Privacy Policy

1. Introduction

SpinBox s.r.o. ("Juice Game", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you use our platform, including the spin boxes, Banana Battle and the kink test.

This policy complies with the General Data Protection Regulation (GDPR) (EU) 2016/679 and other applicable data protection laws.

2. Data Controller

The data controller responsible for your personal data is:

All the ways to reach us about your data are listed in Section 17.

3. Data We Collect

3.1 Information You Provide

• Account Information: Email address, display name, the gender you choose during onboarding, your password (stored only in hashed form by our sign-in provider, never visible to us) and when you confirmed that you are 18 or older and accepted our Terms, together with the IP address, its country and the browser each of those confirmations came from
• Profile Information: Display name, profile picture, bio (optional)
• Creator Applications: Profile and contact details, social media links, identity verification (see Section 7) and payout details: the IBAN and account holder name for SEPA payouts, and your VAT number if you provide one
• Kink Test (optional): Your answers and result, only if you choose to save them, and, if you play a Duet with another person, the nickname, gender, answers and chat messages you give in it (see Section 6)
• Banana Battle: Photos you submit, which are shown publicly next to your username, and your battle results and rankings
• Communications: Help Desk messages, support and content removal requests, feedback

3.2 Information Collected Automatically

• Usage Data: Pages visited, features used, spin history, items won, content interactions
• Device Information: IP address, browser type, operating system, device identifiers
• Where You Came From: The invite code, campaign tags or shared link that first brought you to the platform (see Section 10)
• Cookies and Similar Technologies: See Section 10
• Log Data: Access times, error logs, referring URLs

3.3 Information from Third Parties

• Identity Verification (creators): The verification result and the data read from your identity document, from Didit (see Section 7)
• Google Sign-In: Your name, email address and profile photo, if you choose to sign in with Google
• Payment Providers: None at the moment, because no payment provider is connected yet (see Section 8)

4. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Contract Performance: To provide our services, process transactions, and manage your account
• Legal Obligation: To comply with laws (e.g., age verification, tax reporting, 2257 record-keeping)
• Legitimate Interests: To improve our services, prevent fraud, ensure security, credit referrals, and send service communications
• Consent: For analytics (see Section 10) and marketing communications. You can withdraw consent at any time
• Explicit Consent (Art. 9(2)(a) GDPR): For saving your kink test result, and for a kink test Duet (storing your answers and messages and showing them to the other player), both of which concern your sex life and sexual orientation (see Section 6)

5. How We Use Your Data

• Service Provision: Create and manage accounts, process spins and battles, deliver content
• Verification: Verify the age and identity of creators for legal compliance
• Payments and Payouts: Hand out credits, pay out creator earnings, prevent fraud
• Referral Program: Credit the creator who invited another creator
• Communication: Send service updates, respond to inquiries, provide support
• Security: Detect and prevent fraud, abuse, and unauthorized access
• Improvement: Analyze usage patterns (with your consent where required), improve features, develop new services
• Legal Compliance: Meet regulatory requirements, respond to legal requests

6. The Kink Test (Sensitive Data)

The kink test is optional. You can take it on your own or together with one other person in a Duet. Your answers reveal information about your sex life and sexual orientation, which the GDPR treats as a special category of personal data (Art. 9). We handle it as follows.

