✦ Constella

Privacy Policy

Version dated 24 October 2026

Contents
  1. 1. Data controller
  2. 2. The essentials
  3. 3. The data we process
  4. 4. Purposes and legal bases
  5. 5. Who sees your data
  6. 6. Our service providers
  7. 7. Transfers outside the European Union
  8. 8. Retention periods
  9. 9. Security
  10. 10. Your rights
  11. 11. Deleting your account
  12. 12. Notifications, trackers and audience measurement
  13. 13. Minors
  14. 14. If you live outside the European Union
  15. 15. Changes
  16. 16. Contact

1. Data controller

The controller of your personal data is Kubilay YANAR EI (Bethkepha), entreprise individuelle (EI) (RCS Lyon 130 936 354 (SIRET 130 936 354 00013)), whose registered office is at 30 avenue Maréchal Foch, 69006 Lyon, France (“Constella”, “we”, “us”). For any question about your data or to exercise your rights: contact@constellatcg.com, or Profile › Settings › Help and support, topic “Account, login, personal data”. Constella has not appointed a data protection officer, as it is not required to: these contacts serve that purpose.

2. The essentials

3. The data we process

CategoryData
Accountemail address, first name, password (stored hashed, never in plain text), profile emoji or photo, language, time zone, country and where that information came from, date and version of the accepted terms
Phoneverified mobile number, verification date; codes sent by SMS are only kept as a fingerprint; to fight SMS fraud, each code request leaves a trace that contains neither your number nor your account in plain text: the country of the number and non-reversible fingerprints of the number, of its first digits and of the IP address of the request
Duos and contentduos, invitation codes, bubbles (titles, descriptions, rewards, statuses, dates), shared notes, vouchers, price or reward counter-offers, duo settings
GameXP, levels, achievements, streaks, star points, chests, boosters, cards, the duo’s sky, chosen look
Friends and tradesusername (name chosen at sign-up and number); friends list (requests sent and received, acceptances, refusals, removals, with their dates), blocked accounts, dates of the friend requests you sent; card trades (cards offered and asked for, rarity, status, dates), duplicates set aside by a pending trade; your setting for the “Friends and trades” notification category
Friends leaderboardyour choice to appear in the leaderboard or not, and its date; the leaderboard is calculated each time it is viewed from your game data (level, constellations and skies lit up, different cards, completed albums), without being stored separately
Bonus wheel (video ads)for each video requested, a ticket (random identifier, duo, creation and expiry times; the token sent to Google is only kept as a hash); for each video confirmed by Google: its transaction identifier, the ad unit, the time of the reward, the day and rank of the video, the prize drawn and its quantity, the time the wheel revealed it; your choice about personalised ads (yes or no, its date, the text shown), kept on your phone only
Subscriptionsplan (Constella PLUS or Constella MAX), store (App Store or Google Play) and environment (real or test purchase), product, status, dates (start, expiry, grace period, refund), auto-renewal, transaction identifiers or purchase token provided by the store, Google order number; the random identifier of your account passed to the store at purchase; the store’s notifications (identifier, type, date); the Constella MAX monthly gifts received. We never receive your bank details or your Apple or Google ID
PaymentsStripe customer and account identifiers, Wallet status, amounts, currencies, fees, payment statuses and receipts, ledger of transactions; never card numbers or bank details
Tax obligationsonly if the platform reporting rules apply to you (Terms, Article 9.8): name, address, date of birth, tax identification number, details of the account that receives the sums, sums received and fees collected per quarter
Notificationsdevice notification token, preferences (sound, quiet hours, muted duos), notifications received
Supportyour requests, your messages, the photo you may attach (re-encoded, without its metadata) and the team’s replies
Securitylog of sensitive actions (sign-ins, posts, approvals…) with the IP address, sessions, failed sign-in attempts, two-factor authentication secret (encrypted) and backup codes (hashed); restrictions and suspensions placed on your account, with their reason
Audience measurementfor each day the App was opened: the date, the platform (iOS, Android) and the App version; your account’s origin (for example an invitation), chosen from a closed list
Technical dataApp version, phone language, region and time zone, sent with each request; server technical logs
Error reportsin case of an error or crash, and for a small share of app launches and requests (performance measurement): the device model, the system and App versions, the technical trace of the error or the duration of the operation; never your name, your email address, your number or the content of your messages

