This policy describes how BAUGEY MATHEO, trading as DEVOLIM, processes personal data in connection with the Qui A Raison? mobile application and the https://qui-a-raison.devolim.fr website. It is drawn up in accordance with Regulation (EU) 2016/679 of 27 April 2016 ("GDPR") and French law no. 78-17 of 6 January 1978 as amended, known as the "Informatique et Libertés" act.
In short. For Judge Perruque to rule, the parties' stories, answers and photos are sent to our servers in Europe, then to our artificial intelligence provider (OpenAI), which does not use them to train its models. Photos are never kept: we only keep a short, neutral description of them. Your stories stay sealed: the other side, your friends and other players only see the verdict. Without a profile, you play with an anonymous account; with an Apple or Google profile, other players only see your username. No advertising, no ad tracking, no sale of data. You can erase everything from the app, account included.
1. Data controller
BAUGEY MATHEO, trading as DEVOLIM
248 rue de Bègles, 33800 Bordeaux, France
SIREN: 948 000 757
Email: [email protected]
Given the nature and volume of the processing, appointing a data protection officer is not required under Article 37 of the GDPR. Any request concerning personal data can be sent to the address above.
2. Our principles
- The minimum by default. No name, email address or phone number is required to play: an anonymous account is enough. The optional profile is only used for the features with friends.
- Sealed stories. What each party tells the judge cannot be read by the other party, by other players or from the app: only the server accesses it, to write the questions, the verdict and, if you post the case, its summary.
- No photos kept. Attached photos are analysed for the case, then are not stored anywhere on our side.
- The phone only talks to us. The app never contacts the artificial intelligence provider directly: everything goes through our server functions, which filter what goes out and what comes back.
- No training, no sale. Your content is not used to train any artificial intelligence model and no data is sold.
- No advertising, no ad tracking.
3. Data processed
3.1 On your device
Your settings (appearance, sounds, vibrations), the state of the welcome screens and rating prompts, and a cache of your Premium access are stored on your phone. Dictation uses your phone's speech recognition, provided by Apple or Google under their own terms: the app only receives the resulting text and does not record your voice. The camera is used to take an exhibit or to scan a friend's QR code; scanning is processed on the phone.
3.2 Anonymous account and profile
When the app is first opened, Firebase Authentication creates a random technical identifier, with no email or password. If you create a profile, this account is linked to your Apple or Google account: Firebase Authentication then stores that account's identifier and, for Google, the Google account's email address, name and photo as sent by Google (no email address is requested from Apple). This information is never shown to other players.
Your profile includes your username and avatar colour, visible to all signed-in players, as well as your points, free cases, game statistics (cases, wins, losses, appeals, votes) and badges. We also record the version of the rules and of the agreement about the judge that you accepted, and the state of your offer (free or Premium) with your usage counters.
3.3 Cases
For each case, we store on our servers: the mode and topic chosen, the names or usernames of the parties, the dates and status of the case, each party's story (typed or dictated text), the judge's questions and the answers, a neutral description of each photo, the verdict (case number and nickname, share of the blame, grounds, sentence) and, where applicable, the appeal verdict.
Photos (reduced on the phone before sending) are sent to our server functions and then to OpenAI, which examines them in low resolution and writes the description; they are not stored anywhere on our servers. Stories, answers and descriptions are kept in a part of the database closed to the app: the other party and the jurors only see the verdict.
If a story mentions violence, threats, coercive control, suicidal thoughts or a minor in danger, no verdict is given: the case is marked "help" with a general category (in a case on two phones, always the same general category, so that the other party cannot tell what was written), and our logs keep only that category, never the text.
3.4 Artificial intelligence
The judge's questions, verdicts, express debates, summaries (public court and cases shared between friends) and public court translations are written by an OpenAI model, called only by our server functions. It receives: the text needed for the task (stories, answers, names of the parties, topic, a debate's question and sides, or a summary to translate), any photos, and a hashed identifier, derived irreversibly from your technical identifier, which lets OpenAI fight abuse without knowing who you are. Texts and photos also go through OpenAI's automated moderation tool, before and after, as do comments written under a shared case. We ask OpenAI not to store the exchanges in its tools; OpenAI does not use them to train its models and may keep them for up to 30 days to detect abuse, before deleting them.