Taking the Test on Your Own

• While You Play: As you take the test on your own, your answers, your progress, the nickname you enter and, once you reach it, the result calculated from your answers are sent to our servers, together with your account if you are signed in. While the test is in its trial phase our team can follow them as you play, to see how the test is used and to fix it; every time staff open them is logged. We keep this record while the test is in its trial phase and delete it when you delete your account, or when you ask us to (if you played without an account, tell us the nickname and roughly when you played). You can take the test without an account.
• Explicit Consent: We store your result only if you tick the consent box and then tap Save. If you tick the box before signing in, the same browser tab may show it ticked again once you are signed in, but your result is saved only when you tap Save yourself; nothing is ever saved automatically. Without that consent nothing from the test you take on your own is kept beyond the record of your play described above.
• What We Store: Your individual answers, the result calculated from them (a score for each role, your strongest roles, the gender you selected and your orientation as you answered it) and the date. The gender you select is also saved to your profile if it does not have one yet.
• Who Can See It: Outside a Duet, your result is not shown to other users or creators unless you share it yourself. A share link shows your result profile, without your name or account details, to anyone who has the link and lets them compare with you; you can revoke it at any time. Creators can also switch on a badge that shows their strongest role on their public creator profile; it stays off until they switch it on. A revoked link and its preview image can stay visible for a few minutes (up to about 10) while cached copies expire.
• Staff Access: A small number of authorised Juice Game administrators can access saved results, including individual answers, when needed for support, safety or abuse handling. Each such access is recorded (see Records of Administrator Actions in Section 12). We never sell this data or use it for advertising.
• Analytics: If you allow analytics (see Section 10), we only record steps such as starting, finishing, saving, sharing or comparing the test, never your answers, roles or scores, and share links are removed from the page addresses we record.
• Partner Comparison: The comparison with someone else's shared profile is calculated in your browser and is not stored.
• Retaking the Test: A new saved result replaces the previous one, and an existing share link then shows the new result.
• Deletion and Withdrawal of Consent: You can delete your saved result at any time with "Delete result" in the test. This also removes your share link and badge (cached copies of the link can stay visible for a few minutes) and withdraws your consent (without affecting processing that took place before). When your account is deleted, your result, answers and share link are deleted with it at the end of the 30-day recovery period.

The Duet (Playing Together)

• How It Works: In a Duet two people take the test together. One of you starts it and sends the other an invite link. You answer the same rounds of questions, and after each round that you have both finished you see each other's answers in it and how well they match. A Duet has a chat. You can play with or without an account.
• Explicit Consent: Before you start or join a Duet, you confirm that you are 18 or older and tick a consent box: you agree that your answers and messages are stored on our servers until the Duet expires (14 days) or is deleted, and that the other player sees your answers after each round, your messages as soon as you send them and your whole result once you have both finished the Duet. Without that consent you cannot take part. We record when you gave it. What you write in the chat is treated with the same care as your answers.
• What We Store: For each player: the nickname you choose for the Duet, the gender you select, your answers, when you joined and gave your consent, when you were last active in the Duet, and the chat messages and emoji reactions you send. If you are signed in, or sign in from the Duet, we also store your account ID with your place in it. For the invite link and for each player's place we store only a fingerprint (hash) of its secret key, never the key itself. The match between your answers is calculated on our server whenever one of you opens the Duet and is not stored.
• Who Can See It: Only the two players. While you play, the other player sees your nickname, your gender, whether you are online, how many questions of the current round you have answered (not your answers) and your chat messages as soon as you send them. They see your answers in a round only after you have both finished that round (your orientation is one of the answers of the first round), and your result only after you have both finished the Duet. Your answers to the two questions about a much younger adult partner and about teaching someone less experienced (the Age gap role) are never shown to the other player or counted in the match, and that role is left out of the result they see. Your other answers about age, such as the ones about an older partner, are shown like any other answer. A Duet is never public and is not shown on your profile. Anyone who has the invite link can see the nickname of the player who started the Duet and take the free place until the second player has joined, so send it only to the person you want to play with.
• Without an Account: If you play without signing in, nothing links the Duet to an account. Your browser keeps the key to your place in it (local storage) so you can come back to it on that device; anyone who uses that browser can too. The key stops working once the Duet is deleted. If you sign in from the Duet (for example to save your result), your place in it is linked to your account.
• Saving Your Result: A Duet puts nothing on your account by itself. To keep your own result from a Duet, you save it to your account like a result of the test on your own: with the consent box and the Save button described above.
• How Long We Keep It: A Duet and its chat are deleted 14 days after the Duet was started, usually during the following night, unless the account of either player is under a legal hold (see Section 12). After those 14 days the Duet can no longer be opened.
• Deleting a Duet: Either player can delete the Duet at any time. This deletes it, with all answers and messages, for both players, because a Duet is one shared thing, and it withdraws your consent (without affecting processing that took place before). When an account is deleted, at the end of the 30-day recovery period, every Duet it took part in is deleted with it, for both players, if it has not expired already. The only exception is a Duet whose other player's account is under a legal hold (see Section 12): it is kept for that hold, but your nickname, your answers and the link to your account are removed from it, and nobody can open your place in it again. The gender you selected and the chat stay in it until it is deleted.
• Staff Access: Our administrators do not open Duets; there is no administrator tool for them. The only exception is a copy of your data that you ask us for (see Section 13): it holds your own side of each Duet you played with your account (your nickname, gender, orientation, answers and your own messages, never the other player's), and making it is recorded (see Records of Administrator Actions in Section 12). If you played without an account, we cannot tell which Duet was yours, so it cannot be part of such a copy.
• Analytics: If you allow analytics (see Section 10), we only record that a Duet was started, joined or finished and whether you were signed in, never nicknames, answers, matches or messages, and Duet links are removed from the page addresses we record.