Stripe directly collects, on its own behalf, the data needed for payments and, if you activate your Wallet, for verifying your identity (ID document, date of birth, address, bank details).

If you watch a bonus wheel video, Google (Google Ireland Limited; Google LLC) directly collects, on its own behalf, the data needed to show the ad, measure its delivery and prevent fraud: IP address, technical information about the device and the App, interactions with the ad and, in the European Economic Area, the United Kingdom and Switzerland, your choices in its consent form. We do not send it your name, email address, phone number or account identifier: only a random single-use token, which it sends back to us to confirm that the video was watched. If personalised ads apply to you (Article 12), Google also uses your phone’s advertising identifier (IDFA on iPhone, advertising ID on Android) and the advertising profile it links to it.

4. Purposes and legal bases

WhyLegal basis
Create and manage your account, duos, bubbles, the game and notificationsperformance of the contract (the Terms)
Let you add friends by their username, manage your friends list and blocks, and trade cards between friendsperformance of the contract (the Terms, Article 8)
Calculating and showing the friends leaderboard, if you choose to appear in itperformance of the contract (the Terms, Article 8)
Limit trades to prevent abuse (trades per week depending on the plan, pending offers, username lookups, age of the account and of the friendship, verified number, no back-and-forth) and keep a log of tradeslegitimate interest (fairness of the game and fraud prevention)
Process payments between partners and the service feesperformance of the contract
Making, where applicable, the platform reports to the tax authorities (DAC7)legal obligation (Articles 1649 ter A et seq. of the French General Tax Code)
Sell and manage your Constella PLUS or Constella MAX subscription: verify the purchase with the store, unlock the benefits, follow renewals, cancellations and refundsperformance of the contract (the Terms, Article 10)
Verify your phone number, prevent multiple accounts, fraud and abuselegitimate interest (security of the Service and fairness of the game)
Secure accounts, keep a log of sensitive actionslegitimate interest; legal obligation to ensure security
Answer your support requests and reportsperformance of the contract; legitimate interest
Handling reports, moderating content and enforcing the Terms (restrictions, suspensions)legitimate interest (users’ safety); legal obligation (Regulation (EU) 2022/2065, the Digital Services Act)
Keep our accounting records, produce the yearly statement, respond to the authoritieslegal obligation
Measure the App’s audience for our own uselegitimate interest (you can object, Article 12)
Detecting and fixing technical errors, measuring performance (error reports)legitimate interest (proper functioning and security of the Service)
Offering you, at your request, rewarded video ads, checking with Google that they were watched, drawing and giving you the bonus wheel prizeperformance of the contract (the spin you request); fraud prevention: legitimate interest; Google’s access to your device in the EEA, the United Kingdom and Switzerland: your consent, collected through Google’s form
Personalise these ads (advertising identifier, Google’s advertising profile)European Economic Area, United Kingdom, Switzerland, Quebec, Turkey and wherever the law requires it: your prior consent, which you can withdraw at any time; United States and Canada outside Quebec: our legitimate interest in funding the Service through advertising, with your right to refuse at any time (Article 12)
Send you notificationsperformance of the contract, with your permission given in the phone’s settings

