This Privacy Policy explains how we collect, use, disclose, and protect personal data when you use Vicariously Thru You (VTY)—our website and progressive web app, including mini-games, marketplace, chat & groups, push notifications, and support (the “Service”).

Summary: We collect account and gameplay data to run VTY, keep it fair, localize content, and improve the experience. We aim to store data in the EU when feasible and use trusted providers. You control your rights (access, deletion, etc.).

1) Scope & Roles

  • Controller: VTM ES (to be incorporated), Estonia (EU).
  • Applies to: Visitors, registered players, creators, and support contacts using our website/PWA, including push notifications and chats.
  • Children: Not directed to children under 13 (or under 16 in the EEA/UK). If you believe a child used VTY, email contact@vtm.lat.
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2) Data We Collect

2.1 You provide

  • Account & Profile: email, username/handle, avatar, locale, and profile details you add.
  • Content: public showrooms, messages in DMs/groups, bids/listings.
  • Support: help requests, bug reports.

2.2 Collected automatically

  • Usage & Device: app version, pages/screens, taps/clicks, session timestamps, approx. region/timezone, language, device/OS/browser, crash/error logs.
  • Gameplay & Economy: session seeds/results, cooldowns, rewards, AFK claims, marketplace orders, bids/reveals, anti-abuse signals.
  • PWA specifics: service worker cache events, install/uninstall, push subscription (web push token), background sync.
  • Cookies/Storage: strictly necessary auth/session storage; we avoid cross-site tracking cookies by default.

2.3 From other sources

  • Auth providers: if you use Google/Apple sign-in, we receive basic account info.
  • Payment providers: when you buy premium features/items, we receive payment status (not full card data).
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4) Ads & Marketing

  • Default: VTY does not use invasive third-party ad tracking in the core loop.
  • If we add optional rewarded placements later: we’ll clearly disclose the ad partner, ask for any required consent, and provide a simple opt-out. No “always-on” behavioral ads without choice.
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5) How We Share Data

We share data only as needed to run the Service—never to sell personal data.

  • Vendors/Processors: hosting/CDN, databases, authentication, error monitoring, analytics, messaging/push, content moderation, and payments. These providers process data under contracts that include data-protection terms.
  • Other users: your public showroom and display name/handle are visible to anyone with the link. Messages in DMs/Groups are visible to participants and may be processed for moderation.
  • Legal & safety: to comply with law, enforce terms, or protect users and our Service.
  • Business changes: in a merger/financing/asset sale, your data may transfer consistent with this Policy.
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6) International Transfers

We aim to keep primary storage in the EU/EEA when feasible. Some providers may process data in countries outside the EEA (e.g., the United States). When we do, we use appropriate safeguards such as EU Standard Contractual Clauses (SCCs) and additional measures where required. You can contact us for details about specific transfer mechanisms.

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7) Retention

  • Account data: while your account is active and then typically up to 24 months after inactivity (or earlier if you delete your account and no legal basis requires more).
  • Gameplay/economy logs: typically 24 months for anti-abuse and auditability.
  • Chats: as long as the conversation exists; deletions remove content from user view and our active systems, with short-term backups expiring per cycle.
  • Legal/financial records: retained as required by law (e.g., 5–10 years in some jurisdictions).
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8) Your Rights

EEA/UK (GDPR)

You have the right to access, rectify, erase, restrict, object, and data portability. You may also withdraw consent at any time where processing is based on consent. You can lodge a complaint with your local authority; in Estonia, that’s the Estonian Data Protection Inspectorate.

California (CCPA/CPRA)

California residents have rights to know/access, delete, correct, and opt-out of sale/sharing of personal information. We do not sell your personal information. You also have the right to limit use of sensitive personal info where applicable and freedom from discrimination for exercising your rights.

Brazil (LGPD) and others

You may have similar rights under local laws. We honor valid requests consistent with applicable law.

How to exercise your rights: email contact@vtm.lat from your account email and describe your request. We’ll verify and respond within the statutory timeframe.

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9) Security

  • Encryption in transit, secure hosting, and environment-scoped secrets.
  • Row-Level Security and server-verified economy mutations.
  • Rate limits, cooldowns, and anomaly detection to combat abuse.
  • Access controls, logging, and monitoring across critical systems.

No system is perfectly secure. If we learn of a breach affecting you, we’ll notify you and regulators as required.

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10) Your Choices

  • Account & Profile: edit your profile, change your visibility (public showroom vs. private vault).
  • Push notifications: enable/disable in-app and via your browser/OS settings.
  • Language & accessibility: select supported languages, reduce motion, high-contrast mode.
  • Cookies/storage: you can clear site data in your browser; note that strictly-necessary auth/session storage is required for the Service to function.
  • Delete account: email contact@vtm.lat to request deletion. We’ll remove or anonymize your personal data unless retention is required by law or for ongoing disputes/fraud prevention.
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11) Automated Decision-Making

We use limited automation (e.g., spam/abuse detection, cooldown enforcement, basic content moderation and translation). These processes are designed to protect players and platform integrity and do not produce legal or similarly significant effects without human review. You can contest an automated decision by contacting us.

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12) Payments

When you make a purchase, payments are processed by our payment partner (e.g., a PCI-DSS–compliant processor) acting as an independent controller for your card data. We receive only limited information (e.g., success/failure, last4/card brand, receipt metadata).

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14) Changes to This Policy

We may update this Policy to reflect changes to our products, laws, or practices. We’ll post the new version with a new Effective date and, where appropriate, notify you via the app or email. Your continued use after the update means you accept the changes.

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15) Contact

Questions or requests about privacy?
Email: contact@vtm.lat
Controller: VTM ES (to be incorporated), Estonia

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California Notice at Collection

We collect the categories described in Section 2 for the purposes in Section 3. We do not sell personal information. We may “share” limited identifiers for optional ads only with your consent. Retention periods are in Section 7. Your rights are in Section 8.

This document is a practical, product-aligned draft. It’s not legal advice. Before publishing, consider a quick review by counsel, especially to confirm data-hosting regions, payment processor names, and any ad partners.