Privacy Policy

Last updated: 13 October 2026

This policy explains what personal data Komnu collects when you use the Komnu app or visit komnu.app, why we collect it, who receives it, how long we keep it, and what rights you have. Komnu is an app for hosting and joining sport games. We wrote this policy to match how the app actually works.

1. Who we are

Komnu is operated by Komnu, an eenmanszaak (sole proprietorship) registered in the Netherlands (Chamber of Commerce (KvK) number 42175589, VAT (btw) number NL005558432B92), at Oder 20, 2491 DC Den Haag, the Netherlands. We are the controller of your personal data under the EU General Data Protection Regulation (GDPR) and the Dutch GDPR Implementation Act (UAVG).

Contact for anything about privacy: support@komnu.app. We have not appointed a data protection officer, because the law does not require one for Komnu: we do not monitor people on a large scale or process special categories of personal data on a large scale. Contact us directly at this address.

2. Summary

• You need an account to use the app, and you must be 18 or older.
• Open games are public. A game's title, notes, time and exact meeting point are shown in the app and on the public website. The website never shows who hosts or plays.
• Your location is used only when you tap something that needs it, Check in or Use my location, and only after you allow precise location in the app. We do not track you in the background, and we do not store the coordinates from a check-in. Pins you save, such as your home area or a game's meeting point, are stored.
• On the free plan, joining or hosting a game also checks that you are within 150 km of the game. The app takes one approximate location when you tap Join or Create, our server compares the distance, and we do not store the location (see section 3.4). Pro members are not checked.
• We do not sell your data and we do not show ads. Product analytics and crash reports are off by default. You can turn analytics on when you set up your account or later in Settings, and turn it off again at any time in Settings (see section 3.11).
• Community posts are visible to members of the same country, Pro users and moderators (added for lawyer review). What you post in the Community tab (posts, comments, photos and videos), with your name and picture, can be read by signed-in members of that country's community, by Komnu Pro users and by Komnu moderators. You always see your own posts. We check posts and photos with an automated tool before and after publishing (see section 3.8).
• You can download your data and delete your account in the app's settings. You can also delete your account at komnu.app/account/delete after signing in. Your account is deleted for good 7 days after you ask, unless you cancel.

3. What we collect and why

3.1 Your account

• Sign-in. You sign in with Google, with Apple (on iPhone and iPad), or with an email address and password. With Google, we receive your Google account ID and email address. With Apple, we receive an Apple account ID and an email address. If you choose Apple's Hide My Email, that address is a private relay address that forwards our emails to you, and Apple does not tell us your real address. With email, we store your address and a one-way hash of your password, never the password itself. To confirm a new email address we email you a 6-digit code. We keep only a scrambled (hashed) version of it, and it expires after 10 minutes.

• Date of birth. We check it once to confirm you are 18 or older, then discard it. We store only that you are 18+ and when this was confirmed. An under-18 attempt is remembered to prevent retries; unfinished sign-ups, including blocked attempts, are deleted after 30 days from account creation.

• Store age check (US store accounts only). If your App Store or Google Play account is a US account, the app asks the store for the age range on your account when you sign up, and after that at most once every 12 months. We never ask for this if your store account is from another country. We keep only the time of the last check, never the age range or the store's answer. If the store reports that you are under 18, we record a block (your account and the time, nothing else) and the app shows that Komnu is for adults only. This applies whether the check happens while you sign up or after you have finished setting up your account: the block starts at once, and an account blocked after setup is deleted 30 days later, the same as a blocked sign-up. If the store gives no answer, for example because you choose not to share it, your date of birth is used as above.

• Accepting the Terms. When you sign up, you confirm that you are 18 or older and that you accept our Terms of Service. We store which version of the Terms you accepted, and when. Our Privacy Policy is linked beside that checkbox for your information; it is not something you accept.

• Legal basis: performance of our contract with you (Art. 6(1)(b) GDPR). For the age check and the record of your acceptance, also our legitimate interests in keeping minors off the service and in being able to show which Terms you agreed to (Art. 6(1)(f)). For the store age check, our legitimate interests in keeping minors off the service and in meeting the app store age laws of US states (Art. 6(1)(f)).

• Required and optional data. To sign up you need an email address and password or Google/Apple sign-in, a date of birth (checked once, not kept), gender and a username. Bio, profile picture, profile photos and captions, favourite sports and a home area are optional. Location, notifications, analytics and crash reports are also optional.

3.2 Your profile

• Name and handle. Your username and a number, for example Alex#0420. Other users see them on rosters, in chats and on your profile.
• Gender. You choose male, female or non-binary when you set up your account. Once set, you cannot change it in the app; email us to correct it. Your gender is shown on your profile to signed-in users who can see your profile. Gender is not a special category of personal data under Article 9 GDPR, and we never use it for advertising or profiling.
• Bio, profile picture and up to 10 profile photos (with captions). All optional. Your picture and photos are shown only to people who share a current or recent game with you, or with whom you have an accepted direct-message conversation.
• Played together. You appear in the played-together / mutual connections list by default. Turn off “Show me in mutual connections” in Settings to hide yourself from it (the setting is show_in_mutuals).
• Favourite sports and a home area. We use them to show you games near you.
• Legal basis: contract (Art. 6(1)(b)).

