Last updated: 7 October 2026
This Privacy Notice explains which personal data we process when you use the app "100 Heads" (the "Service"), why we do so, what rights you have and how you can exercise them. Privacy is very important to Jaysquared Till Henrik Jonathan Hillebrand ("Jaysquared", "we"). We process personal data only where there is a legal basis; where there is none, we ask for your consent. Processing always complies with the General Data Protection Regulation (GDPR), the German Federal Data Protection Act and the German Telecommunications Digital Services Data Protection Act (TDDDG).
The controller within the meaning of the GDPR is:
Jaysquared Till Henrik Jonathan Hillebrand
c/o IP-Management #44575, Ludwig-Erhard-Str. 18, 20459 Hamburg, Germany
Email: support@jaysquared.com
Website: www.jaysquared.com
Please contact us if you want to know which data we hold about you or if you want your data corrected or deleted.
Player account
On first launch, Firebase Authentication creates an anonymous account with a random user identifier (UID). Alongside it we store: your player name (random at first, changeable by you), your avatar colour, the game language, your skill rating (one number per language), the creation date, your settings (for example whether your rounds may be used as recordings) and, if you have allowed notifications, a push token. The account is tied to your installation. Where the app offers "Sign in with Apple" and you use it, Apple stores the link; we receive only a pseudonymous identifier from Apple and no email address unless you share it.
Purpose: providing the game, recognising your progress, assigning duels. Legal basis: Art. 6(1)(b) GDPR (contract). Retention: until you delete your account, or until we delete it after 12 months without activity (see "Deleting your account").
Duels and rounds
For every duel we store the identifiers and player names of both players, the boards played, points, round results, timestamps and the winner. For every round you play we store its course: every typed answer verbatim (at most 100 characters), the time it was entered, whether it counted as a hit or a miss and which board answer it was matched to. After playing the same round themselves, your opponent sees which answers you found, your points and your strikes. Your typed answers are stored only on our servers; neither your opponent nor you can retrieve them through the app.
Purpose: running the duel, showing the course of play to both players, verifying the scoring, improving the answer boards (see below). Legal basis: Art. 6(1)(b) GDPR. Retention: until you delete your account; finished duels are also deleted no later than 12 months after they end.
After a round you can rate its question (thumbs up or down, optionally with a reason such as "answer missing"). We store the rating with your identifier, the round it belongs to and that round's result (points, answers found, strikes, whether you won the round), and count it anonymously per question. If you choose "inappropriate", we also create a report so that we check the question by hand; it contains your identifier until you delete your account and is kept without it afterwards; the report is deleted 12 months after it was filed or last reopened.
Purpose: finding and improving poor questions. Legal basis: Art. 6(1)(f) GDPR; our legitimate interest is offering good questions. Rating is optional. Retention: until you delete your account; the anonymous counts are kept.
Please do not type personal details about yourself or others (names, addresses, phone numbers) during a round. Such entries are not part of the game but are stored like any other answer.
Recorded rounds
If no human opponent is available for a player, they play against a recording of a round another player played on the same board. Your rounds may be used this way too. The other player then sees your player name, your avatar colour and the course of the round (hits, misses and timings), but not your typed answers and not your user identifier. For this we keep an index of your rounds with your identifier, skill rating and score.
Purpose: providing an opponent when nobody is online. Legal basis: Art. 6(1)(f) GDPR; our legitimate interest is offering a playable duel at all times. You can object at any time in the settings; from then on no new recordings of you are created. Retention: until you delete your account. Copies of your recordings in other players' duels are anonymised on deletion (player name and avatar colour are removed).
Challenges (links)
If you challenge a friend via a link, we create an invitation containing your identifier, the boards played and your rounds. The link itself contains only a random invitation identifier and no personal data. The text you pass on when sharing contains your player name, your opponent's player name and both scores. Invitations expire after 14 days.
Legal basis: Art. 6(1)(b) GDPR. Retention: 14 days after expiry, at the latest when you delete your account.
Replay video and share card
On request the app renders a video or an image of your round on your device. It shows the question, the board, your points and your player name, but no typed answers and not your opponent's name. The file stays on your device until you share it or save it to Photos (iOS asks for your permission). We do not receive the file.
