Privacy policy
This document describes exactly what happens to your data in the Meldly app and on this website. We wrote it so that it can actually be read to the end.
- In short
- Who is responsible for the data
- What we do NOT collect
- What data and what for
- Do you have to provide it
- Photos from scanning
- Automated decisions
- Who we entrust data to
- Transfers outside the EEA
- Your rights
- Right to object
- Deleting the account
- Age of users
- This website
- Security
- Changes
In short
Meldly is a point counter. To work, it needs an e-mail address (or a Google account), a player name and the results of your games — and nothing beyond that.
We show no ads and we do not collect the advertising identifier. We do not sell or share data for marketing purposes. We have no access to your location, your contacts or your phone number.
We do not store the photos from tile scanning. A photo is processed and deleted immediately after the result is returned. The one exception — a problem you report yourself — is described explicitly below.
Who is responsible for the data
The controller of your personal data is Krzysztof Bzdęga, a sole trader operating under the business name Asgard-Technologies Krzysztof Bzdęga, ul. Limby 7 lok. 10, 71-784 Szczecin, Poland, entered in the Central Register and Information on Economic Activity (CEIDG), NIP 5941472283, REGON 320102307. The same business is the publisher of the Meldly app on Google Play.
Contact on personal data matters: contact@meldlyapp.com. We answer requests concerning your rights without undue delay, and at the latest within one month of receiving them. If the matter is complex, we may extend that period by two months — we will tell you about it and why.
We have not appointed a data protection officer, because in our case this is not required. Data matters are handled directly by the controller, at the address above.
What we do NOT collect
We start with this list, because it is usually more important than the list of data collected, and it is rarely given:
- the advertising identifier (AAID, IDFA) — the app does not ask for it and shows no ads;
- location — neither precise nor approximate;
- contacts, address book, calendar, text messages or call history;
- your phone number;
- payment data — we never see your card or bank account number; the payment is handled by Google Play, and all we receive is the information that a subscription is active;
- your IP address in plain form — in the app; we store only an irreversible hash of it. The web server logs of this website are a separate matter, described in the section This website;
- photos — see the separate section below.
What data and what for
| Data | What for | Legal basis | How long |
|---|---|---|---|
| E-mail address, password hash, player name, avatar, language, country | creating and running the account, logging in, recovering access | performance of the contract (art. 6(1)(b) GDPR) | for as long as the account exists, then anonymisation within 30 days |
| Year of birth | checking the minimum age and adapting features to the age bracket | legitimate interest — compliance with the age requirement and protection of minors (point (f)) | for as long as the account exists |
| Identifier at the login provider (Google) and the e-mail address from there | linking the Meldly account with the Google account, if you choose that way of logging in | performance of the contract (point (b)) | until the provider is disconnected or the account is deleted |
| Games, rounds, results, groups and seasons | the essence of the service — this is what you use the app for | performance of the contract (point (b)) | until the game or the account is deleted |
| Token and premium balance, the history of how it was credited | settling the paid features and being able to reconstruct how the current balance came about | performance of the contract (point (b)) | for as long as the account exists |
| Billing events from the subscription operator (event identifier, type, expiry date) | establishing whether a subscription is active, including when the app is closed | performance of the contract (point (b)) and a legal obligation (point (c)) | 5 years from the end of the tax year, where they constitute an accounting document — in a form stripped of identifying data |
| The cropped photo of the tile rack (the image alone, without EXIF metadata) | reading the points you asked for | performance of the contract (point (b)) | we do not save it — it exists only in memory for the duration of the request; what happens to it at the model provider is described in the section Photos from scanning |
| The photo and description you send in a “Report a problem” report | investigating the recognition fault you reported | your consent (art. 6(1)(a) GDPR) | until the report is closed, no longer than 90 days; once consent is withdrawn — immediately |
| Scan metadata: the result, a category from a closed list, the number of tokens, the duration | settling tokens, detecting abuse, improving recognition quality | legitimate interest — protection against abuse of a paid API and accountability (point (f)) | for as long as the account exists |
| Refresh tokens: the token hash, the device identifier, a hash of the IP address | keeping you logged in and detecting token theft | legitimate interest — security of user accounts (point (f)) | until the token expires or you log out |
| One-time codes: the code hash, the address it was sent to, the number of attempts | confirming the e-mail address and resetting the password | performance of the contract (point (b)) | until the code is used or expires |
| Technical server logs | diagnosing failures and security | legitimate interest — maintaining and securing the service (point (f)) | written only when an error occurs, overwritten in rotation — they cover the last few days of traffic |
Why for some data we write “for as long as the account exists” rather than a specific number of months. Because that is how it really is. We would rather give the criterion we actually apply than a period we do not enforce — a retention statement with nothing behind it is worse than none at all. Shorter, automatic periods for scan metadata are planned; once they are running we will change this document and give the number here.