3.3 Games you host or join

• Hosting. When you host a game, we store what you enter: sport, title, notes, time, skill level, price, number of players, and the meeting point you pin on the map. Optionally, we also store a route (only the line on the map; the original GPX file, its timestamps and its metadata are discarded). The title and notes pass through our automated filter (see 3.6), and we store only the filtered version.
• Finding the place name. While you create or edit a game, each time you place or move the meeting point the app sends its exact coordinates to our server (/geo/place) to look up the place name and city. We do not store that lookup; like every request, it appears in our server logs for 7 days (see 3.11).
• Weekly series. If you set up a weekly series, we store its details, including the meeting point coordinates, until you delete the series or your account.
• Where the meeting point comes from. You can place it by hand on the map, or with Use my location (see 3.4). If you use your location, the stored point can be your exact position at that moment; move the pin if you do not want that.
• What the public sees. Open games are public by design:
  • Signed-in users see the game with your username as host.
  • The public website (komnu.app) shows an open game's title, notes, time, price, skill level, player count, the exact pinned location and its place name to anyone, without an account. It never shows the host's or the players' names or photos. The app tells you this when you create an open game.
  • The share link page (/g/…) shows only the city.
  • Do not put personal information in a game's title or notes.
• Joining. When you join, we record your place on the roster or waitlist. The host and the other players see your username.
• Waitlist. When a place opens, the waitlist promotes Pro members first, then everyone else in the order they joined.
• High fives after a game (added for lawyer review). After a game has ended, and for 48 hours after its end time, a player who checked in at the game can give a high five (🙌) to another player who also checked in (the host counts as a player), with at most one optional tag: on time, fair play, good level or friendly. We store the game, who gave high fives, who received them, the tag and the time. The giver can change the tag or take the high fives back while the 48 hours are open. You cannot give high fives to, or receive them from, someone you have blocked or who has blocked you. Other people never see who gave high fives: your profile shows signed-in users only how many different people gave you high fives and your three most common tags, and the giver sees the players they themselves gave high fives to. High fives are not deleted with the game 7 days after it ends, so your profile summary stays; they are deleted when you or the other person deletes their account. Your data export lists the high fives you gave and the high fives you received (without who gave them).
• Legal basis:
  • Contract (Art. 6(1)(b)) for running games.
  • Our legitimate interest (Art. 6(1)(f)) for post-game high fives, an optional way for players to recognise each other. We judge that it does not override your interests because it is limited to players who checked in together, shows only counts and tags, and never shows who gave them. You can object by emailing us. [VERIFY: for lawyer review, whether 6(1)(f) or 6(1)(b) is the right basis]
  • Our legitimate interest (Art. 6(1)(f)) for showing open games on the public website. Hosts want players to find their game and the meeting point is a public place, so we judge that this does not override your interests, as long as the website shows no names. If a public listing would affect you, email us and we will look at it.

3.4 Location and check-ins

• Your choice first. Before the app reads your precise location for the first time, it asks you on its own screen. The screen says what is read (your exact position), why (to check in at games and to place pins near you), what is stored (the pins and meeting points you save) and that you can withdraw your choice in Settings. You choose "Allow precise location" or "Not now"; nothing is pre-selected and it is not part of accepting the Terms. Only after you allow it does your phone ask for its location permission. We ask everyone, wherever you live, and the sign-up permissions page asks the same question.
• Without your permission. You can place pins on the map by hand and browse games on the map as usual. Check-in is not available; the app tells you so and links to the setting. The app reads no location at all.
• Withdrawing. Turn off precise location in the app's Settings, next to the analytics and crash-report switches. The app stops reading your location straight away. Pins you have already saved stay; delete them yourself if you want them gone. You can also withdraw the device permission in your phone's settings.
• Use my location. In the app this moves the map to where you are. We read your location once, when you tap it. We never use background location.
• Browsing the map. When you browse games on the map, the app sends us the area of the map you are looking at (its corners), not your position, to load the games in it. The map images come from OpenFreeMap, which receives your IP address and the map area you view (see section 4). On the website, your location never leaves your browser.
• Pins you save. A pin you place, by hand or with Use my location, is stored when you save it:
  • your home area and alert zones (a centre point and a radius), so we can tell you about new games inside them, until you delete the zone or your account;
  • a game's meeting point, until the game is deleted 7 days after it ends (open games show it publicly, see 3.3);
  • a weekly series' meeting point, until you delete the series or your account. If you used your location to place it, the pin can be your exact position at that moment. Only you see your home area and alert zones.
• Check-in. When you tap Check in at a game, the app sends your precise location once, with its accuracy. We use it only to confirm you are within 100 metres of the meeting point or route, and then discard it. We do not store those coordinates. We store only the time of the check-in, and the game's city in your game history.
• Free plan: joining and hosting near you. On the free plan you can join a game (including its waitlist) or host one only if you are within 150 km of its meeting point. To check this, the app asks your phone for one approximate location at the moment you tap Join or Create game (or save a change that moves a game's meeting point). It asks only for approximate location, not your exact position, and it asks separately from the precise-location choice above. The app sends that location to our server together with a yes-or-no value saying whether your phone reports it as simulated by software (a "mock location"). The server measures the distance to the game and answers. We do not store the location or that value, we do not write them to our logs, and we do not send them back to you or to anyone else: the server uses them for that single request and then drops them. If you are too far away, or your phone says the location is simulated, we refuse the action and tell you why. If you do not want to share your location, you can still browse, and Pro members can join and host games anywhere: Pro members' locations are not requested or checked. If you have turned on analytics (see 3.11), a refusal is recorded as an event with the reason and a rough distance range such as "150 to 200 km", never coordinates.

