Privacy Policy

Version 1.1 · Last updated April 2026

1. Controller

Jan Köhler & Roman Lautner Vibesolutions GbR

represented by Jan Antonio Köhler and Lutz Roman Lautner

Augustenstr. 12, 26441 Jever, Germany

Email: info@vibesolutions.de

2. General Information

We process personal data in accordance with applicable law, in particular the GDPR and German data protection law (BDSG). This Privacy Policy explains which data we process, for which purposes, and on which legal basis.

3. Categories of Data Processed

Depending on your use, we may process:

  • Usage and device data (for example, IP address, browser, access time)
  • Geolocation data (coordinates if location features are enabled)
  • Content data (uploaded GPX files and generated route/game data)
  • Payment-related data (for example, payment status, transaction ID, payer email address via PayPal)
  • Feedback and report data (game ratings, content reports without personal identification)

4. Purposes and Legal Bases

PurposeLegal basis
Provision and operation of the website and APIsArt. 6(1)(f) GDPR
Contract performance and payment processing for paid unlockArt. 6(1)(b) GDPR
Abuse prevention and system security (bot protection, rate limiting)Art. 6(1)(f) GDPR
Analytics and usage measurement (Matomo, cookieless)Art. 6(1)(f) GDPR
Processing game ratings and content reportsArt. 6(1)(f) GDPR
Compliance with statutory retention obligationsArt. 6(1)(c) GDPR

5. Specific Processing Activities

5.1 Server Operations and Logs

When you access the website, technically required log data may be processed (for example, IP address, timestamp, requested resource, status code, user agent) to ensure stable and secure operation.

5.2 Location Data During Gameplay

For location-based game functions (for example, proximity to waypoints), browser/device location data may be used. Location access is subject to browser and operating system permissions. Location data is not stored server-side.

5.3 GPX Upload and Game Generation

Uploaded GPX data is processed server-side to generate routes, waypoints, and quiz content. The coordinates contained are used exclusively for internal waypoint calculation and for anonymized queries to public POI data sources (Wikipedia, Nominatim).

5.4 Game State and Local Storage

Game-related data (game progress, completed waypoints, last selected difficulty) may be stored in your browser's localStorage to preserve progress between sessions. This storage resides exclusively on your device and is not transmitted to our servers.

5.5 Payment Processing (PayPal)

Payments are processed via PayPal. Payment-related data (in particular the payer's email address, transaction ID, amount, currency) is transferred to PayPal and stored by us after successful payment for accounting and tax purposes.

Recipient: PayPal (Europe) S.a r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg

More information: https://www.paypal.com/de/legalhub/paypal/privacy-full

5.6 External APIs Used for Core Features

Depending on the feature used, the following external services are called server-side (no direct connection between your browser and these services):

ServicePurposeData transmittedThird country?
Wikipedia MediaWiki APIPOI search and article contentGPS coordinates (anon.), article titlesNo
OpenStreetMap NominatimReverse geocodingGPS coordinates (lat/lon)No
OpenRouteServiceRoute planning; geocodingCoordinates; for geocoding: user-entered place name (free text)No
OpenRouter (AI infrastructure)Routing to AI language models for quiz generationExclusively public Wikipedia texts and POI names; no personal user dataUSA (SCCs)

5.7 Bot Protection (Cap.js)

To protect public forms (for example, GPX upload) against abusive automated requests, we use Cap.js. The Cap.js instance is self-hosted within our own cluster and does not share data with any third party.

5.8 Analytics (Matomo)

We use Matomo (self-hosted in our own cluster) to analyze page views and navigation patterns. Matomo is configured to set no cookies (cookieless tracking) and to anonymize IP addresses before any storage. No data is shared with third parties.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in anonymized usage statistics for service improvement).

5.9 AI-Assisted Quiz Generation(Transparency notice under Art. 50 EU AI Act)

Quiz questions, answer options, and explanatory texts are generated using AI language models provided via the OpenRouter service (USA). The inputs consist exclusively of publicly available Wikipedia texts and geographic place names — no personal user data is transmitted to the AI model.

In accordance with Art. 50 of the EU AI Act, we inform you that the quiz content is AI-generated. Wikipedia source references are provided to support factual plausibility.

5.10 Game Ratings and Content Reports

Users may optionally submit game ratings (overall score 1–5, optional sub-scores and comment) and report inaccurate quiz content. These submissions do not contain personal data (no name, no email address) and are stored server-side.

Legal basis: Art. 6(1)(f) GDPR (legitimate interest in quality assurance and improvement of game content).

5.11 Internal Email Notifications

Incoming content reports and game ratings are forwarded as internal notifications by email to the operators. We use the SMTP service of Hetzner Online GmbH (Industriestr. 25, 91710 Gunzenhausen, Germany) for this purpose. No personal user data is included in these emails.

6. Recipients and Processors

Where legally required, service providers are engaged under a data processing agreement (Art. 28 GDPR).

RecipientPurposeLocation
Hetzner Online GmbHHosting (server, database, SMTP)Germany
PayPal (Europe) S.a r.l. et Cie, S.C.A.Payment processingLuxembourg
OpenRouter Inc.AI language model infrastructure (no personal user data transmitted)USA

7. International Data Transfers

RecipientCountryTransfer mechanism
PayPalUSA / LuxembourgStandard Contractual Clauses (SCCs) under Art. 46 GDPR; PayPal privacy information
OpenRouterUSAStandard Contractual Clauses (SCCs) under Art. 46 GDPR; no personal user data transmitted; OpenRouter privacy policy

8. Storage Duration

Data categoryRetention periodLegal basis
Server log dataMax. 30 daysOperational security
Game and route dataFor the duration of service operationService purpose (permanent access via share link)
Payment receipts10 years§§ 147 German Tax Code (AO), 257 German Commercial Code (HGB)
Game ratings and content reports2 yearsQuality improvement
localStorage (user's device)Until deleted by the user in their browserStored locally

9. Data Subject Rights

Under GDPR, you have in particular the following rights:

  • Access (Art. 15 GDPR)
  • Rectification (Art. 16 GDPR)
  • Erasure (Art. 17 GDPR)
  • Restriction of processing (Art. 18 GDPR)
  • Data portability (Art. 20 GDPR)
  • Withdrawal of consent with effect for the future

To exercise your rights, contact: info@vibesolutions.de

10. Right to Object (Art. 21 GDPR)

You have the right to object at any time to the processing of your personal data carried out on the basis of Art. 6(1)(f) GDPR (legitimate interest).

This applies in particular to the anonymized usage analytics (Matomo). Upon receipt of your objection, we will cease the relevant processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms.

Object by email: info@vibesolutions.de

11. Right to Lodge a Complaint

You have the right to lodge a complaint with a competent data protection supervisory authority. The authority responsible for us is:

Die Landesbeauftragte für den Datenschutz Niedersachsen (LfD Niedersachsen)

Prinzenstraße 5, 30159 Hannover, Germany

Phone: +49 (0) 511 120-4500

Website: lfd.niedersachsen.de

12. Data Security

We implement appropriate technical and organizational measures to protect data against loss, misuse, and unauthorized access.

13. Changes to this Privacy Policy

We may update this Privacy Policy if legal, technical, or organizational requirements change. The current version published on this page applies.