7. Identity Verification (Didit)

Identity verification is currently required only from creators. It is carried out for us by Didit (didit.me), which acts as our processor.

• What Is Collected: Photos of your identity document (front and back) and the data printed on it (full name, date of birth, gender, document type and number, personal number where printed, issue and expiry dates, issuing country, nationality and address where printed), a live selfie and a short liveness video, the result of comparing your face with the document photo, your verified phone number, and technical data from the session such as your IP address and its approximate location.
• Why: To confirm that you are 18 or older and the person you say you are, to prevent fraud and impersonation, to make sure payouts go to you, to determine the country used for referral rates, and to meet our legal obligations. While we keep the selfie (see Retention below), our administrators also use it to check that content features the verified creator.
• Biometric Data: Comparing your selfie with your document photo involves biometric data. It is used only for this check.
• Legal Basis: Performance of the creator agreement (you cannot become a creator without verification), our legal obligations to verify age, and our legitimate interest in preventing fraud.
• Where It Is Kept: Didit returns the result to us, and we keep a copy of the data, images and video in our own secured storage on Google Cloud. Only authorised administrators who review creator applications can access it. Didit deletes its own copy of the check on our instruction within 90 days, so the periods below apply to our copy.
• Retention:
  • If your application is rejected or withdrawn, the selfie, the liveness video and the face comparison are deleted within 90 days of the decision.
  • If your application is approved, the liveness video and the face comparison are deleted within 90 days of the approval. We keep the selfie for as long as you are a creator, because our administrators compare new uploads with it, and delete it within 90 days of the closure of your creator account.
  • The rest of the verification data is kept for as long as your application is open or you are a creator, and after that as follows.
  • For a rejected or withdrawn application, all other verification data is deleted 6 months after the decision. We keep a short record of the decision for 3 years: the account it belongs to, the creator name applied for, when the application was submitted, the result, when and why it was decided and by whom, whether you have seen the decision, and whether the applicant was under 18. If you start an application but never submit it, all of its verification data, the selfie and the video included, is deleted after 6 months without activity; we then keep only the account it belongs to, the date and whether the applicant was under 18, for 3 years.
  • If the check shows that you are under 18, all of the verification data and what you entered in the application are deleted within a day, whatever the stage of the application. Only the short record of the decision described above stays, for 3 years, noting that the applicant was under 18. What happens to the rest of the account is set out in Section 15. This does not apply if you are or have been a creator: your approval confirmed that you were 18 or over, and the verification data behind it is kept as proof of age for the periods set out here. If a check of a creator, current or former, shows them under 18, nothing is deleted early; the periods set out here still apply, and our team reviews the account and decides on it (Section 15).
  • For a former creator, the identity document and the data read from it are kept while cards that fans have won from them remain on Juice Game, and then for 7 years, as proof of age and identity and to defend legal claims.