3.5 Friends, shared cases, jurors and public court
- Friends: your friends list, the relationship you specify (partner, friend, flatmate, family, colleague) and friend requests sent and received. Search works on the beginning of the username.
- Cases shared between friends: when one of the parties shares a judged case, the judge writes a summary of it (the context, the question at stake and a summary of each story, never the stories themselves). This summary, the nickname, the topic, the parties' names, the share of the blame, the grounds, the sentence and, where applicable, the appeal are shown to both parties and to the friends of each party who shared the case. The other party is notified and can, like you, remove the case at any time, with its votes and comments.
- Friends' votes and comments: people who can see a shared case can vote for one of the parties and comment on it. The vote (the side chosen) and comments are stored with their author's username and avatar colour, and are visible to everyone who can see the case, including friends of the other party whom you may not know. Before it is published, a comment is stripped of links, addresses and numbers and checked by OpenAI's moderation tool; if it cannot be checked, it is not published. Its author and both parties can delete it; a comment reported three times is removed.
- Jurors: the friend you ask to decide sees the ruling (not your stories); their vote and any comment, checked by the moderation tool, are stored in the case.
- Public court: if you post a judged case, the judge writes a neutral, anonymised summary of it (no first names or details that could identify you), translated into several languages and shown to all players, with the vote count. Your author identifier is kept separately, out of players' reach. The country set on your phone (two letters, for example FR) is stored with the case and shown as a flag; nothing more precise. For each vote, we store the side chosen, linked to your technical identifier, to prevent multiple votes and calculate your points. A case reported several times is removed from the court; a copy is kept separately for review, along with the reports.
3.6 Notifications
If you allow them, a device token issued by Firebase Cloud Messaging (through Apple's notification service on iPhone) is stored with the platform, to notify you of a summons, a story given by the other party, a deadline about to expire, a verdict, an appeal, a friend request or a new friendship, a case shared by a friend, a vote or comment on a case that concerns you, a vote milestone in the public court or a free case. After three days without opening the app, a single reminder may point out new public court cases: for this, we store the date you last opened the app. A notification may contain a person's username or name and a case's nickname, never the content of a story. In the app's settings, you can turn off friends' notifications and public court notifications; this choice is stored on our servers. You can withdraw permission at any time in your phone's settings.
3.7 Messages and reports
A message sent from "Une idée, un souci ?" (An idea, an issue?) is sent without name or email, with your technical identifier, its type, the app version and the platform. A report stores your technical identifier, the content concerned and the reason chosen; for a comment, the reported text and its author's identifier are kept with the report, for review. Emails you send us are kept in our mailbox.
3.8 Usage measurement and stability
Google Analytics for Firebase receives app usage: screens viewed (under generic names), steps completed and buttons tapped (for example a case created, with its mode and topic, or the number of photos attached), the answers given during sign-up (your age range, for example "25 to 34", never your exact age, your gender or "prefer not to say", and the kind of disputes you came to settle), purchases, with a random installation identifier specific to the app (not the advertising identifier), technical information (device model, system, app version, language) and an approximate location (country, region) inferred by Google from the IP address. Never the text of a story, a username or a verdict. Firebase Crashlytics receives crash reports (device model, system version, app state and error codes at the time of the problem, installation identifier). Firebase Remote Config provides remote settings with no personal data. "Erase all my data" resets the phone's usage measurement identifier.
3.9 Protecting the service
Every request to our servers carries a Firebase App Check attestation (Apple's App Attest and DeviceCheck, Google's Play Integrity) proving it comes from the genuine app; we do not keep these attestations. Usage counters (numbers and dates, no content) are linked to your technical identifier, and some to your hashed IP address (an irreversible fingerprint), to apply usage limits and prevent abuse. Our server functions keep technical logs (call metadata, errors), which contain neither your stories nor your answers.
