Privacy policy

1. In short

• We only ask for what the service needs to work. We don't sell data or show advertising.
• If you have an account, the controller of your data is the website's owner. If you answer a survey, the controller of your answers is the alliance that sent it to you; we store them on its behalf.
• Data is stored on servers in the European Union (Ireland).
• The website only uses technical cookies: the session one, the language one if you choose a language and, in the dashboard, three small ones for notices and first steps. There are no analytics or advertising cookies.
• For any question or to exercise your rights, write to soporte@kingdomanager.com.

2. Who processes your data

Kingdom Manager is provided by its owner, who is the controller of account data and the processor of survey answers, as the next section explains.

For now, Kingdom Manager is a personal project in its testing phase: it's free, charges nobody and shows no advertising. While that remains the case, its owner is identified by the name of the service and its contact email:

• Service: Kingdom Manager (formerly Community Surveys)
• Website: kingdomanager.com
• Email: soporte@kingdomanager.com

Before charging for any plan, the owner's full name, tax ID (NIF) and address will be published in the legal notice, as the Spanish Information Society Services Act (LSSI) requires from anyone providing a service as an economic activity.

There is no data protection officer: given its size and activity, the law doesn't require one.

3. Two different roles

The GDPR distinguishes between whoever decides what some data is used for (the controller) and whoever processes it on someone else's behalf (the processor). In Kingdom Manager there are two situations:

• Accounts. The data of people who sign up (owners and collaborators of alliances) is processed by the owner as controller, to provide them with the service.
• Members. The alliance that launches a survey decides to collect its answers: its owner is the controller of that data and decides what it is used for. The website's owner is its processor: it stores and processes the data only to provide the service to that alliance, under the data processing agreement that is part of the terms of use.

4. If you have an account

What data

• Your email and your password. The password is stored hashed with a one-way algorithm: nobody can read it.
• Your display name, if you set one, and your preferences (language and theme).
• The alliances you create (name, logo and the details their category asks for, such as its tag), the surveys you launch, the invitations you create and your collaborators' permissions.
• Your plan and, once there are payments, your subscription details (never your card details, which the payment provider will handle).
• The date and version of the terms you accepted when signing up.
• Technical security logs: the accounts provider records the IP address and browser of each login, and the hosting provider, those of each request to the website.

What for and on what legal basis

• Providing the service: creating your account, storing your alliances and surveys, showing you the results and sending you the essential emails (confirming the account, resetting the password, changing the email), in the language you choose. Basis: performance of the contract you accept when signing up (article 6.1.b GDPR).
• Showing your name and email to your team: people who share an alliance with you see your display name, and an alliance's owner sees their collaborators' email. Basis: the contract.
• Protecting the website against unauthorised access and abuse, with the technical logs. Basis: the legitimate interest in keeping the service secure (article 6.1.f).
• Complying with the law, for example tax obligations once there are payments, or a request from an authority. Basis: legal obligation (article 6.1.c).

We don't send advertising. If we ever want to send you news, we'll ask for your permission first.

For how long

For as long as you have the account. You can delete it whenever you want from Settings: your account, your alliances with all their surveys, members and answers, and your logos are deleted at that moment. The providers' technical logs delete themselves within a few days. Deleted data may remain until it expires in the database provider's automatic backups, which are only used to restore the service after a failure. If the law requires keeping some data (for example, invoices), it will be kept locked for the time the law sets.

5. If you answer a survey

The link to a survey is sent to you by an alliance, usually yours. That alliance is the controller of your answers: it decides what to ask, what it uses it for and how long it keeps it. Its name appears at the top of the form. For anything about your answers, contact it first; if you write to us, we'll pass it on.

What data is stored

• The identifier the survey asks for to recognise you (in Call of Dragons, your game ID) and your name in the community.
• Your answers (for example, your power, your playing hours or your troops), the date and time of each submission and the language you answered in.
• The language your browser prefers (for example, pt-BR), which the browser itself sends on every visit, even if the website isn't in that language yet. The alliance sees how many of its members ask for each language, and we use it, added up across the whole website and without looking at who is who, to decide which languages to translate it into.
• The country you connect from, as a two-letter code (for example, ES). The hosting provider works it out from your IP address and it is stored with each answer, so the alliance can see where its members are from. If you use a VPN, the VPN's country shows up. The IP address isn't stored.
• A pseudonymised fingerprint of your connection, to limit how many answers or PIN attempts arrive from the same connection and stop programs that fill in forms. It's a code calculated from your IP address with a secret key that only exists in the database (IPv6 addresses are grouped by network, /64), so it doesn't reveal what the IP was. After 24 hours it stops being used and is automatically deleted on the next visit to any form. Basis: the legitimate interest in protecting the form against abuse, which is part of the service we provide to the alliance.
• When you send the form or enter the PIN, a Vercel check (BotID) runs in your browser to tell a person apart from an automated program. It analyses technical signals from the browser at that moment; it isn't used to identify you or for advertising.

What you write is also saved in your own browser until you send it, so you don't lose it if you close the page (see the cookies section).

Who sees it and how long it lasts

Your answers are seen by the alliance's owner and the collaborators they give permission to. The alliance can delete your answers or your member record whenever it wants, and everything is deleted if it deletes the survey, the alliance or its account. We don't use your answers for anything of our own: the only thing we look at is how many answers come from each browser language, added up across the whole website, based on our legitimate interest in translating it into the languages most asked for.

