Data Protection Statement (Art. 13 & 14 GDPR)

Last updated: August 29, 2025

This statement informs you about the processing of personal data as required by Articles 13 and 14 of the EU General Data Protection Regulation (GDPR).

1. Data Controller

Cello’s GmbH
3114 Wichtrach
Switzerland
Legal contact:
Cello Spring – tickertactics@cello.ch

2. Purposes of Processing

We process personal data to:

• Register and manage user accounts
• Enable multiplayer functionality (e.g., invitations and guest player tracking)
• Analyze website usage (via self-hosted Umami analytics)
• Maintain and improve the quality of our online game
• Store temporary game state during active play (via session cookies)

3. Categories of Data Processed

• Account data: email, username, first name, last name (via Clerk)
• Game data: guest player names (stored in game history)
• Usage data: anonymized analytics information
• Cookies: essential session cookies for game state and login persistence

4. Legal Basis

Processing is carried out under:

• Art. 6(1)(b) GDPR – Necessary for the performance of a contract (game services)
• Art. 6(1)(f) GDPR – Legitimate interests (improving services and preventing abuse)
• Art. 6(1)(a) GDPR – Consent for optional cookies, if introduced in the future

5. Recipients of the Data

• Authentication services: Clerk (used for user management)
• No data is sold or shared with advertisers.

6. International Data Transfers

Your data may be processed in Switzerland, the EU, and the USA. Adequate safeguards such as standard contractual clauses are implemented where required.

7. Retention Period

We store your data as long as you maintain an account or as long as necessary for legal and operational purposes. Session cookies used for game state are temporary and expire automatically.

8. Rights of Data Subjects

You have the right to:

• Request access, correction, or deletion of your personal data
• Restrict processing or object to processing
• Receive your data in a portable format

To exercise your rights, contact: tickertactics@cello.ch

9. Right to Lodge a Complaint

If you believe your data is being processed unlawfully, you have the right to lodge a complaint with a data protection authority in your EU member state or in Switzerland.

10. Mandatory or Voluntary Provision of Data

Providing your email, username, and name is mandatory to create an account and access the game. Guest players’ names are optional and only used for in-game history.

11. Automated Decision-Making

We do not perform automated decision-making or profiling with legal or significant effects on you.

12. Changes to this Statement

We may update this Data Protection Statement periodically. Updates will be published on our website.