• Check-in count. Your total number of check-ins (and the badge it earns) is shown with your profile to signed-in users. It is not public. Your list of past check-ins is private unless you choose to share it. Your check-in list and played-together records cover only the last 12 months; your stored lifetime check-in total and badge tier are kept until account deletion.
• Legal basis:
  • Your consent (Art. 6(1)(a)), given in the app and through the device permission, for reading your location. You can withdraw it at any time in Settings.
  • Contract (Art. 6(1)(b)) for the features themselves and for storing the pins you save.
  • Contract (Art. 6(1)(b)) for the free-plan distance check: it is a term of the plan, runs only when you ask to join or host, and nothing is kept. Reading your approximate location for it is strictly necessary for the join or host action you requested.

3.5 Messages, photos, voice clips and videos

• What you can send. Each game has a match chat for its host and players. You can also send direct messages to other users, including photos, voice clips, video messages (Pro) and shared games.
• Photos and videos. Location metadata is removed from photos and videos on your phone before upload.
• Who can read them. People in the conversation can read your messages. If a message is reported, a Komnu moderator can also see that message, including its original unfiltered text, and the details provided with the report (see section 3.6).
• Deleting a message. You can delete your own message for everyone.
• Replies (added for lawyer review). When you reply to a message in a match chat or a direct message, we store a link to the message you answered, in the same conversation. We do not copy its text: the quote the readers see is read from the original message and shows its filtered text (up to 120 characters). If the original is deleted for everyone, or its sender is someone a reader has blocked, the reply keeps its link but that reader sees no text. The link is kept as long as the reply and goes with it when the conversation is deleted.
• Muting a game chat (added for lawyer review). You can mute one game chat for 8 hours, 1 week or until you turn it off. We store that setting for you and that game: the game, until when, and the time you set it. While it is active we do not send push notifications for that chat and it does not light the unread dot; the messages stay in the chat. Nobody else sees your setting. It is deleted when you unmute, 7 days after the game ends with the game, or when you delete your account. Legal basis: contract (Art. 6(1)(b)).
• How long we keep them. A match chat is deleted 7 days after its game ends. A direct message conversation is kept until you or the other person deletes your account; then the whole conversation, with its photos, voice clips and videos, is deleted for both of you.
• Legal basis: contract (Art. 6(1)(b)).

3.6 Automated filtering and moderation

• Automated filter. It checks chat and direct messages, bios, feedback posts, and game titles and notes for severely offensive words. Other people see a censored version. For messages, bios and feedback posts we also keep your original text, so a moderator can review a report about it. For game titles and notes we store only the censored version. The same filter refuses offensive usernames.
• Reports and decisions. Reports are reviewed by a person. Any action we take on a report is decided by a person, for example removing a profile picture, giving a warning, suspending an account, or deleting the account of someone under 18.
• Telling you about decisions. If we act against your content or account, we send you a statement of reasons in the app, and by email if your account has an email address. It says what we decided, the facts, the rule in our Terms, and how to appeal: by email to support@komnu.app within six months. If you reported something, we tell you the outcome in the app.
• Suspension. While an account is suspended, the app shows until when. The account can still read its notifications, download its data and delete itself.
• Community posts and comments (added for lawyer review). Before a Community post or comment is saved, our own filter refuses text with severe slurs and repeated identical text; plain swearing is allowed. After it is saved, an automated check by Cloudflare Workers AI scores the text and any photos (see section 3.8). A high score can hide the item at once until a person has looked at it; a medium score keeps it visible and puts it in a review queue. The automated tool never deletes anything for good: only a person at Komnu can remove an item. Videos are not checked automatically and are reviewed only after a report. [VERIFY: counsel to confirm that temporary automated hiding pending human review is not an Art. 22 decision]
• No Article 22 decisions. Komnu makes no decisions based solely on automated processing that have legal or similarly significant effects on you (Art. 22 GDPR).
• Legal basis: our legitimate interest in keeping the community safe (Art. 6(1)(f)). For the statements of reasons and outcome notices, our legal obligations under the EU Digital Services Act (Art. 6(1)(c)).

3.7 Friends, blocks and reports

• Friends. You add a friend by scanning their in-app QR code in person.
• Nicknames. You can give someone a private nickname that only you see.
• Blocks. If you block someone, neither of you sees the other's games or messages.
• Reports. You can report a profile, a chat or direct message (including a photo, voice clip or video), a game or its route, or a feedback post. We store the report, what it is about, the details you give, and the moderator's decision, and delete unresolved reports after 12 months from creation and resolved reports 1 year after resolution. When you report content, we also keep a copy of it as evidence, so that a moderator can still review what was reported if it is edited or deleted. We copy only content you could see yourself when you reported it. The copy is kept as long as the report it belongs to and is deleted together with that report. If you report someone who appears to be under 18, we review the report and delete that account if they are.
• Legal basis:
  • Contract (Art. 6(1)(b)) for friends and nicknames.
  • Legitimate interest in safety (Art. 6(1)(f)) for blocks and reports.

