What the Shell

Privacy Policy

Last updated: 2 May 2026

Translations of this document into nine other languages are provided for your convenience. In case of any discrepancy between this English version and a translation, the English version controls.

1. Data Controller

Charles Smith (trading as Ludisto)
Gartenstr. 3a
10115 Berlin
Germany

Email:

If you have questions about your data or want to exercise any of the rights described below, email us. We’ll reply in English, German, or Esperanto.

2. What This Policy Covers

This policy explains what happens to personal data when you use What the Shell — the mobile and tablet app and the companion website at whattheshell.games. It applies to everyone, but it is written with the General Data Protection Regulation (GDPR / DSGVO) in mind because we are based in Berlin.

You can play What the Shell against the computer or in tutorial mode without an account and without sending any personal data to our servers beyond the minimal anonymous analytics described in section 3.5. Personal data is only collected when you choose to play online, which requires an account.

3. What We Collect and Why

3.1 Account data (only if you create an account)

3.2 Game data

Game records (moves, outcomes, timestamps, and the usernames of the two players) are visible to the two players of the game. We may also use individual games to showcase or promote the Service, as described in Terms of Service, section 6.

What is never shared publicly: your email address, IP address, password hash, push notification tokens, account metadata, and preferences.

3.3 Push notification data (only if you allow notifications)

When you grant notification permission in the app, your device issues a push token:

We store this token against your account so we can notify you when it’s your turn, your opponent has resigned, a rematch has been requested, etc. You can revoke the permission in your operating system settings at any time — that invalidates the token and we stop being able to reach you.

3.4 Technical data (server logs)

Our hosting provider (Vercel) keeps standard HTTP access logs — things like IP address, user agent, request path, timestamp — for a short period, for security and operations. We do not read or aggregate these logs for analytics.

3.5 Anonymous in-app analytics

The app records two kinds of best-effort analytics:

We use these to understand whether the tutorial is working and whether the AI difficulty curve feels right. We do not use any third-party analytics, tracking, or advertising SDK.

3.6 Beta tester email updates

While What the Shell is in beta, every account created on the website is automatically enrolled in occasional email updates for testers. These messages cover things like new build releases, known issues, planned events, and other information directly relevant to your role as a beta tester. They are not promotional emails for the general public.

To unsubscribe, reply to any such email with “unsubscribe” and we will remove you from the list. Unsubscribing only affects these tester updates — you will still receive transactional emails (sign-up confirmation, password reset) because those are required to operate your account.

When the game leaves beta and reaches general release, this auto-enrollment ends. You will receive one final email inviting you to opt in to the post-launch newsletter; without that opt-in, you will not receive further updates from us.

3.7 Booth and demo devices

At in-person events and game-industry showcases, What the Shell may run on shared tablets in a special “booth mode” signed in to generic system accounts that we operate. If you play on one of those tablets:

4. Lawful Basis

We rely on the following lawful bases under Art. 6 GDPR:

5. Who We Share Data With

We use a small number of service providers (“processors” under GDPR) to operate the game. We have or are in the process of executing data processing agreements (DPAs / Standard Contractual Clauses) with each of them.

ProviderPurpose
Vercel Inc.Hosts our website and API backend; serves web pages; writes server logs.
Upstash Inc.Stores account and game data in a Redis database; daily backups to Vercel Blob.
Upstash QStashRuns scheduled tasks (move deadline reminders, daily backups).
ResendDelivers transactional emails (sign-up confirmation, password reset).
Apple Inc.Delivers push notifications to iOS devices via APNs.
Google / FirebaseDelivers push notifications to Android devices via FCM.

All of the providers above are US-incorporated. Upstash Redis — which holds your account and game data — is configured to store that data in the EU (Frankfurt, eu-central-1). Data residency for the other providers is being verified during an in-progress service audit and will be reflected here as that work completes.

We do not sell or rent your data to anyone. We do not use it to profile you or to build advertising audiences.

6. International Transfers

All of the providers above are US-incorporated companies. Where personal data does cross to the United States, those transfers rely on the European Commission’s Standard Contractual Clauses and, where applicable, the EU–US Data Privacy Framework. The exception is Upstash Redis, where data is stored in the EU as noted above; the SCC framework still governs the processor relationship with the US-incorporated entity. You can request a copy of the relevant safeguards by emailing us.

7. How Long We Keep Your Data

8. Your Rights

Under GDPR you have the right to:

To exercise any of these, email . We’ll respond within 30 days.

9. Security

10. Children

Accounts require you to be at least 16 years old, the DSGVO baseline in Germany. The game itself can be played without an account by anyone of any age — against the computer or through the tutorial — and collects only the anonymous analytics described in section 3.5.

11. Changes to This Policy

We may update this policy as the game evolves. If the change is material (new data categories, new processors, changes to your rights), we will announce it by email to registered users. The “last updated” date at the top of this page will always reflect the latest version.