Privacy policy

For an account we store:

• your username;
• your password, as a hash only (never in plain text);
• your e-mail address (required; for players under 16 a parent's) and when it was confirmed. We use it only to confirm the account (a 6-digit code valid for 30 minutes), for "Forgot password" (a code valid for one hour) and to tell you about your account – never for newsletters or advertising. Up to five accounts can share an address (e.g. brothers and sisters with one parent). The address is deleted with the account. Mail is sent through the Spacemail service of Spaceship, Inc. (USA), see 6.12;
• your acceptance of the terms of use (version and time);
• the date you signed up.

Legal basis: Art. 6(1)(b) GDPR (the contract for using the game).

To prevent abuse we briefly count sign-up and sign-in attempts per account and per IP address:

• sign-up: at most 20 per hour per IP;
• sign-in: at most 5 failed attempts per account and 30 per IP in 15 minutes;
• every action in the game: a limit per character.

These counters live only in the server's cache and expire with their time window. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in a secure service).

For your character we store what the game needs:

• character: name, looks, chosen traits, mood and mood of the day, the character's language;
• earned in the game: coins, tickets, inventory, house and furniture, pet, job, guild, collection book, gifts, guest-book entries, votes (mayor, island);
• game history: relationships and memories between characters, events in the village;
• place and time: position in the village and last place visited, times of your last activity.

Other players in your village see your character, its name, looks, position and what it does in the game. Please do not use your full real name as your character's name.

Legal basis: Art. 6(1)(b) GDPR.

So that others can see you walk, your device keeps sending your position in the village to our real-time server. It only forwards it to the others in the same village and does not store it. There is no free chat between players, only fixed phrases and gestures from a list. Legal basis: Art. 6(1)(b) GDPR.

You can connect with people you know in real life. Every account has a friend code (e.g. MOND-4827) that you give out yourself; nobody can search for names. You can also show the code as a QR code and scan it with the camera. The camera picture is only read on your device (on Android with Google's on-device barcode recognition ML Kit) and is neither stored nor sent to us.

A friendship only exists once the other person agrees. For this we store the code, who is friends with or has asked whom, and whom you have blocked. Your friends see your game name, your character, whether you are online and which village you live in – nothing else.

Friends can only send each other fixed sentences and pictures from a list, no free text. We keep these messages for 30 days; they are deleted at once when a friendship ends, when somebody is blocked and with the account. Legal basis: Art. 6(1)(b) GDPR.

If a friend lives in another village, you can visit them there for up to one hour. During the visit, the people in that village see your game name, your character, where it stands in the village and which village you are from – nothing else. They can only address you with fixed sentences and gestures, no free text. What you catch or find there goes into your own bag.

For this we store who visits whom, in which village, where your character stands there, when the visit began and ended, and how many things you picked up. Ended visits are deleted after 14 days, and at once with the account. Beyond that there is no record of where you have been. If somebody sends you home, we note that with that person together with their invitations (only which character and on which day), so that you can only come back after a new invitation.

In the settings anyone – including parents for their child – can switch "Allow visits" off. Then nobody can visit that player and they visit nobody; visits in progress end at once. Blocking somebody or ending a friendship also ends a visit at once. Legal basis: Art. 6(1)(b) GDPR.

Every character has a market stand in front of its house. There you lay out things from the game at a price you choose within a fixed range; other players in your village and neighbour characters can buy them. Payment is in game coins only. We store what you lay out and, for each sale, what was sold when and for how many coins, with the buyer's game name, so you can see who bought from you. Sales are deleted after 30 days, and at once with the seller's account. If a buyer deletes their account, their game name stays in that list at most until the 30 days are over.

You can give things from your bag to neighbour characters and other players – to other players only when they stand next to you in your village or are your friends. Coins cannot be given. We store who gave what to whom and when; the receiver sees your game name and the gift. Gifts are kept for 30 days and deleted at once with the giver's or receiver's account. Legal basis: Art. 6(1)(b) GDPR.

