Privacy policy, DOTOG app (BlueBuddys)

Last updated: 2026-11-02

Other legal documents: Legal notice · Terms and conditions · Cancellation policy for digital content · Account deletion

1) Information about the collection of personal data and contact details of the controller

1.1 We are pleased that you use our app DOTOG (brand name “BlueBuddys”). Below, we explain how we handle your personal data when you use our app.

1.2 The controller responsible for data processing within the meaning of the General Data Protection Regulation (DSGVO) is:

Frank Reuter, trading as “Minntera”
Döhlener Hang 3
01705 Freital
Deutschland
Tel.: +49 173 1843424
Email: mail@dotog.app
VAT identification number: DE242649636

“DOTOG” and “BlueBuddys” are product brands of Minntera / Frank Reuter.

Note on the data protection officer: We have not appointed a data protection officer. Please send data protection questions to the address in the legal notice.

1.3 The app uses SSL or TLS encryption. All connections to the Firebase cloud (login, data queries, AI chat) take place exclusively over HTTPS.

1.4 Target audience (Mixed Audience): DOTOG is intended for families, shared households and project/class groups. The app is used by adults and children. There is no minimum age; DOTOG is recommended from age 7. We treat the data of minors and adults differently:

Privacy by Design (Art. 25 DSGVO): We follow the principles of data minimisation and privacy by default. Profiles are private (only group members can see them). There is no advertising tracking. We compile usage statistics only with your consent and never for child accounts or anonymous accounts (section 3); we report crashes pseudonymously via Firebase Crashlytics. Promotional push notifications require opt-in (for adults) and are always disabled for children. Functional notifications (e.g. task and appointment reminders) are enabled by default as part of the app's functionality and can be disabled by category at any time.

Apple App Store: “Made for Kids: No”. Google Play: Mixed Audience. DOTOG is listed under Lifestyle in both app stores.

2) Log files when using our mobile app

When you download the app from an app store, information is transmitted to the app store (username, email, account customer number, download time, payment information, device identifier). We have no influence over this data collection.

When you use the app, technically necessary connection data is generated and processed by our processor Google (Firebase) for provision, stability and security:

Google processes this connection data as a processor (Art. 28 DSGVO, see section 3) and stores the IP address only briefly for security and abuse prevention. We do not store these IP addresses in our own logs, analyse them or create location or movement profiles.

Legal basis: Art. 6 Abs. 1 lit. f DSGVO (legitimate interest in stability + functionality).

We do not collect IMEI, IMSI, MSISDN, MAC addresses or advertising identifiers (IDFA / AAID). Where Firebase App Check, Firebase Authentication or Firebase Crashlytics process installation tokens that cannot be linked to an individual, this is exclusively for security, stability and abuse prevention (Art. 6 Abs. 1 lit. f DSGVO).

No automated decision-making with legal effects within the meaning of Art. 22 DSGVO takes place as part of server log processing.

3) Service providers and recipients used

Data processing agreements (AVV) have been concluded with providers acting as processors (Art. 28 DSGVO). Apple and Google are independent controllers for payment processing (in-app purchases and subscriptions), rather than processors; they only transmit transaction and subscription status data to us (legal basis Art. 6 Abs. 1 lit. b DSGVO). We base transfers to third countries (USA) primarily on the EU Standard Contractual Clauses (SCC 2021/914, Module C2P) pursuant to Art. 46 Abs. 2 lit. c DSGVO. Where a provider is also listed under the active EU-US Data Privacy Framework (European Commission adequacy decision 2023/1795), we cite the DPF as an additional, secondary basis. Background: the General Court of the European Union dismissed the action for annulment of the DPF adequacy decision (judgment of 03.09.2025, Latombe, T-553/23); the adequacy decision therefore remains in force. Nevertheless, we treat SCC as a robust primary basis that remains effective even if the DPF ceases to apply in future. The “Basis for transfer to third countries” column shows the applicable basis for each provider. We can provide you with a copy of the EU Standard Contractual Clauses on request at mail@dotog.app.

