Privacy and cookies

Who is responsible

The data controller is Paolo Cappelletti, operating under the FluxDigital brand, Via Trieste 8, Villa Guardia (Como), Italy. Contact: hello@fluxdigital.app.

This notice covers the Ten Pair Duel landing page, email signup and mailing list. It does not replace the privacy information for the iPhone app, the App Store or other FluxDigital services.

What data is used

The signup asks for your email address. Sender also records information needed to manage the subscription, such as the source form, consent and signup dates, subscription status, delivery errors and unsubscribe requests. Technical records may include an IP address and browser or device information.

When you visit the landing or load the embedded signup form, our website and email service providers receive connection information such as your IP address, the requested page, time and browser details, to deliver and secure the service. The form provider also reports form views and submissions.

Sender’s email service records message openings and link clicks using tracking pixels and tracked links. These can associate the message, opening or click time, IP address and device information with your subscription. We use these reports to understand email engagement. Image blocking, privacy features and automated link checks can affect their accuracy.

We do not ask for your Apple Account password, payment details or in-app purchase history through this form. Apple handles redemption and eligibility in its own systems.

Why we use it

With your consent, we use your address to send the Welcome Pack email and occasional Ten Pair Duel news and game updates, including the email measurement described above. The legal basis is consent under Article 6(1)(a) GDPR; consent also applies to non-essential tracking under the applicable electronic communications rules. Signing up is voluntary; you can use the game without joining this mailing list. An email address is necessary to send the pack by email.

Submitting the form with your consent starts your subscription and triggers the Welcome Pack email. No separate confirmation email is required.

Limited delivery, security and consent records are also used to prevent abuse, handle requests and demonstrate how the subscription was obtained. This processing relies on our legitimate interest in operating a secure, permission-based mailing list, under Article 6(1)(f) GDPR. Legal obligations apply where required.

Who processes the emails

We use Sender, operated by UAB Sender.lt, as our email service provider. It processes subscriber data on our behalf to manage forms, subscriptions and email delivery. Sender states that subscriber data is hosted in the European Union by default.

EU hosting does not mean that all processing stays in the European Economic Area. Sender’s Data Processing Agreement provides for international processing and lists sub-processors inside and outside the EEA. For its US sub-processors, that agreement identifies the EU–US Data Privacy Framework as a transfer safeguard. You can request information about the applicable safeguards and a copy of the relevant documentation from hello@fluxdigital.app. See also Sender’s privacy policy.

Access is limited to the controller and service providers involved in hosting, email delivery, subscription management and technical support, acting within their roles. Authorities or professional advisers may receive relevant records when required by law or necessary to handle a legal claim.

We do not sell this mailing list or upload it to Meta advertising audiences as part of this signup.

How long we keep it

We keep your active subscription until you unsubscribe, or for a maximum of 24 months without a confirmed interaction, such as a new request or a reply from you. We then remove the inactive contact from the active mailing list and delete personal data no longer needed. An automatically detected email opening alone does not restart this period.

Unsubscribing stops future marketing emails; it does not immediately erase the contact’s existing history. A minimal suppression record may be kept while needed to prevent further marketing. We retain only the consent, unsubscribe or request records needed to demonstrate compliance or handle legal claims, for the period applicable to that purpose. You can ask us to erase other data.

Technical connection records are kept only for the time needed to operate the service and investigate security incidents. Browser storage has the separate lifetimes described below. Data already received by Meta is subject to Meta’s retention policy.

Optional advertising measurement

Where advertising measurement is enabled on this landing, Meta Pixel loads only after you select “Allow”. It measures page visits and successful Welcome Pack signups so we can understand which ads bring interested players. The legal basis is your consent under Article 6(1)(a) GDPR and the applicable rules on non-essential cookies. Selecting “Decline” does not prevent you from requesting the Welcome Pack. This choice is separate from consent to receive emails and their tracking.

Meta receives the event type, page and referral information, IP address, browser and device information, and its advertising identifiers. The integration does not send your email address, name, Sender subscriber ID or form-field values to Meta. Automatic event detection and advanced matching are not used. Meta may associate events with its own account and advertising data. See Meta’s privacy policy and cookie policy for its processing, recipients and international transfers.

For the collection and transmission covered by the GDPR, FluxDigital and Meta Platforms Ireland Limited, Block J, Serpentine Avenue, Dublin 4, Ireland, act as joint controllers under the Meta Controller Addendum. We provide this notice and implement the consent controls; Meta handles rights requests concerning the data it stores after transmission. Meta’s subsequent processing is its own responsibility. You can exercise your rights with either party; Meta’s contact details and privacy request options are in its privacy policy.

Privacy choice · necessary local storage

ten-pair-marketing-consent-v1 stores your allow/decline choice and its expiry for 180 days in this browser. It contains no email address. It is used to remember and respect your choice, not for advertising.

Meta attribution · optional cookies

If allowed, Meta may set _fbp to recognise a browser (90 days, as stated in Meta’s cookie policy) and _fbc to attribute an advertising click. Meta controls the cookies’ lifetimes and may update them; see Meta’s cookie policy for details of its cookies and choices.

Signup counting · session storage

After an allowed, successfully measured signup, ten-pair-lead-sent-v1-live stores only a yes/no flag for the browser tab’s session, to avoid counting the same signup again. It contains no email address or subscriber ID.

You can change your choice at any time using . Declining after allowing stops subsequent events and removes this landing’s accessible first-party Meta cookies. It does not recall data already sent to Meta. Email subscription and unsubscribe choices remain separate.

Your choices and rights

Use the unsubscribe link in an email, or write to hello@fluxdigital.app. Withdrawing consent does not affect processing that was lawful before withdrawal.

To request withdrawal of email tracking consent separately, contact us at the same address. Sender currently does not offer a setting that disables tracking while keeping its automated emails active. Unsubscribing stops future marketing messages through Sender; it does not erase tracking data already recorded. Website cookie choices do not change email tracking.

You can request access, correction, erasure, restriction and, where applicable, portability of your data. You can object to processing based on legitimate interests and to direct marketing. You may complain to your local data protection authority or the Italian Garante per la protezione dei dati personali.

This mailing list does not make automated decisions that have legal or similarly significant effects on you.

We normally respond to privacy requests within one month. If a permitted extension is needed because a request is complex, we will explain this within that month. We may ask for enough information to verify that the request concerns your data.