3.8 Feedback board and Community

• What we store. We store the posts, votes and reports you make on the in-app feedback board.
• Anonymous posts. If you post anonymously, other users do not see your name, but we still know who wrote the post.
• Language of feedback posts (added for lawyer review). When you save a feedback post, our server detects its language and stores the language code and whether the detection was reliable, so that readers can filter the board by language. Posts that already exist get the same label.
• Community posts (added for lawyer review). The Community tab has one community for each country, with channels for sport categories, General and Announcements. You post to your home country (Komnu Pro members can join more countries). A post has a title, optional text, an optional link, one required topic label, an optional game you host or joined, up to four photos and, with Komnu Pro, one video. Any signed-in user can comment on a post, and like a post. Posts, comments, like counts, photos and videos are visible to all signed-in users, with your name and profile picture. They are not shown on the public website, and not between people who blocked each other. Other users see how many likes a post has, not who liked it. Do not post anything you want to keep private.
• What we store for Community. For a post: its id, author, country, channel, topic label, title, text, link, linked game, detected language and its reliability, moderation status, moderation scores and reason, like and comment counts, and the times it was created and deleted. For a comment: its id, post, the comment it answers, author, text, depth, language, moderation status, scores and reason, and the times it was created and deleted. For each photo or video: its id, post, author, type, the file, its position and moderation status. For a like: the post, you and the time. For your home country and other countries: the country, whether it is home, and when you joined or last changed it. To limit spam we keep, for each of your actions (post, comment, like), a counter and its last update time.
• Language detection (added for lawyer review). We detect the language of the text of each post and comment on our own server and store the result. If the text is too short or unclear, we use your app language and mark it as not reliable. Nothing is sent to anyone else for this.
• Automated moderation (added for lawyer review). After you post, we send the text (title and text) of a post or comment, or one photo, to Cloudflare Workers AI (the Clef-flash model), which answers fixed questions: sexual content, harassment or hate, violence or gore, self-harm, spam or scam, illegal content. We store the scores and act on them as described in section 3.6. Cloudflare acts for us as a processor, does not use this data to train its models, and the transfers are covered by Cloudflare's Data Processing Agreement, the EU-US Data Privacy Framework and Standard Contractual Clauses (see sections 4 and 5). [VERIFY: Cloudflare's retention of Workers AI inputs is not documented; AI sub-processors CoreWeave (US) and Nebius (UK); no EU-only processing]
• Scanning of images for child sexual abuse material (added for lawyer review). Images that Komnu serves through Cloudflare can be checked by Cloudflare's CSAM Scanning Tool against known illegal material. A match is blocked and Cloudflare tells us. [VERIFY: that the tool covers our media hostname]
• Telling you about removals (added for lawyer review). If an administrator removes your post or comment, we send you a statement of reasons as described in section 3.6. It says what was decided, why, which rule applies, whether an automated check (the Workers AI scores) led to the decision or to hiding the item, and how to appeal. Hidden and removed items stay visible to you, with the reason.
• Legal basis: contract (Art. 6(1)(b)) for posting, commenting, liking and your home country; our legitimate interest (Art. 6(1)(f)) for language detection, the spam counters, the automated moderation and the CSAM scan, which keep Community safe and usable; our legal obligations under the Digital Services Act (Art. 6(1)(c)) for statements of reasons. For the feedback board, our legitimate interest in improving Komnu (Art. 6(1)(f)). [VERIFY: counsel to confirm each basis, in particular 6(1)(f) for the AI scoring and for the CSAM scan]

3.9 Notifications

• What we store. We keep in-app notifications, your notification settings and your device's push token.
• Asking for permission. During sign-up we explain what notifications are for and ask for your permission. You can continue without allowing them. The Firebase Cloud Messaging (FCM) push token is created only after you allow notifications.
• How push is delivered. Android push notifications are delivered through Google Firebase Cloud Messaging. A chat or message notification includes the sender's name and the message text so it can be shown on your lock screen, so that text passes through Google. Push notifications on iPhone are not available yet; when they are, they will be delivered through Apple Push Notification service in the same way.
• Controlling push. You can switch categories off in the app, or turn off notifications in your device settings.
• Legal basis:
  • Contract for the in-app notifications.
  • Your consent, given through the device prompt, for push.

3.10 Komnu Pro

• Who handles payment. Payments are handled by Apple (App Store) or Google (Google Play). We never see your card details.
• How Pro is verified. RevenueCat checks your subscription for us. RevenueCat receives a random pseudonymous ID that Komnu creates for you (not your Komnu profile ID, your name or your email address) and your purchase records from the app stores. When your account is deleted, we also ask RevenueCat to delete its record for you. The app’s Pro purchase screen (Paywall) and subscription management screen (Customer Center) are provided by RevenueCat, so it also receives what you do on those screens.
• What we store. We store when your Pro access ends.
• Legal basis: contract (Art. 6(1)(b)).

