Privacy policy

1. Who is responsible

The data controller for the MaxTheFun app and for maxthefun.com is MaxTheFun (company in formation), [registered address to be added], registered in [country of registration to be added] under number [registration number to be added].[to confirm] For anything about your personal data, write to privacy@maxthefun.com. For help with the app, write to support@maxthefun.com.

2. The MaxTheFun app

No account needed: a random device identifier

When you first open the app it creates a random identifier and keeps it in your phone's secure storage. The app sends it with every request to our servers, so they can keep your plans and purchases together without asking who you are. It is not your phone's advertising identifier and contains nothing about you or your phone.

Your plans, preferences and live days

To build and keep your plans we store on our servers, linked to that identifier:

• the visit dates, rides and must-dos you choose, breaks, and the plans we generate for you;
• your group settings: the height of the shortest rider (so rides they cannot board stay out of the plan) and whether you use single-rider lines. This is a number, not a name or an age;
• for live guidance days: which rides you ticked as done or skipped, the current route and your end-of-day summary;
• how many free previews you have used.

Some preferences stay only on your phone: language, distance units, your answer to the usage-statistics question, and which tips and prompts you have already seen. The app is available in English, French, Spanish, German, Dutch and Italian.

Purchases

Payments go through Stripe's secure checkout page. Stripe collects your payment details and an email address for the payment; we never see or store your card number. From Stripe we receive and keep a record of each purchase: what you bought, the amount and currency, the date, and a payment reference. Your credits (plans, live days, unlocked dates) are stored with your device identifier.

Email: receipts and restoring purchases (optional)

• Receipts. After a payment we email a receipt, through Amazon Web Services, to the email address you gave on the Stripe checkout page.
• Keeping your plans safe. After paying, the app may ask for an email address. This is optional and the purchase works without it. If you give one, we store it with your device identifier so that your purchases can be found and restored later.
• Restore on another phone. If you sign in to restore your purchases, we create an account with Amazon Cognito that holds your email address (and a password, if you chose one; it is stored as a secure hash). Signing in usually works with a one-time code that we email you. Your purchases and plans are then linked to that account.
• Sharing a day with your group. If you share a park day, we email an invitation, through Amazon Web Services, to each address you enter (up to five), with your first name only if you chose to give one. We keep those addresses with the shared day so you can see who joined and remove anyone. An invited person signs in with a one-time code sent to that address and then sees the plan and the live day read-only; they cannot change it. We remember the app language of an invited person so later invitations reach them in it. "Delete my data" removes the shares you made and, for an invited person, their invitations.

Location: only for live guidance

The app asks for location permission only when you start live guidance, and only while the app is in use. It never tracks you in the background. Guidance works without it; the map just cannot show where you are.

• On your phone. During a live day your position is used on your phone to show you on the map. Separately, if you have already given permission, the app checks once when you open it whether you are at the resort without a plan for today, so it can offer to make one. That check happens on your phone and nothing is sent.
• Sent when you tap Replan. When you ask for a new route from the map, the app sends your current coordinates to our servers once, so the new route starts where you stand. They are used for that one calculation. We do not store them or keep a history of where you have been. If the position is not at the resort, it is ignored.
• Sent for live suggestions. During a live day the app suggests what to do next from where you are. For that it sends your position rounded to about 100 metres, again when you have moved that far or finished a stop. It is used for that one answer and not stored.

Usage statistics and ad measurement: only with your consent

We would like to know which screens help, where people get stuck, and which of our adverts bring people to the app. The app asks once, on first launch, about two separate things, each with its own switch, both off until you turn them on: usage statistics (through Google Analytics for Firebase) and ad measurement (through Adjust). You can allow one, both or neither. Until you allow one, nothing is collected for it, and the app works the same if you say no. You can change either answer at any time in the app's Settings, under Your data.

With your consent to usage statistics, the app sends events such as "plan requested", "paywall viewed", "purchase completed" (product and price, plus a code made from the purchase that cannot be turned back into its payment reference) and "ride done" (which ride), plus screen views. It never sends your email, your location, your device identifier or plan and payment references. Google Analytics adds its own information: a random app-instance identifier, your device model, operating system, app version, language and approximate region (worked out from your IP address). Google's advertising features are switched off: no advertising identifier, no ad personalisation, no advertising use of that data.

