Privacy Policy — Podium

Operator: telluric.solutions Ltd., Israel · Contact: privacy@telluric.solutions · Effective: 2026-09-18

The Hebrew text above is the legally binding version. This English version is provided for convenience.

1. What this document is

Podium is a ranking trivia game. This document explains, in plain language, what data is created when you play, why we use it, who else sees it, how long we keep it and how you control it. It is written to comply with Israel's Protection of Privacy Law, 5741-1981 (including Amendment 13) and the Protection of Privacy Regulations (Data Security), 5777-2017, and — for players in the European Union / EEA — with the General Data Protection Regulation (GDPR).

telluric.solutions Ltd. is the "database controller" under Israeli law (the "controller" in GDPR terms) for the data described here.

2. The short version

• There is no sign-up. No email, no password, no phone number. We do not know who you are.
• Your identity in the game is a random ID stored in a browser cookie; a random nickname, coins, XP and play history hang off it.
• You can delete your account with one tap inside the game. Deletion is immediate and irreversible.

3. What data is created and stored

3.1 Guest identifier (the podium_uid cookie) — required to play

The first time you play, the server creates a random user ID (a random string containing no personal detail) and stores it in a cookie named podium_uid.

Important: this cookie is the only thing linking you to your account. Clearing cookies, switching browser or device, or playing in a private window creates a new, empty account. Currently there is no way to recover a previous account, and we cannot do it for you because we hold nothing that identifies you.

3.2 Profile

The nickname is shown publicly on leaderboards to all players. If you choose to type your real name or another identifying detail into it, that is your choice and it will be visible to others. We do not ask for it and do not need it. We recommend keeping the random nickname.

3.3 Gameplay data

• Matches you started, the questions served in each round, the order you submitted, the server-computed score, streaks, and helps used.
• Response timing: for every submission we store how long the answer took (milliseconds) and the round's open/deadline timestamps. This feeds the speed bonus and automation detection (see section 4).
• Daily-challenge attempts and their results.
• The history of questions you have seen (so the same question is not served again within 30 days).
• Daily missions and achievements.

3.4 Game economy

Coin balance, an append-only ledger (every credit or debit, its source and time), help inventory, and entitlements (e.g. "remove ads"). There are currently no real-money purchases, so we hold no payment details of any kind.

3.5 Question reports

When you report a question ("wrong data", "unclear wording", etc.) we store: the question ID, your user ID, the reason (chosen from a fixed list — there is no free-text field) and the time. Reports are used to fix questions.

3.6 Analytics — only if enabled, and only with consent

The game is built so that analytics is an optional add-on. When the operator configures an analytics key, usage events are sent to PostHog (default host: PostHog's EU servers, eu.i.posthog.com).

What is sent: event name, your random ID (as distinct_id), a timestamp, and context: language, platform (web/pwa/ios/android), app version and a session ID. No text you wrote, no name and no contact details are sent.

Event categories (full list in src/lib/analytics/events.ts):

"Phase 2" events (ranked play, purchases, offline) are declared in code but never fire until those features exist.

Legal basis: informed consent (Protection of Privacy Law ss. 1 and 3 — "consent"; GDPR Art. 6(1)(a); ePrivacy rules in EU member states), given after the notice required by s. 11 of the Law. ⚠️ VERIFY WITH COUNSEL — confirm the cited sections. See the consent banner spec in the consent document. You can withdraw consent at any time from settings.

⚠️ VERIFY WITH COUNSEL — as of writing there is no consent mechanism in the code: if a PostHog key is configured, events are sent immediately. The key must not be set in production before the consent mechanism (consent.md) is implemented, or this document is untrue.

3.7 Error reporting — only if enabled

When the operator configures a Sentry DSN, technical errors are sent to Sentry so we can fix bugs. What is sent: error type, error message, stack trace (file and function names in our code), release version, and the context from 3.6 (language, platform, version, session ID). Your user ID and game content are not sent.