3.11 Logs, security, analytics and crash reports

• Server logs. Our servers log each request: IP address, browser or app version, the page or API address requested, your user ID if you are signed in, and the result. We keep these logs for 7 days to protect the service and fix faults. We also count actions to enforce rate limits. Legal basis: legitimate interest (Art. 6(1)(f)).
• Product analytics (optional). Analytics is off by default. If you turn on “Share usage analytics” when you set up your account or later in Settings, the app sends usage events to PostHog to help us improve Komnu: which screens you open, joining and hosting games, creating a series, and purchasing Pro. These events are tied to your Komnu user ID, never your email address. PostHog hosts the data in its EU cloud in Frankfurt. Our PostHog project anonymises IP addresses (anonymize_ips: true). The apps contain no advertising tools and do not read your device's advertising ID. Turning analytics off in Settings stops it and resets your device's analytics ID. Legal basis: your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time in Settings.
• Firebase on Android. The Android app does not start Firebase when it opens. Until you allow notifications or turn on crash reports, it sends nothing to Google and stores no Firebase identifier on your phone. Allowing notifications starts Firebase so the FCM push token can be created (see 3.9). Crash reporting stays off in that case, but Crashlytics keeps a random installation identifier on your phone without sending it. Legal basis: for push, providing the notifications you asked for (Art. 6(1)(b)); for crash reports, your consent (below).
• Crash reports (Android, optional). The Android app includes Google Firebase Crashlytics. It is off unless you turn on "Send crash reports to help fix bugs" during sign-up or in Settings, under Account. When it is on and the app crashes, it sends a technical report: where the code failed, your device model, its operating system and app version, and random installation identifiers. It is not linked to your Komnu account. Turning it off stops the reports and deletes any that were not yet sent. The iPhone app sends no crash reports.
• Legal basis: your consent (Art. 6(1)(a)), which you can withdraw at any time with the same switch.

3.12 The public website

• No account and no tracking. You can browse komnu.app without an account. It uses no local storage and no analytics or tracking, and no cookies outside the account deletion page.
• Signing in to delete your account. On komnu.app/account/delete you can sign in with your Komnu email and password, Google or Apple (when available on that page). While you are signed in there, we keep your sign-in in an encrypted cookie that only that page uses and that expires after 30 minutes (__Secure-komnu_del_session). Google and Apple sign-in also use a cookie for up to 10 minutes to complete the sign-in safely (__Secure-komnu_del_oauth), and the page uses one for up to 2 minutes to show you the result of what you did (__Secure-komnu_del_flash). Your browser's scripts cannot read these cookies, they hold no tracking data, and signing out deletes them. They are strictly necessary for the service you asked for, so we do not ask for consent. Legal basis: performance of our contract with you (Art. 6(1)(b)).
• Other browser storage. The home page uses the browser's session storage to remember whether you paused the scrolling banners (komnu.marquee.ticker.paused / komnu.marquee.cities.paused). This is deleted when you close the tab, and it is never sent to us.
• Who receives your IP address. Your browser sends your IP address to our website host, as with any website. The map loads from OpenFreeMap, which also receives your IP address and the map area you view.
• Use my location. "Use my location" on the website map stays in your browser. Only the visible map area is sent to us, to load games.
• Legal basis: legitimate interest (Art. 6(1)(f)).

3.13 Profile visits

• What we record. When you open another member's full profile, we record that visit with the date and time, at most once per member you view per UTC day.
• Who can see it. The member you viewed can see that you visited if they have Komnu Pro. Members without Pro only see a count, not who visited.
• How long we keep it. Visits are kept for 30 days, then deleted automatically.
• When we do not record a visit. We do not record visits to your own profile, or visits between members if either has blocked the other. We also do not record visits by or to accounts that are deleted or in the deletion grace period.
• Account deletion. Deleting your account deletes the visits you made and received.
• Your data export. It includes the visits you made and received.
• Hide my visits. Turn on “Hide my visits” in Settings and your visits are not recorded, and the visits you already made are deleted.
• Legal basis and right to object. Our legitimate interest in helping members understand profile interest (Art. 6(1)(f)). You have the right to object: use “Hide my visits” or email us. Turning it on stops new records and deletes the visits you already made.

3.14 Emails to support

• What we receive. When you email support@komnu.app, we receive your email address, your name if you give it, your message and any attachments, and the date and technical details of the email. You do not need a Komnu account to email us.
• What these emails are for. Requests to use your data rights, reports of illegal content (which ask for your name and email address), complaints about our moderation decisions, requests to delete an account when you cannot sign in, and any other question. We use the email to answer you, to carry out what you ask, to check that a request about an account comes from its holder, and to keep a record of how we handled it.
• How long we keep it. Until we have dealt with your request, and then 1 year, so we can show how we handled it.
• Legal basis:
  • Our legal obligations (Art. 6(1)(c)) for requests under the GDPR and reports of illegal content under the Digital Services Act.
  • Our legitimate interest in helping the people who contact us and in handling complaints properly (Art. 6(1)(f)) for everything else.

3.15 Legal claims

• What we do. If we need to establish, exercise or defend a legal claim, for example about an injury at a game, a moderation decision or a court order, we may use the personal data that the claim concerns.
• How long we keep it. We do not keep data in advance in case a claim might come. Data is kept beyond the periods in section 6 only when an actual claim, or one we have concrete reason to expect, needs it: only the data that claim needs, and only until it is settled or can no longer be brought. Then we delete it.
• Legal basis: our legitimate interest in protecting our rights (Art. 6(1)(f)).

