Privacy Policy of “QR Hunt”

THE CREATORS RESERVE THE RIGHT TO CHANGE THE GAME WHILE IT IS RUNNING. How changes to this policy are announced — in the “Changes” section.

In force from 21 October 2026.

Here we write what personal data the “QR Hunt” game collects, why, who sees it, how long we keep it and what rights you have. The policy follows Regulation (EU) 2016/679 (General Data Protection Regulation, GDPR) and the Bulgarian Personal Data Protection Act.

In brief

• You sign in with bansko.be. From there we receive your profile number, name and email.
• Anyone, even without signing in, sees in “Prizes” the top five of each age category: the leaderboard name, points and category. Signed-in players also see “Leaderboard” — all players with at least one point. Your real name, email and date of birth are not shown.
• We take your location when scanning and for radar requests: only while following with “Where is it?” is on. The radar does not record your position. The camera reads the code inside the phone itself.
• Friends are added in person, with an in-game code valid for 10 minutes, and adults also from the map, with a request the other person accepts. Your friends see only your leaderboard name. The map shows no names: a friend’s name appears only when you tap their avatar. Above the first three adults in each category the map shows a crown with their place (1–3); because the leaderboard is by name, the crown can give away where that person is (section 4).
• The Helper (optional) uses your position only to work out the level and forgets it. We do not record it and do not send it to the database. The server keeps only counters for the limits, for up to 24 hours.
• The game works only within the territory of Bansko Municipality. Outside it we refuse and do not keep your coordinates.
• Volunteers who suggest places also submit a photo. Read section 2 (“If you are a volunteer”) and section 5.
• The cookies for signing in always work. Meta cookies (Meta Pixel) for measuring the game’s ads are used only if you accept them; you can change your choice under “Cookies” at the bottom of the page.
• We send notifications (push) only if you turn them on yourself under “Notifications”. You can turn them off at any time. Installing the game as an app stores nothing new on the server.
• We send an email at the start of the game only if you ask for it yourself. You can unsubscribe at any time.
• You can ask for a copy or deletion of your data at support@bansko.be.
• If you are under 18, show this page to a parent.

1. Who is responsible for your data

The controller of personal data is the organizer of the game — VIEM-STROY OOD (ЕИК 101699006; registered office: 3 Petko R. Slaveykov Street, 2770 Bansko; support@bansko.be).

“We” in this text means the organizer. The “Creators” are the organizer and the team that makes the game on its behalf.

Sign-in uses a bansko.be profile. bansko.be is the organizer’s site, separate from the game. For the data in your profile there, its policy applies: bansko.be/privacy (opens in a new tab).

2. What data we collect

From bansko.be, at every sign-in

• your bansko.be profile number;
• the name in the profile;
• the email in the profile.

Your profile in the game is created at the first successful sign-in, even before you choose a leaderboard name. At every sign-in we update the name and email from bansko.be and do not keep the old ones. The exception is the log of team actions: in it the name or email stays as it was at the time of the action. Another exception is the copy of the start email: it keeps the email address it was sent to (section 10). Your password stays in bansko.be: the game does not see it and does not store passwords.

Data you enter

• leaderboard name;
• date of birth (day, month and year);
• optionally: whether we should write to you when the game begins (section 10).

Data the game creates

• an internal player number and when the profile was created;
• if you signed up before the start — your hunter number: the sequence number under which you joined the list of hunters (“Hunter #…”);
• your points;
• the hints you bought: for which place, when and for how many points — to calculate your total and to check disputes;
• when you got the one-time notifications bonus (+33 points), if you got it: a time in your record, so it is not given twice;
• whether you take part in the leaderboard and the prizes;
• your counted scans: which plaque, when, how many points and at what distance from the marker — the point of the place from which the radius is measured;
• your counted golden scans (see “Golden codes” in the Rules): which place, which code, which Sofia day, when, how many points and at what distance from the marker. We keep them in a separate list, but like scans;
• your age category and your place in it: the game calculates them from the date of birth, the points and the end date of the campaign (19 November 2026) every time it shows them, and does not store them separately;
• for each age category the current top three (the crowns): the internal numbers of the players and the time of the last change. The record is overwritten on every change;
• how many partner logos you have seen while scanning today: a counter for the day, without coordinates and without a plaque code. It is deleted automatically within 3 days after the day. When you open the scan screen, a service token is also created (which player, which partner, which day); it is valid for 10 minutes and is deleted in the hourly clean-up.

From the phone — when scanning and with the radar

When you attempt a scan, the phone sends the code from the plaque, its coordinates and the GPS accuracy. With the radar it sends the position and accuracy while following with “Where is it?” is on (section 9).

What you see and what we keep on a refusal. For “too far” the game shows you only a rough band — near, far or very far, described in a sentence — and your phone’s GPS accuracy, not metres. The exact distance to the marker, rounded to 10 m, we keep only in the database, for checking against fraud. We do not show it to players. For a refusal “outside Bansko Municipality” we do not calculate distance and do not keep coordinates. The radar receives, together with the position, which is its current target (an opaque internal plaque number, with no name and no plaque code), in order to answer you. None of this is recorded.

Technical data

• cookies for the session and for sign-in (section 8);
• counters against abuse: your internal number and how many attempts you have left;
• a counter of radar requests: your internal number and when you asked, to stop abuse. It sits only in the memory of the game’s server, not in the database, and disappears on restart (section 9);
• Helper counters: your internal number, the sequence number of the request, when the session started, when you last asked, how many notifications were sent this hour, when the pause after “Burning!” ends and a counter of unrealistic jumps. No position. They are deleted after 24 hours without use (section 9);
• the random number of every one-time sign-in key from bansko.be (token) and when it expires — with no link to you. We keep it so that a token cannot be used a second time.

If you turn on notifications (push)

You receive notifications only if you turn them on yourself on the “Notifications” page. Then we keep, linked to your profile:

• the subscription address (endpoint) that your browser gets from its vendor’s notification service;
• the subscription keys (p256dh and auth): we use them to encrypt the message so that only your device can read it;
• the topics you chose: start, leaderboard. If you also chose “hints” before 19 October, the topic stays recorded, but it is no longer offered and nothing is sent on it;
• the language of the notifications: Bulgarian or English;
• when the subscription was created and when we last sent a notification successfully.