5. Who sees your data

6. Our service providers

ProviderRoleLocation
Stripe (Stripe Payments Europe, Limited; Stripe, Inc.)payments, payment accounts, identity verificationIreland, United States
Apple (Apple Distribution International Ltd.; Apple Inc.) and Google (Google Ireland Limited; Google LLC)sale, billing and refunds of subscriptions through the App Store and Google Play; verification of purchases and notifications of their statusIreland, United States
Twilio (Twilio Ireland Limited; Twilio Inc.)sending verification codes by SMS (your number and the code) and, if we enable it, checking the number’s line typeIreland, United States
Railway Corporation, San Francisco, CA, USA — railway.comhosting of the server and databaseUnion européenne — Pays-Bas (Amsterdam, région « EU West » de Railway)
Brevo (Sendinblue SAS), 106 boulevard Haussmann, 75008 Paris, Francesending emails (codes, support replies, security alerts)see opposite
Expo (650 Industries, Inc.)routing push notifications (device token, notification title and text)United States
Apple (Apple Push Notification service) and Google (Firebase Cloud Messaging)delivering notifications to your phoneUnited States
Sentry (Functional Software, Inc.)tracking of technical errors and performance (error reports, Article 3), without identifying dataEuropean Union (Germany); company based in the United States
Cloudflare (Cloudflare, Inc.), where applicabledelivery of card images: no account data, only technical connection data, including the IP addressglobal network; company based in the United States

Providers that process your data on our behalf (processors) are bound by a contract complying with Article 28 of the GDPR, which requires them to process it only on our instructions and to protect it. Stripe, Google for advertising, and Apple and Google for the sale of subscriptions act as independent controllers, for their own purposes (Article 5).

7. Transfers outside the European Union

Some providers, as well as Google for advertising, are established or process data outside the European Economic Area, notably in the United States. These transfers are based on the European Commission’s adequacy decision on the EU–US Data Privacy Framework where the recipient is certified under it, or otherwise on the European Commission’s standard contractual clauses, supplemented where necessary by additional measures. You can obtain a copy by writing to us. The location where our servers are hosted is given in Article 6. If you live outside the European Union, your data is processed in the countries listed in Article 6.

8. Retention periods

DataPeriod
Account, duos, bubbles, gameas long as your account exists; anonymised as soon as it is deleted (Article 11)
Username, friends list, blocks, trade historyas long as your account exists; when it is deleted, your friends, requests and blocks are erased, your pending trades cancelled, and completed trades stay linked to the anonymised account (Article 11)
Phone numberas long as it is linked to your account; after the account is deleted, only a (non-reversible) fingerprint is kept for 30 days to prevent an account from being recreated straight away with the same number
Anonymous trace of SMS code requests (country, fingerprints)30 days
Verification codes (email, SMS)valid for a few minutes to a few hours, then erased no later than 30 days afterwards
Login sessionsat most 90 days, then erased no later than 30 days after they expire
Notifications90 days after being read; at most 180 days if never read
Log of sensitive actions (with IP address)365 days
Audience measurement25 months
Bonus wheeltickets: deleted one day after they expire (they are valid for 30 minutes); videos confirmed by Google and prizes drawn: 90 days (the prize won stays in your game, like other items); Google keeps its own data under its own rules; your choice about personalised ads: on your phone, until you change it or delete the App
Support requestsA closed request disappears from the App 30 days after it was closed, and is then deleted automatically (messages and attached photo included); a request about a payment, a report or a bubble is kept 5 years after its last activity, as evidence in case of a dispute, then deleted; the same applies to a request left open. Copies: the support team receives an email alerting it to each new message, without its content; an excerpt of the team’s replies appears in your notifications (duration: “Notifications” row) and the full reply in the email you receive
Payments and ledger10 years, under accounting obligations; Stripe keeps its own data according to its legal obligations
Data for platform tax reports (where applicable)the period required by law, 10 years at most
Subscriptions (transaction identifiers, plan, dates, store)as long as your account exists; after its deletion, linked to the anonymised account for 10 years, under accounting obligations; store notifications: 90 days
Account restrictions and suspensionsas long as your account exists; deleted when it is deleted (a record of the action remains in the log of sensitive actions)
Error reports90 days at most at Sentry

9. Security

Hashed passwords, encrypted connections (HTTPS), encrypted two-factor authentication secrets, session tokens stored in the phone’s secure storage, team access protected by mandatory two-factor authentication and logged: we apply measures suited to the risk. As no system is infallible, we will inform you and the competent authority of any data breach that poses a risk to you, as provided by law.

