Legal & Data Protection
Privacy notice
Last updated: 13 October 2026
KROSS (kross.im) is a training simulator for frontline humanitarian negotiation. This notice explains what personal data KROSS processes, why, who receives it, and what you can do about it.
Who is responsible
KROSS is run by Denis J, who is responsible for your personal data (“we” below). Contact for anything about privacy: [email protected].
Please do not enter real sensitive information
The scenarios are fictional. Do not put real names, real locations of operations, security details, or other sensitive information about yourself or anyone else into session messages, notes, questions to the coach, briefs for AI scenario writing, or trainer twists. Session dialogue, coach questions, AI scenario briefs and trainer twists are sent to an AI model provider in China (see below), and so are preparation and reflection notes when the coach uses them. We do not remove identifying details from that text. Trainer comments on turns and private observer notes are not sent to the AI.
What we process
If you sign in with Google: we request Google’s basic profile and email scopes. We store your Google account ID, your name, your email address and whether Google verified it. Other basic profile fields Google may return (such as a picture) are not saved. We do not request access to your contacts, files, calendar or other Google data.
If you play as a guest: no name or email. We create a random guest account.
What you write and what the simulator produces: your messages in a session, your preparation and reflection notes, questions you ask the debrief coach, briefs and scenarios you write (including your answers in the guided scenario builder), the simulator’s replies, scores and debriefs, and the pictures painted for scenarios you build, which are stored with the scenario as its cover.
In an organisation: your membership and role. Trainer comments on your turns and trainer twists are stored with the session.
Usage records: for each AI model call, the number of input and output tokens (pieces of text), the time, the model and its role, whether the call succeeded and how long it took, and the random identifiers of the account, organisation and session it belonged to. These records contain no message text. We use them to apply daily limits and control costs.
We also keep counters for session starts, write requests and allocated storage, and reservations for paid AI work. They contain random account and organisation identifiers and counts, not message text. Deleting content does not reset these allowances. Obsolete daily write counters are removed during the daily clean-up; cumulative storage counters remain to prevent repeated deletion from bypassing limits.
Technical data: our servers log requests, including your IP address, to keep the service running and secure.
If you write to us: the contact details and whatever you include, to answer your request.
Why, and on what legal basis
- To provide the training service you asked for (accounts, playing scenarios, debriefs, organisations, writing scenarios): performance of our agreement with you (GDPR Art. 6(1)(b)).
- To keep the service secure and affordable (sign-in sessions, server logs, abuse prevention, daily usage limits): our legitimate interest in running a safe service that we can pay for (GDPR Art. 6(1)(f)).
KROSS does not use your data for advertising and does not sell it. Google Analytics data collected on this website is processed by Google under Google’s own terms and settings.
Who receives your data
- Admins of organisations you join (your trainers): your name, email address and role. For solo sessions you play while that organisation is selected, they can read the session, your preparation, reflection and debrief, follow it live, and add comments that you do not see. Test runs of your own scenarios (playtests) are visible only to you.
- Other people in KROSS, for scenarios you share: members of an organisation can read scenarios shared with it; its admins can read private drafts you submit to them for publication; public scenarios can be read by anyone using KROSS, including guests, and are managed by the people who run KROSS.
- Our hosting provider in the European Union, which runs our servers and database.
- Our AI model provider, DeepSeek (People’s Republic of China). It receives the text used for simulation and feedback: the relevant scenario content, the dialogue and the simulator’s replies, scores and outcomes, trainer twists, questions to the coach (each is first sent for a topic check, even if it is then refused) and recent coach chat, your preparation and reflection notes when the coach uses them, and briefs and builder answers you submit for AI scenario writing (even if you never save or play the result). We do not attach your account name, email address or Google account ID to these requests, but if you type identifying information into that text, DeepSeek receives it.
- Google, to sign you in. If you email our Gmail address, Google also processes that correspondence.
- Google’s Gemini API (Google LLC, United States), to paint scenario pictures in the guided builder. It receives a short scene description that our AI model writes from your scenario text (places, vehicles, situation; the model is told to leave out names), and, for the final picture, the first picture to update. Google LLC takes part in the EU-U.S. and Swiss-U.S. Data Privacy Frameworks.
