FAHHHH Privacy Policy
Last updated: November 11, 2026
In brief
- We do not ask for your name, email address, phone number, age or gender. Your player profile is linked to a random ID.
- Photos only leave your device when you play them. They pass through our server in the EU and are automatically deleted there as soon as they are no longer needed for the round.
- After the game, played photos are stored locally on the devices of the other players. We can no longer delete them there.
- Usage analytics and error reports with PostHog (servers in Frankfurt): pseudonymous, without advertising IDs, solely to improve the app. You can turn them off at any time at the top of the privacy policy in the app.
- No advertising, no advertising IDs, no sale of data, no recognition of who is in a photo, no AI training with your photos.
1. Controller
The controller within the meaning of the General Data Protection Regulation (GDPR) is:
SlayTech UG (haftungsbeschränkt), c/o Francisco Soares Kaufmann, Annafeldstraße 1, 86919 Utting am Ammersee, Germany
Represented by the managing directors Nick Werner and Francisco Soares Kaufmann. Commercial register: Local Court (Amtsgericht) Augsburg, HRB 43213.
Contact and privacy requests: info@fotobingo.app
2. Player profile and age confirmation
When you first start the app, it signs you in anonymously (see Section 6). This creates a random ID. Linked to it are the display name you chose, your profile picture and your confirmation that you are at least 16 years old, with a timestamp and the version of the terms of use. If you do not upload a profile picture of your own, we show a placeholder. We store a profile picture of your own at Cloudflare R2 with data location in the EU until you remove it or delete your profile.
Even though we do not know a name or an email address, this information is pseudonymous and therefore personal data within the meaning of the GDPR. We treat it accordingly.
Your display name and profile picture are only seen by the other players in the rounds you take part in. We store your display name and age confirmation in Google Cloud Firestore with data location in the EU.
Legal basis: Art. 6(1)(b) GDPR (performance of a contract). For proof of the age confirmation, additionally Art. 6(1)(f) GDPR (legitimate interest in being able to demonstrate compliance with the minimum age).
3. Photos
Photos are the core of FAHHHH. This is how a photo moves through the game:
- Gallery: With your permission, the app accesses your gallery locally to show you photos to choose from. These photos do not leave your device. You can limit access to selected photos or revoke it at any time in the system settings. You decide yourself which photos you take into your hand.
- Playing: Photos in your hand stay on your device. A photo is only uploaded to our server once you play it. Before that, we remove metadata such as GPS location and camera data.
- Transfer: The photo is uploaded, encrypted (TLS), to our storage at Cloudflare R2 with data location in the EU. From there, the devices of the other players in the same round retrieve it. Only devices that have joined the round get access.
- Deletion on the server: The photo is automatically deleted as soon as it is no longer needed for the round.
- After the game: The photo is stored locally on your device and on the devices of all other players in the round. We have no access to it and cannot delete it there. If you delete the app, the photos on your device are removed, but not those on the devices of the others.
To suggest good photos for your deck, the app looks at photos on your device: whether there are faces in them and how sharp and well lit they are (Apple's on-device image analysis). This happens only on your device. Neither the photos nor the results leave it, and the results are deleted with "Delete my data". We do not recognize who is in a photo and do not use your photos to train AI models.
People in photos: Played photos may show people who are not playing themselves. For them, we transfer the photo on the basis of our legitimate interest in providing the game (Art. 6(1)(f) GDPR). Anyone who plays a photo must make sure that the people shown in it agree (§ 7 of the terms of use). Persons concerned can contact us at any time.
Legal basis for the transfer of your own photos: Art. 6(1)(b) GDPR (performance of a contract). Gallery access: your permission via the operating system.
4. Premium subscription and purchases
You buy FAHHHH Premium through the Apple App Store or Google Play. Apple or Google handle payment, billing and refunds as independent controllers under their own privacy policies. We do not receive your payment data.