10. Your rights

You have the right of access, rectification, erasure, restriction, portability and objection (in particular to audience measurement, and to processing based on our legitimate interest on grounds relating to your particular situation), the right to withdraw your consent at any time, without affecting what was done before, and the right to set instructions on what happens to your data after your death.

Automatic measures. Some security measures are taken automatically: payment caps, refusal of a username, a longer or shorter hold on a payment depending on its authentication and the accounts’ history, suspension of receiving money while your Stripe balance is negative (lifted automatically once it is back to zero or positive). They are necessary for performing the contract and preventing fraud (Article 22 of the GDPR): you can at any time have a member of our team review them, express your point of view and challenge them, by writing to support.

You can lodge a complaint with the French data protection authority (CNIL, 3 place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France, www.cnil.fr) or with the data protection authority of your country.

11. Deleting your account

How: in the App, Profile › My account › Delete my account, then confirm with your password. Deletion is possible as soon as no bubble is in progress in your duos (complete or cancel them first). Without the App, you can also request it on the Delete my account page: enter your account’s email address, then confirm using the link, valid for one hour, that we send there (and your two-factor authentication code if it is on). The deletion is then the same as from the App. If you can no longer access the App, write to contact@constellatcg.com from your account’s email address.

What is deleted immediately: your email address, first name, photo, phone number, country, sessions, notification tokens, notifications, verification codes, two-factor authentication secret, the history of the notes you wrote, and your bonus video tickets and history. Your duos are dissolved. Your username is retired: it is given to no one else for 90 days (only the part of the username before “#”, in lower case and without accents, and the number are kept during that time, with no link to your account); your friends list, friend requests and blocks are erased, and your pending card trades are cancelled (duplicates set aside go back to their owners).

What is kept, linked to an anonymised account that no longer directly identifies you: payments and the ledger (accounting obligations), bubbles and content shared with a partner, support requests and the security log, for the periods in Article 8. Your number’s fingerprint is kept for 30 days. Your subscription data is kept in the same way, and the random identifier passed to the stores is replaced: it no longer designates anyone. Deletion does not cancel an ongoing subscription: only the store (App Store or Google Play) can. The history of card trades completed with your friends also stays linked to the anonymised account: your former friends see “Deleted account” there.

Good to know. The messages and photo of a support request that is kept may still contain information about you: they are only kept for the periods in Article 8, then deleted, and you can ask for them to be deleted earlier once they are no longer needed as evidence. Your Stripe payment account, if you have one, is not closed by the deletion: Stripe, as an independent controller, keeps your data under its own legal obligations, and you can ask it to close the account, directly or through support. Any balance left in it is transferred to you free of charge (Terms, Article 16).

12. Notifications, trackers and audience measurement

13. Minors

Constella is reserved for adults (at least 18, or the age of majority in your country if it is higher). We do not knowingly collect data from minors and therefore never collect a minor’s consent (in France, a minor can only consent alone to the processing of their data from the age of 15); if we learn that an account belongs to a minor, we delete it.

14. If you live outside the European Union

The rights in Article 10 are available to you wherever you live. In addition:

15. Changes

We may change this policy. The date of the update is shown at the top of the page; a significant change is announced in the App.

16. Contact

Kubilay YANAR EI (Bethkepha), 30 avenue Maréchal Foch, 69006 Lyon, France — contact@constellatcg.com. Help and support: contact@constellatcg.com, or Profile › Settings › Help and support.