With your consent to ad measurement, the app uses Adjust to learn which advert or link led to the app being installed, and whether that led to a purchase, so we can tell which adverts work. Adjust receives an identifier it creates for the installed app, your device model, operating system, app version, language and IP address, and the same kind of events as above. It also receives your phone's advertising identifier if your phone provides one; on an iPhone that happens only if you also answer yes to Apple's "Allow tracking" question. Purchases and registrations are reported to Adjust by our server, not by the app: when you buy something, or add a restore email for the first time, our server tells Adjust that it happened (for a purchase, its amount and currency; never your email or payment details), together with Adjust's identifier for the installed app and your advertising identifier if the app had one. For this the app gives our server those two identifiers while ad measurement is on; we keep them at most 90 days and delete them as soon as you switch ad measurement off or use "Delete my data". Adjust may tell the advertising network that showed the advert (for example Meta) that an install, a registration or a purchase, with its amount, followed. Adjust tells us the network, campaign and advert an install came from, and we keep that with your device identifier until you delete your data. We do not use it to show you adverts.[to confirm]

Some of our adverts carry an offer, such as a lower price. When Adjust tells us that the app was installed from such an advert, or when you type the code shown in it, we apply that offer to your purchases. We keep which offer you have, when it started and ends, and the purchase it was used for, with your device identifier until you delete your data. So that Adjust's answer can reach the right phone, the app gives Adjust a code made from your device identifier that cannot be turned back into it; what Adjust tells us about the install is kept at most 90 days. You never need to allow tracking to get an offer: the code in the advert works the same.[to confirm]

Crash reports

The app contains no crash-reporting tool of its own. If you have allowed Apple or Google to share app diagnostics with developers, they may give us anonymous crash reports under their own privacy terms.[to confirm]

Notifications

The app may ask for permission to send notifications. The current version sends none, and no notification token is sent to our servers.

Technical data

Like any online service, our servers see your IP address and technical request details. We use them to run the service and protect it from abuse, for example counters that limit how many free previews one network or device can request per day. Those counters are deleted automatically after 2 days. Our servers also keep technical logs, which can include your device identifier, to find and fix faults and to trace payments.

What our servers record about your phone

To understand how people find their way through the app (how many plan a day, open the prices, choose an option and buy), our servers keep one record per device identifier with what the app's requests already show:

• the country your IP address belongs to, looked up on our own servers in a database bundled with them, and your IP address shortened so that it no longer points to one connection (the last part removed). The full IP address is not stored. The country is not your position: the app's location is described above;
• whether the phone runs iOS or Android, the app version and the app's language;
• only while usage statistics is switched on: your phone's model and the version of its operating system. Switch it off and the app stops sending them, and they are removed from the record;
• when you first opened the app, first made a plan, first opened the prices, first chose an option, first bought and first upgraded.

Everything in this record is deleted 12 months after it was started, and at once with "Delete my data". The country, phone type, system and language are also kept with each purchase and each first step in our own statistics, which hold a scrambled key instead of your device identifier; they are removed there 12 months after they were recorded. Nothing in the record is shared with Google, Adjust or anyone else.

3. This website

Browsing the site

This website sets no cookies and carries no advertising trackers and no third-party analytics. We keep our own visit logs: for each request, the time, the page, your IP address, your browser and device type, and the page you came from. We use them to count visits and to keep the site secure. They are deleted after 30 days.

Links in our adverts and posts

Links we publish that start with maxthefun.com/go/ count the click before sending you on to the page or app store they lead to. Everyone who follows the same link is sent to the same place. For each click we record the time, the link and the campaign details it carries, your IP address, your approximate location worked out from it (country, region, city) and your network provider, your browser, device and language, the page you came from, and whether the click looks automated. We use this to see which adverts work and to spot fake clicks. The IP address is deleted after 30 days; the rest of the record, which then no longer contains it, is kept as statistics.[to confirm]

Email you send us

If you email us, we process your address and message to reply. Incoming mail is received through Amazon Web Services and delivered to our team mailbox, which is hosted by Google.

4. Why we use your data (legal bases)

• To provide the app you use and the purchases you make (performance of a contract, Article 6(1)(b) GDPR): the device identifier, plans, preferences, live days, purchases and credits, receipts, the restore email and account, and your coordinates when you tap Replan.
• Your consent (Article 6(1)(a) GDPR), given separately for each: usage statistics through Google Analytics (which also lets the app send your phone's model and system version to our servers), ad measurement through Adjust, and access to your phone's location, which you control through the permission your phone asks for.
• Our legitimate interests (Article 6(1)(f) GDPR): keeping the service secure and free of abuse, fixing faults, counting website visits and clicks on our own advert links, understanding how people move through the app from the record our servers keep about each phone (country, shortened IP address, phone type, app version, language and when each step was first reached), answering your emails, and defending legal claims.
• Legal obligations (Article 6(1)(c) GDPR): keeping payment and accounting records as tax law requires.