3.10 Data about other people
A story often talks about someone else: the other party, and sometimes third parties. The other party is also playing: they give their own story and see the verdict. For third parties mentioned, processing is limited to what the game needs, involves no profiling and is based on legitimate interest; informing them individually would involve disproportionate effort (Article 14.5.b of the GDPR), as we have no means of identifying them. We ask you not to mention identifiable third parties or sensitive information (health, intimate life, opinions, contact details). If a story contains such information anyway, it is processed only for the case and used for nothing else.
4. Legal bases
| Purpose | Legal basis |
|---|---|
| Running the game: account, profile, cases, questions and verdicts, appeal, debates, friends, shared cases, jurors, public court, points, notifications | Performance of the contract (terms of use and sale) |
| Premium offer and access check | Performance of the contract |
| Detecting distress and showing helplines | Legitimate interest in protecting people, and vital interests (Article 6.1.d of the GDPR) where someone is in danger |
| Moderation, usage limits, anti-abuse counters, hashed IP address, App Check, hashed identifier sent to OpenAI, technical logs, handling reports | Legitimate interest: keeping the service and players safe |
| Data about third parties mentioned in a story | Legitimate interest: enabling the game, within what is necessary |
| Usage measurement, crash reports, remote settings | Legitimate interest: improving the app and fixing errors |
| Answering your messages and emails | Legitimate interest: responding to your requests |
| Answering requests to exercise your rights, keeping purchase records | Legal obligation |
5. Recipients and processors
| Provider | Role | Data concerned |
|---|---|---|
| Google Ireland Limited (Firebase, Google Cloud), Gordon House, Barrow Street, Dublin 4, Ireland | Accounts (Authentication), database (Firestore, Europe region), server functions (europe-west1 region, Belgium), notifications (Cloud Messaging), App Check, Analytics, Crashlytics, Remote Config, technical logs | Technical identifier, linked Google or Apple account information, profile, cases, friends, votes, counters, notification tokens, IP address and call metadata, installation identifier, usage, crash and approximate location data |
| OpenAI Ireland Ltd (Dublin, Ireland) and OpenAI, L.L.C. (San Francisco, United States) | Writing questions, verdicts, debates, summaries and translations; describing photos; automated moderation | Texts needed for the task, photos, hashed identifier, without your identity |
| RevenueCat, Inc. (United States) | Subscription management and Premium access check | Technical identifier, transaction information sent by the store |
| OVH SAS, 2 rue Kellermann, 59100 Roubaix, France | Website hosting | Website technical logs |
| Apple and Google | Sign in with Apple or Google, sale and payment on their stores, genuine app attestation, dictation, store rating prompt, as controllers of their own processing | Your Apple or Google account data |
Google, OpenAI, RevenueCat and OVH act as processors, on our instructions and under the contractual commitments required by Article 28 of the GDPR. Apple and Google, for sign-in with their account, sales on their stores and services linked to your account, act as controllers of their own processing, under their privacy policies.
Within the game, other players see what this policy describes: your username and avatar, the verdicts of the cases they take part in or that you share with them, and the anonymised summaries in the public court.
No data is sold, rented or transferred to third parties for commercial purposes.
6. Transfers outside the European Union
Some data may be processed in the United States (OpenAI, RevenueCat, and Google for certain services such as Authentication, Analytics and Crashlytics). These transfers are covered by the European Commission's adequacy decision on the EU-US Data Privacy Framework where the recipient is certified under it, and otherwise by the standard contractual clauses adopted by the European Commission. You can obtain a copy of these safeguards by writing to us.