Answer collection ("crowd answers")
Where the app offers it, you can voluntarily answer one or two questions blind after a duel. We store these answers with a pseudonymous hash of your identifier, the answer text, the language and the time. Once enough answers have been collected they are combined into an anonymous answer board with percentages; the board can no longer be traced back to individuals. Answers are automatically filtered for profanity and personal details before they are stored.
Legal basis: Art. 6(1)(a) GDPR (consent, revocable at any time; under 16 only with a parent's or guardian's permission). Retention: individual answers until they are combined into a board, at the latest until you delete your account; the anonymous board indefinitely.
Improving the answer boards
When the AI judgement classifies a typed answer as a hit or a miss for a specific board answer, we store the normalised spelling (lower case, no punctuation) as an additional accepted or rejected spelling on the board. This list contains no identifier and no reference to you. It is anonymous and is not deleted.
Checking player names
When you change your player name, our servers check the new name automatically: first against fixed rules (length, characters, no contact details, a short blocklist), then through an Anthropic language model that receives only the entered name, no identifier and no other data. A rejected name is not stored. Legal basis: Art. 6(1)(f) GDPR (legitimate interest in a game free of insulting or unlawful names). The section "Artificial intelligence" applies to the transfer to Anthropic.
Reports
If you report a question, an answer or a player name to us by email, we process your message as described under "Email". Legal basis: Art. 6(1)(f) GDPR (legitimate interest in a safe game). Retention: 12 months after the report is closed. Reports created by rating a question "inappropriate" are described under "Duels and rounds".
Notifications (push)
So that a duel does not stall, the app registers for quiet notifications on first launch: they appear only in the Notification Centre, without a banner or sound. For this we store a push token that Firebase Cloud Messaging and Apple use for delivery. When a human opponent is waiting for you, iOS asks whether notifications may also appear as banners with sound. A notification contains your opponent's player name (for example "... is now playing against you"). You can switch notifications off in the iOS settings at any time; the token is then no longer used and is removed when you delete your account. Legal basis: Art. 6(1)(b) GDPR (informing you about your duels); storing the token on your device is strictly necessary for this notification service (Section 25(2) no. 2 TDDDG).
Technical data
When you access our servers (Firebase), your IP address, the time, the requested function and the device and app version are necessarily processed. Google keeps this data in server logs for a short time to secure operations, detect abuse and fix errors. Our own logs contain the user identifier and the duel identifier in error cases; these logs are deleted automatically after 30 days. Legal basis: Art. 6(1)(f) GDPR (security and troubleshooting); Section 25(2) no. 2 TDDDG.
Local data on your device
The app stores cached boards, rounds not yet uploaded, your settings and generated replay files on your device. This data leaves your device only as described above and is deleted together with the app. Legal basis: Section 25(2) no. 2 TDDDG (storage on your device that is strictly necessary for the app to work) and Art. 6(1)(b) GDPR.
Usage statistics
To understand whether the app is used and whether players come back, we count on our own servers (Firebase, europe-west3) how many accounts opened the app, played or were newly installed per day, and derive aggregated figures from that (such as active users per week and month, or the share still using it after one, seven or 30 days). For this, we store only three calendar days with your account: the day of installation and the last day you opened the app and the last day you played. When you open the app, it sends a short request with no further content to our servers for this. We use no analytics SDK for this, build no profiles, link the data with nothing else and do not pass it on; only totals are evaluated. The days are deleted together with your account. Legal basis: Art. 6(1)(f) GDPR (our legitimate interest in running and developing the app according to how it is actually used).
What we do not do
Apart from the in-house usage statistics described above, we use, apart from the Google Mobile Ads SDK (AdMob, see "Advertising (Google AdMob)"), no analytics or tracking SDKs, no third-party crash reporting and no other advertising network, read the advertising identifier (IDFA) only with your permission, do not build user profiles and do not sell data. Should this change, we will update this notice and, where required, ask for your consent first.
If your typed answer is similar to, but not the same as, an answer on the board, we have it judged by an AI language model. For this, our servers send the following data to Anthropic (a model of the Claude family): the question, the answer being looked for with its known spellings, and your typed text (at most 100 characters). No identifiers, player name, device information or IP address of yours are transmitted. The same happens afterwards for answers that could not be judged during the round. Anthropic processes the data on our behalf in the USA, does not use it to train its models and normally deletes it within 30 days; inputs that Anthropic's automated safety systems classify as abuse may be kept by Anthropic for up to two years. Transfers to the USA are covered by the Standard Contractual Clauses approved by the European Commission, which form part of our data processing agreement with Anthropic.
