Legal
Privacy Statement
Controller: [rechtsvorm en naam exploitant], with its registered office in [plaats], office address: [adres], Chamber of Commerce number [KvK-nummer], e-mail: [contact e-mail]. Data Protection Officer: [in te vullen, of "nog niet aangesteld"].
This statement is written in plain language. A short summary is at the top. The full text follows below.
Read this first — short
- Qoinomics is an online world in your browser. To make it work, we process data about you: your account, your messages, your movements in the world and (if you buy something) your orders.
- We never sell your data and do not pass it on for advertising. (In the draft phase there are no advertising cookies or tracking pixels — we will check this before publication.)
- We ask for consent for things that are not necessary; for everything else we use another legal basis, which we explain below for each type.
- If you are under 16, we ask your parent or guardian for consent for processing that is based on consent.
- You have rights: access, correction, erasure and more. E-mail [contact e-mail] and we will respond within one month.
- Do you think we are doing something wrong? Then you can file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).
1. Who is responsible?
Qoinomics ([rechtsvorm en naam exploitant], [adres], [KvK-nummer]) is the company that offers this online world and decides which data is processed and why. In this statement we call ourselves "Qoinomics", "we" and "us".
Questions about your data? E-mail [contact e-mail].
2. What data do we process, why and for how long?
The table below shows for each purpose: which data, on which legal basis, to whom we pass it on and how long we keep it. The retention periods are design choices by Qoinomics — we say honestly how long we intend to keep something, and we do not keep it longer than necessary for the purpose.
| # | Purpose | Data | Legal basis | Recipients | Retention period (design) |
|---|---|---|---|---|---|
| 1 | Creating an account and logging in | e-mail address and name from your Google account, Google account ID, username | Performance of the contract (providing the service) | Google (see section 5), hosting provider | As long as your account exists + [12] months after closure (for administration and recovery after misuse) |
| 2 | Making the world work | username, avatar and profile settings, language preference | Performance of the contract | Hosting provider and realtime provider (Ably), insofar as technically involved | As long as your account exists |
| 3 | Chat and messages | public chat messages, private messages | Public chat: performance of the contract and legitimate interest (safe environment). Private messages: performance of the contract | Other users (the messages themselves), hosting provider, realtime provider (Ably) | Public chat: [30–90] days. Private messages: [30] days |
| 4 | Voice with other players (peer-to-peer) | spoken audio (with a direct connection goes straight from browser to browser), connection data (such as IP address) | Performance of the contract | The other players nearby; in case of technical problems our TURN relay (see section 5) | No storage of voice by us [design choice, to be confirmed: we do not intend to record voice; if a recording function is added later, we will state it here and ask for consent where necessary] |
| 5 | Talking to AI characters (NPCs) | your messages to the character and, in voice conversations, your voice | Performance of the contract (the NPC function) | OpenAI (see section 5) | [30] days in our logs |
| 6 | AI moderation of chat | chat messages being checked | Legitimate interest: keeping the community safe, in particular for minors | OpenAI (moderation API) | [30] days |
| 7 | Automatic translation | Dutch text on screen and in the world (may also contain user text, such as cards) | Legitimate interest: making the world understandable for non-Dutch speakers | OpenAI (translation API) | Translated text for a maximum of [12] months in the translation cache |
| 8 | Creating an avatar from a photo (optional) | the photo you upload | Consent (you choose this yourself) | OpenAI (image API) | [Design choice, to be confirmed: delete the photo immediately after generation] |
| 9 | Payments and credits | order data, payment status, invoice data, wallet and item transactions | Performance of the contract and legal obligation (tax) | Stripe or Mollie (see section 5) | Order and invoice data [7] years; the underlying transaction data necessary to substantiate the financial records [same]; further purchase history [2] years |
| 10 | Security and fraud prevention | IP address, device and browser data, login times | Legitimate interest: securing accounts and payments | Hosting provider, insofar as technically involved | [6–12] months |
| 11 | Movement and presence in the world | position in the world, presence signals | Legitimate interest: technical operation (who is where) and combating misuse | Other users see where you are (within the rules of the world) | Aggregated statistics [30] days; detailed logs [7–30] days |
| 12 | Moderation and enforcement of the code of conduct | reports, decisions, relevant message fragments | Legitimate interest: safe community; performance of the contract | Authorities where required by law (see section 9) | [6–12] months |
| 12a | Age and parental consent | stated date of birth/age, contact details of the parent/guardian, proof of consent | Protection of minors; consents are requested separately | Hosting provider | Proof of consent [2 years after account termination, to be confirmed] |
| 12b | Uploads by users | business cards/logos, podcast audio | Performance of the contract (the chosen functions) | Other users (the published content), hosting provider | As long as the content is on the platform; after deletion another [30] days in back-ups |
| 13 | Support and complaints | your messages to us, contact details | Performance of the contract / legitimate interest (handling complaints) | Hosting provider | [12] months after handling |
Sources of data. Your data comes from: you (what you fill in and share), your Google account (when logging in), other users (for example if they report you) and automatically (technical log data).
