How we look after your information

The short version

• No accounts. No emails, no passwords, no ages. You type a room code and a name, that’s it.
• Cameras start off. A player has to tap to turn theirs on, and can switch to a cartoon at any time.
• We never record anything. No video, no voice, no photos are ever stored by us, and we use no recording feature at the company that relays the video.
• Filters are drawn on the player’s own phone before the video leaves it. Our game server never sees a face.
• An adult lets every player in.
• Rooms disappear five minutes after everyone leaves, and after four hours at most. Everything about the players in them goes too.
• We count totals, not people — like “words found this week”. Nothing in them can identify anyone.
• No adverts, no tracking cookies, no analytics companies. We don’t sell or share anyone’s information.

1. Who we are

Grid Gang is made by Duothink Ltd, a company registered in Scotland, company number SC886148, registered office Cullyblean Steading, Tullynessle, Alford, Aberdeenshire, AB33 8QR. We are registered with the Information Commissioner’s Office (ICO) as a data controller, registration number ZC148263 (see the ICO register).

For family games we are the controller of the information described here. For classroom games, see Schools.

Contact: hugh.mackenzie247@gmail.com. We aim to reply within a week, and always within one month.

3. Face tracking is not face recognition

To put a moustache in the right place, the player’s own phone works out where their eyes, nose and mouth are in each video frame, using Google’s free MediaPipe software running inside the browser on the phone. We serve that software from our own website, so using it sends nothing to Google, and we block its built-in usage reporting. The phone may also spot a rude hand sign and swap that player to their cartoon for a few seconds.

The measurements are used for that frame and thrown away. They are never used to work out who someone is, never compared with anyone else’s face, and never sent to us or anyone else — only the finished, filtered picture leaves the phone. We do not process biometric data. In UK law, biometric data is information about a person’s body that is processed to identify them, or confirm who they are. Our code only finds where a face is, on the player’s own phone, to draw a filter; it never works out whose face it is, and the measurements never reach us.

The cartoon that copies your expressions works the same way: the phone reads smiles and open mouths, and only the cartoon is sent.

4. Why we’re allowed to use this information (lawful basis)

UK data protection law says we need a reason (a “lawful basis”) for using personal information. For everything in section 2 we rely on legitimate interests: running the game people have chosen to join, and keeping it safe. That covers the names, scores and filters held in a room; the live video and voice players choose to turn on; the name filter, the room-code guessing protection and the host’s let-in and remove controls; and the anonymous totals and problem reports that tell us whether the game is working.

Using legitimate interests means we must weigh our interests against yours — and, because children play, the ICO says children’s interests need extra protection. We wrote that balancing test down (a “Legitimate Interests Assessment”). In short: we only use what the game needs, keep it no longer than the room lasts, record nothing, start cameras and microphones off, and an adult lets every player in. We decided these protections make the use fair for children and adults alike. You can ask us for a copy.

We don’t rely on consent, so nobody — child or adult — is asked to tick a box or “agree” to anything, and the special rule about getting a parent’s consent for children under 13 (which applies only when a service relies on consent) does not apply. You can still object at any time (section 10); in practice the easiest way is to play as a cartoon, or to leave the room, which deletes everything about you in it.

The anonymous totals (for example “words found this week”) are counted without any name, code or address, so they cannot identify anyone once counted.

7. Children

Grid Gang is made to be played by children with an adult running the game. We don’t ask anyone’s age; instead we treat every player as if they might be a child. We follow the ICO’s Children’s Code (the Age Appropriate Design Code):

• High privacy by default — cameras off, microphones off, and in classrooms voice off and face swap off.
• No profiling, no location, no adverts, nothing designed to keep children playing longer.
• Share prompts appear only on the host’s (the adult’s) screen. We never nudge children to post.
• A child can switch to a cartoon at any time, without saying why.

Because we don’t check ages, we give everyone — adults included — the protections the Children’s Code asks for children. Our plain-words explanation for parents is the safety page.

8. Players in another house

A player who isn’t in the room (for example a grandparent) joins with the room code or a link, waits in the same waiting room, and is let in by the host. Their screen shows the players’ faces or cartoons, like the TV does, and they can talk to the room once they tap their microphone on. Their video and voice are handled exactly like everyone else’s: relayed live, never recorded. If the host removes them, their name and score are deleted from the room straight away.

9. Schools

In classroom games the school decides to use Grid Gang with its pupils and runs the game through its teacher. The school is the controller of its pupils’ information in the game (the class list it enters and any summary it saves), and we act as the school’s processor for classroom rooms, using that information only to run the game. We stay the controller of the anonymous totals and our own safety protections. We will sign a data processing agreement on request, and help with your data protection impact assessment (DPIA).

Classroom defaults: pupils are cartoons, not cameras (the teacher can allow cameras, and each pupil still chooses); voice off; face swap off and can’t be switched on; pupils tap their name from the teacher’s class list, which is kept in the teacher’s browser and held by us only while the room is open; the end-of-session summary is shown only to the teacher and never kept by us. More: Grid Gang in the classroom.

10. Your rights

Under UK data protection law you (or your parent or carer) can ask to see the information we hold about you, have it corrected or deleted, restrict or object to how we use it, and get a copy. In practice we hold almost nothing: once a room closes everything about its players is gone, and we can’t look up a past player because we never knew who they were. During a game, the host can remove you, which deletes your name and score from the room at once. Children can ask for themselves, and we’ll explain things in a way they understand.

If you’re unhappy with how we’ve handled your information, please tell us first. You can also complain to the Information Commissioner’s Office (ICO): ico.org.uk/make-a-complaint, 0303 123 1113.

11. Reporting a problem

The host can use Report a problem in the game, or email us at hugh.mackenzie247@gmail.com. We aim to reply to every email within 7 days. A report never contains video, pictures or voice — we don’t have any. If something suggests a child may be at risk we’ll point you to the police or CEOP; because we keep no recordings we usually can’t provide evidence ourselves. More on the safety page.

12. Security

Everything travels encrypted: the web pages and game connection over HTTPS, and live video and voice with the encryption built into every browser’s video calls. Our Cloudflare key stays on our server, never in the web page. Room codes can’t be found by trying them in order. And because we keep no video, and no names or scores after a room closes, there is very little that could ever leak.

13. Changes and contact

If we change this policy we’ll update the date at the top, and for anything important we’ll put a notice on the home page. Questions: hugh.mackenzie247@gmail.com.