3.16 Age check for users in the UK and Australia (added for lawyer review)

This section applies if Komnu is offered where you live, or you set your home there. Komnu may not be available in every country, and this section does not mean it is.

• Who is checked. You are asked to pass an age check if any one of these is the United Kingdom or Australia: the country of your App Store or Google Play account, the country of your home pin, or the home country of a community you belong to. Once you have passed, we do not ask again.
• What happens. The App opens our provider's page in your browser. It estimates your age from a live image of your face. If the estimate is close to 18, you are asked to show an ID document instead. The check is run by Didit (see section 4), not by us. We never see your face image or your ID document.
• What Komnu keeps. Only that you are over 18 ("over 18: yes"), the time of the check and Didit's session reference. We keep these for as long as your account exists. We do not keep your face image, your ID document, your date of birth or the estimated age.
• What Didit keeps. As soon as we have read the result, we ask Didit to delete the session. As a back-stop, Didit's own retention is set to the shortest period its service allows (currently one month), so data is removed even if a deletion request does not go through. [VERIFY: the retention period set in the Didit account, and that Didit deletes the face image and ID document on session deletion]
• Legal basis. Compliance with a legal obligation (Art. 6(1)(c)): the UK Online Safety Act 2023 and the Australian Online Safety Act 2021 rules for social media minimum age. [VERIFY: counsel to confirm that these obligations apply to Komnu, and whether a face age estimate counts as biometric data under Art. 9(1) GDPR and UK GDPR that needs explicit consent (Art. 9(2)(a)), or is not processed "for the purpose of uniquely identifying" a person]
• If you do not pass. You can try the check once a day. If you do not finish it, nothing is blocked or deleted: your account stays locked and the App shows only the age check until you pass. If the face estimate says you are under 18, you are asked to show an ID document instead. Only an ID document that shows you are under 18 blocks your account. A blocked account is deleted 30 days after the block (see section 6). You can also delete your account yourself at any time (section 7).

4. Who we share data with

We share personal data only with these parties. Our processors may use it only to provide their service to us.

• Other users and the public. They see what Section 3 describes. Hosts and players decide for themselves what they do with what they see on Komnu, and they are responsible for that; this policy covers only what Komnu does. Our Terms of Service limit them to using it for organising and playing games.
• Legal requests. We may disclose data where the law requires it, for example to comply with a court order, or to the police where the Digital Services Act requires us to report a threat to someone's life or safety.
• Company sale or merger. If Komnu is sold or merged, your data may move to the new owner, under this policy.
• No selling or ads. We do not sell your personal data and we do not share it for advertising.

5. International transfers

Some of the recipients above are in the United States or may process data there. Where a recipient is certified under the EU-US Data Privacy Framework, we rely on that adequacy decision. Otherwise we rely on the European Commission's Standard Contractual Clauses. [VERIFY for each provider] You can ask us for a copy of the safeguards at support@komnu.app.

PostHog hosts our analytics data in the EU (Frankfurt), but PostHog Inc. is a US company. Its Data Processing Agreement (DPA), including the Standard Contractual Clauses (SCCs), provides safeguards for any transfers outside the EEA. PostHog Inc. also participates in the EU-US Data Privacy Framework, including its UK and Swiss extensions (PostHog DPA, section 10.3).

Cloudflare R2 stores our media in Western Europe (WEUR), a location hint within the EU/Western Europe, not an EU jurisdiction setting. Cloudflare Inc. is a US company and participates in the EU-US Data Privacy Framework (DPF). We rely on that adequacy decision for covered transfers to Cloudflare; its Data Processing Agreement (DPA) also includes Standard Contractual Clauses (SCCs).

Cloudflare Workers AI (automated moderation of Community posts, section 3.8) runs on Cloudflare's global network and can process the text and photos we send outside the EU, including in the USA. These transfers are covered by the same Cloudflare DPA, the EU-US Data Privacy Framework and the SCCs. Cloudflare does not use this data to train its models. [VERIFY: Cloudflare's current documentation and sub-processor list for Workers AI]

Didit (age check, section 3.16) processes the data in the EU (AWS) by default, so a transfer outside the EEA arises only if its sub-processors or support access it from elsewhere. Any such transfer relies on the safeguards in our Data Processing Agreement with Didit. [VERIFY: the signed DPA, its Standard Contractual Clauses and Didit's sub-processor list]

6. How long we keep your data

7. Deleting your account

You can delete your account at any time in the app's settings, or at komnu.app/account/delete after signing in with your Komnu email and password or with Google or Apple (when available on that page): type DELETE to confirm.

The 7-day grace period: when you confirm, we record when you asked and email you the scheduled deletion date, 7 days after your request. Your account is locked straight away: you can only check the deletion status, download your data, repeat the deletion request, cancel the deletion, leave games you joined or cancel games you host. Your profile and the games you host stay visible to other users until the deletion. Your account is deleted for good on or shortly after the scheduled date.

Changing your mind: sign in, in the app or at komnu.app/account/delete, and choose Cancel deletion before the 7 days end. Signing in alone does not cancel the deletion. We email you to confirm the cancellation, and your account works as before.

If you cannot sign in: follow the email steps at komnu.app/account/delete, or write to support@komnu.app from the address on your account. We check that the request comes from you, delete the account without the 7-day wait, at the latest within one month, and confirm by email.

