Privacy Policy for the PaintWalk app

Last updated: 7 October 2026 · Deutsche Fassung

This privacy policy applies to the PaintWalk app for Android and iOS, to the web version of PaintWalk and to the website paintwalk.de. It explains which data we process, why, on what legal basis, who receives it and when we delete it.

Summary

PaintWalk is a game in which you paint pixels onto a world map while you walk. To do that, the app needs your precise location.
If you turn on lock mode, the app collects your location even when your screen is locked or you are using another app. It runs until you stop it or until you have painted no new pixel for two hours, and for four hours at most.
For every pixel you paint, we store the centre of the pixel, accurate to about 3 metres, the time, the GPS accuracy and your speed, together with your account. Taken together, this shows where and when you painted. After 90 days we remove the link to you from this history and shorten the time to the day.
Painted pixels are visible to everyone on the world map. If you play anonymously, the app does not show your name or profile picture with them.
Our database is in a data centre in Frankfurt am Main, Germany.
PaintWalk shows no ads. An advertising SDK from Google is included in the app but does not start. It only starts if we switch ads on and you have consented beforehand.
You can delete your account in the app or at paintwalk.de/delete-account/.

1.Who is responsible

X-Concapps GmbH
Bismarckplatz 7
45657 Recklinghausen
Germany

Managing directors: Birgit Großhanten, Jonah Großhanten
Phone: +49 157 37312502
Email: info@x-concapps.com

For all privacy questions and deletion requests, write to info@x-concapps.com.

2.Where your data is stored

We store your account, game progress, painted pixels and painting history with Supabase. Our contracting partner is Supabase Pte. Ltd., 65 Chulia Street #38-02/03, OCBC Centre, Singapore 049513. Our Supabase project is located in the EU region (Frankfurt am Main, eu-central-1) in an Amazon Web Services data centre. Requests from the app to our server pass through Cloudflare's network.

Supabase processes this data on our behalf. The basis is Supabase's data processing agreement, which contains the European Commission's standard contractual clauses. For support and operations, Supabase staff may also access the data from outside the EU, for example from Singapore or from Supabase, Inc. in the US (see section 5).

3.Which data we process and why

3.1Account and sign-in

Data

Email address, password (we store it only as a hash, never in plain text), user ID, username, display name, when you registered and when you were last active, your game statistics (for example the number of pixels painted), your language setting and whether you play anonymously.

You can sign in with email and password, with Google or with Apple. If you sign in with Google, Google sends us your name, your email address and the link to your Google profile picture. If you sign in with Apple, Apple sends us your email address or, if you choose, a relay address created by Apple, and your name if you agree.

If you do not choose a username yourself, we create a provisional one from the part of your email address before the @ sign. You can change it at any time.

Purpose

To create your account, sign you in and link your game progress to you.

Legal basis

Art. 6(1)(b) GDPR. Without an account we cannot provide the game to you.

Recipients

Supabase (storage and sign-in). If you sign in with Google, also Google; if you sign in with Apple, also Apple (see 3.11). Google and Apple learn that you are signing in to PaintWalk.

Retention

Until you delete your account (see section 4).

3.2Painting and location

Data

While you paint, the app continuously reads your precise location (GPS) on your device. When you paint a pixel, the app sends to our server: the position where you paint (of which we only store the centre of the pixel, accurate to about 3 metres), the pixel, the colour, the time, the GPS accuracy and your device's speed, together with your user ID. We also keep a list of the pixels you have painted in your profile.

You do not need location access to view the map. You can only paint with location access, because the game checks that you are at the pixel.

Purpose

So that you can only paint pixels near you and your pixels appear on the map.

Legal basis

Art. 6(1)(b) GDPR. Painting where you are is the core of the game. Reading your location on your device is covered by Section 25(2) No. 2 of the German Telecommunications Digital Services Data Protection Act (TDDDG), because this is strictly necessary for you to use the painting feature you asked for.

Recipients

Supabase.

Retention

A pixel stays linked to you with its position until someone else paints over it or you delete your account. 90 days after painting, we shorten the time to the day and delete the GPS accuracy and speed.
The list of pixels you painted in your profile is kept until you delete your account.
For painting history, see 3.4.

3.3Lock mode: location while your screen is locked

Lock mode lets you keep painting while you walk with your phone in your pocket. You turn it on yourself in the open app with the lock icon. Before the first start, the app explains in a separate notice what will happen and only starts lock mode once you tap "Agree".

Data

The same as in 3.2. While lock mode runs, however, the app also collects your location when your screen is locked, when you use another app or when PaintWalk is not in the foreground, and paints pixels as you go.

How long

Lock mode ends

when you stop it: on Android with the stop button in the notification, on all devices by tapping the lock icon again,
by itself when you have painted no new pixel for two hours,
four hours after it started at the latest.