For notifications from the server we keep two more things. First: that a personal notification was sent to you today and of which kind — “Someone passed you” or a crown one (entering, leaving or changing metal in the top three) — your internal number, the day and the kind; we delete it after 7 days. Second: which general notification was sent (for example the start) — only a key and a time, with no data about a player. Some general notifications (for example for a “happy hour”) go only to adult players: on the day of sending we check from your date of birth whether you are 18 or older. The result is not stored. In the same way, for personal notifications we check from your date of birth whether you are under 18: children get no personal notifications from 19:00 to 08:00. A skipped notification is not sent later. The organizer may also send a manual notification about the game under the “Hunt start” topic — to adults (on the day of sending we check by your date of birth whether you are 18 or older; the result is not kept) or to everyone with this topic; not from 22:00 to 08:00, and to everyone not from 19:00 to 08:00 either (then the send is refused). The third kind is a notification to one player chosen by the organizer (found only through a name search): it goes only to the subscriptions that have at least one topic switched on, and it can reach you whichever topics you chose, as long as notifications are on. It is not sent from 22:00 to 08:00; if you are under 18 by date of birth (no date of birth counts as a minor), it is not sent from 19:00 to 08:00 either. For such a send we keep in the team’s action journal the recipient (number and name — your leaderboard name, otherwise your bansko.be name), the title and the text, for up to 1 year after the end of the campaign (section 7). The send log holds no data about you.

The bonus for turning on notifications (+33 points, once): we keep only when it was given. Consent to notifications and its withdrawal work as before; withdrawal never takes points away.

The subscription address is unique to the browser and device, so it is personal data. The log of sent notifications has no data about players: it keeps only when, on which topic and with what title a notification was sent, how many were sent, how many did not arrive and how many subscriptions were removed, and whether an administrator or the system sent it.

If you add a friend

• who your friends in the game are and since when;
• your invitation code while it is valid: a random code valid for 10 minutes;
• counters of codes and acceptance attempts (against abuse);
• in your scans: a “+2 together” note when you received the bonus for hunting with a friend.

The camera reads a friend’s code on your phone, just like a plaque code (section 9).

If you send or receive a friend request from the map

Adults only, when the live map is open to players.

• who sent the request to whom, when, and its status (pending or declined);
• counters of requests sent (against spam).

The recipient sees your leaderboard name in the request. By sending the request you agree that they see it. A decline is not shown to the sender. When you accept, the request is deleted and only the friendship remains.

If the team takes measures

• The log of team actions keeps what was done, when and by whom. It also holds your leaderboard name, or, if you have none, your name from bansko.be.
• If we reset your leaderboard name, we keep the old name and the reason. The old name stays forbidden for everyone.

If you write to us

• We keep your email and our reply: your email and names, your leaderboard name and whatever you write to us.

If you win a prize

• On collection we check your identity document. We do not copy it.
• We sign a record: your names, the prize, the category, the place, the date and who handed it over.
• If you are under 18, the prize is collected by a parent or guardian. We also check their document and enter their name in the record.
• If the law requires it — for example for taxes — we enter in the record also the personal identification number (ЕГН) or foreigner’s number (ЛНЧ) and submit them to the National Revenue Agency.
• If the prize is in your name — for example a season ski pass or a game with a code in your name — we give its issuer your names and the data it requires (section 5).

If you are on the game team

• We keep a log of your actions in the management panel.
• When a team member gains or loses access to the management panel, their bansko.be name and email stay in the log.
• If you send a test start email from the panel, it goes to your bansko.be email. The address it was sent to stays in the log.
• Other team members see in the panel your bansko.be name and email, your number there and your leaderboard name.
• With the “Activate here” button (shown in Bulgarian only) the browser takes your position once. We keep only the distance to the centre of the place and the GPS accuracy, rounded to the metre. We do not keep your coordinates.
• “Use my location” takes your position once. It becomes the coordinates of the place only if you save the form.
• Profiles with access to the panel are automatically outside the leaderboards and the prizes.

If you are a volunteer

A volunteer is an adult player to whom the organizer has given this role (Rules, section 4). A volunteer suggests places for plaques and, after approval, may stick up and activate on site the plaques of their approved place.

• From your bansko.be profile we have the same as for every player: number, name and email.
• For every suggestion we keep: position and GPS accuracy, where the position was taken from (GPS or map), the photo, a note to the team, the hint and the short public description (optional), which you write and which a person from the team accepts or edits, the area from reverse geocoding, when it was submitted, status (pending, approved, declined), who reviewed it, when, the reason for refusal and the link to the approved place. The safety checkboxes on the suggestion screen are not recorded: they are a reminder to you as you fill it in. The volunteer does not set the name of the place or the radius.
• The position of the suggested place comes from the “Use my location” button: this is the position of your phone at the moment of submission. The position can also be picked on the map. While the suggestion is linked to your profile, it is data about you.
• Your actions as a volunteer go into the log of team actions: giving or withdrawing the role, submitting a suggestion, approval or refusal, activating a plaque. Your name or email stays there as it was at the time of the action.
• With the “Activate here” button (shown in Bulgarian only) the volunteer is like the team: the browser takes their position once, and we keep only the distance to the centre of the place and the GPS accuracy, rounded to the metre. We do not keep their coordinates.
• Volunteer profiles are automatically outside the leaderboards and the prizes. They stay so even after the role is withdrawn.

Rules for the photo. Photograph only the place of the plaque, in a public place, away from the roadway. No people or faces, especially children. No vehicle registration plates. No private property, except with the owner’s consent. Before upload, the browser shrinks the photo to at most 1600 pixels and strips its metadata (EXIF), including GPS coordinates. Every photo is viewed by a person from the team before publication: they check it for faces and registration plates.

Rules for the texts. The hint (10 to 300 characters) and the short description (up to 200 characters, optional) are written by you. Describe how to reach the plaque without giving away the exact place: no addresses, house numbers, or names or details of people. Do not put personal data in the note to the team.

