Beta — last updated 2026-07-26
PoseDuel Privacy Policy (Draft)
DRAFT for review by qualified Swiss counsel — not legal advice. Published as a beta draft; counsel review is still required before public (non-beta) launch.
Effective date: 26 July 2026 (beta) Who we are (the "controller"): Iris360 SA, Chemin Davel 14, 1009 Pully, Switzerland — the company that makes PoseDuel (poseduel.com). Privacy contact: privacy@poseduel.com. EU representative (GDPR Art. 27): Mike Nolet — reachable via privacy@poseduel.com.
PoseDuel is a game for children that uses your cameras to turn physiotherapy home exercises into gameplay. That means we handle video and movement data of children — the most sensitive kind of data there is. This policy explains, in plain language, exactly what we collect, why, how long we keep it, and the controls you have. The short version: you choose a privacy mode, the strictest cloud mode is the default, all modes are free, and we never sell data or show ads.
1. What we collect
| Category | What it is | Who it's about |
|---|---|---|
| Camera video | Live video from the laptop/desktop webcam and, if you pair one, a phone camera, while your child plays. Whether video ever leaves the device depends on your privacy mode (Section 3). | The child (and anyone who walks into frame — keep the play space clear) |
| Pose data | Skeleton keypoints (dots-and-lines stick-figure coordinates) computed from the video, plus rep counts, movement-quality scores, and exercise timing. Pose data is not a photo, but it is still personal data — movement patterns can be identifying. | The child |
| Account data | Parent's email address, password (hashed), display/hero names for child profiles (we ask you to use nicknames, not real names), age band of the child, subscription and payment status. We do not collect the child's email, phone number, or precise location. | The parent; minimal child profile info |
| Health-context data | The exercise program configured for your child (which exercises, targets, difficulty tiers). We do not ask for diagnoses, and we ask you not to enter medical details in free-text fields. | The child |
| Telemetry | Technical logs: session times, feature usage, errors, device/browser type, approximate region from IP (for security and server routing), performance metrics. No advertising identifiers, no cross-site tracking, no third-party analytics cookies. | Mixed |
| Communications | Emails you send us, and consent records (what you agreed to, when, and how we verified you're the parent). | The parent |
We never: sell personal data, show ads, use advertising trackers, or use your child's data to train third-party AI models. Google Gemini processes clips only to generate feedback for you; we use it via API, whose terms prohibit using our data to train Google's models.
2. Why we process it (purposes and legal bases)
European and Swiss law require us to name a legal basis for every use of personal data — this table is that list, in plain language.
| Purpose | Data used | Our legal basis |
|---|---|---|
| Running the game: detecting reps, scoring movement quality, progressing the child through encounters | Video (per mode), pose data, exercise config | Running the platform: our contract with you. Anything about the child (video/pose/health context): explicit parental consent (GDPR Arts. 6(1)(a), 9(2)(a); FADP Art. 6(7)) |
| AI feedback on exercise form (our AI movement coach — an AI, not a physiotherapist) | Video clips (Balanced/Full Analysis modes), pose data | Explicit parental consent |
| Personalised difficulty thresholds | Pose data history | Explicit parental consent |
| Improving our detection and scoring models | Pose data and (Full Analysis mode only) video, per Section 3 | Separate, optional explicit parental consent — never required to play |
| Review of selected clips by qualified movement professionals under confidentiality contract, to keep scoring honest | Exemplary clips (Balanced/Full Analysis only) | Explicit parental consent (called out in the mode description) |
| Accounts, billing, support | Account data, communications | Contract performance; legal obligations (accounting) |
| Security, abuse prevention, debugging | Telemetry | Legitimate interest — narrow logs, short retention (GDPR Art. 6(1)(f)) |
| Proving we obtained proper parental consent | Consent records | Legal obligation / legitimate interest |
For US users, we comply with COPPA (16 CFR Part 312): we obtain verifiable parental consent before collecting any personal information from a child, we collect no more than is reasonably necessary for the child to play, and we maintain a written data retention policy (this Section 3 and Section 4 are its public summary).
3. The four privacy modes — your choice, all free
You (the parent) pick the mode during setup and can change it anytime in Parent Settings. No mode is ever paywalled. The default is Private. Switching down takes effect immediately; switching up requires re-confirming parental consent.
| Mode | What leaves the device | Video retention | Pose data retention | What you trade off |
|---|---|---|---|---|
| Local-Only | Nothing. All processing happens in the browser on your device. | Never uploaded | Never uploaded; stays on-device | No AI form feedback, no personalised thresholds, no cross-device sync |
| Private (default) | Pose/skeleton data only — video never leaves your device | Never uploaded | Kept while the account is active, to power thresholds and progress | No AI video feedback, no clip review |
| Balanced | Video, for processing; pose data | Deleted within 24 hours of processing; a small number of "exemplary clips" per period kept max 90 days for professional review | Kept while account active; contributed to model improvement | Some clips are seen by our contracted movement professionals |
| Full Analysis | Video and pose data | Max 90 days, then deleted | Kept while account active; contributed to model improvement | Most data shared with us; full AI analysis and fastest personalisation |
"Model improvement" means we use the data to make rep detection and form scoring better for everyone. It never means advertising, sale, or unrelated AI training. You can withdraw from model improvement at any time; we stop using your child's data going forward and delete it from our training sets within 30 days.