Reporting: you can report another player in the game ("🚩 Report") and pick a reason from a fixed list (no free text). We keep the report with both game names, the village, the reason and – so that we can check it – the last messages, gifts and visits between the two of you. We are told by e-mail (through Spacemail, see 6.12). Closed reports are deleted after 180 days, every report after one year at the latest, and at once with the reported player's account. Legal basis: Art. 6(1)(f) GDPR (our legitimate interest in protecting young players in the game and enforcing our terms of use).

The game has learning questions, for example on maths, nature or language, suited to your age. For this we only derive an age band from your year of birth (see 6.13): 13–15 or 16+. We store no extra age, and only the band is sent to the app. Without a year of birth the game uses the 13–15 band.

With your account we store your learning progress: which questions you have had, how many you answered correctly per subject, the difficulty level, the counters for the day and your learning badges. The questions are written in advance; no AI is used for them and nothing is sent to third parties. The progress is kept as long as the account exists. Legal basis: Art. 6(1)(b) GDPR.

The village paper is made every morning from what happened in the village the day before, with the game names of the characters involved (see also 6.4). Players with the trade newspaper maker choose up to five of these stories during the day; for this we keep only the current day's choice with their account. The newspaper makers of an issue are named with their game name in that issue's imprint. Issues are kept for 14 days. An issue that newspaper makers helped set is not reworded by the AI (6.4); it appears exactly with the fixed texts that were chosen.

In the settings you can choose "Don't mention me in the village paper". Then your name is printed neither in stories nor in the imprint; what you did at most counts in a total without names. Legal basis: Art. 6(1)(b) GDPR.

In the art studio you trace a picture with your finger or the mouse. For this we only send the strokes (points and colours) to our server; the server itself checks, without AI and without third parties, whether the picture matches the lesson. Pictures that are not accepted are not stored. Accepted pictures are private: only you see them in your portfolio, nobody else. We keep the newest 12 pictures with their lesson, stars and date, and your art studio badges, as long as the account exists; older pictures are deleted, all of them with the account. Legal basis: Art. 6(1)(b) GDPR.

On the free sheet you draw without a lesson. These pictures are not checked as long as they only lie in your portfolio; we keep the newest 12 free pictures besides the lesson pictures.

Pictures on the house wall: you can hang up to three of your pictures in your house. Everybody who is in your house (neighbours you let in, and guests on a visit) then sees them, with your game name as the owner of the house. Before a free picture may go on the wall, an AI checks it: our server paints a picture (PNG) from your strokes and sends only this picture – without a name, a village or anything else – to Anthropic (see 6.4), which checks whether it shows anything rude, violence, forbidden signs, insults, contact details or writing. The picture only hangs on a clear "fine"; we store the result with the picture. Lesson pictures hang without an AI check. Legal basis is Art. 6(1)(f) GDPR (our legitimate interest in protecting young players from unsuitable content and from contact by strangers) and, for showing it in the house, Art. 6(1)(b) GDPR.

Whoever sees a picture on a house wall can report it. It is then hidden from everybody but you until we have checked it, and we receive an e-mail with the picture, the game names of the painter and the reporter and the reason (via Spacemail, see 6.12). We keep the report with our decision; it is deleted with the picture, at the latest with the account. If we remove a picture after a report, we note this on your account (after three times you can no longer hang free pictures); unfounded reports are noted on the reporter's account.

For some texts we use the AI model Claude by Anthropic PBC, 548 Market Street, San Francisco, CA 94104, USA. Anthropic processes the data on our behalf under a data processing agreement (Art. 28 GDPR).

• Conversations with neighbours – What is sent to Anthropic: the names of the characters involved (yours too), mood, relationship, place, topic and the conversation so far (you pick your replies from fixed suggestions); When: when you talk to a neighbour
• The village's day plan – What is sent to Anthropic: names, traits and plans of the neighbour characters and the village's basic facts; When: once a night per village
• Village paper and event texts – What is sent to Anthropic: what happened in the village, with the names of the characters involved (including players who just moved in); When: when events or the paper are shown
• Lyaa, the helper – your own questions – What is sent to Anthropic: the text of your question, your character's and village's names; When: only when you (16+) ask a question, see 6.5
• Pictures on the house wall – What is sent to Anthropic: only the picture our server paints from your strokes – without a name or village; When: only when you want to hang a free picture in your house, see 6.3f

No account data (username, e-mail, password) and no device data is sent. According to Anthropic, data sent through the API is not used to train models. Anthropic deletes the data it receives after 30 days at the latest.