How long we keep it. See section 7.

What we do not collect

• passwords;
• photos and video from the camera when scanning (only volunteers upload a photo — see “If you are a volunteer”);
• phone number, address, gender;
• identity document while you play: we check it only when you receive a prize;
• location outside scanning, radar and Helper requests and outside sharing on the live map; we keep the position for the map only temporarily (it expires in 2 minutes), just to show you live, and we do not archive it (for the team and volunteers see “If you are on the game team” and “If you are a volunteer”).

The application does not record your IP address. The only analytics service is Vercel Web Analytics, without cookies (section 5). For third-party advertising we use only Meta Pixel, and only with consent (section 8). Partner logos in the game are shown by us: we count how many times a scan logo was shown, without telling the partner who saw it (section 2). The hosting provider may keep its own technical logs (section 5).

Do you have to provide data

The law does not oblige you to give us data. It is a condition for taking part under the Rules: without signing in with bansko.be, a leaderboard name and a date of birth you cannot play. Without location you cannot collect points. The radar, the Helper and the volunteer role are optional: without them you play in exactly the same way. Without an identity document you cannot receive a prize. The email at the start is optional: without it you play in exactly the same way. Notifications (push) are optional: without them you play, but you do not get the one-time 33-point bonus.

3. What we use the data for and on what basis

Basis for protection against fraud. Art. 6(1)(f) — legitimate interest: fair play, protected plaques and secure data. You can object to this processing (section 12).

We use consent for the email at the start (section 10), for notifications (section 2) and for Meta cookies (section 8). The location and camera permissions in the browser are not consent under the GDPR: they only let the game reach the phone’s GPS and camera.

We do not sell your data. For third-party advertising we use only Meta Pixel, and only with consent (section 8). Partner logos in the game are shown by us: we count how many times a scan logo was shown, without telling the partner who saw it (section 2).

4. Who sees the data

Every visitor to the site, even without signing in, sees in “Prizes” → “Hall of Fame” the top five of each age category: the leaderboard name, points and category. If you are among them, everyone can tell which age category you are in, including “0–17”. The game calculates the category from your date of birth. The date itself is not shown. The page is public and search engines may show it. That is why you should not write your real name in the leaderboard name.

Signed-in players also see “Leaderboard”: all players with at least one point, with the leaderboard name and points.

Your friends see only your leaderboard name: in their friends list and on the “Become friends with …?” screen when they scan your code. They do not see your date of birth, category, points or scans; they see your position only on the live map and only if you turned on “Show me on the map” (see below). The “+2 together” note in your history does not say which friend scanned: it only shows that one of your friends scanned the same plaque within 15 minutes. The team does not see friendships in the admin panel. Only the technical team with direct database access can reach them.

On the live map (when it is open to players) no names are shown to anyone, administrators included. If you tap a friend’s avatar, you see their leaderboard name; if you tap the avatar of someone who is not your friend, you see only the “Become a friend” button (for adults). Other hunters see only your avatar where you are. Up to 17, you appear only anonymously, to about 150 m, also to friends; you have no “Become a friend” button and receive no requests from the map.

Crown on the map. If you are an adult and among the first three in your category, a crown with your place (1, 2 or 3) is shown above your avatar on the live map. It is seen by adult players who also show themselves on the map, and by administrators; when zoomed out (zoom below 15) only the 1st-place crown is shown. We send only the place to the map, with no name, points or category. “Leaderboard”, though, shows the name of everyone with at least one point, and the Hall of Fame in “Prizes” shows the first five of each category to every visitor. So another player can link the crown to your leaderboard name and to the approximate spot where you are right now. If you do not want that, do not turn on “Show me on the map”, or choose “Invisible”: then you are not on the map and your crown is not seen there. There is no way to show yourself on the map without the crown. A player aged 17 or under gets no crown on the map and sees no crowns there.

Your real name, email, date of birth and the coordinates from your scans are not shown to other players and visitors.

When we announce the winners we publish by category the leaderboard name and points, not the real name — in “Prizes”.

You see your bansko.be name, your leaderboard name, your hunter number, your date of birth, your points, your rank and your last 50 counted scans, including the golden ones: “QR N” (“Golden code · +N” for golden ones), code, points and distance. In your history you also see the hints you bought: “QR N”, price and when, and the “Notifications · +33” row if you got the notifications bonus. In “Prizes” you see your age category and your place in it. On the “You are on the list” screen you see whether we will write to you at the start and to which email.

The organizer’s team sees in the management panel:

• the list of players: leaderboard name, bansko.be name and email, bansko.be number, date of birth, points, when the notifications bonus was given (on the player’s page in the admin), participation in the prizes and when the profile was created;
• refused attempts from the last 24 hours: whose attempt, the place, the reason, the coordinates rounded to about 100 m (no coordinates for a refusal outside Bansko Municipality), the accuracy and the time;
• “missing code” reports: the place, the code (or whether it is active), how many open reports there are, when the last one came, the reasons with counts and the names of the senders. The player has no list. The GPS accuracy and the number of failed attempts are kept but not shown: only the technical team with direct access to the database reaches them;
• the signals of suspicious behaviour (section 13);
• the log of team actions;
• a player’s scan history, together with the hints they bought (place, price, when);
• how many players have collected each plaque, without who;
• the numbers of the list of hunters: how many are signed up, how many want the email at the start, how many emails were sent and how many failed, without who.

The exact coordinates of counted scans are not shown on any screen. Only the technical team with direct access to the database can reach them.

Radar and Helper. The position from the radar and from the Helper is seen by no one: it is not recorded and not shown to the team. In the radar’s response players do not receive plaque coordinates, radii, metres or degrees: they receive a word, a rough direction (an arrow on the map in “Hunt” where you asked), the number of the nearest plaque — “Plaque 3”, without the name of the place (the name is shown after the end of the hunt), a sign of whether the reading is approximate, and the hint of the place when it is unlocked. The distances and radii on other screens are described in “How to play”. For a golden place the radar says only “Golden code · +N pts” (the points for the day), without the name of the venue; there is no hint for it.

