CounterPrivacy policy
Counter ("we", "our", "us") is operated by Julian David Münster, Mühlenkamp 18, 22303 Hamburg, Germany. This Privacy Policy covers the Counter mobile application ("the App") and this website (compcounter.app). It explains what personal data we collect when you use them, why we collect it, who we share it with, and what rights you have under the General Data Protection Regulation (GDPR).
If you have any questions, contact us at mail@compcounter.app.
1. Who is responsible for your data?
The data controller within the meaning of the GDPR is:
2. What data we collect and why
2.1 Account data
When you create an account we collect your email address, display name, username, and date of birth. Your date of birth is used solely to verify that you meet the minimum age requirement of 16 years and is not shared with other users. You may optionally add a profile photo. Providing this data is necessary to create an account; without it you cannot use the App.
You can also create an account with Sign in with Apple or Google. When you use Sign in with Apple, the App asks Apple for your name and email address. Apple may give us a private relay address instead of your real email address. We store the name you share with your account and use it to prefill your display name, which you can change. When you use Google, you are taken to Google's sign-in page and the email address of your Google account is used for your Counter account. Apple and Google process the sign-in under their own privacy policies (see Section 3).
Legal basis: Performance of a contract (Art. 6(1)(b) GDPR). This data is necessary to provide you with an account and the core features of the App.
2.2 Content you create
Counter is built around user-generated content. When you use the App we collect:
- Counter data: counter names, rules, activity types, durations, and settings you configure.
- Counter pictures: an optional picture that a counter's owner or an admin can set. It is shown to the counter's members, and to other users if the counter is searchable.
- Submission photos: photos you take with the camera as proof of completing a counter activity. Photos are available to counter members while voting is open (up to 24 hours) and are deleted when voting closes.
- GPS location data: if you choose GPS verification for a submission, the App captures your GPS coordinates at the time of submission. Location access is requested only when you initiate a GPS-verified submission and is never collected in the background.
- Votes: your vote (approve or reject) on other members' submissions.
- Messages: text messages in counter group chats and direct messages to friends. Each message is deleted automatically 30 days after it was sent; see Section 4.
Profile photos and counter pictures are stored at a web address that is not listed or linked anywhere outside the App. Anyone who has that address can open the picture without signing in.
Legal basis: Performance of a contract (Art. 6(1)(b) GDPR).
2.3 Usage and analytics data
With your explicit consent, we use PostHog to collect analytics about how you use the App, for example which screens you visit and which features you use. This data is pseudonymised: it is linked to a random account ID, never to your name or email address. We use this to improve Counter. Analytics data contains no message content, photo content, or your GPS coordinates.
Legal basis: Consent (Art. 6(1)(a) GDPR). You can withdraw consent at any time in the App settings. Withdrawing consent stops all future analytics collection and does not affect the lawfulness of processing before withdrawal.
2.4 Error and crash data
We use Sentry to automatically collect technical error reports when the App crashes or encounters an error. These reports contain device type, operating system version, App version, and a stack trace. Sentry also receives performance data (how long screens and requests take, for a sample of sessions) and the start and end of each App session, so we can see how often the App crashes. This data does not contain personal content such as message text or photos. Sentry stores these reports in its EU data region.
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR): maintaining App stability and fixing bugs.
2.5 Push notification tokens
If you grant permission, the App stores a push notification token to send you alerts (for example when a new count is waiting for your vote or someone sends you a message). You can revoke this permission in your device settings at any time.
Our backend sends push notifications through Expo's push service (650 Industries, Inc., USA), which forwards them to Apple's Push Notification service. Expo receives your push token and the content of each notification: a title and a short text. Depending on the type of notification, these can contain the sender's display name or username, the name of a counter and, for new messages, the first 60 characters of the message text. Expo also receives internal IDs (for example of a counter, a conversation or a user) that the App uses to open the right screen.
Legal basis: Consent (Art. 6(1)(a) GDPR).
3. Who we share your data with
We do not sell your personal data. We share it only with the following data processors, under contracts that require them to protect it:
- Supabase Ireland Limited: our database, authentication, and file storage provider. Data is stored on servers in the European Union. Supabase Privacy Policy.
- PostHog Inc.: analytics, used only with your consent. We use PostHog's EU-hosted infrastructure so analytics data stays within the EU. PostHog Privacy Policy.
- Functional Software, Inc. d/b/a Sentry: error tracking. Error reports are stored in Sentry's EU data region. Sentry Privacy Policy.
