Privacy
Version: draft 2026-10-21
Who is responsible
Lotus Chess UG (haftungsbeschränkt), [Raphael: address], privacy@mhtirogla.ai. [Raphael: data protection officer, if one is required.]
The short version
We store your email and what we need to run your plan. No passwords, no tracking, no ads, no selling data. Deleting your account removes everything we hold about you at once, except records tax law makes us keep.
What we store and why
| Data | Why | Basis (GDPR) | How long |
|---|---|---|---|
| Email address | sign-in links, account and billing mails | contract, Art. 6(1)(b) | until you delete the account |
| Plan, created date, Stripe customer and subscription ids | run your plan | contract, Art. 6(1)(b) | until you delete the account |
| API key hashes (never the key itself) | check your calls | contract, Art. 6(1)(b) | until you delete the key or account |
| Passkey public keys (never a private key) | passkey sign-in | contract, Art. 6(1)(b) | until you remove the passkey or account |
| Session cookie | keep you signed in | contract, Art. 6(1)(b); strictly necessary, no consent banner needed | until you sign out, at most 30 days. Sign-in links expire after 15 minutes and work once |
| Calls per key per day | limits, usage page | contract, Art. 6(1)(b) | in memory only, reset every day (UTC) and at every restart; never written to disk |
| IP address (in memory) | rate limits for calls without a key, abuse protection | legitimate interest, Art. 6(1)(f) | in memory only, never written to disk |
| Web server access log (IP address, time, requested URL) | operations, abuse protection | legitimate interest, Art. 6(1)(f) | rotated, at most 5 files of 50 MB, then overwritten [Raphael: or turn IP logging off, Tech can] |
| Invoices and payment records | tax and accounting law | legal obligation, Art. 6(1)(c) | as German tax law requires [Raphael: period] |
Documentation requests and searches that found nothing are stored as text only (topic, reason, query), without your email, IP or account. Do not put personal data in them.
Who else processes data
These three are the only processors.
| Who | What for | Data |
|---|---|---|
| Stripe | card payments, billing portal | what you enter at checkout; Stripe processes card data, we never see it. Stripe's privacy policy applies to its part. |
| [Raphael: Postmark or Resend] | sending sign-in links | your email address, the mail itself |
| Hetzner Online GmbH, EU data centre [Raphael: confirm location] | hosting | everything above; all our data is stored there |
[Raphael: data processing agreements with each; note on transfers outside the EU for Stripe and the mail provider, with the safeguard used.]
Your rights
You can ask for access, correction, deletion, restriction, data portability and object to processing based on legitimate interest; you can also complain to a data protection authority. Most of it you can do yourself on the account page (keys, passkeys, delete account). Otherwise write to privacy@mhtirogla.ai.