Volunteers. The team sees in the panel the suggestions: the volunteer’s name and email, the position, the photo and the note. A volunteer sees only their own suggestions and their approved places with the status of their plaques. A player sees the public description of the place — the description written by the volunteer or the area from OpenStreetMap, approved by the team, for example “Bansko, Old Town, near … Street” (without a house number) — together with its name, after the end of the hunt. Until then the place is just “QR N” (“Plaque N” on the map and in the radar), with no name or description; the radius is shown after your first scan there. The hint and its photo are shown to a player only when they unlock: after they buy them for points in the radar at “Hot” or “Burning!” (until they collect a plaque at the place), or after the end of the campaign. The address of the photo is not public.

5. Recipients and processors

• Every visitor to the site — the Hall of Fame and the announced winners in “Prizes” (section 4).
• bansko.be — for sign-in. When you sign in, your browser goes to bansko.be with a return address to the game. If the sign-in started from a plaque, that address also contains the plaque’s code. bansko.be sends the game your profile number, name and email. Today we do not send bansko.be points, scans, refusals, date of birth or your leaderboard name. If this changes, we will update this policy and notify you in advance (section 15).
• Convex, Inc. (USA) — cloud database and server functions. The game’s data is kept there: profiles, scans, refusals, logs, counters, the consents for the start email, the emails themselves and the notification subscriptions.
• Vercel Inc. (USA) — hosting of the site. Vercel keeps technical logs of requests, for example IP address, time and page address. At sign-in the address contains the one-time sign-in key from bansko.be with your number, name and email. Request logs are kept for 1 day. Vercel Web Analytics is also run by Vercel and counts visits without cookies (section 3).
• ImprovMX (USA) and Google (Gmail) — the support@bansko.be mailbox: ImprovMX forwards the emails, and in a regular (personal) Gmail account we read them and reply. Google processes the emails under its own terms.
• Resend (USA) — sends the start email, only to players who asked for it (section 10).
• Meta Platforms Ireland Ltd. — only if you accept Meta cookies (section 8): receives from Meta Pixel the pages viewed and the three registration events, with browser data (IP address, browser type, Meta cookies). It receives no email, name, phone number, date of birth or leaderboard name. For the collection and transmission we are joint controllers with Meta; after that Meta processes the data under its own policy.
• OpenStreetMap Nominatim — only for volunteer suggestions. It receives the coordinates of the suggested place (with “Use my location” this is the volunteer’s position at that moment), in order to return an area: settlement, neighbourhood, street. We do not send the volunteer’s name or email. The service also receives an application identifier and, like any network request, the IP address of the game’s server. The service is operated by the OpenStreetMap Foundation (United Kingdom). It is an independent controller of this data and processes it under its own privacy policy (osmfoundation.org/wiki/Privacy_Policy).
• The prize issuer — only if the prize is in your name (for example a season ski pass or a game with a code in your name). It receives your names and the data it requires for the prize, and processes them under its own policy.
• The notification service of your browser — only if you turn on notifications: Google (Chrome and Android), Apple (Safari and iPhone), Mozilla (Firefox) or Microsoft (Edge). It receives the subscription address and an encrypted message that it cannot read and, like any network request, the IP address of the game’s server. It does not receive your name, email or profile.
• Google — only if a team member opens in Google Maps the place of a refused attempt. Google then sees the rounded coordinates, without your name.
• Google Maps from the starter plaque — only if you press the button on the starter plaque in “Home”. The link carries only the coordinates of the plaque, no data about you. If you open it, Google’s policy applies to Google Maps.
• The National Revenue Agency — only if the law requires tax or a report for the prize.
• Police and other state authorities — when the law requires it or when we report damaged or replaced plaques (Rules, section 9).

Convex, Vercel, ImprovMX and Resend process data on our behalf — only on our instructions. Google processes the emails in Gmail under its own terms.

The radar does not send the position to third parties. The game’s map, if switched on, comes from our server, not from OpenStreetMap: its provider receives nothing from you.

The site’s fonts come from our server, not from Google. The site has no third-party services for chat or “I am not a robot” checks. The only analytics service is Vercel Web Analytics: it counts visits without cookies and without storing anything on your device. For third-party advertising we use only Meta Pixel, and only with consent (section 8). Partner logos in the game are shown by us: we count how many times a scan logo was shown, without telling the partner who saw it (section 2).

“Add to calendar” does not send data about you. The calendar file comes from our server. The link to Google Calendar carries only the event name, the start time and the address of the game. If you open it, Google’s policy applies to Google Calendar.

The partners’ logos lead to their websites; their own privacy policies apply there.

6. Data outside the European Economic Area

• Convex, Inc. is a company in the USA. The game’s database is in the USA (AWS, US East region, Northern Virginia). The game’s data is stored and processed in the USA.
• Hosting of the site: Vercel Inc. is in the USA. Pages are served from the nearest Vercel server (for Bulgaria usually Frankfurt, Germany), and the server functions run in Washington, D.C., USA. The data is processed in the USA.
• Mail: ImprovMX is a company in the USA and forwards inbound emails through servers in France. Gmail is a Google service; the support@bansko.be mail is read in a regular (personal) Gmail account, not in Google Workspace, and Google LLC (USA) processes it under its own terms. Google LLC is certified under the EU–US Data Privacy Framework.
• Resend, which sends the start email, is a company in the USA. More is in section 10.
• Meta Platforms Ireland Ltd. is in Ireland. Data from Meta Pixel may also reach Meta Platforms, Inc. in the USA; the transfer is based on the EU–US Data Privacy Framework (European Commission decision of 10 July 2023), under which Meta is certified.
• The notification services of Google, Apple, Mozilla and Microsoft may also process data outside the EEA, under their own terms. They receive only the subscription address and the encrypted message (section 5).
• OpenStreetMap Nominatim: the OpenStreetMap Foundation is in the United Kingdom. For the United Kingdom there is a European Commission adequacy decision, renewed in December 2025.

7. How long we keep the data

If we need data for a dispute or a fraud check, we keep it until the dispute or the check is finished. If you ask, we delete your data earlier (section 12).

