1. Controller and contact
The controller for the processing described here, within the meaning of Article 4(7) GDPR, is Sebastian Seidel, Zum Isetal 1, 38518 Gifhorn, Germany.
Data protection enquiries and requests under Articles 15 to 22 GDPR: privacy@podium.lol. General support: help@podium.lol.
No data protection officer has been appointed, as the thresholds in Article 37 GDPR are not met.
2. What is public by design
Podium is a public leaderboard, so part of your account is visible worldwide to users of the app and public website, and to anyone who receives a profile link, search result, social preview, or share image. Publishing it is the service you are asking for. Search engines and other third parties may index or cache public pages outside our direct control.
- Your handle, display name, tagline, and profile photo or Motion Card video.
- Your primary and secondary category, your country, and your city if you provide one.
- The links you add to your profile.
- Your current rank, your peak rank, your stake in Crowns, and the boards you appear on.
- Your bids as they happen, shown in the board activity ticker.
Anything in this list is public. Do not put an address, a phone number, a document, or anything else private into a field on your profile.
3. What is not public
Everything else is visible only to you. That includes your email address or sign-in identifier, your Crown balance and wallet ledger, your purchase and subscription history, your notification settings, your Auto-Defend settings, the moderation verdicts and scores held against your content, the reports you file about other users, and your device push token.
4. Categories of data, purposes, and legal bases
The table below is the Article 13 disclosure. Each purpose has one legal basis and no data is used for a purpose not listed here.
- Account data (email address or the identifier returned by Sign in with Apple or Google, account state, language) — to create and operate your account. Legal basis: performance of a contract, Article 6(1)(b).
- Sign-in codes (a six-digit code sent to your email) — to authenticate you. Legal basis: performance of a contract, Article 6(1)(b).
- Profile data (handle, display name, tagline, categories, country, city, links, photo or video) — to publish your listing on the board. Legal basis: performance of a contract, Article 6(1)(b).
- Wallet and economy data (Crown balance, full ledger of grants and spends, bids, stakes, listings, streaks, referral relationships) — to operate the Crown economy and give you a verifiable record. Legal basis: performance of a contract, Article 6(1)(b), and for the retained accounting records a legal obligation, Article 6(1)(c).
- Purchase data (store transaction identifiers, product identifiers, subscription expiry, entitlement state) — to deliver what you bought and to prevent the same receipt being redeemed twice. Legal basis: performance of a contract, Article 6(1)(b), and legal obligation for tax records, Article 6(1)(c).
- Moderation data (verdicts, category scores, flags, reports filed and received) — to keep the board lawful and safe. Legal basis: legitimate interests, Article 6(1)(f), being the protection of users and of the service, and legal obligation where illegal content is involved, Article 6(1)(c).
- Engagement counts (how many times your listing was viewed and each of your links was tapped, with the country of the tap) — to show you whether the board is working for you. These are aggregated counters; we do not store who viewed or tapped. Legal basis: performance of a contract, Article 6(1)(b).
- Push notification data (device token, topic preferences) — to send the notifications you asked for, such as being outbid. Legal basis: consent, Article 6(1)(a), given through the system permission prompt and revocable in Settings.
- Crash diagnostics (stack traces, device model, OS version, app version, a pseudonymous installation identifier) — to find and fix crashes. Legal basis: consent, Article 6(1)(a). Off until you enable it.
- Product analytics (screens opened, funnel steps completed, pseudonymous installation identifier) — to understand where the app is confusing. Legal basis: consent, Article 6(1)(a). Off until you enable it.
- Security and abuse data (rate-limit counters, duplicate-receipt records, records of enforcement action) — to prevent fraud and abuse. Legal basis: legitimate interests, Article 6(1)(f).
- Website request data (IP address, user agent, requested URL, timestamp, response status, and security events) — to deliver and secure the public website and diagnose faults. Legal basis: legitimate interests, Article 6(1)(f).
- Website preferences (language cookie and roadmap votes stored in local storage) — to remember the choice on that device. The language cookie is necessary for the requested localized experience; roadmap votes never leave the device in the current website version.
- Support, feature-request, launch-update, and deletion emails — when you use a website email link, your email application sends the content directly to the relevant Podium inbox. We use it to answer or perform the request and, only when you ask, to send a launch update. Legal basis: performance of a contract, Article 6(1)(b), legal obligation for rights requests, Article 6(1)(c), consent for launch updates, Article 6(1)(a), or legitimate interests in improving and supporting the service, Article 6(1)(f), as applicable.
5. Where the data comes from
Almost all of it comes from you. Two categories do not: Apple or Google provide us with a stable user identifier and, if you allow it, your name and email address when you use their sign-in; and Apple, Google and RevenueCat provide us with purchase and subscription status so we can grant what you paid for. This is the Article 14 disclosure for that data.
6. Automated moderation, and your right to a human
Every image, video frame, and piece of profile text is scored automatically before it is published. A clear pass is published, a clear fail is rejected, and a borderline result is held for a human reviewer. A rejection can hide your content and, for severe categories, freeze your account.
This is automated processing that produces a legal or similarly significant effect on you within the meaning of Article 22 GDPR, so you have the right to obtain human intervention, to express your point of view, and to contest the decision.