The game's questions and answer boards are also generated with the help of Anthropic models; no data of yours is used for that. AI-generated boards are labelled in the app.
Legal basis: Art. 6(1)(b) GDPR: AI judging is part of the game you chose to play. Whether it runs for you is your decision: before your first duel the app asks whether answers should be checked by AI, and you can change that at any time in the settings. With AI judging off, none of your typed answers are sent to Anthropic; answers then only count if they exactly match a spelling stored in the app. Player names are checked independently of this setting (see "Checking player names").
Processor: Anthropic Ireland, Limited, 6th Floor, South Bank House, Barrow Street, Dublin 4, D04 TR29, Ireland (contracting entity) and Anthropic PBC, 548 Market St, PMB 90375, San Francisco, CA 94104, USA (processing).
https://www.anthropic.com/legal/privacy
You are not legally obliged to provide personal data. Without the anonymous account and your entries during a round you cannot play, because the game cannot work without them. Everything else (notifications, question ratings, the answer collection, your own player name) is optional.
The AI judgement of answers and the check of player names are automated decisions. They only affect the course of the game and have no legal or similarly significant effect on you (Art. 22 GDPR). We do not use profiling.
We run the Service on Firebase, a Google platform, and use Authentication (anonymous account), Cloud Firestore (database), Cloud Functions (game logic), Cloud Messaging (notifications), Hosting (website and links) and Cloud Logging (logs). The database and game logic run in the europe-west3 region (Frankfurt am Main). Authentication processes data exclusively in data centres in the USA; Cloud Messaging is a global service where data may also be processed in the USA. Google processes the data on our behalf under Google's data processing terms for Firebase and Google Cloud. For transfers to the USA, Google LLC is certified under the EU-US Data Privacy Framework; Standard Contractual Clauses apply in addition. Firebase Analytics and Crashlytics are not included in the app; advertising (AdMob) is a separate service, see below.
Processor: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland
https://firebase.google.com/support/privacy
https://policies.google.com/privacy
The app is free and funded by advertising: after a finished duel, when you leave the result screen, we show one ad (an interstitial). Ads never appear in the middle of a round. Players with the „Ein Jahr werbefrei“ subscription see no ads, and no ads are requested. For ads we use the Google Mobile Ads SDK (AdMob) from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
What data: when an ad is loaded and shown, Google processes your IP address, device and app data (for example device model, operating system version, app version, language, approximate location derived from the IP address), ad interaction data (ad shown, tapped), other device or app identifiers (for example the vendor identifier and Google's own app identifiers for limiting ad frequency and preventing fraud) and, only if you allow it in the iOS prompt, the advertising identifier (IDFA). Without that permission the app does not read the IDFA.
Legal basis: your consent, Art. 6(1)(a) GDPR and Section 25(1) TDDDG. We ask for it through Google's consent form (a consent management platform) before the first ad is requested. You can keep playing without consenting; Google then shows you only non-personalised or limited ads, without the advertising identifier (IDFA). Withdrawal: at any time in the app under Settings → „Werbung → Einwilligung ändern“ (Advertising → Change consent), with effect for the future. You can also grant or withdraw the tracking permission (advertising identifier) at any time in iOS Settings under Privacy & Security → Tracking.
Transfers: Google may also process the data in the USA. For transfers to the USA, Google LLC is certified under the EU-US Data Privacy Framework; Standard Contractual Clauses apply in addition.
Retention: Google processes the data under its own responsibility, its own policies and retention periods; we store no advertising data ourselves.
https://policies.google.com/privacy
https://policies.google.com/technologies/ads
The „Ein Jahr werbefrei“ subscription (EUR 4.99 per year, renews automatically) removes the ads. Apple is the seller: the purchase runs through your Apple account, and Apple handles payment, billing and renewal. Jaysquared receives neither a transaction identifier nor payment data: whether a subscription is active, and until when, is learned only by the app on your device through StoreKit; nothing about it is sent to Jaysquared's servers. You can cancel at any time in your Apple ID settings (Settings → your name → Subscriptions) or in the app under Settings → „Werbefrei → Abo verwalten“ (Ad-free → Manage subscription), at least 24 hours before the end of the current period. The subscription belongs to your Apple ID, not to your player account: it remains if you sign out or choose „Alle Daten löschen“ (Delete all data), and you can reactivate it with „Käufe wiederherstellen“ (Restore Purchases). Legal basis: Art. 6(1)(b) GDPR.