We only process what we need to unlock Premium: your random ID, the store's transaction ID, the purchased product, price and currency, store and store country, time of purchase, term and refund status. RevenueCat manages the subscriptions for us: RevenueCat verifies purchases with Apple and Google, assigns them to your ID and reports purchases, renewals and refunds to us (see Section 9).
Legal basis: Art. 6(1)(b) GDPR; for preventing abuse after refunds, Art. 6(1)(f) GDPR; for retaining accounting records, Art. 6(1)(c) GDPR.
5. Usage analytics and error reports with PostHog
We analyze how the app is used and record errors and crashes. For this we use PostHog. We record, for example, when the app is opened and closed, rounds started and finished, round size, how well cards land in a round (the average rating per card), errors, crashes and loading times, as well as device type, operating system, app version and language. The events are linked to a random analytics ID stored on your device, not to your name. This is pseudonymous data.
What we do not record: photos or image content, display names, advertising IDs (IDFA, AAID), screens viewed and screen recordings (session recording). Your IP address is discarded on receipt, and no location is derived from it.
We use the data solely to find errors and improve the app. Not for advertising, not for profiles of individual persons, not for disclosure to third parties.
Turning it off: you can turn off "Share usage data" at any time at the top of the privacy policy in the app. PostHog is then no longer started and no more events are sent. The setting is stored on your device.
The provider is PostHog Inc. The data is stored in the PostHog EU Cloud in Frankfurt am Main.
Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is finding errors and improving the app. You can object at any time (Art. 21 GDPR), most easily with the switch at the top of the privacy policy in the app.
6. Anonymous sign-in
For your player profile, we use the anonymous sign-in of Firebase Authentication (Google). This creates a random ID (UID). You do not need an email address, phone number or any other account. For the sign-in, Google processes technical data such as IP address, device type and time of sign-in.
The UID is also your player ID, with which you can send us requests under Section 13.
Legal basis: Art. 6(1)(b) GDPR (performance of a contract).
7. Technical data and security
When the app communicates with our server, our host processes technically necessary connection data: IP address, time, requested resource and technical device data. Without this data, no connection can be established. It is not combined with your player profile and is deleted as soon as it is no longer required for secure operation.
All connections are encrypted with TLS. Only devices of the respective round get access to photos in R2, via time-limited links.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in secure and functional operation).
8. Reports and contacting us
Reports: Since we do not store photos permanently, a report sends the photo concerned from your device to us. Also transmitted are the display name and the ID of the reported person, your ID, the reason for the report and the time. We review the report, take measures under § 9 of the terms of use where appropriate and inform the person concerned. Legal basis: Art. 6(1)(f) GDPR (a safe environment for all players) and Art. 6(1)(c) GDPR, insofar as legal obligations exist, for example under the Digital Services Act.
Blocking: If you block someone, we store the IDs of both profiles so that you no longer end up in the same round. Legal basis: Art. 6(1)(b) GDPR.
Email: If you write to us, we process your email address and the content of your message in order to answer it. Legal basis: Art. 6(1)(b) or (f) GDPR. We run the mailbox via Google Workspace (see Section 9).
9. Recipients
We do not sell your data and do not pass it on for advertising purposes. The following service providers process data on our behalf (Art. 28 GDPR). We have concluded a data processing agreement with each of them.
| Provider | Purpose | Data | Data location |
|---|---|---|---|
| Google LLC, USA (Firebase Authentication) | Anonymous sign-in | UID, technical data | Global |
| Google LLC, USA (Cloud Firestore) | Player profile, rounds, age confirmation, reports, blocks | ID, display name, round data, report data | EU |
| Google LLC, USA (Google Workspace) | Email mailbox for support and reports | Email address, content of the message | Global |
| Cloudflare, Inc., USA (R2) | Storage and transfer of played photos, profile pictures and reported photos | Photos without metadata, connection data | EU (R2 EU jurisdiction) |
| PostHog Inc., USA | Usage analytics and error reports, can be turned off in the app | Pseudonymous usage events, error reports, device data | EU (Frankfurt) |
| RevenueCat, Inc., USA | Verification and management of the subscriptions | ID, transaction and product data, price, store country, technical device data | USA |
Apple and Google process data when you download the app and when you make purchases as independent controllers under their own privacy policies.
