RoutePlay Privacy Policy

Last updated: [to be completed: date]

RoutePlay is a voice-based game app designed to be used by an adult during car trips and to play together as a family. This Privacy Policy explains what data is processed, for what purposes, and which rights you can exercise.

1. Data Controller

Sesterzi 2 Srl
Registered office: [to be completed: address]
VAT / Tax ID: [to be completed]
Website: https://routeplay.it
Contact email: alberto@sesterziconsulting.com

2. Who the app is intended for

RoutePlay is intended for a general audience and for families. It is not designed to be used independently by children on their own device: the app is installed and used on the adult's phone, and the adult manages the gameplay experience.

3. What data we process and why

RoutePlay works without an account or registration and makes no network calls of its own.

a) Microphone and speech recognition

If you choose to play using voice, the app asks for access to the microphone during voice-based game turns. The microphone is used only to understand the spoken answer. Speech recognition is handled by the device's system service:

• on Android, through the speech recognition service available on the device, such as Google's service;
• on iOS, through Apple's Speech framework.

Depending on the settings and the service used, audio may be sent to the relevant provider's servers (Google or Apple) for transcription. RoutePlay does not record or store audio: it receives only the recognized text from the system service, uses it for the game turn and does not save it. Audio is not used for advertising or profiling.

b) Player names and scores

During the game, you may enter player names or nicknames and view scores. This information stays in memory only during the game session and is cleared when the app is closed: it is not permanently stored nor transmitted to Sesterzi 2 Srl.

c) In-app purchases (future feature)

RoutePlay may include in-app purchases or freemium features in the future. In that case, payments will be handled directly by Google Play or the App Store: Sesterzi 2 Srl does not see or store card details or other financial information. The app may receive from the store only the technical information needed to confirm the purchase and unlock the relevant features.

d) Voluntary communications

If you contact us by email, we will process the data you provide, such as your email address and the content of your message, only to respond to your request.

4. What we do not do

RoutePlay does not require an account, does not require login, does not include advertising, does not use advertising SDKs, does not use analytics SDKs, does not use third-party crash reporting tools, does not perform profiling, does not perform advertising tracking, and does not process special categories of personal data under Article 9 GDPR.

5. Legal basis

Under Regulation EU 2016/679 (GDPR):

• performance of a contract or pre-contractual measures (Article 6.1.b GDPR), to provide the app's features, including voice games and any future in-app purchases;
• access to the microphone is subject to the permission you grant through the operating system, which you can revoke at any time in the device settings;
• legitimate interest (Article 6.1.f GDPR), to manage support requests voluntarily sent by email and to protect the proper functioning of the service.

6. Data retention

RoutePlay does not store audio on Sesterzi 2 Srl systems. Player names and scores stay in memory only during the game and are cleared when the app is closed. Emails sent to the support contact are retained for the time necessary to handle the request and for administrative or legal protection needs, and in any case no longer than [to be completed: e.g. 24 months].

7. Recipients and providers

The following providers may be involved in the operation of the app:

• Google, for speech recognition on Android and, in the future, purchases through Google Play;
• Apple, for speech recognition on iOS and, in the future, purchases through the App Store.

These providers process data according to their own privacy policies and terms applicable to their services and operating systems.

8. Transfers outside the European Economic Area

The use of Google and Apple services may involve data transfers to countries outside the European Economic Area. Where applicable, such transfers take place under the safeguards provided by the GDPR, such as adequacy decisions, standard contractual clauses or other legal mechanisms, according to the respective providers' disclosures.

9. Data subject rights

Within the limits set by the GDPR, you may exercise the following rights: access, rectification, erasure, restriction of processing, objection, data portability (where applicable), and withdrawal of consent or permissions (where applicable).

To exercise your rights, you can contact: alberto@sesterziconsulting.com

You also have the right to lodge a complaint with the competent supervisory authority. In Italy, this is the Italian Data Protection Authority: https://www.garanteprivacy.it

10. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to the app, the services used or applicable laws. The updated version will be published on this page.

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