Privacy Policy

Who we are

Lokal Solvr is operated by KVOma, Banebergpassage 2, 6371 HW Landgraaf, the Netherlands (Chamber of Commerce / KvK 42047901, VAT NL005454890B91). We are the data controller for the personal data described here. Our registered contacts are contact@kvoma.com and +31 6 8531 3776; for anything about your data or this Policy, the in-app Support form or support@kvoma.com reaches us fastest. Our lead supervisory authority is the Dutch Autoriteit Persoonsgegevens.

What we collect

• Account details you provide: email, nickname, and optionally full name, country, preferred language, and date of birth (used to confirm you meet the age requirement).
• Precise location: while you play, we use your device location to place you on the map and to verify finds. Verification checks whether you are inside a target radius.
• Photos you take to confirm finds and any places or reports you submit.
• Usage and device data: basic technical logs, app version, and diagnostics needed to operate and secure the service.
• Payment data: purchases are handled by our payment processor; we receive confirmation and limited transaction details, not your full card number.

How we use it

• To run the Game: generate walks, show the map, verify finds, award and track credits/XP.
• To moderate content and handle reports, submissions, and support requests.
• To keep the service secure and prevent abuse or fraud.
• To produce statistics about how the Game is used — how many walks and finds happen in a city or country, which places work, how the service performs — so we can improve it and decide where to expand.
• To comply with legal obligations, including age requirements.
• To promote the Game — showing photos players have taken on our website, in app-store listings, in social posts, and in press material. See “Photos we show” below for the limits and how to stop it.
• With your separate opt-in, to send you product updates. You can opt out at any time.
• With your separate opt-in, to show your nickname and XP on the worldwide leaderboard. It is off unless you turn it on, and you can turn it off again in Profile.

Legal bases (EU/EEA/UK)

Performance of our contract with you covers running the Game — including your precise location. The Game exists to send you to a real place and confirm you got there; it cannot draw the map or verify a find without knowing where you are. Location is necessary to deliver what you signed up for, not an optional extra, so we don’t ask for it as a separate consent.

That comes with a limit we hold ourselves to: we don’t use your location to build a picture of you. No advertising, no profiling, no selling, no ad-tech, and no movement history beyond the walks you can see in your own account. Using your location to target or profile you would need a different legal basis, and we would ask you first. Showing a photo you took is a different thing and is covered below: it says something about a place, not about you.

We do count. To understand where the Game is being played and where to invest, we look at things like how many walks were generated in a city or country, which places get found, and which markets buy credits. That is done on totals and groups — never to profile an individual player, and never shared or sold as personal data. The law treats statistics as a compatible use of data already collected, and the moment a number is small enough to point at one person, it stops being a statistic and we don’t publish or use it that way.

Your device still asks for location permission separately, and you can turn it off at any time in your device settings — most of the Game stops working without it. That permission is a device-level control and is separate from the legal basis above.

Alongside that, we rely on:

• Consent — for optional marketing messages, and for appearing on the worldwide leaderboard. You can withdraw either at any time, and doing so changes nothing else about the Game.
• Our legitimate interests — keeping the service secure, preventing abuse, cheating and fraud, diagnosing what’s broken, understanding how the Game is used at the level of totals so we can decide what to build and where, and showing the photos players take when we promote the Game, on the terms in “Photos we show”.
• Legal obligations — the minimum age requirement, and keeping payment records for as long as Dutch tax law requires.

The leaderboard

There is a worldwide leaderboard ranking players by XP. Appearing on it publishes two things to every other player: the nickname you chose and your XP total. Nothing else — not your real name, not your location, not your photos, not your email. It is off by default and stays off until you say yes, which we ask the first time you open the leaderboard. You can change your mind at any time in Profile, and you disappear from the board immediately. Your XP keeps counting either way, and you can always see your own rank privately, whether or not you are published.

Photos we show

The Game is about places most people walk past, and the best argument for that is a photograph of one. So we may show photos players have taken — both find confirmations and place submissions — when we promote the Game: our own website, app-store listings, social posts, press material. We rely on legitimate interests for this, not on your consent, which means you have an unconditional right to object and we have to earn the balance. Here is how we do that.