Analytics and marketing
At the time this version was issued we use no analytics tool and no marketing notifications. If that changes, we will ask you for separate consent for analytics and separate consent for marketing — not in a single “I accept everything” box — and this document will be updated before anything starts running.
Do you have to provide this data
Providing data is voluntary, but some of it is a condition of concluding and performing the contract — without it the service will not work:
| Data | Required | What if you do not provide it |
|---|---|---|
| E-mail address or logging in with a Google account | yes, one of the two | you cannot create an account or recover access |
| Player name | yes | you cannot keep score or run groups |
| Year of birth | yes | you cannot create an account — we have to check the minimum age |
| Avatar, country | no | nothing — these are purely how your profile looks |
| Photo attached to a problem report | no | we will not be able to check what went wrong, but the app works normally |
Photos from scanning
The app can read points from a photo of a tile rack. This is the most sensitive thing Meldly processes — the frame may contain a face, the inside of a home or documents lying on the table. That is why it works like this:
- Cropping happens on your phone, before anything is sent. What is sent is a fragment of the table with the rack, not a photo of the room.
- EXIF metadata is removed on the phone. A photo from a camera usually contains the GPS coordinates of the place where it was taken — far more serious information than the image itself, so it is gone before anything leaves the device.
- The photo is not saved on our side. It goes to the provider of the recognition model, the result comes back, the image is deleted. This also applies to rejected photos — we do not keep “evidence of abuse”.
- Instead of the image we save a single word from a closed list (for example rack, another game, table with no game, unreadable). This lets us improve recognition quality without storing anything that shows you or your home.
One exception, entirely under your control: if you yourself report a faulty recognition with the “Report a problem” button, we keep that particular photo together with your description — so that it is possible to check what went wrong. The basis is then your consent, given by pressing that button — we deliberately do not base this on legitimate interest, because consent is fairer here and gives you an unconditional right to withdraw. Without such a report the photo is not saved. You can withdraw the report and the photo at any time by writing to the contact address — we then delete them without delay.
If we ever propose keeping photos in order to train a model of our own, it will be a separate switch with a clear description, off by default, which can be turned off at any time. We will never hide such a consent in the terms of service.
Automated decisions and profiling
Reading points from a photo is automated processing, but it is not a decision within the meaning of art. 22 GDPR: you can correct its result by hand and it is you who decides what gets saved. It produces no legal effects concerning you and does not similarly significantly affect your situation.
We do not profile you — we do not build a profile of your behaviour, interests or trustworthiness, and we do not set prices or feature availability on that basis.
An exception to the “you can correct everything” rule are the automatic rate limits and abuse detection — these may temporarily block your ability to scan. If that happens, write to the contact address; a human being will look at it.
Who we entrust data to
| Entity | What it does | What data it sees |
|---|---|---|
| OVHcloud | hosting of the server and the database | all account and game data (stored in Poland) |
| Google Ireland / Google LLC (Gemini API) | recognising the tiles in a photo | only the cropped photo that was sent, with no link to your account |
| RevenueCat, Inc. | handling subscriptions and verifying purchases | your account identifier in our system and the subscription status |
| [to be completed: outgoing e-mail provider] | sending the messages that confirm an address and reset a password | your e-mail address and the content of those messages |
All the entities listed above act solely on our instructions, under a data processing agreement (art. 28 GDPR), and may not use your data for their own purposes.
Entities that are separate controllers
These companies do not act on our behalf — they decide themselves on the purposes and means of processing, under their own privacy policies, which we have no influence over. We are not joint controllers with them; each is separately responsible for its own processing.
| Entity | In what role | What it processes on its side |
|---|---|---|
| Google Ireland Ltd. / Google Commerce Ltd. — Google Play | seller of the paid features and distributor of the app; it is Google, not us, that calculates and remits VAT in the European Union | the data of your transaction and your Google account — we do not see card details |
| Google Ireland Ltd. / Google LLC — logging in with a Google account | identity provider, if you choose that way of logging in | the fact that you logged in to Meldly and the link with your Google account |
Apart from this, we may disclose your data only to authorities entitled to it under the law — and only to the extent to which they oblige us to do so.
