in memory: data is not restored after the app process ends. Starting a new game resets scores and identity history.

Cine sunt? support correspondence is retained for 30 days after the last contact, then deleted.

Deleting correspondence from the mailbox does not mean the provider deletes every backup at the same time. The 30-day correspondence rule does not establish retention periods for website logs or data-rights request records.

8. Your rights

You may request access and a copy of your data, correction of inaccurate data, erasure or restriction of processing under the GDPR. These rights are not absolute: for example, a legal duty or the establishment, exercise or defence of legal claims may limit erasure.

Where processing relies on legitimate interests, you may object on grounds relating to your particular situation. Portability applies to data you provided that is processed by automated means on the basis of consent or a contract. If processing relies on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.

Send your request to contact@dorobantimedia.com. You do not need to create an account or routinely provide identity documents. If there are reasonable doubts about the requester’s identity, we may ask only for additional information needed to verify it. We do not receive game sessions and cannot recover an ended session.

A response must be provided without undue delay and normally within one month of receiving the request. The GDPR permits an extension of two further months depending on complexity and the number of requests; the extension and reasons must be communicated within the first month. Exercising rights is free, subject to the limited exceptions for manifestly unfounded or excessive requests in Article 12(5).

You may complain to Romania’s National Supervisory Authority for Personal Data Processing (ANSPDCP), or the competent authority where you habitually live, work or believe an infringement occurred. This policy does not require you to contact us first. Judicial remedies under the GDPR also remain available. Consult the authority’s procedure for admissibility conditions and supporting documents.

9. Automated decisions and sensitive information

The game automatically determines round results under its rules. This does not profile people or produce legal or similarly significant effects. The website includes no profiling, advertising personalization or forms requesting sensitive information.

10. Children and family use

The game does not ask for a birth date, accounts, photos, voice or location, and has no online chat or user-published content. A nickname is sufficient to play. Adults should help children avoid sending unnecessary personal data by email or telephone.

The applicable age rating is the one displayed for the distributed version in the App Store. Family play does not claim membership in Apple’s Kids Category. If a child sends us personal data for support, its handling must be determined by the request and applicable legal obligations.

11. Updates and external links

A final version will state its effective and last-updated dates. Changes to the product, hosting or support may require an updated policy.

The app’s privacy and support links open your browser and require internet. They do not include player names, answers, scores or reconnection data. Visiting the page involves the website processing described above. Links to Apple, Vercel or public authorities open separate services with their own notices; those services are not embedded in this page.

Sources and further information

Regulation (EU) 2016/679 — GDPRANSPDCPRomanian Law 506/2004 on privacy in electronic communicationsVercel — Data Processing Addendum

Questions and contact

contact@dorobantimedia.com+40 730 000 064Terms and conditions
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DOROBANTI NETWORK S.R.L.Tax identifier (CUI): 51010254Trade Register: J2024047810002Registered office: Aleea Tomești nr. 9, bl. 15, sc. 2, et. 7, ap. 63, Sector 4, București, 042144, România
© 2026 DOROBANTI NETWORK S.R.L.Apple, iPhone, iPad and App Store are trademarks of Apple Inc.