After that, the app no longer collects your location in the background. On Android, your phone shows a notification the whole time that PaintWalk is using your location. Lock mode does not restart by itself after a phone restart or an app update.

Purpose

So you can paint hands-free.

Legal basis

As in 3.2 (Art. 6(1)(b) GDPR, Section 25(2) No. 2 TDDDG). You switched lock mode on yourself. You can take back the agreement you gave in the notice in the app's settings. If lock mode is running, it then stops, and the app asks again the next time you turn it on.

Recipients and retention

As in 3.2 and 3.4.

3.4Your painting history

Data: Each time a pixel is painted, we add an entry to that pixel's history: the position, the time, who painted it, who owned the pixel before, the GPS accuracy and the speed. Taken together, your entries show where and when you painted.
Purpose: We use it to show you the pixels you painted, to be able to restore pixels after errors or abuse, and to detect cheating (see 3.5).
Legal basis: For your own overview and for restoring pixels, Art. 6(1)(b) GDPR. For detecting cheating, Art. 6(1)(f) GDPR (see 3.5).
Recipients: Supabase. What others can see is described in 3.6.
Retention: 90 days after painting, we remove from the entry who painted the pixel and who owned it before, delete the GPS accuracy and speed, and shorten the time to the day. What remains is that the pixel got this colour on that day. If you delete your account, we delete your entries immediately.

3.5Fair play, anti-cheating and moderation

Data: Speed, GPS accuracy, distance to the pixel and how often you paint. If we flag, warn or ban an account for breaking the rules, we store that and the reason. If you report a pixel, we store the report, the pixel, the reason and your user ID.
Purpose: To detect faked locations (GPS spoofing) and automated painting, keep the leaderboard fair and review reported content.
Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is a fair game and a world map that is not shaped by cheating or offensive content. We will send you our balancing assessment on request. You can object (see section 9).
Recipients: Supabase. Reports are also seen by the people who moderate for us.
Retention: We delete speed and GPS accuracy after 90 days (see 3.2 and 3.4).

We keep flags, warnings and bans on your account until you delete your account.

We keep reports as long as we need them to handle them and to detect repeated abuse. If you delete your account, we remove the link to you from your reports.

3.6What others can see

Painted pixels and their colour are visible to everyone on the world map, in the app and in the web version.
Your username and profile picture are part of your public profile. The app only shows them if you do not play anonymously: on your pixels, in the leaderboard and on pictures you share. Anonymous is the default. You can change this in your profile.
On a pixel, others can see when it was last painted, and after 90 days only the day. A pixel's history is visible only to you (your own entries) and to the people who moderate for us.
The leaderboard shows the number of pixels you painted and your rank. If you play anonymously, you appear there without a name.
You can save a map section as a picture in your profile. The picture contains the pixels in it, their position and, unless they play anonymously, the names of the players who painted them. If you share a picture in the community, everyone can see it.
If you vote on a shared painting, we store your vote (up or down) with your account. Others only see the vote totals, not who voted how.
Your email address, GPS accuracy, speed, the list of pixels you painted and moderation data are not visible to others.

Purpose: The shared world map and the competition are the core of PaintWalk.
Legal basis: Art. 6(1)(b) GDPR for the map and the leaderboard. You decide whether the app shows your name.
Recipients: All PaintWalk users. The map can be viewed worldwide.
Retention: As in 3.2 and 3.4. Saved and shared pictures stay until you delete them or your account.

3.7Profile picture: camera and photos

Data: The photo you take or choose yourself. On Android, the app uses the system photo picker and only sees the picture you select. On iOS, your iPhone may ask for access to the camera or photos when you set a profile picture.
Purpose: As the profile picture in your profile and, if you do not play anonymously, in the leaderboard.
Legal basis: Art. 6(1)(b) GDPR. A profile picture is optional.
Recipients: Supabase (profile picture storage).
Retention: Until you replace it or delete your account.

3.8Map (CARTO)

The app loads the background map images from CARTO (basemaps.cartocdn.com). The map data comes from OpenStreetMap.

Data: Your IP address, the map tiles requested (that is, roughly which map section you are looking at) and technical information about your device that is sent with every internet request.
Purpose: So that you can see a map.
Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is being able to show you a map without running our own map servers.
Recipient: CartoDB Inc. (CARTO), 307 Fifth Avenue, Floor 9, New York, NY 10016, USA. Privacy policy: carto.com/privacy.
Third country: USA. CartoDB Inc. is certified under the EU-US Data Privacy Framework (see section 5).
Retention: Set by CARTO. CARTO's privacy policy generally states a retention period of up to two years for personal data.

