← Back to the game

Privacy Policy

Document covering the site and the game FiBunnyCci, at fibunnycci.app
Version 2.3 · change history
Versione italiana

Courtesy translation. The legally binding version of this document is the Italian one. In case of any discrepancy between the two texts, the Italian version prevails.

  • FiBunnyCci uses no cookies, has no analytics, no advertising and does not profile you.
  • No sign-up. You are never asked for a name, email, age or anything else.
  • Saving happens only with the user's consent. Saves stay on the device, in the browser's memory, and are not transmitted to the controller.
  • Your IP address reaches GitHub, which hosts the site, simply because the pages are downloaded. This happens with any website.
  • If you open online PvP, your IP also reaches the Photon servers, which put the two players in touch. If you never open it, that connection is never opened either.

1. Who processes the data

Silviu Robert Plesoiu
Email: fibunnycci@gmail.com

2. What data, and why

The game does not ask for a name, email, age, location, camera, microphone, contacts or payment details. It is free and contains no purchases. There are three cases in which data is processed.

2.1 Hosting (GitHub Pages)

The site is published through GitHub Pages, a service of GitHub, Inc. When your browser requests a page, GitHub records in its own logs the IP address, the time of the request and browser data, for security purposes. Those logs are not accessible to the controller: there is no analytics dashboard and they cannot be linked back to you.

Legal basis: legitimate interest in providing and protecting the service (art. 6.1.f GDPR).

2.2 Online PvP (Photon)

This is an optional mode: it starts by pressing PvP online in the menu, and until that moment no connection is opened. Before opening it the game tells you what it involves and asks your permission: without that it connects to nothing. When you do open it, the browser connects to the servers of Photon, a service of Exit Games GmbH (Hamburg, Germany), which puts the two players in touch and relays the match messages. Photon receives the IP address, the technical data of the connection and the game messages: the move for the turn, the team fielded, the outcome and, at the end of the match, which of the three reactions you pressed.

Nothing that passes through identifies you: no name, no email, no device identifier chosen by us. A player is a number valid for the duration of that match. We have no server of our own: we receive no copy of the matches and keep no leaderboards. The servers used are those of Photon's European region.

In a private match the Share the code button opens your phone's share sheet with the four letters in it. Where you send it is your choice, and the game does not know: no request is made to us.

Legal basis: performance of a service you requested (art. 6.1.b GDPR): the mode exists precisely to play with someone else.

2.3 Saving on your device

On your first new game the game asks whether it may save. If you say no it writes nothing, not even the refusal, and the question comes back on the next new game. You can also turn saving off later, from the Options: from that moment the game stops writing and what was already there stays where it is.

With your yes the game writes to the browser's local storage (localStorage), tied to the fibunnycci.app domain alone: the game in progress (fibunnycci_save), the chapters completed (fibunnycci_story), the graphics quality chosen in the options (fibunnycci_grafica), the language chosen in the options (fibunnycci_lingua), your answer to this question (fibunnycci_consenso), the yes to the online connection (fibunnycci_pvp) and two entries used only by the development tools. They are never sent to a server and contain nothing that identifies you: no user code, no persistent number.

How to delete them: browser settings → privacy → clear browsing data, including «cookies and site data». You lose your saves and start over; the game remains usable.

Legal basis: saving is strictly necessary for the service you yourself request (art. 122 of Italian Legislative Decree 196/2003), so consent would not be mandatory. The game asks anyway, and without a yes it does not write.

3. Cookies

This site installs no cookies, neither first nor third party. No analytics, advertising pixels, social buttons, fonts or libraries loaded from external servers: the Nunito typeface, three.js and the Photon library are all hosted on our own domain.

That is why there is no banner. The consent required by art. 122 of Italian Legislative Decree 196/2003 concerns what is stored on the device beyond what is strictly necessary, and here the only thing stored is the game save, which is the function you ask the game for. With no cookies and no measurement tools, there is nothing to collect consent about. Reference: the Italian Data Protection Authority's cookie guidelines, decision no. 231 of 10 June 2021.

If analytics or advertising ever arrived, they would be blocked until consent and this page would be updated first.

4. Who receives the data, and for how long

No data is transferred or sold, and there is no marketing. Two technical providers are involved: GitHub, Inc. (privacy statement) for hosting, and Exit Games GmbH (privacy statement) only during online PvP.

GitHub is a US company with global infrastructure, so the processing of the logs may involve a transfer outside the European Economic Area; GitHub states that it relies on the Standard Contractual Clauses and/or the EU-U.S. Data Privacy Framework. The controller does not independently transfer any data outside the EEA.

Retention: saves stay on your device until you delete them, and they cannot be touched remotely because we do not have them. Log retention periods are decided by GitHub. An email you send us is kept for as long as it takes to reply.

5. Your rights

Articles 15-22 GDPR give you access, rectification, erasure, restriction, objection and portability. One thing has to be said, though: since no data identifying you is collected, there is no archive in which to look you up, and art. 11 GDPR covers exactly this case. In practice you delete the saves yourself from the browser, for the logs the reference is GitHub, and if you have written us an email, on that data you can exercise every right.

Write to fibunnycci@gmail.com: we reply within one month, extendable by two in complex cases (art. 12.3 GDPR). You may also lodge a complaint with the Italian Data Protection Authority (Piazza Venezia 11, 00187 Rome, garanteprivacy.it) or go to court.

There is no profiling and no automated decision-making concerning you (art. 22 GDPR).

6. Minors

The Terms of Use require that minors play with the consent of whoever holds parental responsibility. The game does not ask for your age and has no way of verifying it, there being no registration.

The game collects no identifying data, contains no advertising, purchases or virtual currency and does not allow content to be uploaded. In online PvP players cannot write to each other: what passes through are the moves and three fixed reactions at the end of the match.

7. Security

The site is served over HTTPS only, with a Content Security Policy that forbids the browser from loading resources from external domains: the only thing that passes is the online PvP connection to Photon, listed one port at a time. There are no keys or credentials in the published code. The most effective measure, however, remains the first one: what is not collected cannot be lost.

8. Changes

This policy may change, especially if new features arrive. Every substantial change is published here before the feature goes live, with the version number at the top updated. The history is in the change log.