The transfer to the USA is based on the adequacy decision for the EU-US Data Privacy Framework, under which Anthropic is certified (Art. 45 GDPR), and additionally on the European Commission's Standard Contractual Clauses (Art. 46(2)(c) GDPR).

Legal basis: Art. 6(1)(b) GDPR (the AI texts are part of the game); for Lyaa see 6.5. If the AI cannot be reached, the game uses pre-written texts.

Every village has Lyaa, a helper who explains the game. Her fixed explanations use no AI.

Your own questions: from the age of 16 you can ask her up to three questions of your own per day. Before your first question you confirm that you are at least 16 and consent to your questions being answered by Claude from Anthropic (USA). Without this consent Lyaa only explains her fixed topics and nothing is sent.

What data:

• the text of your question and Lyaa's answer;
• the time;
• your age confirmation (yes or no, with date) and your consent (with time and version of the notice);
• the number of questions you asked that day.

The question is sent to Anthropic with your character's and village's names (see 6.4). Please do not put personal details such as your real name, address, phone number, e-mail address or passwords into your questions.

Purpose and legal basis:

• answering your question and sending it to Anthropic: your consent, Art. 6(1)(a) GDPR, and Art. 6(1)(b) GDPR. You can withdraw your consent at any time in the settings ("AI questions to Lyaa"); we then delete your stored questions and answers straight away;
• keeping questions for a short time to look into complaints and misuse: Art. 6(1)(f) GDPR.

Retention: questions and answers are deleted automatically after 30 days, and with your account straight away. Our server logs only record that a question was asked, never its content.

No automated decision-making: Lyaa's answers are help texts. They decide nothing about you and change nothing in your game. Lyaa is an AI and can be wrong.

You only get notifications if you allow them: when somebody invites you to a game, the games house calls, or the village votes on a new island. You can switch them off any time in the settings.

• App: we use Firebase Cloud Messaging by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. On the iPhone, notifications are delivered through the Apple Push Notification service. We store the device token, platform, language and the time it was registered.
• Browser: we use your browser's web push service (depending on the browser, e.g. Google, Mozilla or Apple). We store the service address (endpoint) and the keys needed to encrypt the notification.

The content of a notification is short (e.g. "Mia is calling everyone to the games house"). Invalid tokens are removed automatically, all of them with the account. With Google, a transfer to the USA cannot be ruled out. It is based on the adequacy decision for the EU-US Data Privacy Framework, under which Google is certified (Art. 45 GDPR), and additionally on the Standard Contractual Clauses in Google's data processing terms for Firebase (Art. 46(2)(c) GDPR).

Legal basis: your consent, Art. 6(1)(a) GDPR, and § 25(1) TDDDG. You can withdraw it any time by switching notifications off.

You can optionally take or choose a photo to suggest your character's skin and hair colour. This happens only on your device: two colours are read and the photo is then discarded. It is not uploaded and not stored. The app asks for your device's camera and photo permission.

You can found a village, join one with an invite code, or move. A village's founder can ask residents to leave; their game progress is kept.

You can delete your account yourself at any time in the settings, confirming with your password. The following is deleted straight away:

• the account with username, e-mail and password hash, and the "stay signed in" tokens;
• your character with everything that belongs to it: inventory, house, pet, guild, collection book, gifts, memories, relationships, events, notification tokens, questions to Lyaa.

With the account we also remove issues of the village paper and day plans in which your character appears. The village itself stays for its other residents.

Inactive accounts: if you have not signed in for 24 months, we delete your account in the same way. You get a notification a month before, if you allowed notifications. Signing in during that time keeps your account.

Accounts and villages we create ourselves for testing are deleted automatically after a few hours. This does not affect you as a player.