8. Payments

• Test Mode: Payments currently run in test mode. No payment provider is connected, Juice Points are handed out free of charge as test credits, and we do not collect card or bank details from fans.
• Test Earnings: Creator earnings generated with test credits are never paid out.
• Creator Payouts: We use your IBAN and account holder name only to pay out your earnings and for our accounting and tax records.
• Before Real Payments Start: Before we connect a payment provider, we will update this policy and name the provider. Card details will then be entered directly with that provider and will not be stored by us.

9. Service Providers and Data Sharing

We share personal data only with the service providers we need to run the platform, who process it on our behalf, and in the other cases listed here:

• Hosting and Infrastructure: Cloudflare (delivers and runs the website) and Google Cloud / Firebase (sign-in, our main database, located in the EU, server functions, which run mostly in the EU, and file storage, including the copies of identity verification data)
• Media Hosting: Bunny.net (private storage and delivery of creator content, and video streaming through Bunny Stream) and Cloudinary (processing of uploaded images and videos, previews and blurred versions, and Banana Battle photos)
• Identity Verification: Didit, for creators only (see Section 7)
• Analytics: PostHog, hosted in the EU, only with your consent (see Section 10)
• Email: Resend, for account and notification emails
• Sign-In: Google, if you choose to sign in with Google
• Payment Providers: None at the moment (see Section 8)
• Legal Authorities: When required by law or to protect rights and safety
• Business Transfers: In case of merger, acquisition, or sale of assets

Some things are public because you choose to publish them: your creator profile, your Banana Battle entries with your username, and a kink test share link or badge if you create one.

We do not sell your personal data to third parties.

10. Cookies and Similar Technologies

We use cookies and similar browser storage (local storage) as described below. You can change your analytics choice at any time with "Cookie settings" in the site footer.

10.1 Strictly Necessary

These keep the platform working and do not need your consent:

• Sign-in session: Kept in your browser storage by Firebase Authentication until you sign out
• sb_dest (180 days): Remembers that you are signed in, so you go straight to your start page instead of the landing page
• NEXT_LOCALE: Your language
• sb_country (1 hour): The country detected from your connection, used for country-specific features such as creators' country restrictions
• sb_admin (1 hour): Administrator sessions only
• Kink test Duet: The key to your place in a Duet you play, kept in your browser storage so you can come back to the Duet (see Section 6)
• Your choices: Your confirmation that you are 18 or older and your analytics choice (sb_analytics_consent) are remembered in your browser storage

10.2 Functional: Where Your Visit Came From

• sb_attr (60 days): Set on your first visit. It records where that visit came from: a creator invite code (ref), campaign tags (src, utm_*), a shared clip or kink test comparison link, the first page you opened and the time of that visit. Later links do not overwrite it while it exists.
• We use it to credit the right creator for an invitation and to understand which links bring new members. When you sign up, its content is copied once to your account, without any kink test share code: the account only records that you arrived through a comparison link. A Duet link is copied without the Duet's ID, and the invite key in it never reaches the cookie. It is not used for advertising and is not shared with anyone.
• A creator invite code from a link is also kept in your browser storage for up to 60 days, so it is not lost while you sign up and apply.
• sb_attr_reported: Remembers, for your account ID, whether the origin of your visit has already been saved to your account, so it is not sent again once it has been saved.

10.3 Analytics (Only With Your Consent)

• We use PostHog, hosted in the EU. Until you click "Allow analytics" in the cookie banner, PostHog is not loaded at all: no cookie, no browser storage and no request to PostHog.
• After you allow it, PostHog stores an identifier in a cookie and in your browser storage (names starting with ph_) and records the pages you view and named steps such as signing up, opening a creator's page, spinning (including which creator's box), topping up or starting and finishing the kink test. You are identified by your account ID only, never by your email or name. Session recording, heatmaps and automatic click tracking are switched off.
• You can withdraw your consent at any time with "Cookie settings" in the site footer, as easily as you gave it.

