Data & minors

Data controller

The data controller is Grisloup, the trading name of MARCHAL DE GREEF Guillaume, sole trader, 20 rue Lavoisier, 95300 Pontoise, France, SIREN 109354092, RCS Pontoise, grisloup.com (contact: donjons@grisloup.com). Data processing is governed by our privacy policy, of which this page is a faithful summary.

This sheet covers the only country open so far: France. The user declares their country on first use; that choice decides which documents apply and which servers host their data, which cannot be moved afterwards. Further countries will open progressively, and each will arrive with its own terms of service and its own privacy policy, adapted to the law that applies there: see the legal space for the list of open countries and their documents. This sheet describes France; it does not apply to a country that is not open yet.

Data Safety

This table reflects the “Data Safety” declaration of the Google Play listing.

All data travels encrypted and is stored on the servers of the country chosen by the user, today servers located in the European Union for France. The only exceptions stay inside Google: sign-in (account identifier) is processed in the United States, and notifications are routed through Google's global network. Users can request the complete deletion of their data at any time: from the app or via the account deletion page.

Beta waiting list

The website, not the application, offers a form to be told when the betas open. It collects an email address, the sign-up date, the language of the page and the page it came from, and nothing else: the site sets no cookies and runs no analytics. The list is for adults, kept separately from game data, never matched against a player account, never sold or passed on, and deleted in full at the end of the beta phase. You can be taken off it at any time by writing to donjons@grisloup.com.

Retention and withdrawal of consent

For one's own data, withdrawing consent is exercised by deleting the account: it is the same action. For a minor, deleting the clan chief's account dissolves the clan and takes with it the profiles of the children who no longer have a legal guardian.

For a child, consent can also be withdrawn from the app, without deleting the adult's account: on the clan screen, the child's menu offers the chiefs of their clan of origin the option “Withdraw my consent and erase this child's data”. The child leaves the game at once, but nothing is erased yet: during a 3-day reflection period, a chief of that clan can reverse the decision with “Restore this child”, and the child gets their place back intact. Once that period is over, the child's game data is deleted in all their clans and their account is deactivated (if they have no account, their profile is erased); retention and erasure then follow the schedule below.

Deletion happens in three stages:

• immediately: account unusable, profile removed from the clan, data no longer exposed in the game;
• 30 days: retention outside the service, under restricted access, with no use whatsoever (mistake, support, fraud only);
• after that: permanent erasure, with no possible restoration.

Subscription. Deleting the account may not cancel the subscription: billing is handled by Google Play, outside the app. Both deletion paths, in the app and on the site, ask users to cancel it first from their Google account. Content bought in the shop is lost along with the account, with no refund.

Only the records of acceptance survive: kept for 5 years from the withdrawal, closed and deactivated, so that we can demonstrate that valid consent (in particular parental consent, Article 8 GDPR) was actually obtained, and on what date it was withdrawn. Withdrawal only applies going forward and does not make unlawful what was collected while the consent was valid (Article 7(3) GDPR).

Processors and DPA

Hosting and application services are provided by Google Cloud / Firebase: Google Ireland Ltd for France. This processing is governed by Google's data processing addendum (Google Cloud Data Processing Addendum), which we have accepted.

The app also calls the Google Gemini API (Vertex AI) for five features triggered by an explicit action of the user: suggesting a name and description for a character, a clan or a task, answering an adult's questions (the help assistant, a mascot never offered to minors), and writing the clan's adventure tale offered for sharing after a chest has been opened. For that last feature, the clan name, its description and the clan log, which contains the nicknames chosen by the players, are sent to the model. No other personal data is sent: no account identifier, no date of birth, no photo, no video. The assistant receives the question typed and the current conversation, and keeps nothing afterwards. The processing runs on Google servers located in the European Union for users in France, and the data sent is not used to train the models.

Protection of minors

• Mandatory parental consent: a minor can neither create a clan nor join the game on their own. The consent, required by Article 8 of the GDPR, is given by the adult when they accept the terms of service, and it is exercised when they invite the child into their clan or create a player profile for them. The acceptance is recorded and timestamped, so consent always comes before any collection. The declaration of legal guardianship and the consent are restated on screen at the very moment of the act (inviting a member, creating a player profile), together with a link to the terms of service. The child first says whether they wish to play, on their own phone: that wish, which contains no personal data, is shown to the adult as a QR code or a link before they decide, then recorded with their decision. Until the child signs in, nothing is recorded, either on their phone or on our servers.
• Parents keep control: at any time a parent can review the information collected from their child, have it deleted, and refuse any further collection. All three are exercised from the app or by writing to donjons@grisloup.com.
• Continuous supervision: the clan's adults choose the tasks offered to the children, check whether the mission is accomplished and control all administration features.
• Sealed-off clans: no clan can see another clan's data, there is no directory and no player search, and you only join a clan by invitation (QR code or encrypted link protected by a code read out loud). The only exception: a player who belongs to several clans has the same nickname, avatar and title in each of them, seen by the members of each of their clans; nothing else passes from one clan to another.
• No contact with strangers: no messaging, no chat, no content sent by third parties.
• Age thresholds: a single threshold applies, 18: every minor player is subject to their legal guardian's consent, without exception. That is stricter than Article 8 of the GDPR, which lets each Member State set between 13 and 16 the age of a minor's own digital consent (15 in France): we never rely on that option. The exact age is never stored, only the child/adult status is. A parental control (a “parental gate”: a timed arithmetic puzzle) protects access to the adult path. The information provided (date of birth, status as legal guardian) is declarative: the parental gate is a good-practice measure, not an age-verification mechanism, and the terms of service place responsibility for its truthfulness on the user.
• Purchases reserved for adults: the clan subscription and the content shop are accessible only to the adults of the clan. A child cannot buy anything or spend any real money, and is never asked for a payment method. There is no currency to top up, no chest to open for a fee and no purchasable level or XP: nothing that can be bought does the chore for you.
• Adapted documents: the terms of service and the privacy policy exist in a child version, written in accessible language.
• Physical safety: the terms of service remind the clan's adults that they remain responsible for entrusting children only with age-appropriate tasks.
• Sharing reserved for adults: only adults can share an invitation or the clan's adventure tale outside the app.

Content rating

Donjons & Savons aims for a PEGI 3 / Everyone rating: a humorous, kind-hearted heroic fantasy universe, with no realistic violence, no frightening content and no interaction whatsoever with strangers (the game is played exclusively within the family; there is no public chat and no encounters between clans). The app includes in-app purchases reserved for the adults of the clan, declared as such on the store listing.

Target audience

The app is intended for families: it is installed and administered by the parents, and used by the children with their consent and under their supervision. It complies with the Google Play Families policy (no advertising, no advertising identifier, no needless data collection, purchases reserved for adults).