Transfer Impact Assessment (TIA): We have conducted a Transfer Impact Assessment for all US transfers in accordance with EDPB Recommendations 01/2020. Additional safeguards to reduce risk: encryption at rest and in transit (TLS 1.3), hash-only logging during routine operation of the AI chat (no transfer of inputs in plain text to third countries; reported content is stored in plain text for moderation only in the EU (eur3 database), see section 10.6a), access logs, data minimisation (no real names/addresses in third-country data flows except where strictly necessary for the purpose, Apple/Google platform payments). TIA documentation is held internally and can be made available to supervisory authorities on request.

ProviderPurposeRegionBasis for transfer to third countries
Google Ireland Ltd., Firebase AuthenticationLogin + email verification (adults) + Apple Sign-In integrationEU, failover USADPF + SCC 2021/914
Google Ireland Ltd., Firebase FirestoreStorage of profiles, tasks, appointments, rewards, memberships, audit logseur3 (EU multi-region Belgium and Netherlands)DPF + SCC
Google Ireland Ltd., Firebase Cloud Functions (user data)Backend logic (login, account deletion, data export, subscription verification)europe-west3 (Frankfurt)DPF + SCC
Google Ireland Ltd., Firebase Cloud Functions (Health)Status health checks for operator monitoring (no user PII)europe-west1 (Belgium)DPF + SCC
Google Ireland Ltd., Firebase Cloud Messaging (FCM)Push notifications (promotional push only to admins, never to children)EU + USADPF + SCC
Google Ireland Ltd., Firebase CrashlyticsPseudonymised crash reports (no real name; device- and installation-related identifier and a shortened hash value of the account and group identifiers)EU + USADPF + SCC
Google Ireland Ltd., Firebase App CheckSecurity check (Apple App Attest + Play Integrity)EU + USADPF + SCC
Google Ireland Ltd., Google Analytics for FirebaseVersions 1.0.90 to 1.0.109: technical diagnostic events and screen views, not analysed; disabled from 1.0.110; future usage statistics only with consentEU + USADPF + SCC
Google Ireland Ltd., Vertex AI Gemini 2.5 FlashAI assistant “BuddyChat” (see section 10)europe-west4 (Netherlands)Processing in the EU region europe-west4. Any residual connection to the US parent Google LLC is covered by the Google Cloud contract (Data Processing Addendum) and the EU Standard Contractual Clauses 2021/914.
Apple Distribution International Ltd., Apple In-App-PurchaseiOS payment processing (subscription + VIP avatar)EU + USAApple standard contract + DPF
Google Ireland Ltd., Google Play BillingAndroid payment processing (subscription + VIP avatar)EU + USADPF + SCC
RevenueCat Inc.Subscription and one-time purchase managementUSADPA + SCC 2021/914 Module C2P
Google Ireland Ltd., Firebase Cloud StorageData export JSON hosting (signed download URL, valid for max. 7 days)EUDPF + SCC
Hostinger International Ltd.(1) Static hosting of the legal documents at dotog.app (legal notice/privacy/terms and conditions/cancellation policy/account deletion). (2) Email hosting mail@dotog.app + SMTP sending of service emails (account deletion confirmation, data export link).EU (Lithuania, NL)Data processing agreement under Art. 28. Processing in the EU (Lithuania, Netherlands).

Google Analytics for Firebase (usage statistics): The app includes this Google component. In versions 1.0.90 to 1.0.109, it records technical diagnostic events and screen views, without an advertising identifier and without an account identifier, and may transmit them to Google. Google Analytics is not linked to our Firebase project; we do not analyse this data. Collection is disabled from version 1.0.110. In future, we will compile usage statistics, such as which areas of the app are used, only with your express consent (Art. 6 Abs. 1 lit. a DSGVO, § 25 Abs. 1 TDDDG), which you can withdraw at any time in the app under Consents (Art. 7 Abs. 3 DSGVO); never for child accounts or anonymous accounts. Before we introduce this consent request, we will add the scope, recipients and storage period here. We report crashes pseudonymously via Firebase Crashlytics (table above, storage period 90 days).

Sentry and Telegram (operator tools, no user data involved): Sentry GmbH (Berlin / USA) and Telegram FZ-LLC are used exclusively as internal operator tools: Sentry for developer error diagnostics in the internal build pipeline (processes no personal data of app users; crash reporting in the mobile app takes place exclusively via Firebase Crashlytics, see table above), Telegram for system health notifications to the operator personally (Frank Reuter; no transmission of user data). As there is no processing relationship within the meaning of Art. 28 DSGVO regarding user data, we do not list Sentry and Telegram in the subprocessor table. If their use changes (e.g. integration of the Sentry SDK into the mobile app), we will update this section and inform existing users in advance.

Privacy information: Firebase https://firebase.google.com/support/privacy · Apple https://www.apple.com/legal/privacy/de-ww/ · RevenueCat https://www.revenuecat.com/privacy/

4) Contacting us

When you contact us (by email at mail@dotog.app or through the app), personal data is collected and stored solely to respond to your enquiry. Legal basis: Art. 6 Abs. 1 lit. f DSGVO (legitimate interest). For steps towards entering into a contract, Art. 6 Abs. 1 lit. b DSGVO also applies.

5) Data processing when creating an independent account (from age 16)

Under Art. 6 Abs. 1 lit. b DSGVO, we collect the following data during registration:

InformationRequired?Purpose
Email addressRequiredLogin + account identification
Password of your choice (stored only as a hash)RequiredAuthentication
Date of birthRequiredAge check under Art. 8 DSGVO: an independent account is created from age 16, but not under 16 (child route, see section 6). Only the age group is then stored in the user record, not the date of birth.
Display name / nicknameRequiredDisplay in the family group
Avatar selectionRequiredPersonalisation
Streak counter + date of last completionInternal system dataMotivational display (Art. 6 Abs. 1 lit. f)
Cross-group points accountInternal system dataLifetime total of points across all groups (Art. 6 Abs. 1 lit. f)

The information marked as required above is necessary to perform the usage contract. Without it, we cannot create an account and the app cannot be used.

Email confirmation: After registration, a confirmation email is sent (Firebase Authentication standard). The email address is only considered verified once the link has been clicked.

No automated decision-making with legal effects within the meaning of Art. 22 DSGVO takes place when an account is created.

You can delete your customer account at any time:

We follow a 14+16-day hybrid deletion process (DSGVO Art. 17 + requirement of the Apple App Store / Google Play Store):

Retention periods take precedence: we retain invoices and subscription records for as long as required by law, currently 8 years; the legal basis is Art. 6 Abs. 1 lit. c DSGVO (legal obligation). This data is restricted from further use and automatically deleted once the period expires.

Audit log of deletion processes (Art. 5 Abs. 2 accountability): We log account deletions and recoveries in an internal audit_logs collection (fields: action, userUid, emailHash (SHA-256 instead of a plain-text email address), timestamp). Storage period: 30 days, then automatic deletion via Cloud Scheduler. Legal basis: Art. 6 Abs. 1 lit. c DSGVO i. V. m. Art. 5 Abs. 2.

Recovery tokens: The cryptographic one-time tokens generated for account recovery (reconsideration period, days 2-14) are valid for 15 minutes and stored as hashes in a separate cancel_tokens collection (single-use, stored on the server only as a SHA-256 hash; the plain-text token is present only in the email sent to you). After expiry or use, the hashes are completely deleted after 7 days. Rate limit per email address: a maximum of 3 requests every 15 minutes (brute-force protection, Art. 32 DSGVO).

6) Child accounts (under 16) and parental consent under Art. 8 DSGVO

Important for parents and legal guardians: This section explains how children use DOTOG, what data we collect from children and how we obtain your consent as a legal guardian.

Our published child safety standards describe how we protect children and how you can report abuse.

Note on the age threshold under Art. 8 DSGVO: In Germany, Austria and Switzerland, 16 is the threshold for consent. We therefore obtain a legal guardian's consent for all children under 16. From age 16, a person creates their own account; under 16, no independent account is available, only the child route using the child invitation code.

6.1 How does a child join DOTOG?

There is no minimum age; DOTOG is recommended from age 7. A child cannot independently create a DOTOG account. The process is:

  1. An admin has created a family group. Children only belong to the groups of the admin who invited them using the child code.
  2. In their admin account settings, the admin generates a special child invitation code. This is a deliberate action in a logged-in account for users aged 16 and over.
  3. The admin passes the code to the child (verbally or through the family's messenger).
  4. The child installs the app and enters the code. The child chooses a nickname and an avatar.
  5. Only then is the child account created.

6.2 How parental consent works

Before an admin receives a child code, they confirm by ticking a checkbox that they are a parent and consent. The app does not require further proof. Background:

6.3 What data about the child do we process?

InformationRequired?Purpose
Nickname (freely chosen)RequiredDisplay in the family group
Avatar selectionRequiredPersonalisation
Family group membershipInternal system dataGroup authorisation
Tasks + completion statusInternal system dataCore functionality
Points totals + streak counterInternal system dataMotivation mechanics
Redeemed rewardsInternal system dataReward management
AI chat inputs (very restricted)Optional (can be disabled by admin)See section 10

We do not collect the following from children: email address, telephone number, location, contact details, real names, address.

Legal basis for processing children's data: Art. 6 Abs. 1 lit. b DSGVO (performance of the usage contract) or lit. f DSGVO (motivation mechanics and anonymised statistics).

6.4 What can parents (admins) see about their child?

The admin sees the child's open tasks, stars and streak in the ranking, and the rewards the child wants to redeem. The app only displays completed tasks during a sprint. The admin also sees:

The admin does not see:

This separation respects the child's privacy during direct AI communication while maintaining parental supervision of app activities. If the admin believes that a child is using the AI chat inappropriately, they can disable the chat completely for the child (see section 10.4) or terminate the child account.

6.5 Advertising and push notifications to children

Child accounts receive no promotional push notifications. Push notifications to children are limited to purely functional occasions (upcoming task, streak achieved, reward redeemed). Advertising and information about new app features are sent exclusively to admin accounts.

Consent to functional push notifications for a child account is not given by the child, but exclusively by the managing admin (legal guardian), who can withdraw it at any time.

6.6 In-app purchases by children

Children cannot initiate real payments. Subscriptions, VIP avatar purchases and all other monetary transactions are only possible in admin accounts.

6.7 Parental rights

As a legal guardian, you have the right to:

7) Data processing for subscription administration (ongoing subscription)

DOTOG is offered as a digital software subscription. There is a free basic tier and three paid subscription tiers (additionally labelled Familie/WG/Projekt in the app):

Depending on the tier, you can choose monthly or annual billing. The applicable prices are shown to you in the app store or in the app before purchase.

When you subscribe, payment data is processed exclusively by the platform provider:

We receive no credit card details or bank account details. We only receive:

  1. Unique transaction ID
  2. Subscription status (active / expired / cancelled)
  3. Subscription product + renewal date

This data is received through our subprocessor RevenueCat Inc. (USA) on the basis of SCC 2021/914 Module C2P and assigned to your account in Firestore (eur3, EU). Legal basis: Art. 6 Abs. 1 lit. b DSGVO.

Only admin accounts for users aged 16 and over can take out subscriptions. Child accounts have no access to purchases.

You can cancel your subscription at any time in the subscription settings of your Apple or Google account.

8) One-time VIP avatar purchase

You can make a one-time purchase of the VIP package. It costs 3,99 EUR and unlocks all VIP avatars and BonusBuddys, without a subscription. One-time in-app purchase:

Alternatively, you automatically unlock selected VIP avatars when you achieve a daily streak of at least 50 days. This is a game mechanic within the app, without external data transmission.

Only admin accounts can purchase VIP avatars. Child accounts cannot initiate purchases.

9) Content you create in the app

You can create the following in our app:

This content is visible only to members of your group. No public areas, no forums, no external visibility, no links to social media.

When the account is deleted, all content you created is irretrievably removed, with one exception: tasks and rewards that another family member has completed or redeemed remain part of the group statistics in anonymised form (without reference to your profile).

Legal basis: Art. 6 Abs. 1 lit. b DSGVO + Art. 6 Abs. 1 lit. f DSGVO (anonymised statistics).

10) Automated data processing by the AI assistant (“BuddyChat”)

Our app includes an AI assistant (“BuddyChat”) that answers questions about household matters and everyday life.

10.1 Provider: Google Cloud Vertex AI with the Gemini 2.5 Flash language model. Processing takes place exclusively in the EU region europe-west4 (Netherlands). The Cloud Function runs in europe-west3 (Frankfurt). No active data transfer to the USA for AI processing. Any residual connection to the US parent Google LLC is covered by the EU Standard Contractual Clauses (see section 3).

10.2 What data is processed: question entered, role (Admin / Member / Child), subscription status. No real names, email addresses or location data. We do not actively request real names, email addresses or location data. However, as the question is a free-text field, it may contain information that you enter yourself. Please therefore do not include full names, addresses or health information in your question.

10.3 Topic restrictions: BuddyChat answers questions about household matters and everyday life, such as cleaning, cooking or gardening. A narrower range of topics with the strictest filters applies to children. The system does not answer inputs outside this topic whitelist (topic filter in the system prompt + safety settings BLOCK_LOW). Safety-related topics (self-harm, violence, sexual content) are additionally blocked.

10.4 AI chat and children: Children may use BuddyChat with restrictions:

10.5 Legal basis: Art. 6 Abs. 1 lit. b DSGVO (performance of the contract under an active subscription) or Art. 6 Abs. 1 lit. a DSGVO (consent for Free/Trial; for children, consent of a legal guardian under Art. 8 DSGVO).

10.6 Storage period: We store the routine log in pseudonymised form (SHA-256 hash of the request, without plain text) for 30 days, followed by automatic deletion. No model training on your data (Google Cloud standard contract for Vertex AI). For separate storage of reported answers, see 10.6a.

10.6a When you report an answer: You can report any Buddy answer you find inappropriate in the app. This also applies to children. Google Play requires this reporting feature for AI content. As soon as you submit a report, we store the question and answer concerned in plain text on our server (Firestore, eur3 region, EU) so that we can review the case and make Buddy safer. Only the operator (Frank Reuter, Minntera) has access, solely for moderation. Parents, other members and third parties cannot see this content. The legal basis is Art. 6 Abs. 1 lit. f DSGVO: our legitimate interest in the safety and moderation of the AI assistant, meaning the protection of all users, including other children, from inappropriate content. We review the report manually. Once a report has been reviewed, our system automatically removes the reported question and answer during the next daily deletion run. We automatically delete reports that are still open, meaning not yet reviewed, no later than 90 days after the report. In all cases, the content is removed no later than when your account is deleted.

10.7 Your rights: You can disable BuddyChat at any time under Management > Consents. You can send enquiries or requests for corrections to mail@dotog.app at any time.

10.8 Notice under EU AI Act Art. 50 (transparency obligation for AI interaction): You are interacting with artificial intelligence. Answers may contain errors; always check them yourself when making important decisions. Under the EU AI Regulation (VO 2024/1689), this AI is: It is not suitable for making binding or legally relevant recommendations. We meet the additional transparency obligations through this privacy policy and the in-app label “Buddy (AI)” on the chatbot.

11) Fonts and cookies

The app uses only locally bundled fonts. No connection to external font servers. No IP addresses are transmitted to third parties to display fonts.

Cookies: The app does not use cookies. However, it stores data on your device, such as login details, settings, the push token and identifiers for crash reports and for Google Analytics for Firebase (section 3).

12) Invitations, no contact import

DOTOG does not access your address book or contact list. We read no telephone numbers, email addresses or other contact details from your smartphone.

Invitations to a family group are made exclusively through:

13) Push notifications

We send push notifications via Firebase Cloud Messaging (FCM). We distinguish between two types:

a) Functional notifications are part of the app's core functionality and are enabled by default for new users. Legal basis: Art. 6 Abs. 1 lit. b DSGVO (performance of the usage contract) or lit. f DSGVO (legitimate interest in the app functioning); technical access to the device is permitted under § 25 Abs. 2 Nr. 2 TDDDG because it is necessary for the service you have requested. You can disable each category at any time under Management → Notifications or in your device's system settings:

b) Offers / updates (promotional), e.g. information about VIP content or new features. These are disabled by default and are sent only with your express consent (Art. 6 Abs. 1 lit. a DSGVO, § 25 Abs. 1 TDDDG, § 7 UWG). You enable them voluntarily under Management → Notifications. Promotional notifications are never sent to child accounts.

Data processed: For delivery, we store a device-related push token (FCM token, a pseudonymous device identifier assigned by Google/FCM), the device type and the creation time. It is stored in Firebase Firestore (users/<Nutzer-ID>/fcm_tokens, eur3 region, EU). The token is used exclusively for delivery; invalid or deregistered tokens are automatically deleted.

Quiet hours: There are no fixed quiet hours. You silence your phone yourself at night. Time-sensitive appointment reminders you have set yourself are delivered at the time you choose.

Transfer to third countries: Technical delivery via Firebase Cloud Messaging may take place through Google servers in the EU and the USA (safeguarded by the EU-US Data Privacy Framework and Standard Contractual Clauses 2021/914, see section 3).

Withdrawal / objection: You can disable each category again at any time under Management → Notifications or in your device's system settings. This takes effect immediately; future notifications in that category will not be sent. For functional notifications, this is your right to object under Art. 21 DSGVO; for promotional notifications, it is your right to withdraw consent at any time under Art. 7 Abs. 3 DSGVO.

Child accounts (Art. 8 DSGVO): A child account cannot independently give consent to push notifications. This is managed exclusively by the admin with parental responsibility (see section 6.5). Advertising or feature updates are never sent to children, only to admin accounts.

14) Rights of the data subject

Applicable data protection law grants you comprehensive rights as a data subject. You can exercise them through mail@dotog.app or the app's features. We respond to requests within one month of receipt pursuant to Art. 12 Abs. 3 DSGVO. For particularly complex or numerous requests, the period may be extended by two further months; we will inform you within the first month.

Special case: parental rights for child accounts, see section 6.7.

Right to object (Art. 21 DSGVO): you can object at any time to processing based on legitimate interests. You can object to direct advertising at any time without giving further reasons.

15) Duration of personal data storage

Data categoryStorage periodDeletion
Adult account data (email, password hash, UID)While the account is active14 days disabled + 16 days backup = 30 days in total
Child account data (nickname, UID, avatar)While the account is active14 days disabled + 16 days backup = 30 days in total, initiated by the admin
Profile data (avatar, name)While the account is active14 days disabled + 16 days backup = 30 days in total
Task and appointment content, including completion status, appointment reminders and technically necessary exceptions for recurring eventsAs long as necessary to display and organise the group; past one-off tasks and appointments are automatically hard-deleted no later than 366 days after the end of the respective event. Recurring series remain as a rule while active or until deleted.Removal or anonymisation on account deletion as described in section 9; technical backups for a maximum of 30 days.
Reward contentWhile the account is activeAnonymised when the account is deleted
Streak counter and completion dateWhile the account is active14 days disabled + 16 days backup = 30 days in total
Cross-group pointsWhile the account is active14 days disabled + 16 days backup = 30 days in total
AI chat audit logs (SHA-256 hash)30 daysAutomatic (Cron-CF)
Reported AI answers (moderation, question and answer in plain text)Reviewed reports until the review is completed; open reports for a maximum of 90 days from reporting; in all cases no later than account deletionAutomatic daily deletion run (reviewed reports immediately, open reports after 90 days); also automatically when the account is deleted
AI chat safety notice acknowledgementWhile the account is active14 days disabled + 16 days backup = 30 days in total
Audit logs (permission changes, deletion actions)30 daysAutomatic (Cron-CF)
Legal guardian consent audit (Art. 8 ACK)10 years (evidence under Art. 7 Abs. 1 DSGVO)Manually after the period expires
vpcConsents collection (US backup, currently inactive)While in active use; otherwise not in productionn/a in V1, 10 years if activated in the US
Crash reports (Crashlytics)90 daysAutomatic
Push token (FCM)While push notifications are enabledImmediately on opt-out
Subscription transaction IDsAs long as required by law, currently 8 years (Art. 6 Abs. 1 lit. c DSGVO)Automatically after the period expires
One-time VIP avatar purchase receiptsAs long as required by law, currently 8 yearsAutomatically after the period expires
Connection and server log data (including IP), processed by Google/Firebase as a processorBriefly by Google for security; we do not maintain our own IP logsAutomatically according to Google's retention periods
Referral programme: code + referrer↔invitee association + redemption time (section 18)As long as necessary to operate the programme & prevent abuseOn account deletion or when the programme ends
Referral reward (Plus expiry date, “reward granted” flag)While the account is active14 days disabled + 16 days backup = 30 days in total
Referral abuse limit (SHA-256 code counter)15 minutes (rate-limit window)Automatic

Where processing is based on express consent (Art. 6 Abs. 1 lit. a DSGVO), data is stored until you withdraw your consent.

16) Data breach workflow (Art. 33/34 DSGVO)

If a data protection incident occurs that may pose a risk to the rights and freedoms of data subjects:

17) Technical and organisational measures (TOMs under Art. 32 DSGVO)

We use the following technical and organisational measures to protect your data:

18) Referral programme (“Recommend DOTOG”)

Users with a regular account from age 16 (not a child or anonymous account) can invite friends using a personal referral link. If an invited person creates their own regular account through the link and completes initial setup (onboarding), the referrer receives 1 month of DOTOG Plus free as a thank-you.

Data processed: your personal referral code, the account identifiers (user IDs) of the referrer and invitee, the redemption time and status indicators (e.g. “reward already granted”). If the app is installed from the Google Play Store through a referral link, we extract only the referral code from the install referrer provided by Google. There is no further advertising tracking, no device fingerprinting and no sharing with third parties.

Purposes: (1) attributing the referral and correctly granting the reward; (2) preventing abuse (multiple/self-redemptions, automated attempts).

Legal bases: Art. 6 Abs. 1 lit. b DSGVO (performance of the referral feature you actively chose) and Art. 6 Abs. 1 lit. f DSGVO (legitimate interest in reaching more users and preventing abuse).

Children: Child accounts and anonymous accounts are completely excluded from the referral programme; they neither see the invitation prompt nor can they receive or trigger a reward (enforced on the server). No data is processed for them as part of this feature (protection under Art. 8 DSGVO and § 3 Abs. 3 i.V.m. Anhang Nr. 28 UWG).

Recipients / storage location: processing takes place exclusively in our Firebase infrastructure in the EU (eur3 database, functions europe-west3 / Frankfurt). No transfers to third countries take place as part of this feature.

Storage period: we store attribution and reward records for as long as necessary to operate the programme and prevent abuse; technical abuse-limiting counters are automatically deleted after a short period (see overview in section 15).

Participation terms: you can find the full terms at dotog.app/empfehlung-teilnahmebedingungen.html.

Your rights (access, rectification, erasure, restriction, objection, complaint) remain unchanged; see section 14.

Last updated: 2026-11-02, Frank Reuter / Minntera, Döhlener Hang 3, 01705 Freital, mail@dotog.app

Other legal documents: Legal notice · Terms and conditions · Cancellation policy for digital content · Account deletion