What is removed: your sign-in details, 18+ confirmation and its timestamp, your age check record (3.16), gender, bio, profile picture and photos, chat photos, voice clips and videos, alert zones, friends, nicknames, blocks you placed, high fives you gave and received, game-chat mute settings, Community posts, comments, likes, photos and videos, your Community countries and spam counters, notifications and notification settings, push tokens, feedback posts and votes, your record of past games, your Terms acceptance record, and your RevenueCat record. Every direct message conversation you took part in is deleted, for both people in it.

What happens to your games: games you are hosting are cancelled, and your places in other games are released.

What stays: we keep an anonymous "Deleted user" profile so game rosters and match chats still make sense. Match chat messages you wrote stay in that chat, marked as from "Deleted user", until the chat is deleted 7 days after the game ends. Reports that involve you are kept until 1 year after they are resolved. If you were the subject of an open or recently upheld report, we keep a one-way hash of your sign-in identity for 12 months so the account cannot be re-created straight away. If an actual or expected legal claim needs some of your data, we keep that data until the claim is settled (see 3.15).

8. Your rights

Under the GDPR you have the right to:

• access your data. Use Export my data in the app's settings for a copy in JSON format, or email us.
• rectification: correct your data. Change your username or bio in the app; email us for anything else, such as your gender.
• erasure: delete your account in the app or at komnu.app/account/delete (final after 7 days, see Section 7), or email us.
• restriction of processing.
• data portability: the app's export is machine-readable.
• object to processing based on legitimate interest, including the public listing of a game.
• withdraw consent at any time, for example by turning off precise location, crash reports or usage analytics in the app's settings, or location or notification permission in your device settings. This does not affect processing that already happened.

Email support@komnu.app to use any of these rights. We answer within one month. For complex requests we may extend this by up to two more months, and we will tell you if we do. We may need to confirm your identity first, normally by replying from the email address on your account.

You also have the right to complain to the Dutch Data Protection Authority, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl), or to the authority in your EU country. If you live outside the EU, see section 12 for your country; if you live in Quebec, section 12 also lists the rights Quebec law adds.

9. Age limit (18+)

• Who can use Komnu. Komnu is only for people aged 18 and over. We check your date of birth when you sign up. If your App Store or Google Play account is a US account, we also ask the store for your age range (see 3.1). If you are in the UK or Australia, or set your home there, you must also pass an age check (see 3.16).
• Reporting someone under 18. Use "Appears to be under 18" when reporting a profile. You can also report it without an account, for example as a parent: email support@komnu.app with the username or anything else that helps us find the account.
• What we do. If we learn that a user is under 18, we delete the account.

10. Security

• Encryption in transit. All connections use encryption (HTTPS).
• Passwords and codes. Passwords and one-time codes are stored only as hashes.
• Access control. Personal data is reachable only through access-checked server code, never by direct database access.
• Abuse limits. We apply rate limits against abuse.
• On your phone. The app keeps your sign-in tokens in your phone's encrypted storage.
• Breaches. If a breach puts your data at risk, we will notify the Autoriteit Persoonsgegevens and, where required, you.

11. Cookies and storage on your device

• Website. It uses no tracking. The only cookies are the short-lived sign-in cookies on komnu.app/account/delete (__Secure-komnu_del_session, __Secure-komnu_del_oauth and __Secure-komnu_del_flash), which are strictly necessary; see 3.12.
• App. It stores your sign-in tokens (encrypted), your settings (including your crash-report, analytics and precise-location choices), the analytics ID described in 3.11 while analytics is on, and a cache of games and drafts on your phone, so it works quickly and offline. These are needed for the app to work. Uninstalling the app removes them.
• Android crash reports. Firebase Crashlytics, off unless you turn it on, is described in 3.11.

12. If you live outside the EU

We apply this policy, and the GDPR rights in section 8, to everyone, wherever you live. Where the law of your country gives you more, this section says how.

12.1 If you live in Switzerland

• Swiss law. The Swiss Federal Act on Data Protection (FADP) also applies to how we handle your data. The rights in section 8 cover the rights it gives you.
• Complaints. You can complain to the Federal Data Protection and Information Commissioner (FDPIC, edoeb.admin.ch).
• No Swiss representative. We have not appointed a representative in Switzerland. The FADP (Art. 14) requires one only from controllers abroad whose processing of Swiss residents' data is large-scale, regular and high-risk, and ours is not.
• Transfers. Switzerland recognises the EU as giving adequate protection. For recipients in the US we rely on the Swiss-US Data Privacy Framework where the recipient is certified, and otherwise on standard contractual clauses. [VERIFY Swiss transfer mechanism per provider]

12.2 If you live in Singapore

• Data protection contact. For the Personal Data Protection Act 2012 (PDPA), the person responsible for data protection at Komnu is its owner. You can reach the owner at support@komnu.app with any question, complaint or request for access to or correction of your data.
• Complaints. If you are not satisfied with our answer, you can contact the Personal Data Protection Commission (PDPC, pdpc.gov.sg).