The application deletes only expired sign-in keys, copies of start emails, photos of rejected suggestions, unattached uploads, expired notification subscriptions, the subscriptions of deleted profiles, the notification log after 180 days, the Helper counters after 24 hours without use, the records of personal notifications after 7 days, expired friend invitation codes, friend requests from the map after 7 days, the friendships and codes of deleted profiles, the scan logo counters within 3 days after the day and their expired tokens, and expired positions from the live map (over 2 minutes; checked every 5 minutes). Everything else in this section is deleted or anonymised manually by the technical team.

8. Cookies and browser storage

The necessary cookies and browser storage always work: without them you cannot sign in and play. For them the law does not require consent (Art. 4a of the Electronic Communications Act). Meta cookies are separate and used only with consent (below). For bansko.be’s cookies, its policy applies. The visit statistics (Vercel Web Analytics) use no cookies and store nothing on your device, so they are not behind the banner.

Meta cookies — only with consent. We use Meta Pixel to measure the game’s ads, only if you accept the cookies in the banner. Until you choose, and after “Decline”, Meta’s code is not loaded and your browser sends nothing to Meta. After “Accept”, Meta sets the _fbp cookie (up to 90 days) and, if you came from an ad, also _fbc (up to 90 days), and receives: a page view, pressing “Sign up with bansko.be”, the registration form being shown and a completed registration. We send the completed registration only for adult players, with an event number that is not your number in the game. We send no email, name, phone number, date of birth or leaderboard name. The basis is your consent (Art. 6(1)(a) GDPR and Art. 4a of the Electronic Communications Act). You can withdraw it at any time under “Cookies” at the bottom of every page: Meta’s cookies are then deleted and its code stops. How Meta processes the data is set out in its privacy policy.

In browser storage (localStorage) the radar keeps the key radar:on with the value “1” after it has answered for the first time. It remembers that you have used it. It is not sent to the server and stays until you clear the site’s data. The key serves only for the first-use prompt; the radar does not send a position because of it. While following with “Where is it?” is on, the radar also keeps the key qrlov:radar:follow with the value “1”, without a position. It is deleted when you press “Where is it?” again, log out or the server stops following (the table above).

The map. The map (“Hunt”) is another view of the radar and Helper answers. The trail above is kept only on your device; we do not see or receive it. “Clear trail” on the map deletes it. Collected plaques are not shown on the map.

“Sign out” in the game deletes the session cookie, the map data (qrh:), the following flag (qrlov:radar:follow), the radar notification log (qrlov:radar-notify), the plaques you passed (qrlov:near:), the results of saved scans and their lock (qrlov:scan-results:, qrlov:scan-lock:) and stops notifications on this device. Signing out of bansko.be does not sign you out of the game.

Notifications and installing as an app. Notifications are optional. If you turn them on, the browser keeps the subscription on your device and the server keeps the data from section 2. We set no cookie for this. You can turn them off under “Notifications” (the “Turn off notifications” button) or in the settings of the browser or the phone. The game can be installed on the home screen as an app; this is optional too. Installing stores nothing new on the server. The site’s helper program (service worker) keeps on your device only static files — images, fonts and scripts of the site. It does not keep pages (except the “No connection” page), server responses, your profile or your position. You remove them by uninstalling the app or clearing the site’s data. If you press “Later” on the install suggestion, the browser remembers it on the device for 7 days; it is not sent to the server.

9. Location and camera

Location

• The game asks for your location on the plaque page: when it opens (once per tab), when you press “Get position from phone” or “Check and collect points”, and when the camera in the game reads the code of the same plaque. It also asks when you request the radar (below). It also asks on the scan screen while a scan saved offline without GPS is younger than 5 minutes.
• When scanning, it watches GPS for only a few seconds — until it gets a position accurate to 25 m, but no more than about 9 seconds after the first position. Then it stops. Only one position is sent with the attempt. The exceptions are following with “Where is it?” in the radar and the Helper (below). The game does not work in the background.
• The position leaves the phone only together with a scan attempt or with a radar or Helper request. A scan made offline keeps the position on the phone until it is sent.
• You can stop access in the browser settings at any time. Then you cannot collect points.
• The map does not ask for a position by itself. When you turn on “Show me on the map”, your phone sends its position while the map is open and sharing is on; we keep it only temporarily (it expires in 2 minutes, expired rows are deleted by an automatic check every 5 minutes), to show you live. You stop it with “Invisible” or by turning sharing off. Otherwise the map uses only the positions the radar and the Helper already use, and it does not show where the plaques are: no zones, no coordinates, no server marker. The browser never receives the location of a plaque, except the starter one: the button to Google Maps carries its coordinates (section 5). While you have no successful scan, in “Home” you get its points (no hint) and this button.

Radar

The radar (“Where is it?”) is an optional aid when searching. It tells you in one word how close you are to the nearest uncollected plaque — from “Ice cold” to “Burning!” — and, when you are far away, which direction it is in: the map in “Hunt” draws it as an arrow where you asked.

• When a position is sent. Only while following is on. You switch it on by tapping “Where is it?”, and it stays on until you press “Where is it?” again or log out. While it is on, the phone sends a position every few seconds and only while the page is on the screen: while the page is hidden, following is paused and resumes when you come back. There is no time limit and it does not stop by itself when you stand still. The next time you open the “Hunt” tab, following resumes only if it was on and location is already allowed in the browser. Otherwise the radar does not send a position until you press “Where is it?”.
• What is sent. The position, the GPS accuracy and which is the radar’s current target. It is sent over a secure connection, in the body of the request, not in the address.
• What the server does. It rounds the position to a 50 × 50 m square before calculating. It works out one word and a rough direction in one of eight directions. It returns the word, the direction, the opaque number of the plaque it points to — the game shows it as “Plaque N”, without the name of the place, a sign of whether the reading is approximate, the hint of the place when it is unlocked, and how long until you may ask again. It does not return coordinates, metres or degrees. It forgets the position after the response. For a golden place the radar says only “Golden code · +N pts” (the points for the day), without the name of the venue; there is no hint for it.
• What does not happen. The position is not recorded: not in the database, not in a log, not in statistics, and does not reach Convex. The browser never receives plaque coordinates, metres or degrees. The radar does not give points.
• What we keep. Only a counter (your internal number and when you asked) in the server’s memory, to stop abuse. The counter is not a record of positions.
• Basis. Art. 6(1)(b) of the GDPR — performance of the contract for participation. The radar is optional.
• Switching on and off. You switch it on and off with the “Where is it?” button. Logging out also switches it off, and refusing the location permission in the browser stops it. Without the radar you play in exactly the same way. While the radar follows you, the phone itself may show a notification on “Warm”, “Hot” or “Burning!”, only if notifications are on in the game: at most 6 an hour and none from 22:00 to 08:00. Nothing goes to the server.
• When the radar is not switched on by the organizer, it does nothing and does not send a position.

