Privacy Policy
Contents
1. Who Is Responsible for Your Data 2. What Data We Collect and Why 3. Data We Do NOT Collect 4. Who We Share Your Data With 5. Legitimate Interests Assessment 6. Your Rights 7. Data Security 8. Children's Privacy 9. Cookies and Tracking 10. Account Deletion 11. Changes to This Policy 12. Contact1. Who Is Responsible for Your Data (Controller)
The data controller for ShowUp is:
Bogdan Nichovski
Engerstr. 78
32257 Bünde, Germany
Email: privacy@showup.gg
We do not have a Data Protection Officer (DPO) — we are not required to appoint one at our current scale under Art. 37 GDPR.
2. What Data We Collect and Why
2.1 Account Data
Data: Email address, display name, profile photo (optional), date of birth (age verification)
Purpose: Account creation and authentication
Legal basis: Performance of contract (Art. 6(1)(b) GDPR)
Retention: Until account deletion + 30 days
2.2 Authentication Data
Data: Firebase Auth UID, login timestamps, authentication tokens
Purpose: Secure login and session management
Legal basis: Performance of contract (Art. 6(1)(b) GDPR)
Processor: Google Firebase — Google Cloud DPA
Retention: Until account deletion + 30 days
2.3 Commitment and Activity Data
Data: Groups you join, goals you set, daily check-ins, commitment amounts, settlement history
Purpose: Operating the core ShowUp service — tracking commitments and calculating settlements
Legal basis: Performance of contract (Art. 6(1)(b) GDPR)
Retention: Until account deletion + 30 days (anonymized aggregate statistics may be retained)
2.4 Payment Data (when real-money features are active)
Data: Partial card number (last 4 digits), billing country, Stripe customer ID, transaction history
Purpose: Processing commitment settlements and platform fee collection
Legal basis: Performance of contract (Art. 6(1)(b) GDPR); Legal obligation for financial records (Art. 6(1)(c) GDPR)
Processor: Stripe — Stripe DPA
Retention: Transaction records: 10 years (required by § 147 AO / § 257 HGB). We do not store full card numbers.
2.5 App Usage Data / Analytics
Data: Feature usage, screen views, crash reports, device type, OS version
Purpose: Improving the app and fixing bugs
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR)
Retention: 14 months
2.6 Communications
Data: Emails and messages you send to our support address
Purpose: Responding to your inquiries
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR)
Retention: 3 years
3. Data We Do NOT Collect
- We do not collect precise geolocation data
- We do not access your contacts, camera, or microphone without your explicit permission
- We do not sell your data to third parties
- We do not use your data for automated decision-making or profiling that produces legal effects
4. Who We Share Your Data With
We share data only as necessary to operate the service:
| Recipient | Purpose | Location | Safeguard |
|---|---|---|---|
| Google Firebase | Authentication, database, analytics | USA (EU servers available) | SCCs + DPA |
| Stripe | Payment processing, identity verification | EU (Stripe Payments Europe Ltd.) | DPA + SCCs |
| RevenueCat | Subscription management | USA | DPA + SCCs |
| Apple / Google | App distribution | USA | App Store / Play Store T&Cs |
We do not transfer data outside the EU/EEA without appropriate safeguards (Standard Contractual Clauses or adequacy decision).
5. Legitimate Interests Assessment
App Analytics
Our interest: Understanding how the app is used to improve it and fix issues.
User impact: Low — data is anonymized/aggregated, no sensitive categories processed.
Conclusion: Our interest outweighs the minimal privacy impact. Users can opt out in app settings.
6. Your Rights
Under GDPR, you have the following rights. To exercise them, contact: privacy@showup.gg
- Access (Art. 15): Request a copy of all data we hold about you
- Rectification (Art. 16): Correct inaccurate data
- Erasure (Art. 17): Request deletion — we will delete within 30 days, subject to legal retention obligations
- Restriction (Art. 18): Restrict processing in certain circumstances
- Portability (Art. 20): Receive your data in a machine-readable format
- Objection (Art. 21): Object to processing based on legitimate interests
- Withdraw Consent (Art. 7(3)): Where processing is consent-based, withdraw at any time
Response time: We respond within 30 days. Complex requests may take up to 3 months — we'll inform you if so.
Right to complain: You may lodge a complaint with your supervisory authority. For NRW, Germany: Landesbeauftragte für Datenschutz und Informationsfreiheit NRW (LDI NRW).
7. Data Security
- All data in transit is encrypted using TLS 1.2+
- Payment data is handled exclusively by Stripe under PCI DSS Level 1 certification
- Firebase data is encrypted at rest
- Access to production data is limited to authorized personnel only
- We conduct periodic security reviews
8. Children's Privacy
ShowUp is not intended for users under 18 years of age. We do not knowingly collect data from minors. If we discover a user is under 18, we will immediately delete their account and associated data.
9. Cookies and Tracking (showup.gg)
The ShowUp website (showup.gg) may use cookies. We will ask for your consent before placing non-essential cookies.
- Essential cookies: Required for the site to function — no consent required
- Analytics cookies: Used to understand website traffic — require consent
The ShowUp mobile app does not use browser cookies.
10. Account Deletion
You can delete your ShowUp account at any time via Settings → Account → Delete Account.
Upon deletion:
- Your profile, check-in history, and group data will be deleted within 30 days
- Payment transaction records are retained for 10 years as required by law (§ 147 AO)
- Anonymized, non-identifiable aggregate statistics may be retained
11. Changes to This Policy
We will notify you of material changes to this policy via email or in-app notification at least 14 days before they take effect. The date at the top of this document shows when it was last updated.
12. Contact
Bogdan Nichovski
Engerstr. 78
32257 Bünde, Germany
Email: privacy@showup.gg