3.9Place search (Nominatim)

When you search for a place in the app, the app sends your search term to the Nominatim search service (nominatim.openstreetmap.org). The operator also receives your IP address and technical information about your device. If you search for your current location, your position is sent to Nominatim as well.

Purpose: So that you can jump to a place on the map.
Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is offering you a place search.
Recipient: OpenStreetMap Foundation, Cambridge, United Kingdom. Privacy policy: osmfoundation.org/wiki/Privacy_Policy.
Third country: United Kingdom. There is a European Commission adequacy decision for it (Art. 45 GDPR). According to the OpenStreetMap Foundation, it stores personal data in the United Kingdom and the Netherlands.
Retention: Set by the OpenStreetMap Foundation. Its privacy policy does not state a separate period for search queries.

3.10Purchases and subscriptions

Purchases and subscriptions in PaintWalk are handled by Google Play and the Apple App Store. Only Google or Apple receive your payment details (for example your credit card), not us.

Data: Which product you bought, when, the purchase receipt or purchase token, the status of your subscription and what you own in the game.
Purpose: To check that a purchase is genuine and unlock what you bought. The receipt check runs through a service on our Supabase server, which asks Google or Apple.
Legal basis: Art. 6(1)(b) GDPR. Keeping purchase data after you delete your account is based on Art. 6(1)(c) GDPR in conjunction with the tax retention duties under Section 147 of the German Fiscal Code (Abgabenordnung).
Recipients: Google (Google Play) and Apple (App Store), see 3.11, and Supabase.
Retention: As long as your account exists. If you delete your account, we detach the purchase data from your account and keep it restricted for as long as legal retention duties apply. Restricted means we only use it to meet those duties.

3.11Google and Apple: sign-in, purchases, game services

The app connects to Google Play Games (Android) or Game Center (iOS) when it starts. If you are signed in there, Google or Apple learns that you play PaintWalk and stores your achievements. You can sign out of these services in your phone's settings.

Data

Your player ID with Google Play Games or Game Center and the achievements you earn in PaintWalk.

Purpose

So you can collect and compare achievements.

Legal basis

Art. 6(1)(f) GDPR. Our legitimate interest is offering you achievements through your phone's game services.

Recipients for sign-in (3.1), purchases (3.10) and game services

For users in the European Economic Area, Google's privacy policy names Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, as the responsible controller. Google processes the data as an independent controller under policies.google.com/privacy.

For users in the European Economic Area, Apple's privacy policy names Apple Distribution International Limited in Ireland as the responsible controller. Apple processes the data as an independent controller under apple.com/legal/privacy.

Retention

Set by Google or Apple.

3.12Advertising (Google AdMob)

PaintWalk shows no ads. The app contains Google's advertising SDK AdMob, but it does not start. On iPhone and iPad, the app therefore does not ask for permission to track you across apps (App Tracking Transparency) either.

If we switch ads on, the app will ask beforehand whether you consent. Only then does AdMob start, and only then does your iPhone ask for tracking permission. Before that, we will extend this section with the data AdMob receives, the advertising partners involved, the countries, the retention period and how to withdraw your consent. The legal basis will then be your consent (Art. 6(1)(a) GDPR, Section 25(1) TDDDG). You can withdraw it at any time with effect for the future, as easily as you gave it.

We do not pass your location to AdMob.

3.13Contacting us

Data: If you use the contact form in the app: email address, name, user ID and your message. If you email us: your email address and the content.
Purpose: To answer your request.
Legal basis: Art. 6(1)(b) GDPR if it concerns your account or the game, otherwise Art. 6(1)(f) GDPR. Our interest then is answering requests.
Recipients: Supabase (contact form). We receive emails on a mail server in a data centre in Germany.
Retention: We delete contact form requests once your matter is resolved, after 12 months at the latest. We delete emails once your matter is resolved and we do not have to keep them because of legal retention duties.

3.14Notifications and data on your device

PaintWalk shows notifications that are created on your device, for example the notice that lock mode is running. We do not send push messages through a server. On Android 13 and later, the app asks for permission to show notifications.

On your device, the app stores your settings, whether you agreed to the lock mode notice, and your sign-in session so you stay signed in.

Legal basis: Section 25(2) No. 2 TDDDG, because this storage is necessary for the app to work the way you want. Where personal data is involved, Art. 6(1)(b) GDPR applies.
Recipients: None. The data stays on your device.
Retention: Until you sign out, clear the app data or uninstall the app.

3.15Website paintwalk.de and web version

Google delivers the website paintwalk.de and the web version of PaintWalk through its Firebase Hosting service. When you open them, Google receives your IP address, the address requested, the time and technical information about your browser. Google processes this data on our behalf.