Legal basis: legitimate interest — keeping the service working and secure (GDPR Art. 6(1)(f)).

⚠️ VERIFY WITH COUNSEL — Sentry's servers see the browser's IP address as part of the connection. Enable the "prevent storing of IP addresses" project setting in Sentry, and confirm whether error reporting can rest on legitimate interest (as written) or must be folded into consent.

3.8 Rewarded ads — only if enabled

Some features (continue after a miss, an extra daily attempt, a coin bonus) are offered in exchange for watching a video ad. Watching is always voluntary — there are currently no forced ads.

As of writing, the web version uses a mock ad provider that loads no third-party code and collects no data. When a real provider is connected (a rewarded-video ad provider (not yet selected) — e.g. Google AdMob in the native builds), the provider may collect device/advertising identifiers, IP address and ad-interaction data under its own privacy policy: /privacy.

Legal basis: consent. Without consent the ad SDK is not loaded — and the features that depend on an ad are unavailable. On iOS, Apple's App Tracking Transparency (ATT) prompt is shown in addition.

⚠️ VERIFY WITH COUNSEL — once a real provider is connected: update this section with the provider's name, policy link, and whether ads are configured as "non-personalised".

3.9 Technical data at the hosting provider

Like every website, our servers receive an IP address and HTTP headers (browser type, language) with each request. The application itself does not store IP addresses in its database; rate limiting is keyed by user ID, not IP. The hosting provider (Amazon Web Services (Lightsail)) may keep standard access logs for a short period for security and operations.

4. Why we use the data

Purpose limitation: we will not use the data for any other purpose without updating this document and, where required, asking for consent again.

There is no legal obligation to provide us with any data. The only consequence of not doing so: without the cookie, progress cannot be saved; without consent to analytics/ads the game works normally but ad-dependent features are unavailable.

5. What we do not do

• We do not collect name, email, phone, address, date of birth, precise location, contacts or photos.
• We do not sell data or share it for others' marketing.
• We make no automated decisions with legal effect on you. Automatic flagging of statistical anomalies leads to human review, not automatic bans.
• We show no content created by other players, other than nicknames on leaderboards.

6. Who else sees the data

• Other players: your nickname and score on leaderboards. That is all.
• Processors acting for us, only to the extent needed: the hosting and database provider (Amazon Web Services (Lightsail)); PostHog (analytics, if enabled); Sentry (errors, if enabled); a rewarded-video ad provider (not yet selected) (ads, if enabled). Each is bound by a data-processing agreement.
• Authorities, where we are legally required.
• A future acquirer of the game, provided they are bound by this policy.

7. Transfers outside Israel and the EU

• Israel is recognised by the European Commission as providing adequate protection (adequacy decision, reaffirmed in 2024).
• PostHog: hosted in the EU (our default).
• Sentry: United States, under the EU-US Data Privacy Framework and the EU Standard Contractual Clauses.
• Amazon Web Services (Lightsail): Frankfurt, Germany (eu-central-1).

⚠️ VERIFY WITH COUNSEL — confirm the actual server locations and transfer mechanism for each vendor before publishing, and compliance with the Israeli Protection of Privacy Regulations (Transfer of Data to Databases Abroad), 5761-2001.

8. How long we keep it

⚠️ VERIFY WITH COUNSEL — there is currently no automated purge of abandoned guest accounts. Decide a retention period (e.g. delete 12 months after last activity) and implement it, to honour data minimisation / storage limitation.

9. Your rights

Under Israeli law (sections 11, 13 and 14 of the Protection of Privacy Law): to know the purpose of collection and to whom data is passed (this document); to inspect the data held about you; to ask for correction or deletion of data that is inaccurate, incomplete or out of date; and to complain to the Privacy Protection Authority.

Under GDPR (if you are in the EU/EEA): access, rectification, erasure, restriction, portability, objection to processing based on legitimate interest, withdrawal of consent at any time (without affecting prior processing), and complaint to your national supervisory authority.

How to exercise them:

• Erasure: inside the game — Settings → Delete account (section 10). No request to us is needed.
• Access / inspection / rectification / portability: the nickname and preferences can be viewed and edited on the profile screen. For anything else, write to privacy@telluric.solutions. Because we hold nothing that identifies you, you will need to send us the user ID shown on the settings screen so we can locate the account — without it we cannot tell which data is yours. We respond within 30 days. ⚠️ VERIFY WITH COUNSEL — confirm the response deadline. ⚠️ VERIFY WITH DEV — the settings screen does not currently display the user ID; add it.
• Withdraw consent to analytics/ads: Settings → Privacy.

10. In-app account deletion

Settings → Delete account → confirm. What happens:

1. The server deletes the user record and everything that depends on it — profile, wallet, coin ledger, inventory, matches, submissions, daily attempts, leaderboard entries, missions, achievements, reports and question history. Deletion is immediate (not "deactivation", not "marked for deletion").
2. The cookie is removed from the browser.
3. The action is irreversible. There is no grace period and no restore.

What is not deleted by this action: analytics events and error reports already sent to PostHog / Sentry (if enabled). They contain only the random ID, which after deletion links to nothing, and they expire under the retention periods in section 8. Hosting logs likewise follow their own period.

11. Children

The game's content is suitable for all ages. However, it is not directed at children and we do not knowingly collect personal data from minors below the age set by applicable law (in the EU: 16, or the lower age set by the member state). Because we collect no name, age or contact details, we have no way to know a player's age. If you are a parent and believe your child gave us personal data (e.g. a real name as nickname), delete the account inside the game, or write to us.

⚠️ VERIFY WITH COUNSEL — the Protection of Privacy Law sets no explicit age of consent; the customary age (14, via sections 4–6 of the Legal Capacity and Guardianship Law and PPA guidance) needs confirmation, as does its implication for the consent banner. If confirmed, state the number in the text.

12. Security

The guest ID is cryptographically signed; the cookie is httpOnly and shielded from scripts; traffic is HTTPS; scoring and all economy logic run only on the server; secrets are not stored in code, and the system refuses to sign or verify identities in production without a signing secret. We operate under the Protection of Privacy Regulations (Data Security), 5777-2017, at the security level applicable to the database.

⚠️ VERIFY WITH COUNSEL — classification of the database's security level under the regulations (basic/medium/high) and whether a database definitions document is required.

13. Privacy officer and database registration

Amendment 13 to the Protection of Privacy Law (in force August 2025) requires appointing a privacy protection officer for public bodies, data brokers, and organisations whose core activity involves processing data of special sensitivity or large-scale systematic monitoring of people. A small game operator that collects no sensitive data is not required to appoint one, and we have not. Privacy enquiries: privacy@telluric.solutions.

The duty to register a database was narrowed by Amendment 13 to very large databases or databases whose main purpose is passing data to others. Our database is not registered, but the reporting and notification duties to the Authority set out in the law still apply to us.

⚠️ VERIFY WITH COUNSEL — confirm both determinations above against the Privacy Protection Authority's current numeric criteria (data-subject threshold for registration/notification; the definition of "large-scale processing" for the officer requirement), especially as the player base grows.

14. Security incidents

If a serious security incident involving your data is discovered, we will report it to the Privacy Protection Authority as required by the Data Security Regulations, and to the relevant EU supervisory authority within 72 hours as required by GDPR, and we will notify you via an in-game notice (the only channel we have) if the incident may harm you.

15. Changes to this policy

We will update this document as the game changes (e.g. adding account sign-in, purchases, an ad provider). The effective date at the top will change, and a material change will be shown as an in-game notice. If a change requires renewed consent, we will ask for it.

16. Contact

telluric.solutions Ltd. · Israel · privacy@telluric.solutions

Privacy Protection Authority (Israel): https://www.gov.il/en/departments/the_privacy_protection_authority