What is necessary and what is optional? Per function: without account data you cannot log in; without processing your messages the chat does not work; without movement data you cannot walk through the world; without microphone data (which goes directly between players) you cannot use voice. If you refuse one of these processing operations, you cannot use that function — the rest of the world will still work. Optional are, among other things, the photo upload for your avatar (consent) and the use of AI characters (you can avoid them; you then only miss those conversations).
3. Children and young people
Access: you must be at least 13 years old to use Qoinomics. (This is a policy choice that still has to be finally confirmed.)
Consent for data: for processing based on consent, we ask a parent or guardian for consent for users under 16 (as Dutch law requires). For processing that is necessary for the service (such as your account) this consent requirement does not apply — we use another legal basis there.
Consent for purchases is a separate matter: you ask your parent or guardian for this yourself, see the Payment Terms.
Logging in via Google does not prove how old you are. We check age on the basis of what you state and signals afterwards, not on the basis of your Google account alone.
Safety for young people: we show AI characters as AI, we have NPCs ask young people no personal questions [design choice], and we do not show advertising based on the profile of minors.
4. Voice, AI and automated decisions
Voice with other players. When you talk to someone in the world, the sound goes directly from your browser to the other player's browser (peer-to-peer). We do not store voice [design choice: there is no recording function; if one is added later, we will say so here and ask for consent where necessary]. Please note: with a direct connection, the technology may expose your IP address to the other player. If a direct connection fails, the sound goes via our TURN relay; this does not change the content of the conversation. [To be confirmed: whether and how the relay is used by default to limit exposure of addresses.] Connection data for voice is kept briefly for technical purposes.
Talking to AI characters. What you type or say to an NPC (such as Mei or Tony) is sent to OpenAI to generate an answer. OpenAI is a processor for these purposes. Good to know: "not used for training" does not mean "never stored" — how long OpenAI keeps data for abuse monitoring and in which mode is something we check [to be verified]. You can avoid AI characters; you then only miss those conversations.
Automated decisions. We use AI as a tool: AI filters chat for unwanted content and helps with moderation. In our design, a measure against your account (such as a block) is always confirmed by a human, and you can object to it. [Design choice — the technical implementation still has to be checked; until it is established that moderation, fraud and payment processes do not take fully automated decisions with major consequences, this is an intention and not a guarantee.] If fully automated decisions with legal or similarly significant effects are taken, we will state this here and your statutory rights (including human intervention) apply.
5. To whom do we pass on data?
We do not sell your data and do not pass it on for advertising. These are the parties involved in the service:
| Party | Role | What | Where | Transfer outside the EEA |
|---|---|---|---|---|
| [Hosting provider, e.g. IONOS] | Processor | hosts the website and database | [country to be checked] | [to be verified] |
| [Role to be verified: for its own service Google may be an independent controller; its role in our login flow must be determined] | logging in with your Google account | [to be verified] | [to be verified: DPF/SCC] | |
| Ably (realtime) | Processor | chat positions, presence, voice signalling | [to be verified] | [to be verified] |
| Metered (TURN) | Processor | relaying voice when a direct connection fails | [to be verified] | [to be verified] |
| OpenAI | Processor | NPC answers, translation, moderation, avatar from photo | [to be verified] | [to be verified: DPF participation of the correct entity] |
| Stripe / Mollie | [Role to be verified: for their own payment service possibly independent controllers; their role in our payment flow must be determined] | payments | [to be verified] | [to be verified] |
Notes we make honestly:
- A European establishment of a supplier does not automatically mean that all your data stays in Europe; we check per party where data is actually processed.