• Browser: the game sets two strictly necessary cookies:
  • PHPSESSID keeps you signed in during the session and is deleted when you close the browser.
  • REMEMBERME is set only if you choose "stay signed in". It lasts up to one year or until you sign out.

  The game also stores settings in your browser (local storage):

  • language, sound on/off;
  • whether the first hints have been shown, whether you were asked about notifications;
  • which paper you have read and which visitors you have seen.

  This data stays on your device. Legal basis: § 25(2) no. 2 TDDDG (strictly necessary), Art. 6(1)(b) GDPR.

• App: the app stores the sign-in (session cookie) and the same settings on your device.
• No tracking: there are no ads, no tracking, and no analytics or crash-reporting services.

Server and database run on a virtual server of Hetzner Online GmbH, Industriestr. 25, 91710 Gunzenhausen, Germany, data centre in Helsinki (Finland), see section 3. For the game the web server keeps no access logs with IP addresses. The application logs errors and technical events without the content of what players type. We delete these logs and the server's system log after 14 days. Sign-ins are recorded by the system with username, browser identifier and time, without IP address, and these entries are deleted after 7 days.

E-mail: mail about your account (the confirmation code with a link, "Forgot password", notices about your account) is sent through the mail server of the Spacemail service of Spaceship, Inc., 4600 East Washington Street, Suite 300, Phoenix, AZ 85034, USA. This involves your e-mail address, your username and the content of the mail. Mail you write to us at info@lyaa.ai is also kept in our mailbox at Spacemail. Spaceship processes the data on our behalf; the data processing agreement (Data Processing Addendum) is part of Spaceship's terms of service (Art. 28 GDPR). Data may be transferred to the USA. The transfer is based on the European Commission's Standard Contractual Clauses (Module 2, Art. 46(2)(c) GDPR), which are part of that agreement. Legal basis for sending the mail: Art. 6(1)(b) GDPR.

The game is for ages 13 and up; under 16 only with the consent of a parent or legal guardian. It is not directed at children under 13.

At sign-up, and once at the next sign-in for older accounts, we ask for the year of birth. We keep only the year, no day or month. As a year does not give an exact age, we decide carefully:

• Anyone who might be under 13 cannot sign up. So whoever was born in the year in which they turn 12 or 13 can join from 1 January of the following year.
• Anyone who might be under 16 needs a parent's consent. A parent confirms in the game "I am a parent or legal guardian and I agree that my child plays LYAA World", after a short explanation of what the game does.
• We store the year of birth, the confirmation, its time and the version of the text. Legal basis: Art. 6(1)(a) and Art. 8 GDPR.

When an account that may be under 16 signs up, we ask for a parent's e-mail address. The confirmation code goes there, with a short word on what the game is. The consent itself is a confirmation in the game; the mail to the parents makes it easier to follow, but nobody's identity is checked separately.

Asking Lyaa your own questions is only possible from 16 (see 6.5); with a known year of birth only when it certainly means 16. There is no free chat between players.

• Account, character, game progress – Kept: as long as the account exists; deleted after 24 months without signing in (notice a month before)
• Questions to Lyaa – Kept: 30 days
• Year of birth, parental consent – Kept: as long as the account exists
• Village paper (with its imprint) – Kept: 14 days
• Abuse counters (IP, account) – Kept: 15 minutes to 1 hour
• Notification tokens – Kept: until switched off, invalid, or the account is deleted
• Session cookie / "stay signed in" – Kept: session / up to 1 year
• Village events – Kept: 60 days
• Friend code, friends list, blocks – Kept: as long as the account exists
• Messages to friends – Kept: 30 days
• Visits to friends – Kept: 14 days after they end
• Sales at the market stand (with the buyer's game name) – Kept: 30 days
• Gifts – Kept: 30 days
• Learning progress and badges – Kept: as long as the account exists
• Art studio: the newest 12 lesson pictures and 12 free pictures, pictures on the wall, badges – Kept: as long as the account exists
• Reports about pictures on house walls – Kept: with the picture, at the latest with the account
• Reports about other players – Kept: closed: 180 days; at most 1 year
• Village day plans – Kept: 14 days

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