12.3 If you live in the United States

This part is our privacy notice for US state consumer privacy laws, including Connecticut's Data Privacy Act and the laws of states like it. [VERIFY which state laws reach Komnu]

• What we collect, why, and who receives it. Section 3 lists the categories of personal data and why we use them, section 4 who we share them with, and section 6 how long we keep them.
• Precise location is sensitive data. These laws treat location that is accurate to within about 1,750 feet (533 metres) as sensitive data. We use your precise location only after you opt in on the app's own screen (see 3.4), only for the features you ask for, and we never sell it. You can withdraw your consent in the app's Settings at any time, as easily as you gave it, and the app stops reading your location straight away.
• No sale, no targeted advertising. We do not sell personal data, we do not use it or share it for targeted advertising, and we do not use it for profiling that has legal or similarly significant effects on you.
• No AI training. We do not use your personal data to train large language models, and we do not give it to others for that purpose.
• Your rights. You can ask us to confirm whether we process your data and to let you access it, to correct it, to delete it, and to give you a copy you can take elsewhere (the app's Export my data does this). You can also opt out of the sale of your data, targeted advertising and profiling; we do none of these, but you can still ask. Use the tools in the app, or email support@komnu.app. We answer within 45 days, and if we need up to 45 more days we tell you why. We will not treat you differently for using these rights.
• Appeals. If we turn down your request, in whole or in part, you can appeal by replying to our answer or emailing support@komnu.app with the word "Appeal". We answer your appeal in writing within 60 days and explain our decision. If you disagree with it, you can complain to your state's Attorney General; in Connecticut, at portal.ct.gov/AG.
• Age. Komnu is only for adults. For US store accounts we also use the store age check described in 3.1.
• California. Komnu does not meet the thresholds of the California Consumer Privacy Act (CCPA/CPRA). We do not sell or share personal information as those laws define it. If you live in California, you may still use the rights above.
• When this part was last updated. October 2026.

12.4 If you live in Quebec

This part applies to you if you live in the province of Quebec, Canada, on top of the rest of this policy. It follows Quebec's Act respecting the protection of personal information in the private sector (the "Private Sector Act", as amended by Law 25). [VERIFY: counsel to confirm the Quebec text before launch in Canada]

• Person in charge of personal information. The Private Sector Act (s. 3.1) requires us to name one. It is the owner of Komnu, [VERIFY: owner's full name], owner and sole proprietor. You can reach them at support@komnu.app.
• Your rights. You can ask us for access to the personal information we hold about you, and for a copy of it (Private Sector Act, s. 27); to correct it (s. 28); to stop disseminating it or to de-index a link to it, where the law allows (s. 28.1); and, since 22 September 2024, to receive your computerised personal information in a structured, commonly used technological format, or to have it passed to another organisation you name (s. 27). You can also withdraw your consent at any time. Use Export my data in the app's settings, or email us. We answer within 30 days of receiving your request (s. 32).
• Withdrawing consent. Turn off precise location, crash reports or usage analytics in the app's Settings, or delete your account (section 7). Section 8 says how this works.
• Complaints. If you are not satisfied with our answer, you can complain to the Commission d'accès à l'information du Québec (CAI, cai.gouv.qc.ca).
• Data that leaves Quebec. Yes. Our servers are in Germany, and some of our processors are US companies or process data in the USA (see sections 4 and 5: for example Cloudflare, Google, RevenueCat and PostHog). Before communicating personal information about a Quebec resident outside Quebec, the Private Sector Act (s. 17) requires an assessment of the privacy risks. We made one: it looked at how sensitive the information is, why it is used, the protection measures (the EU-US Data Privacy Framework or Standard Contractual Clauses, encryption in transit, access control) and the legal regime of the destination. It concluded that the information would receive adequate protection, taking generally recognised principles into account. [VERIFY: owner and counsel to confirm the assessment's conclusion] You can ask us for a summary at support@komnu.app.
• Location. Komnu reads your precise location only after you choose "Allow precise location" on its own screen; nothing is pre-selected and the choice is not part of accepting the Terms. Until you do, the location functions are off: no check-in, and the app reads no location at all. You can withdraw the choice in Settings at any time. The free-plan distance check asks your phone for one approximate location when you tap Join or Create, uses it for that request only and does not store it (see 3.4). We do not track you in the background.
• Profiling. Komnu does not build profiles of you to predict your behaviour or preferences, and it makes no decision about you based only on automated processing that has legal or similarly significant effects. Automated checks exist only for moderation (see 3.6), and a person decides any action against an account. If that ever changes, we will tell you when the decision is made and let you ask for a review by a person (s. 12.1). Usage analytics is off unless you turn it on (3.11).
• Confidentiality incidents. If an incident presents a risk of serious injury to you, we will notify you and the CAI as the Private Sector Act (s. 3.5) requires.
• French. This policy is available in French. [VERIFY: French version published before Quebec launch]

12.5 If you live elsewhere in Canada

The federal Personal Information Protection and Electronic Documents Act (PIPEDA) applies to how we handle your data, together with the provincial laws that replace it in Alberta and British Columbia [VERIFY]. The rights in section 8 cover access and correction. You can complain to the Office of the Privacy Commissioner of Canada (OPC, priv.gc.ca).

13. Changes to this policy

When we change this policy, we update the "Last updated" date. For important changes we tell you in the app or by email before they take effect.

14. Contact

Komnu, eenmanszaak
Oder 20, 2491 DC Den Haag, the Netherlands
KvK: 42175589
VAT (btw): NL005558432B92
Email: support@komnu.app