4. How long we keep things (retention)
- Video: per the mode table above — 24 hours (Balanced, except exemplary clips at 90 days) or 90 days (Full Analysis). Never longer. Local-Only/Private: we never have it.
- Pose data and game progress: while the account is active. Deleted within 30 days of account deletion.
- Account data: while the account is active; billing records as long as Swiss accounting law requires (10 years, invoices only).
- Telemetry/logs: 90 days.
- Consent records: as long as the account exists plus 5 years (to prove compliance).
When your child no longer needs the service, delete the account (Section 8) — we do not keep children's data "just in case."
5. Who processes data for us (sub-processors)
We use a small set of infrastructure providers under data-processing agreements. They may only process data on our instructions.
| Provider | What they do | Where |
|---|---|---|
| Google Cloud Platform (GCP) | Video/pose storage and processing | europe-west1 (Belgium) |
| Supabase | Database (accounts, progress, pose data) | EU |
| Vercel | Web hosting and serverless functions | EU (its edge network is global) |
| Google Gemini (via API) | Generates AI form feedback from clips/pose data | EU; our data is not used to train Google's models |
| Resend | Sends account and consent emails to parents | EU |
| Qualified movement professionals under contract | Review exemplary clips (Balanced/Full Analysis only) | Switzerland/EU |
ElevenLabs generates the game's sound effects and music during development; no user data is ever sent to it. A payment processor will be added to this table before subscriptions launch. We will update this table before adding any sub-processor and notify account holders of material changes.
6. Children's data and verifiable parental consent
PoseDuel is designed for children roughly 8–14, used under a parent-held account.
- We collect no personal information from a child until we have verified a parent's identity and obtained consent (COPPA "verifiable parental consent"; GDPR Art. 8; Swiss FADP). Verification method we use: payment-card verification (additional methods may be added).
- The consent ceremony shows you exactly what each privacy mode collects before you choose. Consent to play is never bundled with consent to model improvement — those are separate choices.
- We never condition your child's participation, or any prize or feature, on providing more data than the game needs (16 CFR §312.7). Your child's game experience is identical in every privacy mode except for the features that technically require the data (AI video feedback needs video).
- Children never see privacy-mode choices, and nothing in-game rewards or pressures data sharing.
- A recording indicator is shown on every capturing camera while a session runs.
- If we learn we collected a child's data without valid parental consent, we delete it.
7. No sale, no ads
We do not sell or rent personal data. We do not show advertising. We do not permit third parties to collect data through PoseDuel for their own purposes. If US state privacy laws apply to you (e.g., CCPA/CPRA): we do not "sell" or "share" personal information as those laws define it.
8. Your rights and how to use them
Every parent, everywhere: a Parent Settings dashboard where you can view your child's data, change privacy mode, withdraw any consent, export data (machine-readable), and delete the account and all associated data — self-serve, no email required, effective within 30 days across our systems and sub-processors (backups purge within 90 days).
- Switzerland (FADP): right to information (Art. 25), rectification, deletion, data portability (Art. 28), and to complain to the FDPIC (Federal Data Protection and Information Commissioner, Bern — edoeb.admin.ch).
- EU/EEA (GDPR): access (Art. 15), rectification (16), erasure (17), restriction (18), portability (20), objection (21), withdrawal of consent at any time without affecting past lawfulness (Art. 7(3)), and complaint to your national supervisory authority.
- US (COPPA parental rights): review the personal information collected from your child, refuse further collection or use, and direct us to delete it — and we may not deny the child access to the service for exercising deletion rights beyond the data the service genuinely needs.
Withdrawing a consent never degrades your subscription and is as easy as giving it (one click in Parent Settings).
9. International transfers
Data lives in Europe (GCP europe-west1; Supabase EU region). Should a sub-processor ever process data outside Switzerland/EEA, we rely on the Swiss–US Data Privacy Framework / EU–US Data Privacy Framework where the provider is certified, or on the EU Standard Contractual Clauses with the Swiss addendum, plus technical measures (encryption in transit and at rest). Details available on request.
10. Security
Encryption in transit (TLS) and at rest; access to video restricted to the minimum staff and contracted reviewers needed, all under confidentiality obligations, with access logging; signed, expiring URLs for media; regular deletion jobs enforcing the retention table above. No system is perfectly secure — if a breach affects your child's data, we will notify you and the competent authority as the FADP/GDPR require.
11. Changes to this policy
We'll post changes here and email account holders before material changes take effect. If a change expands what we collect from children, we will ask for fresh parental consent first — silence never equals consent.
12. Contact
Iris360 SA — Chemin Davel 14, 1009 Pully, Switzerland · privacy@poseduel.com EU representative: Mike Nolet (via privacy@poseduel.com) · US COPPA inquiries: same email.
This policy is written to satisfy the Swiss FADP, the EU GDPR, and the US COPPA Rule (as amended 2025). If a translation conflicts with the English original, the original governs.