Privacy Policy

Manifest Chess takes your privacy seriously. This policy explains how we use and protect your personal data when you visit the manifestchess.com website (the "Site"), download and use the Manifest Chess desktop application (the "App"), or contact us.

The data controller for the personal data described in this policy is MB Ordinary Ventures, registered in the Republic of Lithuania under company number 307541958, with its registered office at Eduardo Andrė g. 14-5, LT-02232 Vilnius, Lithuania ("we", "us", "our").

You can reach our team at hello@manifestchess.com with any privacy questions or requests.

Depending on how you interact with us, we may collect:

• Contact information: your name and email address when you write to us, sign up for an account, or start a trial.
• Account information: any username or display name you choose, your preferences, and basic account state.
• Payment information: when you subscribe, our payment provider collects the details needed to process your payment. We receive a confirmation of the transaction, but we do not store full card numbers ourselves.
• Linked-platform information: if you choose to connect a third-party chess platform such as Lichess or Chess.com, we receive only the data needed to import the games you have asked to import, for example a username and the games associated with it.
• Correspondence: the contents of emails and support requests you send us.
• Technical information: standard server logs such as IP address, browser type, and pages visited, which web servers record when you visit the Site.

We do not knowingly collect sensitive data or personal data relating to children. If you believe a child has provided us with personal data, please contact us so we can delete it.

We collect personal data when you:

• Visit the Site.
• Download, install, or use the App.
• Create an account, start a trial, or subscribe.
• Connect a third-party chess platform to the App.
• Write to us, fill in a form, or otherwise correspond with us.

Under data protection law, we only use your personal data where we have a legal basis to do so. We use it for the following purposes:

• To provide the Service: set up your account, deliver the App, sync the chess data you ask us to sync, and respond to your questions. Legal basis: performance of our contract with you, or steps to enter into one.
• To take payment and prevent fraud. Legal basis: performance of our contract with you, and our legitimate interests in protecting our business from fraud.
• To run and improve the Site and the App: understand how features are used, fix bugs, and plan improvements. Legal basis: our legitimate interests in operating a reliable product.
• To send service messages: for example trial expiry reminders, billing notices, and important changes to the Service. Legal basis: performance of our contract with you and our legitimate interests in keeping you informed.
• To send marketing communications: see Section 5. Legal basis: your consent, or our legitimate interests where you have not opted out.
• To comply with the law: where we need to keep records, respond to legal requests, or enforce our terms. Legal basis: compliance with a legal obligation, and our legitimate interests.

We will only send you promotional emails about Manifest if you have asked for them, started a trial, or purchased a subscription, and you have not opted out.

You can opt out at any time by clicking the unsubscribe link in any marketing email, or by contacting us. If you opt out, you will still receive essential service messages about your account, your subscription, or important changes to the Service.

We only share personal data with third parties where it is necessary, and only in the following situations:

• Service providers that help us run Manifest, including our payment provider, email delivery provider, hosting provider, and customer support tools. They process data on our instructions and are bound by confidentiality.
• Legal and regulatory bodies where we are required to share data to comply with the law or any applicable regulation.

We do not sell your personal data, and we do not share it with third parties for their own marketing purposes without your express consent.

We store and process personal data within the European Economic Area (EEA). Where any of our service providers process data outside the EEA, we take steps to make sure your data receives an equivalent level of protection, including by relying on the European Commission's adequacy decisions or by putting standard contractual clauses in place.

The Site and the App may contain links to third-party websites or services that we do not control. We are not responsible for their content or practices, and this policy does not apply to them. Please read the privacy policy of any third-party site you visit.

The Site uses cookies and similar technologies as described in our Cookies Policy.

We take the security of your data seriously and use appropriate technical and organisational measures to protect it. We limit access to personal data to those who need it for legitimate business purposes, and they are bound by confidentiality obligations.

The Manifest Chess App processes your chess library locally on your device. Files you import remain on your computer unless you explicitly choose to sync them.

We only keep your personal data for as long as is reasonably necessary to fulfil the purposes for which it was collected.

We keep most of your personal data for as long as you use the Service, or until you withdraw your consent where consent is the legal basis we rely on. We keep information about orders and payments for 6 years after the end of our relationship with you, so that we can comply with our tax and accounting obligations.

Under data protection law you have the following rights:

• The right to be provided with a copy of the personal data we hold about you.
• The right to ask us to correct any personal data we hold about you.
• The right to ask us to delete your personal data in certain circumstances.
• The right to request that we restrict the processing of your personal data in certain circumstances.
• The right to request that we transfer your personal data to yourself or a third party in certain circumstances.
• The right to withdraw your consent to processing where consent is the legal basis we rely on.
• The right to object to the processing of your personal data for direct marketing purposes.
• The right to object to the processing of your personal data in certain circumstances where we rely on a legitimate interest.

You can read more about your rights on the website of the Lithuanian State Data Protection Inspectorate at vdai.lrv.lt.

To exercise any of these rights, please contact us at hello@manifestchess.com. We do not charge a fee, but we may need to ask you for additional information to confirm your identity.

We will respond to legitimate requests within one month. If a request is particularly complex, this may take longer. If so, we will let you know.

Please let us know if any personal data we hold about you is incorrect or out of date so we can fix it.

We review and update this policy from time to time. When we do, we will post the updated version on this page and revise the "last updated" date above. Please check this page when you visit the Site.

We would appreciate the chance to resolve any concerns about your data before you take them further. You can contact us at hello@manifestchess.com at any time.

You also have the right to make a complaint to the Lithuanian State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija) at any time.