Helper

The Helper is an optional aid on the radar. It warns you in one word — “Warm”, “Hot” or “Burning!” — when you get close to an uncollected plaque.

• When a position is sent. Only after you turn it on and while the game is open on the screen. The phone sends a position at most every 20 seconds or when you have moved at least 25 m. It does not send when the GPS accuracy is worse than 60 m.
• What the server does. It works out the level from the position and forgets it. It returns only the word and whether to show a notification. It does not return coordinates, distances, a direction or the name of a place.
• What does not happen. The position is not recorded: not in the database, not in a log, and does not reach Convex. We do not keep a history of your route.
• What we keep on the server. Per player only counters and times for the limits: a sequence number of the request, when the session started (for the 30-minute limit for ages 14–17), when the last one was, how many notifications were sent this hour, when the pause after “Burning!” ends, and a counter of unrealistic jumps in position. They contain no position. They are deleted automatically after 24 hours without use.
• What the phone keeps. An encrypted token with the last position and the plaques already notified, in encrypted form. Only the server can read it. It is valid for 2 hours.
• Speed. If the positions show movement above 30 km/h (for example in a car), notifications are skipped. That is all: the check is not proof of a violation.
• Basis. Art. 6(1)(b) of the GDPR — performance of the contract for participation, at your request, when you turn it on (as with the radar). Notifications on the phone are by your consent, when you allow them in the browser (section 2).
• Children. Under 14 the Helper is off. From 14 to 17 a session lasts up to 30 minutes and there are no notifications from 22:00 to 08:00.
• Switching on and off. You switch it on in the radar area and switch it off there. It also stops by itself: after about an hour without movement, when you leave the game and when the battery drops below 15% (where the phone reports it). Without the Helper you play in exactly the same way.
• When the Helper is not switched on by the organizer or the campaign is not running, it does nothing and does not send a position.

Territory

The game is played only within the territory of Bansko Municipality. When scanning, when a team member or volunteer activates a plaque, with the radar and with the helper, the server checks whether the position is inside the municipality.

• If you are outside the municipality, we only refuse: we do not calculate distance, we do not keep your coordinates (section 2), and the radar does not answer.
• The boundary is based on data from © OpenStreetMap contributors, licence ODbL 1.0 (osm.org/copyright). It is simplified: in the mountains it may be up to about 100 m from the real boundary, and the settlements are not affected. Up to 100 m from the line counts as “inside”. The boundary sits on the server.

Camera

• The camera turns on only when you tap “Scan with the camera” or “Scan a friend”. It uses video only, without sound. The game picks the main back camera and remembers the camera on the phone; “Switch camera” changes it.
• The QR code is read in your phone. Only the text from the code goes to the game’s server.
• The “Photo of QR” button opens the phone’s camera to take a photo of the code. The code is read in your phone: the photo is not uploaded, not sent and not kept.
• We do not keep or send photos or video.
• The camera stops as soon as it reads a code of the game, when you press “Stop the camera” or when you leave the page.
• You can also scan with the phone’s “Camera” app. The game then does not use the camera.

10. Email at the start

The game starts on Sunday, 18 October 2026, at 15:00 Bulgarian time. If you wish, we will write to you when it begins. This is optional: without the email you play in exactly the same way.

How you ask for it. When you sign up for the game there is a checkbox for the email. It is not ticked in advance — you tick it yourself. Afterwards you can change your choice with the switch on the “You are on the list” screen.

What for. We write to you once, when the game begins. The email contains your leaderboard name, your hunter number, a link to the game and an unsubscribe link. We do not send advertising and do not use your email for anything else.

Basis. Your consent — Art. 6(1)(a) of the GDPR.

What we keep:

• that you asked for the email and when;
• how far the email has got and when: pending, sent or failed (with the reason);
• whether and when you unsubscribed;
• a random unsubscribe key. It is in the unsubscribe link in the email;
• the email we send to. We take it from your profile at sending: it is the bansko.be email from your last sign-in.

How you unsubscribe. At any time: with the “Unsubscribe” link that is in every email and the “Yes, unsubscribe me” button — no sign-in needed — or with the switch on the “You are on the list” screen. This is how you withdraw your consent. Withdrawal applies going forward.

Who sends the email. Resend — an email-sending service, a company in the USA. Resend receives your email address and the email itself and processes them on our behalf — only on our instructions. Resend states that it participates in the EU–US Data Privacy Framework. The period for which Resend keeps the log of sent emails: 30 days.

No tracking. We do not track whether you opened the email or what you pressed in it.

How long we keep it. The copy of the email in our database — with the address it was sent to — is deleted automatically 30 days after sending. The rest we keep until we send the start email or until you withdraw consent. Then we delete it or make it anonymous on the organizer’s schedule (section 7).