Transfers outside the EEA
Your account and game data is stored in Poland and does not leave the European Economic Area.
The exception is the Google and RevenueCat services, whose infrastructure covers the United States. These transfers are based on the standard contractual clauses approved by the European Commission and — to the extent that a given entity has joined it — on the adequacy decision (Data Privacy Framework).
You have the right to receive a copy of these safeguards. Write to the contact address and we will send you the text of the clauses used.
Your rights
In relation to your data you have the right to:
- access and a copy — in the app you can download a package with all your data; if you prefer, write to us;
- rectification — you can change your player name, language and avatar yourself in the settings;
- erasure — see the section below;
- restriction of processing;
- data portability — the package mentioned above is in JSON and CSV formats, suitable for loading elsewhere;
- withdraw consent at any time, if we ever ask you for any — withdrawal does not affect the lawfulness of what happened beforehand;
- lodge a complaint with a supervisory authority — art. 77 GDPR lets you lodge it with the authority in the country of your habitual residence, your place of work or the place of the alleged infringement. Our authority is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warszawa — if you live in another EU country, you may just as well turn to the authority where you are.
Right to object
At any time you have the right to object to the processing of your data based on our legitimate interest — that is, to the processing of your year of birth, scan metadata, security data and technical logs.
You raise an objection by writing to contact@meldlyapp.com. Once we receive it we will stop processing that data, unless we demonstrate compelling legitimate grounds which override your interests — and if we conclude that, we will explain to you why.
Deleting the account
You delete the account in the app settings, through the form on this site (without installing the app) or by writing to the contact address. Once you have asked for it:
- the account stops working immediately and cannot be logged in to;
- within 30 days we anonymise the data — the e-mail address, player name and avatar disappear, and game results stop being linked to you;
- we keep accounting documents concerning purchases for 5 years from the end of the tax year, because the ustawa o rachunkowości (Polish accounting law) requires it — also in a form stripped of identifying data.
The thirty-day window is a safeguard against a mistake and against the account being deleted by someone who has taken over access. During that time the deletion can be reversed by writing to the contact address.
Age of users
Meldly is intended for people who are at least 13 years old. When creating an account we ask for the year of birth — the year alone, without the day and month, because that is enough to check the age and it is less data.
The basis for processing the data of a person using Meldly is performance of the contract, not consent, so art. 8 GDPR — which concerns only processing based on consent — does not apply here. If in the future we introduced processing based on consent — analytics, for example — the age threshold that applies is the one in force in the country of your habitual residence. The GDPR sets it at 16, but allows Member States to lower it to no less than 13; some of them have done so, and the Polish legislator has not — in Poland the threshold is 16.
Purchases are a separate matter: a person under 18 may make them only with the consent of their legal representative. We write about this in the terms of service.
If we learn that an account was created by a child under 13, we will delete it. If you are a parent and believe this has happened, write to the contact address.
This website
The meldlyapp.com site is entirely static. It uses no cookies, stores nothing in the browser, and uses no analytics, social plugins or external fonts. We ask for no data here and we build no profiles of visitors.
The hosting server writes standard access logs (IP address, date, page address) — this is necessary to maintain and secure the server, and the basis is our legitimate interest.
Security
- The connection between the app and the server is always encrypted (HTTPS).
- We store passwords only as cryptographic hashes — we do not know your password and cannot reconstruct it.
- We also keep one-time codes and refresh tokens as hashes, not as values.
- In the app we do not save the IP address in plain form — we store only a hash of it, which lets us tell that two logins came from the same place but does not let us establish what that place is. The exception is the technical web server logs of this website (see This website), where the address is written in the standard form.
- Technical logs are written only when something goes wrong.
- The number of login and registration attempts is limited, to make password guessing harder.
- We store data on a server in Poland, with access limited to the controller.
Should a personal data breach nevertheless occur, we will report it to the supervisory authority within 72 hours, and we will notify you without undue delay if the breach may result in a high risk to your rights.
Changes to this policy
We will give notice of significant changes in the app before they take effect. The date and version number at the top of the page always indicate the wording in force. We make previous versions available on request.