You obtain the app through the Apple App Store. Apple processes data of your Apple account under its own responsibility and shares only anonymous statistics with us. Apple delivers notifications through the Apple Push Notification service and, at our request, occasionally shows the App Store rating prompt; whether and when it appears is decided by Apple. Where the app offers in-app purchases or subscriptions, Apple handles them; we receive neither a transaction identifier nor payment data; the app checks on your device through StoreKit whether a subscription is active.
Controller: Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland
https://www.apple.com/legal/privacy/
If you contact us by email, we process your email address and the content of your message to handle your request (Art. 6(1)(b) or (f) GDPR). We delete the correspondence once it is no longer needed, at the latest after 12 months, unless statutory retention obligations apply.
The Service is intended for people aged 12 and over and contains family-friendly content only. The game itself needs no consent. Once features based on your consent are offered (the answer collection), the following applies: if you are under 16, you need the permission of a parent or guardian (Art. 8 GDPR); the app asks for your age there. If we learn that a child's data was processed without the required permission, we delete it.
You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20) and objection to processing based on Art. 6(1)(f) GDPR (Art. 21). You can withdraw any consent you have given at any time with effect for the future; the lawfulness of processing before withdrawal is unaffected.
Right to object: Where we process your data on the basis of Art. 6(1)(f) GDPR, you have the right to object at any time, on grounds relating to your particular situation (Art. 21 GDPR). We then stop the processing unless we can demonstrate compelling legitimate grounds that override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.
You can exercise most rights directly in the app: change your player name, switch off the use of your rounds as recordings, switch off AI judging and delete your account. For everything else, write to support@jaysquared.com. As your account is anonymous, please tell us your player name and, if possible, the player identifier shown in the settings so that we can find your data.
You also have the right to lodge a complaint with a data protection supervisory authority. The authority responsible for us is: Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit, Ludwig-Erhard-Str. 22, 20459 Hamburg, Germany, https://datenschutz-hamburg.de. You may also contact the authority where you live.
When you delete your account in the app (or ask us by email), we delete your anonymous account, your player record including player name and push token, your rounds, the index of your recordings, your invitations and your crowd answers. Ongoing duels are ended. Copies of your recordings in other players' duels are anonymised. Your opponents' finished duels keep your player name and score until their regular deletion (no later than 12 months after the duel ended) so that the opponent can still see their own result. Anonymous answer boards and spellings are kept because they can no longer be attributed to you.
If your account has had no activity for 12 months, we delete it in the same way. Activity means opening the app, starting or joining a duel, finishing a round, rating a question, changing your player name or avatar colour, or creating or accepting a challenge link. This also applies if you log out or delete the app without deleting your account first.
We have implemented technical and organisational measures to protect your data: encrypted transmission (TLS), access rules under which players can read only their own data and the rounds released to them, server-side verification of all game results, key management outside the source code and operator access limited to what is necessary. Internet-based data transmission can nevertheless have security gaps, so absolute protection cannot be guaranteed.
If Jaysquared is involved in a merger, acquisition or sale of assets, your data may be transferred. We will inform you, where required by law, before your data is transferred and becomes subject to a different privacy notice.
For handling mail sent to us we use the services of IMPRESSUM-PRIVATSCHUTZ GmbH, Ludwig-Erhard-Str. 18, 20459 Hamburg. This provider offers a secure and reliable postal address for our project (imprint, privacy notice and other areas as applicable). This constitutes our legitimate interest under Art. 6(1)(f) GDPR. We have concluded a data processing agreement with Impressum-Privatschutz.
https://impressum-privatschutz.de/datenschutzerklaerung/
We update this Privacy Notice when the Service or the law changes. The current version is available in the app and at www.jaysquared.com. If changes require new consent, we will ask for it the next time you open the app.