- Google Analytics (Google LLC, United States), for this website only: the page address visited, your IP address, and basic browser and device information, sent when a page of this website loads. The Google tag is not installed in the app at app.kross.im. Google LLC takes part in the EU-U.S. and Swiss-U.S. Data Privacy Frameworks.
- The people who run KROSS, when needed for support, security or usage limits.
Transfer to China
Text sent to the AI model is processed by DeepSeek on servers in the People’s Republic of China. Neither the European Union nor Switzerland considers China to offer an adequate level of data protection, and we do not have a data protection agreement or standard contractual clauses with DeepSeek. This means that text may be accessible to Chinese authorities under Chinese law, and you may not be able to enforce your rights against DeepSeek. This is why you should keep real sensitive information out of it. If you do not accept this transfer, please do not use the AI features.
How long we keep data
These periods apply to KROSS’s own database. Deleting data in KROSS does not delete copies DeepSeek or Google may already have kept of text or pictures sent to them. A scenario’s cover picture is kept and deleted together with the scenario, so the cover of a shared scenario stays with it.
- Guests: a guest’s sign-in lasts at most 24 hours. Guest accounts and their sessions are removed by a daily clean-up once the account was created before the previous day (UTC), normally within three days.
- Play sessions of signed-in users: removed by a daily clean-up about 12 months after they end. A session that was never finished is removed about 12 months after its last turn or turn attempt. Viewing a session or editing its notes does not extend this. Sessions are also removed earlier when you delete your account.
- Your account: until you delete it, which you can do yourself under My account. If you are the only admin of an organisation that has other members, first make another member an admin. Deleting your account removes your sessions, debriefs and private scenarios, and organisations where you are the only member.
- Scenarios you shared: scenarios shared with an organisation that remains, and public scenarios, stay after you delete your account. The link to your account is removed, but names or other personal details written into a scenario’s text are not erased automatically.
- Usage records and cumulative abuse-prevention counters: kept without an automatic end date. Deleting your account removes the account they point to, but not the records or their identifiers.
- Server logs: only as long as needed to run and secure the service.
Cookies and browser storage
The app at app.kross.im uses only cookies that are strictly necessary: one that keeps you signed in (nlab_session, up to 7 days, or 24
hours for guests) and one that protects the Google sign-in for 10 minutes (nlab_oauth). Your browser also keeps, for
the current tab session, a few interface choices and an invitation link’s token while you sign in (removed once used).
A trainer’s private observer notes stay in that browser until they are erased or the site’s browser data is cleared;
signing out or deleting the account does not remove them. The sign-in cookies are sent to KROSS to recognise you, and
an invitation token is sent to KROSS to show and accept the invitation; observer notes and interface choices are never
uploaded.
This website at kross.im loads a Google Analytics (GA4) tag immediately on every page load, to count visits and page
loads. It sets Google’s own analytics cookies (such as _ga) and sends the page address, your IP
address and basic browser and device information to Google LLC (United States). What Google does with that data is
governed by Google’s own terms and settings. The Google tag is not installed in the app at app.kross.im.
Automated feedback
The AI scores your negotiation turns and writes a debrief. This is training feedback only. KROSS makes no decisions about you with legal or similarly significant effects; if your organisation looks at your scores, a person decides what to do with them.
Your rights
You can ask us for access to your data, a copy in a portable format, correction, deletion, restriction of processing, and you can object to processing based on our legitimate interests. Write to the contact address above; we answer within 30 days. You can also complain to a data protection authority: in Switzerland the Federal Data Protection and Information Commissioner (FDPIC), in the EU the authority of the country where you live or work.
Google user data
KROSS’s use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. We use your Google account ID, name and email address only to sign you in and show who you are inside KROSS.
Children
KROSS is meant for adults in humanitarian work. It is not intended for anyone under 16.
Changes
If we change this notice, we update the date at the top. If a change matters for how your data is used, we will tell signed-in users in the app.