WhoDis Privacy Policy

Draft of 22 October 2026, for review by a lawyer before publishing. Text in [square brackets] must be filled in. It describes the app as built: an 18+ game, guest play with no sign-up, avatars from a built-in set (no photos), no ads or purchases.

1. Who we are

WhoDis is a group chat party game published by Dezynum Software Services (OPC) Private Limited, [registered address], Gurugram, Haryana, India ("we", "us"). We decide how your personal data is used, which makes us the data controller under the EU and UK GDPR and the Data Fiduciary under India's Digital Personal Data Protection Act, 2023.

This policy covers the WhoDis app and the server that runs online rooms. Practice mode, where the phone plays your friends, runs only on your phone; we never receive what you type there.

2. What we collect and why

There is no account and no sign-up. Online play uses a random guest identity that lives on your phone. There are no profile photos: you pick a nickname and an avatar from the app's own set.

DataWhere it comes fromWhy we use itLegal basis (GDPR)
Random player IDCreated by our server the first time you play onlineRecognise your phone between sessions and keep your seat if you drop outContract: providing the game
Nickname and the avatar you picked (its name in our set, such as "animals/fox")YouShow you to the other players in your roomContract
Chat lines, questions, answers and guesses in online roomsYouRun the round and show it to the roomContract
Game results and stats (which face you wore, points, right guesses, players fooled, unanswered questions) and the days you played onlineGenerated by the gameScoreboards, your stats, keeping the service runningContract
Reports you make, and reports made about you, with the room's last 50 messagesYou and other playersKeep players safe, enforce the TermsLegitimate interest in a safe community
Anonymous usage counts: a random ID that changes every day (so it cannot follow a phone over time), a first-open marker sent once per install, app opens, rounds played and how many players, app version and platformThe app, if "Share anonymous usage stats" is on (you can turn it off in settings)See how many people play and which version they useLegitimate interest
IP address and request details in server logsYour phone, automaticallySecurity and abuse preventionLegitimate interest

Where we rely on legitimate interest, you can object (section 5) and we will stop unless we have a compelling reason, such as investigating a safety report.

Some things stay on your phone and never reach us: your answer to the age check (only a yes or no, never your birthday), the faces you have blocked, your practice games and settings.

3. What we never collect, who sees your data, and where it lives

We do not collect your real name, email, phone number, location, contacts, photos, microphone or camera, and we do not use advertising IDs. The app has no ads and no in-app purchases, uses no third-party analytics or crash-reporting service, and we never sell or rent personal data.

Chat is shown live to the room and is not stored, except the last 50 messages that are attached to a report when someone reports a player. During a round the server never tells anyone which player is behind which face; that is shown to the room only when the round ends.

Your data is seen only by:

Our servers are in India. If you play from the EU, UK or elsewhere, your data is transferred to India. We protect those transfers with the European Commission's Standard Contractual Clauses (and the UK addendum) with our providers, and with the security measures in section 7.

4. How long we keep it

We delete data automatically when it is no longer needed.

DataKept for
Live room contents (faces, live chat, questions, guesses)Until the room closes; chat is never stored
Chat attached to a reportWith the report
Reports12 months after the report is closed
Profile (player ID, nickname, avatar), stats and days playedUntil you delete them, or 24 months after you last played online
Game resultsKept; when you delete your data, your seat is renamed "Deleted player" so other players' history stays correct
Anonymous usage counts13 months
Server logs with IP addresses14 days
Backups14 days on our server; encrypted off-site copies 30 days

If we have banned a player ID, we keep that ID (without the nickname) for as long as the ban lasts, so the same phone cannot simply rejoin.

5. Your rights

Wherever you live, you can ask us to:

We reply within 30 days. You can also complain to your data protection authority: in the EU, the authority in your country; in the UK, the ICO; in India, the Data Protection Board of India once you have first raised the complaint with us.

6. Grievance Officer (India)

[Name], Grievance Officer, Dezynum Software Services (OPC) Private Limited, [registered address], email compliance@dezynum.com. We acknowledge complaints within 24 hours and resolve them within 15 days.

7. Security

All traffic between the app and our servers is encrypted (HTTPS and secure WebSockets). Your guest identity is a signed token that only our server can issue. Backups are encrypted before they leave the server. Only our team can reach the database, through SSH keys and a firewall. If a breach puts your data at risk, we will notify you and the relevant authorities as the law requires.

8. Age limit: 18 and over

WhoDis is for adults only. Hidden identities are the heart of the game, so it is not meant for anyone under 18, and Google Play does not offer it to users it knows are under 18. Before the first online game the app asks for a month and year of birth without saying which answer is needed, works out on the phone whether the player is 18 or over, and keeps only that yes or no on the phone. Nothing about age is sent to us. Anyone under 18 cannot play online on that phone. We do not knowingly collect personal data from anyone under 18; if we learn that someone under 18 played online, we delete their data. A parent can ask us to at compliance@dezynum.com.

9. Changes and contact

We will show a notice in the app at least 14 days before a material change to this policy takes effect. Questions: compliance@dezynum.com.

EU representative (required if we target players in the EU): [name and address]. UK representative: [name and address].