10.4 Counting Sign-Ups

Two small values of our own help us count sign-ups correctly. They never leave your browser by themselves.

• sb_auth_source (this browser tab only): Remembers where you opened the sign-in window, for example the landing page or a creator's page. It is stored even before you answer the cookie banner, because signing in with Google can leave the page and come back. It is only added to the sign-up event, which reaches PostHog only if you allow analytics.
• sb_signup_tracked: Remembers the account ID whose sign-up was already counted, so it is not counted twice. Until you allow analytics it is kept only in the memory of the open page and is gone when you reload or close it; only after you allow analytics is it stored in your browser storage.
• If you decline analytics or withdraw your consent, both are deleted and not stored again.

11. International Data Transfers

Some of our service providers are based outside the European Economic Area (EEA) or have group companies there, for example in the United States, so your data may be transferred to and processed in such countries. When this occurs, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions for countries with equivalent data protection, including the EU-US Data Privacy Framework for certified providers
• Binding Corporate Rules where applicable

12. Data Retention

We retain your data for the following periods:

• Account Data: For as long as you have an account. When you delete it, we close it at once and delete it after a 30-day recovery period, during which you can restore it by signing in. The deletion covers your profile, collection, spin history, notifications, saved clips, reviews of cards, kink test, and Banana Battle photos and the name on your entries. What stays of payments, spins and Banana Battle entries is set out under Payments, Spins and Payouts below
• Deletion Record: After the deletion we keep only a minimal record for 3 years, to defend legal claims (Art. 17(3)(e) GDPR): your account ID, when the account was created, when the deletion was requested and carried out, who started it (you, our support team, a ban or the closure of a creator account) and why, how you signed in, your Juice Points balances at that moment, when you accepted our Terms and confirmed that you are 18 or older (for each of those confirmations, the last 10 at most, also the IP address, its country and the browser it came from), and whether the account was banned. Then the record is deleted
• E-mail Lock: If your e-mail address was verified, the deletion record also holds a fingerprint (hash) of it for 6 months, so that the address cannot be used to sign up again during that time. Then the fingerprint is deleted. An unverified address is not locked
• Kink Test Result and Answers: Until you delete them, or until your account is deleted at the end of the 30-day recovery period
• Kink Test, Record of Your Play: The answers, progress and nickname sent while you play (Section 6) are kept while the test is in its trial phase, until your account is deleted at the end of the 30-day recovery period, or until you ask us to delete them
• Kink Test Duets: 14 days from when the Duet was started, then deleted with its chat, usually during the following night; earlier if either player deletes it or the account of a player is deleted. Longer only while the account of either player is under a legal hold (see Legal Hold below)
• Identity Verification (creators): As set out in Section 7. In short: the liveness video and the face comparison until 90 days after the decision on your application; the selfie of a rejected or withdrawn applicant until 90 days after the decision, and a creator's selfie until 90 days after the closure of the creator account; the rest while your application is open or you are a creator, and for the periods in Section 7 after that
• Payments, Spins and Payouts: Records of real payments, of spins, of Banana Battle entries and of creator payouts are kept for 10 years from the end of the year in which they took place (VAT and accounting law; spins and entries are part of the creators' earnings records, also when they were paid with test Juice Points). Once an account is deleted, its payment records no longer hold its e-mail address, but they keep the billing name and address given at checkout. Spin records and Banana Battle entries stay under the account ID; they never hold an e-mail address, and the deletion removes the name and photo from the entries. Test payments are deleted together with the account
• Creator Payout Details: The IBAN in a creator profile is deleted when the creator account is closed; the copy in the payout records is kept as above. The IBAN and contact e-mail address given in a creator application are deleted at the latest with the rest of the verification data (Section 7): 6 months after the decision on a rejected or withdrawn application, and for a former creator together with the identity document
• Bans: Records of a ban (the e-mail address and account ID of the banned account, how it signed in, when and why it was banned and, for a banned creator, the entry on our identity verification provider's blocklist) and the disabled sign-in account, which still holds the e-mail address, name and profile photo link it had, for as long as the ban applies, reviewed after 3 years
• Records of Administrator Actions: When one of our administrators acts on an account (for example decides on a creator application or a payout, deletes, bans or restores an account, closes a creator account, places or lifts a legal hold, releases an e-mail lock, exports an account's data or opens a saved kink test result), we keep a record of what was done, to which account, by which administrator, when and why. These records are deleted 3 years after the action, unless the account concerned is under a legal hold (see Legal Hold below)
• E-mails We Send: A record of which e-mail we sent to which account and when (for example the confirmation of a creator application, the decision on it or a message from our support team), without the address or the text of the e-mail. It is deleted with your account, and otherwise 3 years after the e-mail was sent, unless the account concerned is under a legal hold
• Support Communications: 3 years after resolution
• Usage Logs: 12 months
• Analytics Data (only with your consent): 12 months
• First-Touch Attribution: The sb_attr cookie expires after 60 days; the copy saved to your account is deleted with your account
• Marketing Consent Records: Duration of consent plus 3 years
• Legal Hold: Where data is needed for a dispute, a chargeback, a court or police request or a report of illegal content (such as child sexual abuse material or fraud), we keep the data concerned for as long as the matter requires, even beyond the periods above

