Privacy Policy

Status: April 2026

This Privacy Policy informs you about the processing of personal data on the website empathysolutions.de and all associated subdomains (e.g., quiz.empathysolutions.de, game.empathysolutions.de, editor.empathysolutions.de, api.empathysolutions.de).

1. Controller

Name:
Witalij Semenenko

Address:
c/o Impressumservice Dein-Impressum
Stettiner Str. 41
35410 Hungen
Germany

Contact:
E-Mail: info@empathysolutions.de

2. Hosting and Server Location (USA)

Our website is hosted on servers of netcup GmbH, Daimlerstraße 25, 76185 Karlsruhe, Germany. The hosting plan we use is located in the data center in Manassas, Virginia, USA.

This may result in the transfer of personal data to the USA. This applies in particular to:

• IP addresses (truncated or full, depending on technical necessity)
• Technical connection data
• Server log files
• Data transmitted automatically when calling up the website

The transfer takes place on the basis of:

• the EU-US Data Privacy Framework (DPF), as far as applicable,
• the Standard Contractual Clauses (SCC) pursuant to Art. 46 GDPR,
• additional technical and organizational measures (SSL encryption, access restrictions).

Netcup remains our contract partner based in Germany. We have concluded a Data Processing Agreement (DPA) with Netcup pursuant to Art. 28 GDPR.

3. Access Data / Server Log Files

When you visit our websites, the following data is processed automatically:

• IP address
• Date and time of access
• Browser type and version
• Operating system
• Referrer URL
• Visited pages
• Technical error codes

This data is technically required to provide the website. The legal basis is Art. 6 Abs. 1 lit. f GDPR (legitimate interest in secure operation). The data is deleted after 14 days at the latest.

4. Registration and User Accounts

Registration is required for certain functions (e.g., quiz creation, games, premium functions). In doing so, we process:

• E-Mail address
• Username
• Password hash
• Registration and login timestamps
• Account settings
• Quiz data, scores, leaderboards
• Premium status and credits

The legal basis is Art. 6 Abs. 1 lit. b GDPR (performance of a contract).

5. Premium Features, Upgrades and Credits

Users can purchase credits to unlock premium features. In doing so, we process:

• Contract data (purchased credits, upgrades, runtimes)
• Transaction metadata (e.g., "payment successful")

We do not store full payment details. Payment providers (e.g., Stripe, PayPal, credit card) process payment data independently. The legal basis is Art. 6 Abs. 1 lit. b GDPR.

6. Cookies and Local Storage

We use exclusively:

• Technically necessary cookies
• Local Storage
• Session Storage

These serve to maintain logins, activate premium functions, and save user preferences. No tracking cookies are set. The legal basis is Art. 6 Abs. 1 lit. f GDPR (legitimate interest in a functional website).

7. Analytics and Error-Tracking Tools

We currently do not use any analytics tools (e.g., web analytics) or error/performance monitoring services. Should this change in the future, this privacy policy will be updated in advance and the consent banner described in Section 8 will be extended with the corresponding category before any such tool is loaded.

8. Cookie/Storage Consent Banner

On first visit, a consent banner appears with the categories Technically necessary (always active), Statistics and Marketing (both disabled by default, as nothing currently relies on them). The "Accept all" and "Necessary only" buttons are styled equally; "Settings" allows a granular choice.

The choice made is stored locally in the browser (Local Storage, key cookie_consent) and can be revoked or changed at any time via a permanently visible 🍪 icon.

9. Contacting Us

When contacting us by email, we process:

• E-Mail address
• Content of the message
• Metadata (e.g., time, sender)

The legal basis is Art. 6 Abs. 1 lit. b GDPR (performance of a contract) or Art. 6 Abs. 1 lit. f GDPR (legitimate interest in processing requests).

10. Sharing of Data

Personal data is shared only with:

• Hosting service provider (netcup GmbH)
• Payment providers (e.g., Stripe, PayPal)

We do not share data for commercial or advertising purposes.

11. Data Retention

We store personal data only as long as necessary to provide our services, perform the contract, or comply with statutory retention obligations.

12. Data Subject Rights

Users have the right at any time to:

• Access (Art. 15 GDPR)
• Rectification (Art. 16 GDPR)
• Erasure (Art. 17 GDPR)
• Restriction of processing (Art. 18 GDPR)
• Data portability (Art. 20 GDPR)
• Object to processing (Art. 21 GDPR)

For this purpose, you can contact us at: witalij.sem@gmail.com

13. Withdrawal of Consent

To the extent that processing is based on consent, you may withdraw it at any time with effect for the future.

14. Security

We use appropriate technical and organizational measures to protect personal data, including:

• SSL encryption
• Access restrictions
• Password hashing
• Regular updates
• Server monitoring

15. Scope of Application for Subdomains

This Privacy Policy applies to:

• empathysolutions.de
• All subdomains
• All associated web applications

16. Changes to this Privacy Policy

We reserve the right to adapt this Privacy Policy to meet changing technical or legal requirements.