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Privacy Policy

Last updated: June 27, 2026

1. Data Controller

Binary Spirit S.L.
Based in Spain
Contact: privacy@fairdivider.com

2. What Data We Collect

Fair Divider collects the minimum data necessary to provide the fair division service:

We do not collect email addresses, phone numbers, payment information, location data, or require user accounts.

3. How We Use Your Data

4. Legal Basis (GDPR Art. 6)

5. Data Retention

6. Cookies and Similar Technologies

Fair Divider relies on strictly necessary cookies and equivalent storage technologies, which are exempt from prior consent under Article 22.2 of the Spanish LSSI-CE and the AEPD 2023 Cookie Guide. The website additionally offers optional analytics cookies that load only after you opt in, as described in section 7. The full inventory (strictly necessary own cookies, Cloudflare Turnstile cookies served on the multi-device page, browser-storage entries, and the optional analytics cookies set only after opt-in) is documented in our Cookie Policy.

We do not use advertising cookies, tracking pixels, or third-party cookies for profiling or behavioural advertising. The only non-essential technologies are the optional analytics described in section 7, which run solely with your consent. Cloudflare Turnstile is loaded on /multi for anti-abuse purposes only and sets no analytics or advertising cookies.

7. Optional Analytics (With Your Consent)

In addition to the strictly necessary technologies above, the Fair Divider website can load two optional analytics tools. They are disabled by default and run only after you give explicit consent.

Legal basis — your consent (Art. 6.1.a GDPR; Art. 22 LSSI-CE, which requires prior opt-in for non-essential cookies). When you first use the website we ask whether to enable analytics. You can choose "Accept all" (strictly necessary + analytics) or "Essential only" (no analytics); analytics stays off unless you opt in. Your choice is stored in your browser under the fd-analytics key.

Withdrawing consent. You can change your mind at any time — withdrawing is as easy as giving consent. Use the "Cookie settings" link in the footer of the Fair Divider app (the calculator pages) to reopen the chooser and switch analytics off; the analytics tools will no longer load.

International transfers. Google and Microsoft may process analytics data outside the European Economic Area (for example, in the United States) under the EU Standard Contractual Clauses and/or the EU-US Data Privacy Framework, in accordance with Chapter V of the GDPR.

Retention. Google Analytics data is retained for approximately 14 months; Microsoft Clarity data is retained for approximately 90 days (the providers' configured/standard retention periods).

8. Data Sharing

We do not sell, rent, or share your personal data with third parties. Our infrastructure providers process data on our behalf:

If you opt in to the optional website analytics described in section 7, Google Ireland Limited (Google Analytics 4) and Microsoft Ireland Operations Limited (Microsoft Clarity) also act as data processors on our behalf. We never sell your personal data.

9. International Transfers

Your data is primarily processed within the European Union (Hetzner Germany, MongoDB Atlas EU). Cloudflare may process traffic through global edge servers under Standard Contractual Clauses (SCCs) compliant with GDPR Chapter V.

If you opt in to optional analytics, Google and Microsoft may also process data outside the EEA (for example, in the United States) under the EU Standard Contractual Clauses and/or the EU-US Data Privacy Framework, as detailed in section 7.

10. Your Rights (GDPR Articles 15-22)

You have the right to:

To exercise any right, contact privacy@fairdivider.com with your division session code. We will respond within 30 days.

How to exercise your rights: Send an email to privacy@fairdivider.com identifying yourself. We will respond within a maximum of 1 month as required by Article 12.3 GDPR. If your request requires extraordinary complexity, we may extend this period by up to 2 additional months with prior notice.

11. Right to Complain

You have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) at www.aepd.es, or with your local supervisory authority.

12. Children

Fair Divider is not directed at children under 16 years of age. We do not knowingly collect data from children.

13. Automated Decision-Making

Fair Divider uses a mathematical optimization to calculate fair divisions. This is a mathematical computation, not profiling or automated decision-making with legal effects as defined in GDPR Art. 22.

14. Mobile Apps

The forthcoming Fair Divider apps for iOS and Android use the same /api/v1 backend described in this policy. Unlike the website, the native apps do not include the optional analytics described in section 7: they do not collect any additional personal data, do not use Google Analytics, Microsoft Clarity, or any other third-party analytics or advertising SDK, and do not request device permissions beyond what is strictly required for the user-initiated action (for example, sharing a room link). Diagnostic data sent by the operating system to its respective app store (Apple App Analytics, Google Play Console) is governed by the privacy policies of Apple and Google respectively, and not by Binary Spirit S.L.

15. Account & Data Deletion

Fair Divider does not require a user account. Server-side division sessions auto-expire after 7 days. To delete your data sooner, or to remove all locally stored data on your device, see our dedicated Account & Data Deletion page.

16. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated date.

17. Contact

For privacy-related inquiries: privacy@fairdivider.com