13. Your Rights (GDPR)

Under GDPR, you have the following rights:

• Right of Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your data ("right to be forgotten"). You can also delete your account yourself in Settings (see Section 12)
• Right to Restriction: Limit how we process your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for marketing
• Right to Withdraw Consent: Withdraw consent at any time (without affecting prior processing)
• Right to Lodge a Complaint: File a complaint with a supervisory authority

To exercise your rights, use one of the contact options in Section 17. We will respond within one month.

Supervisory Authority: Office for Personal Data Protection (ÚOOÚ), Pplk. Sochora 27, 170 00 Praha 7, Czech Republic

14. Data Security

We implement appropriate technical and organizational measures to protect your data:

• Encryption of data in transit (TLS/SSL) and at rest
• Access controls and authentication requirements
• Regular security assessments and monitoring
• Employee training on data protection
• Incident response procedures

15. Children's Privacy

Juice Game is strictly for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If we discover that an account belongs to a minor, we delete it without the 30-day recovery period; only what Section 12 says we keep after a deletion (such as the deletion record and payment records) stays. If the identity check of a creator applicant shows that they are under 18, our copy of their verification data and what they entered in the application are deleted within a day, and we keep only the short record of the decision, which notes that the applicant was under 18 (Section 7). Didit deletes its own copy of the check within 90 days. At the same time the account goes on a list for our team, which reviews it and deletes it as above once it has confirmed that the account belongs to a minor. This does not apply to a current or former creator: their approval confirmed that they were 18 or over, and that verification data is kept as proof of it (Section 7). If a check of a creator shows them under 18, nothing is deleted early; the account goes on the same list, and our team reviews it and decides on the account and its verification data. If you believe a minor has provided us with personal data, please contact us (see Section 17).

16. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by email or through a notice on our platform. The "Last Updated" date at the top indicates when the policy was last revised. Where a change needs your consent, for example a new use of your kink test data, we will ask for it again rather than rely on your continued use of the platform.

17. Contact Us

For privacy-related inquiries or to exercise your rights:

• Support Chat: When signed in, send us a message through Support in your account settings
• Email: compliance@spinbox.app
• Address: SpinBox s.r.o., Dandova 2619/13, Horní Počernice, 193 00 Praha, Czech Republic

To have content that shows you removed, use the content removal request form. For everything else, see our Contact page.