- 650 Industries, Inc. (Expo): delivery of push notifications, as described in Section 2.5. Expo is based in the USA and processes this data on our behalf under the data protection terms in its Terms of Service (Section 3.2); the transfer basis is the Standard Contractual Clauses approved by the European Commission (module two, controller to processor), which are part of those terms. Expo Privacy Policy.
If you sign in with Apple or Google, that provider processes the sign-in under its own privacy policy.
We may also disclose personal data when required by law or to protect the legal rights of Counter users.
4. How long we keep your data
- Account data: kept for as long as your account is active. When you delete your account in the App, your account and profile data, including your profile photo and any data export files, is deleted immediately, except as described for messages and submission history below.
- Submission photos: deleted when the voting window closes (the cleanup runs every few minutes), or immediately when the associated submission is deleted.
- Counter pictures: kept for as long as the counter exists, including after it has ended. Setting a new picture replaces the previous one. The picture belongs to the counter, so it stays when the member who set it deletes their account.
- Messages: each message is deleted automatically 30 days after it was sent. The App does not currently offer deletion of individual messages before then. If you delete your account, the messages you sent remain visible to the other participants of that conversation until they reach 30 days, with your name and profile removed so they can no longer be attributed to you. If you need a specific message removed sooner, contact us at the address below.
- Submission history and activity: if you delete your account, your counter submissions and the reports you filed stay with your name removed. Entries in a counter's activity history about member removals and role changes keep the name the member had at that time. Counters you own stay for their other members and ownership passes to another member automatically; if you are the only member, the counter ends.
- GPS coordinates: stored with the proof and deleted together with it when the voting window closes.
- Analytics data: retained by PostHog for up to 12 months. Withdrawing consent stops new collection but does not delete data already collected; contact us to have it deleted sooner.
- Error reports: retained by Sentry for 90 days.
5. Your rights under GDPR
As a data subject in the EU you have the following rights. You can exercise most of them directly within the App:
- Right of access: you can request a copy of all personal data we hold about you. Use the "Export my data" feature in Settings, or contact us by email.
- Right to rectification: you can update your display name, username, and profile photo at any time in the App.
- Right to erasure: you can delete your account via Settings → Delete account. Your account and profile data is deleted immediately; Section 4 explains which records stay with your name removed. You can also request deletion by email.
- Right to data portability: you can export your data in machine-readable format via Settings → Export my data.
- Right to restrict processing: you may request that we restrict processing of your data in certain circumstances. Contact us by email.
- Right to object: you may object to processing based on legitimate interests. Contact us by email.
- Right to withdraw consent: for analytics (PostHog) and push notifications, you can withdraw consent at any time in the App settings.
To exercise your rights, contact: mail@compcounter.app. We will respond within 30 days. If you believe your rights have not been respected, you have the right to lodge a complaint with the supervisory authority in your country of residence. In Germany, the competent authority is the Hamburgische Beauftragte für Datenschutz und Informationsfreiheit (HmbBfDI).
6. Minimum age
Counter is intended for users aged 16 or over. We verify age at registration by collecting your date of birth. If we become aware that a user is under 16, we will delete their account and all associated data promptly.
7. International data transfers
Supabase (database, authentication and file storage), PostHog (analytics) and Sentry (error reports) store your data in the European Union. Push notifications are the exception: they pass through Expo's push service in the USA, on the basis of Standard Contractual Clauses approved by the European Commission (see Section 3), and are then delivered by Apple's Push Notification service.
8. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. When we make significant changes we will notify you within the App. The effective date at the top of this page always reflects the most recent update. Continued use of the App after a change constitutes acceptance of the updated Policy.
9. Automated decision-making
We do not use your data for automated decision-making or profiling that produces legal or similarly significant effects. Submission approvals are decided by human votes from counter members.
10. This website
The website compcounter.app is hosted by IONOS SE, Elgendorfer Str. 57, 56410 Montabaur, Germany. When you open a page, the server records your IP address, the date and time, the page requested, the referring page and your browser type in log files. This is needed to deliver the site and keep it secure. Log files are kept only as long as needed for these purposes and are then deleted by IONOS.
The website sets no cookies, uses no analytics and loads nothing from other servers, except for the invite page described below. The sign-in data in an email confirmation link is not sent to our server. It stays in your browser and is only passed to the App when you tap the button on the confirmation page.
The page for invite links (compcounter.app/join/…) loads the counter's name and member count from our server at Supabase. The invite token from the link and your IP address reach that server with the request. The page sets no cookies.
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR).