Privacy policy, DOTOG app (BlueBuddys)
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:
- Users aged 16 and over create their own account and are an “Admin” or “Member” of a group (see section 5).
- Children (under 16) receive a special child invitation code from an admin. The child uses this code to create their own account in the family group. Special safeguards under Art. 8 DSGVO apply, including consent from a legal guardian; see section 6 for details and the process.
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:
- Date and time of the request
- HTTP status code
- Amount of data sent in bytes
- Operating system used (iOS / Android) + version
- App version
- IP address
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.
| Provider | Purpose | Region | Basis for transfer to third countries |
|---|---|---|---|
| Google Ireland Ltd., Firebase Authentication | Login + email verification (adults) + Apple Sign-In integration | EU, failover USA | DPF + SCC 2021/914 |
| Google Ireland Ltd., Firebase Firestore | Storage of profiles, tasks, appointments, rewards, memberships, audit logs | eur3 (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 + USA | DPF + SCC |
| Google Ireland Ltd., Firebase Crashlytics | Pseudonymised crash reports (no real name; device- and installation-related identifier and a shortened hash value of the account and group identifiers) | EU + USA | DPF + SCC |
| Google Ireland Ltd., Firebase App Check | Security check (Apple App Attest + Play Integrity) | EU + USA | DPF + SCC |
| Google Ireland Ltd., Google Analytics for Firebase | Versions 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 consent | EU + USA | DPF + SCC |
| Google Ireland Ltd., Vertex AI Gemini 2.5 Flash | AI 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-Purchase | iOS payment processing (subscription + VIP avatar) | EU + USA | Apple standard contract + DPF |
| Google Ireland Ltd., Google Play Billing | Android payment processing (subscription + VIP avatar) | EU + USA | DPF + SCC |
| RevenueCat Inc. | Subscription and one-time purchase management | USA | DPA + SCC 2021/914 Module C2P |
| Google Ireland Ltd., Firebase Cloud Storage | Data export JSON hosting (signed download URL, valid for max. 7 days) | EU | DPF + 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:
| Information | Required? | Purpose |
|---|---|---|
| Email address | Required | Login + account identification |
| Password of your choice (stored only as a hash) | Required | Authentication |
| Date of birth | Required | Age 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 / nickname | Required | Display in the family group |
| Avatar selection | Required | Personalisation |
| Streak counter + date of last completion | Internal system data | Motivational display (Art. 6 Abs. 1 lit. f) |
| Cross-group points account | Internal system data | Lifetime 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:
- Directly in the app under Management > Delete account.
- Through the website at dotog.app/kontoloeschung.html (self-service form with email confirmation).
- By sending a message to mail@dotog.app.
We follow a 14+16-day hybrid deletion process (DSGVO Art. 17 + requirement of the Apple App Store / Google Play Store):
- Day 1 (immediately): Your account is disabled (Auth.disabled) and hidden in all groups (soft delete via the deletedAt field). Group points, stars, streak and memberships are immediately removed from live aggregates.
- Days 2-14 (reconsideration period): You can cancel deletion at any time. Process: enter your email address on the DOTOG app's login screen. As the account is disabled, a Restore account button appears. When you click it, we send you an email with a one-time recovery link (valid for 15 minutes, single-use, 256-bit random token). You click the link, confirm recovery at dotog.app/cancel.html, and the account is reactivated immediately (authentication account unlocked, scheduled deletion discarded). Important: Membership, stars and streak are not restored; you must rejoin the group using an invitation code (provider's “Fresh start” decision; Art. 17 DSGVO requires deletion, not an entitlement to restoration).
- Day 15: Permanent deletion from the live database (authentication account, profile data, tasks, appointments, memberships, subscription link) via Cloud Scheduler at 03:00 Berlin time.
- Days 15-30: Technical backup (rotating Firebase/Hostinger snapshots, max. 30 days). Afterwards, the data is irretrievably deleted.
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:
- An admin has created a family group. Children only belong to the groups of the admin who invited them using the child code.
- 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.
- The admin passes the code to the child (verbally or through the family's messenger).
- The child installs the app and enters the code. The child chooses a nickname and an avatar.
- 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:
- The admin has created their own account with email verification and password protection.
- Generating a child code is a deliberate action in a logged-in account for users aged 16 and over.
- Before generating the code, the admin must actively tick this checkbox.
- The admin can deactivate the code and terminate the child account at any time.
- Audit trail: The confirmation is stored in an audit-proof manner together with the exact wording, version and a timestamp (retention for 10 years as evidence pursuant to Art. 7 Abs. 1 DSGVO).
6.3 What data about the child do we process?
| Information | Required? | Purpose |
|---|---|---|
| Nickname (freely chosen) | Required | Display in the family group |
| Avatar selection | Required | Personalisation |
| Family group membership | Internal system data | Group authorisation |
| Tasks + completion status | Internal system data | Core functionality |
| Points totals + streak counter | Internal system data | Motivation mechanics |
| Redeemed rewards | Internal system data | Reward 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 child's avatar
- The number of AI chat requests per day (anonymised statistics)
The admin does not see:
- The wording of the child's AI chat inputs (child's privacy, section 10).
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:
- View the child account and its activities at any time (except AI chat history, see 6.4)
- Delete the child account, either yourself from within the child account using the in-app Delete account button (see section 5: 14-day reconsideration period + 16-day backup retention = 30 days in total) OR by an informal request to mail@dotog.app (Frank Reuter / Minntera will manually delete the account within the same 14+16-day period and confirm deletion in writing)
- Deactivate the child code so that no new child can join
- Request access (Art. 15 DSGVO) and a data export (Art. 20 DSGVO) for the child account
- Rectification (Art. 16 DSGVO) of the child's data
- Restriction (Art. 18 DSGVO) of processing
- Object (Art. 21 DSGVO) to processing based on legitimate interests
- Withdraw consent to the processing of the child's data at any time, resulting in account deletion
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):
- Free: 1 group, up to 4 members, a maximum of 2 open tasks and 2 open appointments per group at the same time, limited Buddy questions
- Plus (“Familie”): up to 2 groups, up to 5 members, unlimited tasks and appointments
- Pro (“WG”): up to 5 groups, up to 10 members, unlimited tasks and appointments
- Ultra (“Projekt”): up to 10 groups, up to 100 members, unlimited tasks and appointments
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:
- iOS: Apple In-App-Purchase
- Android: Google Play Billing
We receive no credit card details or bank account details. We only receive:
- Unique transaction ID
- Subscription status (active / expired / cancelled)
- 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:
- Price: 3,99 EUR once for the VIP package (Non-Consumable IAP)
- Payment processing: Apple IAP / Google Play Billing, managed via RevenueCat
- Data categories identical to section 7
- Retention: transaction ID restricted from further use for as long as required by law, currently 8 years (Art. 6 Abs. 1 lit. c DSGVO)
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:
- Tasks (with points rewards, optionally recurring)
- Appointments (dated events for the group, e.g. birthdays or medical appointments, just for you or shared)
- Rewards (what players can “buy” with points, e.g. “stay up 1 hour longer”)
- Family statistics (automatically generated from points totals)
- Sprint challenges (time-limited competitions within the group)
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:
- Daily limit: 5 requests per day for children (a maximum of 10 if the group has an active subscription); 5 per day for adults in the free tier or 25 per day with a subscription
- Before first use, the child must acknowledge a safety notice
- The admin can disable AI chat completely for the child at any time (Management > Consents)
- The admin does not see the wording of the child's AI chat inputs (child's privacy)
- During normal operation, we only store a pseudonymised SHA-256 hash of the question (see 10.6), not its wording. The only exception is when someone reports an answer as inappropriate (see 10.6a). In that case, we store the reported question and answer so that we can review them. The admin still cannot see the wording of the child's inputs.
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.
- NOT classified as a prohibited AI system (Art. 5).
- NOT classified as a high-risk system (Anhang III) (BuddyChat is not an educational assessment system, but a helper for questions about household matters and everyday life).
- Classified as “Limited Risk”; the transparency obligation under Art. 50 is fulfilled.
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:
- Invitation link (shared by you via WhatsApp, email or a messenger of your choice; the app does not initiate this itself)
- Invitation code for adults
- Child invitation code (only for children under 16, see section 6.1)
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:
- Tasks & appointments: reminders of tasks open today and appointments you have created yourself (e.g. “1 hour before”)
- Challenges: new sprint challenge and win notification
- Streak: notification when your streak continues
- Rewards: reward requests and approvals
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.
- Right of access (Art. 15 DSGVO): information about the data processed, purposes of processing, recipients and storage period.
- Right to rectification (Art. 16 DSGVO): correction of inaccurate data.
- Right to erasure (Art. 17 DSGVO): deletion of your data. In the app: Management > Delete account. On the web: dotog.app/kontoloeschung.html.
- Right to restriction of processing (Art. 18 DSGVO).
- Right to data portability (Art. 20 DSGVO): data export in a machine-readable format. In the app: Management > Download data; we send JSON by email.
- Right to withdraw consent given (Art. 7 Abs. 3 DSGVO): at any time with effect for the future. Withdrawing consent is always as easy as giving it; we inform you of this before you give consent.
- Right to lodge a complaint (Art. 77 DSGVO): you have the right to lodge a complaint with any supervisory authority, in particular the authority at your habitual residence or place of work. The authority responsible for us is the Saxon Data Protection and Transparency Commissioner, Devrientstraße 5, 01067 Dresden, www.datenschutz.sachsen.de.
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 category | Storage period | Deletion |
|---|---|---|
| Adult account data (email, password hash, UID) | While the account is active | 14 days disabled + 16 days backup = 30 days in total |
| Child account data (nickname, UID, avatar) | While the account is active | 14 days disabled + 16 days backup = 30 days in total, initiated by the admin |
| Profile data (avatar, name) | While the account is active | 14 days disabled + 16 days backup = 30 days in total |
| Task and appointment content, including completion status, appointment reminders and technically necessary exceptions for recurring events | As 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 content | While the account is active | Anonymised when the account is deleted |
| Streak counter and completion date | While the account is active | 14 days disabled + 16 days backup = 30 days in total |
| Cross-group points | While the account is active | 14 days disabled + 16 days backup = 30 days in total |
| AI chat audit logs (SHA-256 hash) | 30 days | Automatic (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 deletion | Automatic daily deletion run (reviewed reports immediately, open reports after 90 days); also automatically when the account is deleted |
| AI chat safety notice acknowledgement | While the account is active | 14 days disabled + 16 days backup = 30 days in total |
| Audit logs (permission changes, deletion actions) | 30 days | Automatic (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 production | n/a in V1, 10 years if activated in the US |
| Crash reports (Crashlytics) | 90 days | Automatic |
| Push token (FCM) | While push notifications are enabled | Immediately on opt-out |
| Subscription transaction IDs | As 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 receipts | As long as required by law, currently 8 years | Automatically after the period expires |
| Connection and server log data (including IP), processed by Google/Firebase as a processor | Briefly by Google for security; we do not maintain our own IP logs | Automatically 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 abuse | On account deletion or when the programme ends |
| Referral reward (Plus expiry date, “reward granted” flag) | While the account is active | 14 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:
- We notify the competent supervisory authority (Saxon Data Protection and Transparency Commissioner) within 72 hours of becoming aware, pursuant to Art. 33 DSGVO.
- If the risk is likely to be high, we inform you without undue delay by email about the incident, the nature and scope of the data affected and recommended protective measures, pursuant to Art. 34 DSGVO.
- If a data breach involves children's data, we also actively inform the responsible legal guardians (admin accounts), regardless of whether the formal threshold of Art. 34 DSGVO would be exceeded.
17) Technical and organisational measures (TOMs under Art. 32 DSGVO)
We use the following technical and organisational measures to protect your data:
- Encryption: TLS 1.3 for all data transmissions; encryption at rest in Firestore (AES-256, managed by Google).
- Authentication: Firebase Authentication with a hashed password (Firebase's own modified scrypt process); Apple Sign-In as an alternative authentication method; re-authentication for sensitive actions (account deletion, child code generation).
- App integrity: Firebase App Check (Apple App Attest + Google Play Integrity) to prevent bot access and manipulated app versions.
- Permission management: Firebase Security Rules with fine-grained, custom-claims-based access checks for each group and role.
- Data minimisation: hash-only logging for routine AI auditing (SHA-256 instead of plain text); reported answers are stored separately for a limited period for moderation (see 10.6a); no IP logs of our own, as the connection IP is processed briefly for security only by Google as a processor and is not analysed by us.
- Automatic storage limitation: TTL-based Cron Cloud Functions delete audit logs after 30 days; crash reports after 90 days.
- Audit trail: critical actions (account deletion, legal guardian consent, permission changes) are recorded in an immutable audit log.
- Backup and recovery: Firestore Point-in-Time Recovery and daily rotating snapshots (Firebase + Hostinger), retained for max. 30 days. After day 30, deleted data is irretrievably removed (consistent with section 5, hybrid deletion process 14+16=30 days).
- Processing on our behalf: AVVs under Art. 28 DSGVO with all subprocessors; third-country transfers based primarily on SCC 2021/914 (DPF as a secondary basis where listed, see section 3).
- Controller access management: solo entrepreneur setup; admin access to Firebase only through a personal account with mandatory 2FA.
- Regular review (Art. 32 Abs. 1 lit. d DSGVO): quarterly review of Firestore Security Rules and TLS configuration; annual self-assessment of the TOMs and the subprocessor list; documentation of reviews in the internal audit log.
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.