• A person reviews every photo before it is used. Nothing is selected automatically.
• We don’t use a photo in which anyone is recognisable — that is a decision to drop the photo, not to blur it.
• We don’t attach your name, nickname, or account. If you’d rather be credited, ask and we will credit you.
• We don’t publish the time it was taken or the exact coordinates. We may name the place; where you were and when is not part of it.
• We only use content from accounts aged 16 or over, because 16 is the Dutch age of digital consent and we are not comfortable promoting the Game with a 13-year-old’s photograph.
• We never license or sell your photos to anyone else for their own advertising.

To object, message us through the in-app Support form or support@kvoma.com and say you’d rather your photos weren’t used. There is nothing to justify and nothing else changes about the Game. We stop, and that photo isn’t used again. One honest limit: something already printed or already posted and reshared can’t always be pulled back out of the world — we remove it from everything we control and stop using it going forward.

Who we share it with

We use a small number of providers to run the Game, and share only what each one needs to do its job. We don’t sell your personal data and we don’t share it for advertising.

• Supabase — database, sign-in, and photo storage. Your account, walks and photos are stored here, in the EU (Sweden).
• Vercel — hosting for the website and the API, including server logs.
• OpenRouter — routes our text-generation requests to the AI models we use. These prompts contain place information, not your personal data.
• Stripe — payments on the web. Your card details go to Stripe and never reach us.
• Apple — purchases made inside the iOS app are sold by Apple; we receive a confirmation and a transaction reference.
• Expo — delivers push notifications, so it receives your device’s push token and the text of the notification.
• OpenFreeMap — map tiles. Your device fetches these directly, so OpenFreeMap sees your IP address and the part of the map you’re looking at; we send it nothing about you.
• Cloudflare — protects the private endpoint our content pipeline runs behind.
• Greenhost (Amsterdam) — hosts the server running our own content-generation pipeline (n8n), which we operate ourselves.

We may also disclose data where the law requires it, or where we need to establish or defend a legal claim.

Retention

We keep personal data while your account is active. When you delete your account we delete your profile, your walks, the places you discovered, your photos, and your support messages — permanently, not just hidden.

Three things outlive the account. Places you submitted stay in the game as anonymous content, no longer linked to you, so the map doesn’t lose a location when someone leaves. Payment records are kept for 7 years because Dutch tax law requires it; they no longer identify you. And we keep anonymous statistics about the walks that were generated — the day, the town, the size of the area, and what building it cost us to run — with your name, your account, the exact spot and the places you visited all removed, so the figures can’t be traced back to you or to each other.

Your rights

• Access, correct, or delete your personal data, and request a copy (portability). You don’t have to ask us for the copy: “Download my data” in your profile gives you a machine-readable file of everything we hold about you, straight away.
• Object to or restrict certain processing, and withdraw consent where we rely on it.
• Object specifically to us showing your photos when we promote the Game. One message stops it, with no reason needed — see “Photos we show”.
• Delete your account. This permanently removes your profile, your walks, the places you visited and your photos; places you submitted remain as anonymous content, payment records are kept as long as tax law requires, and anonymous statistics about what was generated are kept with nothing linking them to you.
• Complain to your local data-protection authority.

Children

The Game isn’t intended for children under 13 (or under the applicable digital-consent age where higher). We don’t knowingly collect data from them; if you believe a child has given us data, contact us and we’ll remove it.

International transfers

Your account, game data and photos are stored in the EU. Several of the providers above are established in the United States — Vercel, OpenRouter, Expo and Cloudflare, and Supabase’s own administrative access — so some data does reach the US.

For those transfers we rely on the European Commission’s Standard Contractual Clauses, and on the EU–US Data Privacy Framework where the provider is certified under it. Email support@kvoma.com if you’d like a copy of the safeguards we rely on.

Security

We apply reasonable technical and organizational measures: photo storage is private and not publicly listable, access to production data is limited, and we keep only what the Game needs. No service is perfectly secure, though, and we can’t promise otherwise.

Contact

To exercise your rights or ask about this Policy, use the in-app Support form or email support@kvoma.com.