11. Children

• Under 18 you play with the consent of a parent or guardian. Under 14 — only with the consent and involvement of a parent or guardian and with the child’s own bansko.be profile (see the Rules, section 4).
• This consent is for taking part in the game under the Rules. It is not consent for personal data: we use children’s data on the same bases as for all players (section 3). The exception is the email at the start: it is by consent (section 10).
• The email at the start for a child under 14 is requested by the parent or guardian: they tick the checkbox. From the age of 14 the child can ask for it themselves.
• We do not ask for a document for the consent while the child plays. The parent confirms it when collecting the prize, or when we ask for it.
• The game does not verify age. The date of birth is entered by the player. When a prize is collected, we check it against an identity document.
• If a player under 18 is among the top five in their category, their leaderboard name and points are visible publicly in “Prizes”. That is why a child’s leaderboard name should not reveal their real name.
• If we find out that a player under 18 is playing without the consent of a parent or guardian, we remove the profile from the leaderboard and the prizes and ask for consent. If there is no consent, we delete the profile. If the player signs in again with bansko.be, the game creates a new profile; we remove that one from the leaderboard and the prizes as well.
• The radar applies to children too. A child’s position, like an adult’s, is not recorded (section 9). The Helper is off under 14; from 14 to 17 a session lasts up to 30 minutes and there are no notifications from 22:00 to 08:00. Only adults can be volunteers.
• Any player can have friends, including under 18. For a child, a friend is added only in person, for example a child and a parent: the child shows their code to someone next to them or scans theirs. There is no search by name and no messages. Up to 17, the child neither sends nor receives friend requests from the map and stays anonymous on it. A friend sees only the leaderboard name. A parent or guardian can remove a friend together with the child (“Remove”).
• A parent or guardian can exercise the child’s rights under section 12.
• Meta cookies are accepted in the banner. For a child under 14 the parent or guardian decides. We send the completed registration to Meta only for adult players (section 8).
• Up to 17, no partner logo is shown while scanning. The “Kindly supported by” strip is seen by everyone, and nothing is counted or stored for it.
• At some places a child sees, after scanning, a short fact about the place (“Did you know?”) instead of the advertisement. The server decides whether you see it from the date of birth, which we already use for the age category. Nothing is stored for the fact.
• Notifications for a child under 14 are turned on by the parent or guardian. From 14 the child can turn them on alone (section 2). The notification log has no data about players.
• Children under 18 (by date of birth) get no personal notifications (“Someone passed you” and crown ones) from 19:00 to 08:00; for adults it is from 22:00 to 08:00.
• A player under 18 gets no crown on the live map and sees no crowns there (section 4).
• The prize of a player under 18 is collected by a parent or guardian.

12. Your rights

You have the right:

• of access — to learn what data we have about you and to receive a copy;
• to rectification — to have wrong data corrected, for example the date of birth. The correction is made by an administrator, with a reason, and goes into the log of team actions. You correct the name and email in bansko.be, and the game updates them at your next sign-in;
• to erasure — to have your data deleted. You then lose your points, your place on the leaderboard and participation in the prizes. Erasure is done manually by the technical team: there is no button for it in the game. If you then sign in with bansko.be again, the game creates a new profile without points. We may keep data that we need by law or for a dispute, for as long as necessary;
• to restriction — to have us stop using your data while we check something you contest;
• to object — to processing on the basis of public interest or legitimate interest (section 3). We stop, unless we have overriding legitimate grounds, for example a fraud check;
• to withdraw your consent for the email at the start — at any time, with the unsubscribe link in the email or with the switch on the “You are on the list” screen (section 10); for notifications, with “Turn off notifications” under “Notifications” or in the browser settings (section 2); for Meta cookies, with “Cookies” at the bottom of every page (section 8). Withdrawal applies going forward;
• to portability — to receive the data you gave us, and your scans, in a machine-readable format;
• to stop a child’s participation — a parent or guardian can withdraw their consent for the child to play, with a letter to us. We then remove the profile from the leaderboard and the prizes and delete it. You stop the location and camera permissions in the browser settings (section 9);
• to lodge a complaint — with the Commission for Personal Data Protection (КЗЛД): Sofia 1592, 2 Prof. Tsvetan Lazarov Blvd., kzld@cpdp.bg, www.cpdp.bg. You can also go to court.

How. Write to support@bansko.be from the email of your bansko.be profile, so that we can recognise you. If you write about a child, state their leaderboard name and the email of their bansko.be profile. If we cannot recognise you, we will ask for more information. We answer within one month. For complex requests the period may become up to three months — we will then tell you why. We do not charge a fee.

There is no button in the application for deleting or downloading data. Requests are carried out manually by the technical team, so write to us.

13. Automated decisions and profiling

• Every scan is checked automatically: whether you are in Bansko Municipality, the code, whether the plaque is active, whether you already have the points from it, the distance, the GPS accuracy and the attempt limits. The result — points or refusal — is automatic. You can try again. If you think there is a mistake, write to us.
• The game shows the team signals based on simple rules. This is an automatic assessment of behaviour (profiling), not a decision:
  • two counted scans by one player at least 300 m apart, between which a speed above 50 km/h is needed — for the last 24 hours;
  • 10 or more refusals in one hour from one player — for the last 24 hours;
  • 10 or more attempts from far away — more than 500 m and more than five times the radius — on one plaque from at least three players, for the last 24 hours;
  • an attempt to scan a new, not yet activated plaque by a player outside the team — for the last 30 days.
  • 10 or more “outside Bansko Municipality” refusals on one plaque from at least three players — for the last 24 hours (a sign of a shared photo of the code). Refusals outside the municipality do not keep coordinates.
• A signal is not a decision. Whether a player is removed from the leaderboard and the prizes is decided by a person from the team. You can ask for review by a person, express your view and contest the decision.
• The territory check is automatic: a scan, radar or helper request outside Bansko Municipality is refused without a person. You can ask a person to review the refusal.
• The radar’s word and direction are calculated automatically. They are an aid, not a decision: they give no points and do not penalise you. The same goes for the Helper’s level; the speed check only skips notifications when you move fast (for example in a car).
• The prize ranking is calculated automatically from the points. The winners are announced by a person from the team after checking the ranking. On collection a person also checks the document.
• You can ask a person to review a refused scan, your ranking or your removal from the leaderboard.
• We do not take decisions based solely on automated means that have legal effects for you or similarly significantly affect you.