Purpose: To deliver the pages and detect abuse.
Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is delivering the website and the web version securely and reliably.
Recipient: Google (Firebase Hosting).
Third country: Firebase Hosting is a global service. Data may be processed in Google data centres outside the EU, including the US (see section 5).
Retention: According to Google, Firebase Hosting keeps IP addresses for a few months.

3.16Sharing

If you share a picture through your phone's share menu, it goes to the app you choose there. What that app does with it is up to its provider.

4.Deleting your account

You can delete your account at any time:

in the app under Settings, "Delete account",
on the web at paintwalk.de/delete-account/, even if you no longer have the app installed, or
by email to info@x-concapps.com. We confirm receipt within 5 working days and delete the account within 30 days.

What we delete immediately

your account with email address and sign-in data,
your profile with username, profile picture and the list of pixels you painted,
your entries in the painting history (3.4),
your saved pictures (favourites) and the pictures you shared yourself,
your votes on pictures,
your in-game items (inventory),
your contact form requests.

What remains

Your painted pixels stay on the world map with their colour, place and time, but without a link to your account.
Reports you made about content are kept, but without a link to you, so that we can keep reviewing reported content.
We detach purchase data from your account and keep it restricted for as long as legal retention duties apply (see 3.10).
Supabase makes backups of our database. Deleted data may remain in them until these backups are overwritten in the normal cycle. We only use backups to restore the database after an outage.

An active subscription does not end automatically with your account. Cancel it in Google Play or in your Apple account settings.

If you signed in with Apple, you can disconnect your Apple ID from PaintWalk in your Apple ID settings under "Sign in with Apple".

5.Transfers outside the EU

Our database is in the EU (section 2). Some recipients are based outside the EU or access data from there:

Recipient	Used for	Country	Basis
Supabase Pte. Ltd. and Supabase, Inc.	support and operation of our database (3.1 to 3.7, 3.10, 3.13)	Singapore, USA	European Commission standard contractual clauses (Art. 46(2)(c) GDPR) in Supabase's data processing agreement
CartoDB Inc. (CARTO)	map images (3.8)	USA	European Commission adequacy decision on the EU-US Data Privacy Framework (Art. 45 GDPR); CartoDB Inc. is certified under it
OpenStreetMap Foundation	place search (3.9)	United Kingdom	European Commission adequacy decision for the United Kingdom (Art. 45 GDPR)
Google (Firebase Hosting)	website and web version (3.15)	worldwide, including USA	adequacy decision on the EU-US Data Privacy Framework (Art. 45 GDPR), Google LLC is certified under it; otherwise standard contractual clauses in Google's data processing terms for Firebase

Google Ireland Limited and Apple Distribution International Limited (3.11) are based in Ireland. According to their own statements, they also transfer data to the US: Google relies on the EU-US Data Privacy Framework, Apple on standard contractual clauses.

You can request a copy of the standard contractual clauses for Supabase from us at info@x-concapps.com. You can check whether a US company is certified under the Data Privacy Framework at dataprivacyframework.gov.

6.Security

The app sends data to our server encrypted (HTTPS). We restrict access to the database with access rules per table and column, so that others only see what is described in section 3.6.

7.Do you have to provide data?

You are not legally required to give us data. Without an account you cannot paint. Without location access you cannot paint, but you can still view the map. A profile picture, a display name and showing your name are optional.

8.Automated decisions

Each time you paint, PaintWalk automatically checks speed and GPS accuracy. If they are outside the limits for fair play, the pixel is not painted. This only affects that single paint action. People decide on flags, warnings and bans of accounts. We do not make decisions based solely on automated processing that produce legal effects concerning you or similarly significantly affect you (Art. 22 GDPR).

9.Your rights

You have the right to

access your data (Art. 15 GDPR),
have incorrect data corrected (Art. 16 GDPR),
erasure (Art. 17 GDPR),
restriction of processing (Art. 18 GDPR),
data portability (Art. 20 GDPR).

If you have given consent to something, you can withdraw it at any time with effect for the future (Art. 7(3) GDPR).

Write to info@x-concapps.com. We will reply within one month (Art. 12(3) GDPR).

10.Complaints to a supervisory authority

You can lodge a complaint with a data protection supervisory authority (Art. 77 GDPR). The authority responsible for us is:

Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen
(State Commissioner for Data Protection and Freedom of Information of North Rhine-Westphalia)
Kavalleriestraße 2-4
40213 Düsseldorf, Germany
Phone: +49 211 38424-0
Email: poststelle@ldi.nrw.de
Web: www.ldi.nrw.de

11.Age

PaintWalk is intended for people aged 16 and over.

12.Changes

If the way PaintWalk processes data changes, we update this policy and the date at the top. If we want to use data for a new purpose, we will tell you beforehand (Art. 13(3) GDPR).