Privacy Policy
Last updated 23 August 2026
1. Definitions and interpretation
In this policy, the following terms have the following meanings:
- "the App" means the Manifest Chess desktop application.
- "the Site" means the manifestchess.com website.
- "the Service" means the App, the Site, and the related online services we provide.
- "personal data" means any information about you from which you can be identified, as defined in the EU General Data Protection Regulation (GDPR).
- "we", "us", "our" means Ordinary Ventures MB, as described in section 2.
- "you", "your" means the person using the Site or the App, or otherwise dealing with us.
- "EEA" means the European Economic Area.
2. Information about us
The Site and the App are operated by Ordinary Ventures MB, registered in the Republic of Lithuania under company number 307541958, VAT number LT100020339915, with its registered office at Eduardo Andrė g. 14-5, LT-02232 Vilnius, Lithuania ("we", "us", "our").
We are the data controller responsible for the personal data described in this policy. You can reach our team at hello@manifestchess.com with any privacy questions or requests.
3. What this policy covers
This policy explains how we use and protect your personal data when you visit the Site, download and use the App, or contact us. Please read it carefully so you understand how we handle your data and the rights you have.
4. What personal data we collect and how
Depending on how you interact with us, we may collect the following personal data:
| Data we collect | How we collect it |
|---|---|
| Contact information | Your name and email address, which we collect 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, which we collect when you create and use an account. |
| Sign-in details | If you sign in with Google or Apple, the provider shares your email address with us so we can identify your account. Google may also share your display name and profile picture where you have made these available. Apple may share your name on first sign-in, and lets you use a private relay email address instead of your real one. |
| Payment and subscription information | When you subscribe through the Mac App Store, Apple takes the payment and we never see your card details. We receive confirmation of the purchase and your subscription status, which our subscription provider validates from the App Store receipt. |
| Linked-platform information | If you 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. |
| Usage data | How you use the App: which features you open, when you create or import into a database, when you run a game review and its outcome, when you link Lichess or Chess.com, and similar product events. Each event carries your app version and your operating system platform. These events are linked to your account and are not anonymous. Section 9 says who processes them. |
| Device and identifier data | A device or installation identifier generated by our analytics tool, your app version, and your operating system platform. |
| Chess positions from a game review | When you run a game review, the App sends the positions of that game to our evaluation service so it can return cached engine evaluations. Section 8 explains what this does and does not include. |
| Databases you back up | When you use cloud backup, the games in that database are written out as PGN, compressed, and stored by us so you can restore them. Only the databases you choose to back up are uploaded. Section 8 explains this alongside the other chess data we receive. |
| Technical information | Standard server logs such as IP address, browser type, and pages visited, which web servers record when you visit the Site, and request logs for our API. |
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.
5. How we use your personal data and our legal bases
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:
| Purpose | Legal basis |
|---|---|
| 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. | Performance of our contract with you, or steps to enter into one. |
| To manage your subscription, confirm your purchase with Apple, and prevent fraud. | 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. Our analytics events are linked to your account, so we can see how an individual account uses the App, and our analytics tool stores an identifier on your device. | Our legitimate interests in operating a reliable product. You can object to this processing at any time by emailing us, and deleting your account removes your analytics profile. |
| To send service messages, for example trial expiry reminders, billing notices, and important changes to the Service. | Performance of our contract with you, and our legitimate interests in keeping you informed. |
| To send marketing communications, as described in section 6. | 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. | Compliance with a legal obligation, and our legitimate interests. |
6. Marketing
We will only send you promotional emails about Manifest Chess 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.
7. How long we keep your data
We only keep your personal data for as long as is reasonably necessary to fulfil the purposes for which it was collected.
| Data | How long we keep it |
|---|---|
| Account data (email address, name, sign-in identity) | Kept while your account exists. Deleted when you delete your account. |
| Databases you back up | Kept so that you can restore them. We may delete stored backups after your subscription ends, and they are deleted when you delete your account. |
| Usage events and your analytics profile | Kept while your account exists, and no longer than we need them to understand how the App is used. Your analytics profile is deleted when you delete your account. |
| Server and API request logs, including IP address | Kept only as long as we need them for security and diagnostics, then deleted. |
| Support correspondence | Kept while we need it to deal with your query and any follow-up, then deleted. |
| Order and payment records | Kept for 6 years after the end of our relationship with you, so that we can comply with our tax and accounting obligations. |
Where consent is the legal basis we rely on, we stop the processing when you withdraw it.