14. Security

• The game does not store passwords.
• The sign-in cookies are sent only over a secure connection (HTTPS) and are not accessible to scripts in the page.
• The browser does not talk to the database. Only the game’s server reaches it, with a secret key.
• The sign-in key from bansko.be (the token) is signed, valid for up to 15 minutes and accepted only once.
• The management panel is only for the team. Permissions are checked at every action.
• Every change by the team goes into a log that cannot be edited from the panel.
• Scan attempts are limited.

No system is completely secure. If a breach endangers your rights, we will notify the Commission for Personal Data Protection and you, when the law requires it.

15. Changes

THE CREATORS RESERVE THE RIGHT TO CHANGE THE GAME WHILE IT IS RUNNING.

When a change in the game affects personal data, we also update this policy. We publish changes on this page with a new date. If the change is material — new data, a new purpose or a new recipient — we will notify you in the game or by email before it takes effect.

16. Contact

• Personal data questions: support@bansko.be
• Rules of the game · How to play

Versions

• 8 October 2026 — first version.
• 8 October 2026 — radar, territory of Bansko Municipality, volunteers, reverse geocoding and automatic advice on volunteers’ texts.
• 9 October 2026 — Meta Pixel only with consent, cookie banner, “Welcome” page after registration.
• 10 October 2026 — notifications (push) and installing as an app.
• 10 October 2026 — Helper, personal and general notifications from the server (what we keep and for how long).
• 10 October 2026 — map: trail and markers only on the device (qrh:), no plaque locations.
• 11 October 2026 — missing details filled in: recipients, countries and bases for transfers, retention periods, the basis for volunteers and for protection against fraud; the automatic advice on volunteers’ texts stopped; no data protection officer.
• 12 October 2026 — visit statistics with Vercel Web Analytics, without cookies.
• 13 October 2026 — wording on processors (sections 5, 6 and 10) and mail clarified: support@bansko.be is read in a regular Gmail account.
• 13 October 2026 — the “Kindly supported by” strip: the partners’ logos lead to their websites.
• 15 October 2026 — one “Where is it?” button: the radar follows until you press it again or log out, pauses while the page is hidden, without the 10-minute limit or the stop when you stand still; the qrlov:radar:follow key; choosing a target removed.
• 15 October 2026 — a notification from the phone itself on “Warm”, “Hot” and “Burning!” while the radar follows, only with notifications on in the game; section 8 also describes the keys qrlov:radar:follow, qrlov:radar-notify, qrlov:compass, qrlov:panel:presence, qrlov:panel:radar, qrlov:intro, qrlov:notify-card:dismissed-until and qrlov:registered:; the “Hunt” tab.
• 15 October 2026 — the radar gives the plaque number, not the place name (sections 2, 4 and 9); the description is shown after finding; the qrlov:near: key.
• 15 October 2026 — friends and the “+2 together” bonus: what we keep, who sees it and for how long.
• 15 October 2026 — the scan logo only for signed-in adult players; a counter of times shown and caps (what we keep and for how long). The “Kindly supported by” strip stays for everyone and is not counted.
• 17 October 2026 — friend requests from the live map (adults only): what we keep (who to whom, when, status), who sees it and for how long (up to 7 days); no names on the map.
• 17 October 2026 — the radar is in “Hunt” for all players: the word in the band, the rough direction as an arrow on the map.
• 18 October 2026 — scanning without internet: the keys qrlov:scan-queue:v1:, qrlov:scan-results:v1: and qrlov:scan-lock:v1: and the position on the phone until it is sent.
• 19 October 2026 — “Leaderboard” shows all players with at least one point (until now the top 20); some notifications (for example for a “happy hour”) go only to adult players, based on the date of birth.
• 19 October 2026 — hints for points and a starter plaque in “Home” for a player with no scan (points, no hint; a button to Google Maps): we keep which hints you bought, when and for how much (for the total and to check disputes); no notification for a new hint, and the “hints” topic is no longer offered; if you chose it before 19 October it stays recorded and nothing is sent on it.
• 19 October 2026 — golden codes: we keep golden scans (the same data, purpose, basis and retention as scans) in a separate list; the date of birth also decides whether a child sees the “Did you know?” fact; Google Maps gets the venue’s coordinates only if you press the button; corrected: we store the full date of birth (day, month and year) and no longer list it among what we do not collect; the position for the live map is temporary (2 minutes), not “never” — clarified in “What we do not collect” and “Location”; collected plaques are not shown on the map, and positions of collected plaques stored earlier in the browser are only deleted.
• 19 October 2026 — “happy hour” from the organizer’s dashboard (the notification to adults is at most one per hour); notifications bonus: we keep when it was given (+33 points, once); crowns: we keep the current top three per category (internal numbers and time of the last change), overwritten; the record of today’s personal notification also says the kind (overtaken or crown) and is deleted after 7 days; children under 18 get no personal notifications from 19:00 to 08:00.
• 20 October 2026 — manual notifications from the organizer: a separate notification about the game under the “Hunt start” topic, to adults or to everyone with the topic; not from 22:00 to 08:00, and to everyone not from 19:00 to 08:00 either.
• 20 October 2026 — golden places are no longer listed in “Home” and there is no button to Google Maps for them: Google Maps opens only from the starter plaque.
• 20 October 2026 — manual notifications from the organizer also to one chosen player: only to that player’s subscriptions with at least one topic switched on, whatever the topics; not from 22:00 to 08:00, and to a minor not from 19:00 to 08:00 either; we keep the recipient (number and name), the title and the text in the team’s action journal (up to 1 year after the end of the campaign).
• 21 October 2026 — until the hunt ends the player sees only “QR N” for places in the result, the history and “Home” (“Plaque N” in the radar and on the map), no name or description, and for golden ones no venue name; the scanner remembers the phone camera you chose (key qrlov:camera, only a camera number, not sent to the server), and “Photo of QR” reads the code in the phone and uploads nothing; “Report: missing code”: we keep the place, the code, the profile, the reason, the GPS accuracy, the number of attempts, the time and the status, without coordinates; only the team sees the reports; sessionStorage holds the attempt counter and the places already reported; a crown with the place (1–3) above the avatar of the first three adults in each category on the live map: who sees it, that it can be linked to the leaderboard name and the position, the legal basis and how to avoid it (“Invisible”); children have no crown on the map.