To exercise it, use the appeal link shown when content is rejected, or write to privacy@podium.lol. A person, not the system, reviews the appeal.
The logic involved is content classification against fixed safety categories, with score thresholds chosen by us; there is no profiling of you as a person, no scoring of your behaviour, and no advertising use.
Content involving minors is treated as zero tolerance and is escalated immediately, without waiting for an appeal.
If automated moderation gets your photo wrong, you can demand a human review of that decision, and we have to give you one.
7. Recipients and processors
We use a small number of processors, each under a data processing agreement under Article 28 GDPR and each for a single purpose. The Subprocessors document lists them with their locations. In summary:
- Convex — database, file storage, and server functions. Everything in the app passes through it.
- Resend — delivery of the six-digit email sign-in code, so it receives your email address.
- Apple and Google — sign-in, if you use it, and payment processing. We never see your card details.
- RevenueCat — verification of receipts and subscription state.
- OpenAI — automated moderation of images, video frames, and profile text. Content is sent to the moderation endpoint only and is not used to train models.
- Sightengine — second-opinion moderation for borderline images only, and only when enabled.
- OneSignal — push notification delivery, only after you allow notifications.
- Sentry — crash reports, only after you consent.
- PostHog — product analytics, only after you consent.
- OpenAI Sites and Cloudflare — private-preview and website hosting and content delivery. They process ordinary web request metadata such as IP address, user agent, requested URL, and timestamp.
- Professional advisers and authorities — only where we are legally required to disclose, or need to establish or defend a legal claim.
We do not sell personal data and we do not share it for advertising purposes.
8. International transfers
Several processors are established in the United States. Transfers to them are made under the European Commission’s standard contractual clauses of 4 June 2021, supplemented by our own assessment of the transfer, and where the recipient is certified, under the EU–US Data Privacy Framework.
A copy of the safeguards for a specific transfer can be requested at privacy@podium.lol.
9. Retention
We keep each category only as long as it is needed for its purpose.
- Profile data, listings and links: until you change or delete them, or you delete your account.
- Photos and videos: until replaced or deleted; the stored file is deleted with the account.
- Wallet ledger, purchase records and invoices: up to 10 years from the end of the year in question, because German commercial and tax law requires it (section 257 HGB, section 147 AO). These records survive account deletion in reduced form, keyed to an internal identifier rather than to your profile.
- Moderation verdicts, scores and enforcement records: 2 years, so that repeat abuse can be recognised, and longer where needed to establish or defend a legal claim.
- Reports you file: 2 years.
- Engagement counters: 13 months, then aggregated.
- Crash reports: 90 days. Product analytics: 12 months.
- Push tokens: until you revoke the permission or the token becomes invalid.
- Records of accounts terminated for serious abuse: a minimal record, being a hash of the identifier and the reason, kept for 3 years to stop the account being recreated.
- Website server and security logs: normally 30 days, and longer only when needed to investigate abuse, an outage, or a legal claim.
- Support, feature-request, and deletion correspondence: up to 2 years after the request is closed, and longer only where a legal retention duty or claim requires it. Launch-update requests are kept until the update is sent or consent is withdrawn, whichever comes first.
- Language preference and local roadmap votes: held on your device until they expire or you clear browser storage.
10. Your rights
Under the GDPR you have the right of access (Article 15), rectification (16), erasure (17), restriction (18), data portability (20), and the right to object to processing based on legitimate interests (21). Where processing is based on consent, you may withdraw it at any time with effect for the future (7(3)), which does not affect the lawfulness of processing before withdrawal.
Write to privacy@podium.lol. We answer within one month, extendable by two further months for complex requests, and we will tell you if we need the extension. We may ask you to confirm you control the account before acting on a request.
You can request account deletion at podium.lol/delete-account or by writing to privacy@podium.lol. The current app version does not yet expose a deletion control in Settings. Analytics and crash-report consent can be withdrawn in the app.
You also have the right to lodge a complaint with a supervisory authority, in particular in the member state of your residence, place of work, or the place of the alleged infringement. Our lead authority is Die Landesbeauftragte für den Datenschutz Niedersachsen, Hannover, Germany.
11. Providing data, and what happens if you do not
Providing a sign-in identifier, a handle, and a category is necessary to create a listing; without them there is no account and no board entry. A photo, a tagline, a city, and links are optional, though a listing without a photo is far less effective. Notifications, analytics, and crash reporting are entirely optional and refusing them does not restrict the service.
12. Security
Data is encrypted in transit with TLS and at rest by our infrastructure provider. Session tokens are held in the platform keychain or keystore. Access to production data is limited to the operator. Purchases are verified server-side against the store, so a client cannot grant itself Crowns. We keep an immutable ledger of every Crown movement so that any discrepancy is detectable.
13. Children
Podium is not intended for anyone under 16, and we do not knowingly process the data of a child. Accounts we believe belong to a child are frozen and deleted, and the associated content is removed.
If you believe a child is using Podium, report the profile in the app or write to legal@podium.lol and we will act promptly.
14. Changes to this policy
We update this policy when the processing changes. The date at the top always reflects the current version, and a material change is announced in the app or on the website before it takes effect.