We do not sell your data, we do not show you other companies' adverts, and we do not make automated decisions that have legal or similarly significant effects on you. We measure how our own adverts perform as described above.

5. Who processes your data

We use these service providers. Each processes data only for us and under a data processing agreement, except where noted.

• Amazon Web Services (Amazon Web Services EMEA SARL): hosting, database, server logs, website visit and click records, receipt and sign-in emails (Amazon SES) and restore accounts (Amazon Cognito). All in the EU region of Ireland (eu-west-1). The website is delivered through Amazon's worldwide content delivery network.
• Stripe (Stripe Payments Europe, Ltd., Ireland): payments. For fraud prevention and its own legal duties as a payment provider, Stripe also acts as an independent controller under its privacy policy.
• Google (Google Ireland Limited): Google Analytics for Firebase, only with your consent, and our team mailbox.
• Adjust (Adjust GmbH, Germany): ad measurement in the app, only with your consent.[to confirm]
• Meta (Meta Platforms Ireland Limited): receives from Adjust, only with your consent to ad measurement, that an install, a registration or a purchase followed one of its adverts.[to confirm]

Stripe, Google and Meta may process data in the United States. Those transfers rely on the EU-U.S. Data Privacy Framework, under which these companies are certified, and on the European Commission's standard contractual clauses. Amazon Web Services may access data from outside the EU for support and security, under the same safeguards.[to confirm]

Queue data and maps come from third-party sources that we credit in the app: a public queue-time data service and OpenStreetMap contributors (map geometry, ODbL). The country of an IP address comes from IP Geolocation by DB-IP (CC BY 4.0), a database we keep on our own servers. They are sources of data, not processors: the app sends them nothing about you.

6. How long we keep it

• Plans, preferences, live days, purchases, credits and the restore email: for as long as you use the app, until you delete them with "Delete my data" or ask us to.
• Restore accounts: until you ask us to close yours.
• Your coordinates when you tap Replan: not stored.
• Abuse-prevention counters: 2 days.
• The record our servers keep about your phone (country, shortened IP address, phone type, app version, language, model and system version, and when you first reached each step), and the same details kept with your purchases in our statistics: 12 months after the record was started, then deleted.
• Website visit logs: 30 days.
• Clicks on our advert links: the IP address for 30 days; the rest as statistics without it.
• Ad measurement at Adjust: as set in our Adjust account.[to confirm]
• What Adjust passes to Meta: under Meta's own retention rules.[to confirm]
• Server logs: up to 90 days.[to confirm]
• Usage statistics in Google Analytics: 14 months, then deleted by Google.[to confirm]
• Payment and accounting records: as long as tax and accounting law requires, usually up to 10 years. Stripe keeps its own payment records under its policy.[to confirm]
• Email correspondence: as long as needed to handle your request, then no more than 24 months.

7. Your rights

Under the GDPR you have the right to:

• access your data and get a copy;
• correct it;
• delete it. In the app, go to Settings, then Your data, then "Delete my data". This permanently deletes your plans, History, live days, purchases and credits on our servers, including those linked to a restore account, and resets the app on your phone. Deleted purchases cannot be restored or refunded. To also close your restore account and remove your email address from our records, email privacy@maxthefun.com;
• data portability: receive the data you gave us in a machine-readable format;
• restrict or object to processing based on our legitimate interests;
• withdraw consent at any time, without affecting what was done before. Usage statistics and ad measurement: switch either off in Settings, under Your data. Location: switch it off in your phone's settings.

To use any of these rights, email privacy@maxthefun.com. Most customers have no account, so we may ask you to send the request from the app or to show you hold the device, so that we never hand one person's data to another. We answer within one month.

You also have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU country where you live or work, or where you think the problem happened.

8. Children

MaxTheFun is meant to be used and paid for by adults planning a visit, including with their family. It is not directed at children under 16, and we do not knowingly collect their data. The group setting for the shortest rider's height is a number only and does not identify a child. If you believe a child has given us personal data, email us and we will delete it.[to confirm]

9. Cookies and similar technologies

This website sets no cookies. The app stores its device identifier and preferences on your phone because it needs them to work. Google Analytics stores its own identifier on your phone only after you allow usage statistics; Adjust stores its own only after you allow ad measurement.

10. Security

Data is encrypted in transit, and stored with Amazon Web Services in the EU with access limited to the people who run the service. Your device identifier works like a key to your purchases, so it is kept in your phone's secure storage.

11. Changes

If we change this policy we will update the date at the top. For significant changes we will tell you in the app or by email before they apply.

12. Contact

Privacy questions and requests: privacy@maxthefun.com. Help with the app: support@maxthefun.com. Postal address: MaxTheFun (company in formation), [registered address to be added].