- For transfers to countries outside the European Economic Area, we use, where necessary, the standard contractual clauses of the European Commission or the participation of the relevant entity in the EU-US Data Privacy Framework; the correct arrangement per party is [to be verified]. If you would like to know which safeguard applies to which party, or a copy of it, you can ask via [contact e-mail].
- With parties acting as our processor, we conclude a data processing agreement describing what they may do and how they protect your data. For parties that are independent controllers (such as possibly Google and the payment services for their own purposes), their own privacy policy applies.
- Network traffic to our Content Delivery Network (for fast loading of the 3D world) processes IP addresses; [to be checked: whether this network sets cookies — this is also stated in the cookie policy].
6. How long do we keep data?
The retention periods are in the table in section 2. We want to make two things extra clear:
Tax retention (seven years) applies to the financial records: order and invoice data and the underlying transaction data necessary to substantiate those records. This period does not apply to your chat messages, your movements or your AI conversations — we keep those for a shorter time, as shown in the table.
The periods are our responsibility. We regularly review them ourselves against the purpose and the law; you can always ask questions about them via [contact e-mail].
7. Your rights
You have the right to:
- ask which data we hold about you (access), and receive a copy;
- have errors corrected;
- have data erased (for example if we no longer need it), with exceptions, such as: data we are legally required to keep (such as invoices) and data we keep for as long as necessary for the establishment, exercise or defence of legal claims or a legal obligation — such retention is not unlimited and does not follow automatically from every investigation;
- restrict processing (for example during a dispute about the accuracy of your data);
- data portability: you can receive the personal data you have provided to us and that is processed automatically on the basis of consent or the contract, in a common format, to take to another service;
- object to processing based on our legitimate interest — we then weigh your interest against ours and explain this;
- withdraw consent you gave earlier (for example for the photo function). Withdrawal does not have retroactive effect, but applies to everything thereafter.
How do you request this? E-mail [contact e-mail]. You do not have to say why. We respond within one month. If it is complicated or you have made many requests, it may take two months longer — we will let you know in good time. We may ask for additional information if we are not sure it is you; we never ask for more than necessary to identify you. It is free of charge, unless you keep repeating clearly unreasonable requests. If you are under 16, we will also help you exercise your rights, and involve your parent/guardian where necessary.
8. Security and data breaches
We protect your data with technical and organisational measures: encrypted connections (HTTPS), role-based access restriction, back-ups and logs of authorisations. [To be confirmed: MFA on admin accounts, penetration test before launch.]
If your data is unintentionally made public, stolen or erased due to a breach, we will report this without undue delay and, where possible, within 72 hours of discovery to the Dutch Data Protection Authority, unless the breach is unlikely to result in a risk to you. If there is likely to be a high risk to you, we will inform you without undue delay, with advice on what you can do (subject to statutory exceptions).
9. Data provided to authorities
We only pass on your data to the police or judicial authorities when the law requires or permits it. We are thinking, for example, of the European legislation for online platforms, which requires the reporting of suspected serious criminal offences (involving a threat to the life or safety of persons). We refuse requests for data without a legal basis, unless a competent authority obliges us to provide it.
10. Changes
We may change this statement, for example in the event of new functionality or new legislation. The current version is always available on the website, with a date and version number. We clearly announce major changes within the service.
11. Complaints
If you think we are not handling your data properly, you can raise this with us via [contact e-mail]. In addition, you may always file a complaint directly with the Dutch Data Protection Authority (autoriteitpersoonsgegevens.nl); complaining to us first is not required.