### 1. Controller and contact
Controller for the platform: ULTIDO GmbH, [PLACEHOLDER: registered address, Pulheim], represented by [PLACEHOLDER]. Email: max@ultido.com, Phone: +49 221 16535560. Data Protection Officer: [PLACEHOLDER / "not appointed"]. `[LAWYER REVIEW: DPO obligation.]`
### 2. Two controllers
Ultido is controller for game profile/account, game state, cross-park persona, AI image feature, platform operation. The respective **park** is controller for email marketing; at collection Ultido acts as the park's processor (Art. 28), and after double-opt-in confirmation the record is handed over to the park (controller-to-controller). Park contact: [PLACEHOLDER].
### 3. Data, purposes, legal bases
*(See the table in the German section — identical categories: email = Art. 6(1)(b); profile/state/persona = Art. 6(1)(b); marketing = Art. 6(1)(a) + §7 UWG, park as controller; photo = Art. 6(1)(a) + §22 KUG, transient; logs/IP = Art. 6(1)(f)/(c); consent log = Art. 6(1)(c) w/ Art. 7.)*
### 4. Recipients and subprocessors
Vercel (hosting, EU region/US parent), Clerk (auth, US), Supabase (DB, EU region/US parent), Cloudinary (media, US parent), Google Cloud/Vertex (AI styling, transient photo), GPU host [PLACEHOLDER], n8n (self-hosted). Art. 28 DPAs in place/to be concluded. Details in the Subprocessor Register (Doc. 8).
### 5. International transfers (Chapter V)
Several providers process in or are owned in the US. Transfers rely on EU Standard Contractual Clauses (Art. 46(2)(c)) and/or, where certified, the EU-US Data Privacy Framework. Safeguards available on request. **AI image hybrid:** depending on the chosen style, the photo is processed **either** on Ultido's own EU-region infrastructure **or** via Google Vertex (possible US processing under EU SCC); in both cases the original is processed transiently and not stored. `[LAWYER REVIEW per provider.]`
### 6. Retention
As in the German table: account for the duration of use (deletion after [PLACEHOLDER] inactivity or on request); confirmed marketing lead until withdrawal; unconfirmed lead deleted after DOI TTL; original photo transient (not stored); styled image [PLACEHOLDER]; logs [PLACEHOLDER]; consent log relationship + limitation period (~3 years). `[LAWYER REVIEW.]`
### 7. Your rights
Access (15), rectification (16), erasure (17), restriction (18), portability (20), objection (21); withdraw consent at any time (Art. 7(3)). Requests to max@ultido.com; marketing-related requests are forwarded to the responsible park. You may lodge a complaint with a supervisory authority ([PLACEHOLDER: LDI NRW] or your local authority).
### 8. Obligation to provide
Email is required for the account and reward; without it the Service cannot be used. Marketing and AI consents are voluntary with no disadvantage if refused.
### 9. Automated decision-making / profiling
No Art. 22 automated decisions with legal effect. The cross-park persona serves recognition/personalisation only. `[LAWYER REVIEW if used for ad targeting.]`
### 10. Minors
See youth-protection module (Doc. 6). Consent age in Germany: 16 (Art. 8); below that, parental consent is required.
### 11. Changes
We update this Notice when processing changes; the version published in the Service governs.