Authorities and courts only receive data if we are legally obliged to provide it (Art. 6(1)(c) GDPR). Lawyers and tax advisors only receive data insofar as this is necessary to fulfill legal obligations or to defend legal claims.
10. Transfers to third countries
We store photos, player profiles and analytics data in the EU. However, Google, Cloudflare and PostHog have their headquarters in the USA, so access from the USA, for example for support or maintenance, and access by US authorities cannot be completely ruled out. RevenueCat processes subscription data in the USA. The anonymous sign-in via Firebase Authentication may run through servers of Google outside the EU.
For such transfers, we rely on the adequacy decision for the EU-US Data Privacy Framework (Art. 45 GDPR), insofar as the provider is certified (Google and Cloudflare), and additionally on the standard contractual clauses of the European Commission (Art. 46(2)(c) GDPR). For PostHog and RevenueCat, we rely solely on the standard contractual clauses. You can check the current certification status at dataprivacyframework.gov. You can obtain a copy of the safeguards on request.
11. Retention period
We only store data for as long as is necessary for the respective purpose or required by law.
| Data | Location | Deleted |
|---|---|---|
| Played photos | Cloudflare R2 (EU) | Automatically, as soon as they are no longer needed for the round |
| Photos after the game | Devices of the other players | Not within our control; on your device when you delete the app |
| Your own profile picture | Cloudflare R2 (EU) | When you remove it or delete your profile |
| Player profile, age confirmation | Firestore (EU) | When the profile is deleted; inactive profiles after 12 months |
| Round data without photos | Firestore (EU) | 30 days after the end of the round |
| Analytics events and error reports | PostHog (EU) | As soon as no longer required for the analysis |
| Connection data | Cloudflare | As soon as no longer required for secure operation |
| Reports with photo | Cloudflare R2 and Firestore (EU) | 6 months after closure, longer only in the case of ongoing proceedings |
| Ban lists after violations | Firestore (EU) | As long as a legitimate interest exists |
| Purchase and subscription data | Firestore (EU), RevenueCat (USA) | For the duration of the subscription; accounting records 8 to 10 years (§ 147 AO, § 257 HGB) |
| Email requests | Google Workspace | 12 months after the last contact |
12. Minimum age
FAHHHH is intended for persons aged 16 and over. We do not ask for a date of birth, only for a confirmation that you meet the minimum age. We do not knowingly process data of younger persons.
If we learn, for example through a notice from parents, that a younger person is using FAHHHH, we block the player profile and delete the associated data. Parents and guardians can reach us at info@fotobingo.app.
13. Your rights
Under the GDPR, you have the following rights: access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), objection to processing based on legitimate interests (Art. 21) and withdrawal of consent given, with effect for the future (Art. 7(3)).
Since we do not know your name or email address, we can only match requests to you if you tell us your player ID. You can find it in the settings of the app. Without it, we may not be able to identify you (Art. 11 GDPR).
You can delete your player profile directly in the settings. The deletion does not cover photos on the devices of other players, because they are not under our control there.
We answer requests within one month. You also have the right to lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). The authority responsible for us is:
Bavarian Data Protection Authority (Bayerisches Landesamt für Datenschutzaufsicht, BayLDA), Promenade 18, 91522 Ansbach, www.lda.bayern.de
14. Changes and contact
We adapt this privacy policy when features or legal requirements change. We will inform you about material changes in the app. If a processing activity that is based on your consent changes, we will ask you again.
Privacy questions: info@fotobingo.app