8. How and where we store and transfer your data
Several of our service providers are based in the United States, so your personal data is transferred outside the European Economic Area (EEA). This applies to sign-in (Google), analytics (Mixpanel), subscription management (Apple and RevenueCat), and hosting.
Where we transfer personal data outside the EEA, we rely on the European Commission's adequacy decision for the EU-US Data Privacy Framework where the provider is certified under it, and on standard contractual clauses otherwise. You can ask us for details of the safeguards that apply to a specific transfer.
We use appropriate technical and organisational measures to protect your personal data. 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 keeps your chess library on your device. Game files, databases, and the games you import are stored locally in the App and are not uploaded to us.
There are two exceptions. The first is game review. When you run one, the App sends the positions of that game to our evaluation service so it can return cached engine evaluations. It sends the positions only, as FEN strings, with no player names, event details, or other game metadata. The request is authenticated, so those positions are associated with your account. Positions are chess facts and are not unique to you, but we treat the fact that you reviewed them as personal data.
The second is cloud backup. When you back a database up, the App writes that database's games out as PGN, compresses them, and uploads the result to our storage so you can restore it on another device. This happens only for the databases you choose to back up, and only when you ask for it. Storage is limited to 10 GB per account.
No other feature sends chess data off your device.
9. Sharing your personal data
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 Chess. We name the ones that receive personal data: Google (Firebase Authentication, sign-in and account identity); Mixpanel (product analytics, see the next bullet); Apple (App Store purchases, billing, and subscription management); RevenueCat (validates App Store receipts and tracks your subscription status); and our email delivery and hosting providers. They process data on our instructions and are bound by confidentiality.
- Analytics: we use Mixpanel to understand how the App is used. When you sign in, we send Mixpanel your account identifier, your email address, your display name, and whether you have an active subscription. Usage events are linked to that profile, so they are not anonymous and not merely aggregated. Analytics traffic is routed through our own server at api.manifestchess.com before it reaches Mixpanel, so Mixpanel does not receive your IP address directly.
- Identity providers:we use Google's identity service to confirm who you are when you sign in, whether you choose Google, Apple, or an email sign-in link. Google receives the data needed to perform that check, such as your email address. If you sign in with Apple, Apple also receives the details needed to validate your Apple ID. Each provider's own privacy policy applies to its use of your data.
- 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, we do not share it for cross-context behavioural advertising, and we do not share it with third parties for their own marketing purposes without your express consent.
10. Your rights
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.
11. How to exercise your rights
You can delete your account yourself at any time. In the App, go to Settings, then Legal, and choose Delete account. On the Site, sign in and choose Delete account on your account page. This works whether or not you have an active subscription. Deleting your account removes your account record and your analytics profile, and it stops all further processing.
Your chess databases live on your own computer, so deleting your account does not delete them. You remove those by deleting the files. If you subscribed through the App Store, deleting your account does not cancel the subscription: cancel that in your Apple Account settings.
To exercise any other right, or to ask us to delete your account for you, 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.
12. Your California privacy rights
If you are a California resident, the California Consumer Privacy Act gives you the right to know what personal information we collect and why, to request a copy of it, to ask us to delete or correct it, to opt out of any sale or sharing of it, and not to be discriminated against for exercising these rights.
In the past 12 months we have collected these categories of personal information:
- Identifiers: email address, name, and account and device identifiers.
- Commercial information: your subscription and purchase history.
- Internet or network activity: how you use the App and the Site.
- Other user content: the chess positions in a game you run a review on, as described in section 8.
We collect these for the purposes set out in section 5. We do not sell your personal information and we do not share it for cross-context behavioural advertising.
To exercise a right, delete your account in the App under Settings, then Legal, or email us at hello@manifestchess.com.
13. Withholding information
You can choose not to provide certain personal data to us. However, some data is necessary for us to provide the Service. For example, we need an email address to create your account. If you do not provide data that we need, we may not be able to provide part or all of the Service to you.
14. Third-party links
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.
15. Cookies
The Site uses cookies and similar technologies as described in our Cookies Policy.
16. Keeping us up to date
Please let us know if any personal data we hold about you is incorrect or out of date so we can fix it.
17. How to contact us
If you have any questions about this policy or how we handle your personal data, please email us at hello@manifestchess.com.
18. Changes to this policy
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.
19. Complaints
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.