The legal basis for collecting your answers is decided by the alliance (usually, your consent when answering or its legitimate interest in organising the community). Answering isn't mandatory.

6. If you write to us

If you write to soporte@kingdomanager.com, we use your email and what you tell us to answer you. Basis: your request and the legitimate interest in helping you. We keep the conversation for as long as needed to resolve it and, at most, one year afterwards, unless it is part of exercising a right, which is kept for the time needed to prove it was handled.

If you send us a suggestion from the suggestion box in the panel, we keep what you write, whether it's an idea, a bug or something else, the page you send it from, the website language and your account, and we get a notice by email with your display name and your email. Only we read it, to improve the website and, if needed, to write to you to understand it better. Basis: the legitimate interest in improving the service (article 6.1.f GDPR). If you delete your account, your suggestions are left with nothing linking them to it; the email notice is kept like any other message to support.

7. Providers and international transfers

We don't share data with third parties, except where the law requires it. We are helped by technical providers that only process the data to provide their service to us, under processing agreements that oblige them to protect it:

• Supabase, Inc.: database, accounts and files (logos). Data is stored in Ireland (European Union).
• Vercel Inc.: website hosting and anti-bot check (BotID). The website runs in Dublin (Ireland), and its network serves the pages from the point closest to you.
• Resend: sending the website's emails (confirming the account, resetting the password, changing the email) and the suggestion notices to support, from Ireland.
• ImprovMX Incorporated: forwards the messages written to soporte@kingdomanager.com to the owner's mailbox, including the suggestion notices.

All four companies are based in the United States, so some data may be processed there (for example, to provide technical support). Those transfers rely on the EU-US Data Privacy Framework, under which Vercel and Resend are certified, and on the European Commission's standard contractual clauses, which Supabase's processing agreement includes. For the forwarding of support emails, the transfer is necessary to handle the enquiry you send us (article 49.1.b GDPR).

8. Cookies and data in your browser

A cookie is a small file the website stores in your browser. Kingdom Manager only uses cookies that are essential for it to work or to give you something you ask for, which under article 22.2 of the Spanish LSSI don't need your consent:

• sb-…-auth-token (first-party, technical): keeps your session open when you log in with your account. It lasts until you log out or, at most, 400 days. While you confirm an email there may be another short-lived one with the same name ending in “code-verifier”. People who answer a survey without an account don't get any.
• idioma (first-party, personalisation): remembers the language you choose in the selector (Spanish or English), also when you answer a survey. It's only created when you choose one, or when you log in to keep your account's language, and it lasts one year.
• cs-aviso (first-party, technical): only in the dashboard, it carries to the next page the notice about what you just did (“Survey launched”, “Member deleted”…). It's deleted once shown and lasts one minute at most.
• cs-enlace-copiado and cs-pasos-ocultos (first-party, personalisation): only in the dashboard, they remember in which alliances you've already copied a survey link and in which you've hidden the “First steps” card. They only store those alliances' ids and last one year.

Until you choose a language, the website uses the one your browser says it prefers, which the browser itself sends on every visit. It isn't stored.

The website also saves in your browser (local storage, not cookies), only for your convenience:

• The draft of your answers to each survey, the day you sent them from that browser and, if the survey asks for it, its PIN, so you don't lose them if you close the page and so we can remind you that you already answered. While you answer, also that you have already started, so that changing the language doesn't take you back to the welcome screen; this is deleted when you close the tab.
• The theme you choose in Settings (light, dark or the system's).
• The language of the last page you saw, so that pressing Back doesn't show you a saved page in the previous language.

We don't use analytics, advertising or social media cookies. If we ever add them, we'll ask for your permission first. You can delete cookies and local storage from your browser settings; if you delete the session cookie, you'll have to log in again.

9. Security

All connections are encrypted (HTTPS). The database applies row-level rules: each account can only read and change its own data and what has been shared with it, even if someone tried to bypass the website. Secret keys only exist on the server, the public form has limits against abuse and passwords are stored hashed. If there were a security breach that put your data at risk, we'd notify the Spanish Data Protection Agency and, when the law requires it, you.

10. Your rights

Regarding your data, you can ask at any time for:

• Access: knowing what data of yours we process and getting a copy.
• Rectification: correcting it. You change your name, email and password yourself in Settings.
• Erasure: deleting it. You delete your account yourself in Settings.
• Objection to and restriction of processing.
• Portability: receiving your data in a format you can take to another service.

Write to soporte@kingdomanager.com from your account's email (or, if you are a member of an alliance, say which one and your identifier). We'll answer within one month at most. We'll only ask for something else to identify you if there are reasonable doubts that it's you. We don't make automated decisions that significantly affect you.

If you think we haven't handled your request properly, you can lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) or with the data protection authority of the EU country where you live.

11. Minors

You must be of legal age to create an account. Answering a survey doesn't need an account: it's the alliance that launches it that must make sure its members can answer it. In Spain, children under 14 need their parents' or guardians' consent for their data to be processed on the basis of consent.

12. Changes to this policy

If we change this policy, you'll see it in the date at the top. If the change is important, we'll let you know by email before it applies.