7. Retention periods
| Data | Period |
|---|---|
| Account, profile, friends, cases (stories, answers, photo descriptions, verdicts), cases shared between friends (summaries, votes, comments), posted cases, votes and points | Until you erase them ("Erase all my data") or ask for them to be deleted |
| Photos | Not kept by us; up to 30 days at OpenAI |
| Texts sent to OpenAI | Up to 30 days at OpenAI |
| Usage counters linked to the technical identifier or hashed IP address, Premium access cache | About 40 days after their last update |
| "An idea, an issue?" messages and reports | 12 months, or immediately with "Erase all my data" |
| Copy of a public case removed after reports | Until its author's data is erased |
| Case shared between friends, with its votes and comments | Until one of the parties removes it or erases their data; your votes and comments on other people's cases are deleted with your data |
| Notification tokens | Until replaced by the phone or until data is erased |
| Server function technical logs | About 30 days |
| Usage data linked to a device (Analytics) | 2 months |
| Crash reports (Crashlytics) | 90 days |
| Transaction information (RevenueCat) | Length of the subscription, then periods required by law |
| Emails sent to support | 3 years after the last exchange |
8. Advertising and tracking
Qui A Raison? shows no advertising and does no ad tracking. The phone's advertising identifier is not collected, and the app does not ask for Apple's tracking permission (App Tracking Transparency), which it does not need.
9. Subscriptions and purchases
Payments are collected by Apple (App Store) or Google (Google Play): the publisher sees neither your identity nor your bank details. RevenueCat, our subscription management provider, receives your technical identifier and the transaction information sent by the store (product, dates, country, currency, receipt) in order to grant Premium access. Our server functions query RevenueCat to check this access and cache the answer (see section 7).
10. Security
Exchanges with our servers are encrypted (HTTPS). The server only accepts requests from the genuine app (App Check) with a valid session; the database is closed by default and the app can only read what concerns it. Stories, answers and photo descriptions can only be read by the server. Secret keys stay on the server, texts sent to the model are isolated and checked, usage limits protect the service, and access to the administration tools is restricted to the publisher.
11. Website
This website sets no cookies and uses no audience measurement tool. Fonts are hosted on our own servers: no request is made to a third party during your visit. The host (OVH) keeps technical logs (IP address, pages requested) for security purposes, for a limited period.
12. Your rights
Under Articles 15 to 22 of the GDPR, you have the right of access, rectification, erasure, restriction, objection and portability, as well as the right to set instructions regarding what happens to your data after your death (Article 85 of the "Informatique et Libertés" act). These rights are exercised by email at [email protected]. We reply within one month, which may be extended by two months for complex requests.
The simplest way is to act from the app: Profil, Réglages, "Effacer toutes mes données" (Profile, Settings, Erase all my data) immediately deletes your profile and username, your friends and friend requests, your cases, the shared cases you are a party to (with their votes and comments), your votes and comments on other people's cases, your cases posted to the public court, your juror votes, your points, your messages and reports, your counters and Premium cache, then your account itself; the phone's usage measurement identifier is reset. In a case on two phones, the other party keeps the verdict, but your story is erased and your name replaced with "Partie effacée" (Party erased). Your votes in the public court remain counted, linked to a technical identifier that no longer matches any account. Texts already sent remain for up to 30 days at OpenAI, and usage data, crash data and logs follow the periods in section 7. As we do not know your identity, an email request must state your username, and we may ask you to prove that it is your account (Article 11 of the GDPR).
13. Complaint to the CNIL
If, after contacting us, you believe your rights are not being respected, you can lodge a complaint with the Commission nationale de l'informatique et des libertés (CNIL): 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France, or online at cnil.fr. You may also contact the supervisory authority of your country of residence within the European Union.
14. Minors
The app is intended for people aged 15 and over, the age from which a minor can consent alone to data processing for an online service in France (Article 45 of the "Informatique et Libertés" act). If you learn that a child under 15 has sent us data, write to us: we will delete it.
15. Changes
This policy may be amended to reflect legal or technical changes. The date of the last update is shown at the top of the page; substantial changes are announced in the app.
This is a translation provided for convenience. In the event of any discrepancy, the French version prevails.