Privacy Policy
Last updated: 2026-06-11
This document is a working draft. Final wording is subject to legal review.
1. Controller
The controller of personal data is [OPERATOR_NAME], registered at [OPERATOR_ADDRESS], company ID [COMPANY_ID] ("we"). Contact: [CONTACT_EMAIL].
This policy covers the Jolt mobile application and the joltapp.net websites.
2. What data we process
Beta signups: e-mail address, chosen platform (Android/iOS), language, referral code, confirmation timestamps.
App account data: e-mail or sign-in identity, profile name, avatar, learning progress (XP, streaks, answers), device push token (if enabled).
Website analytics and marketing data: only with your consent (see Cookie Policy).
3. Purposes and legal bases
Providing the beta programme and the app (performance of contract, Art. 6(1)(b) GDPR).
Sending the confirmation e-mail and beta access link (consent, Art. 6(1)(a) GDPR — double opt-in).
Analytics and marketing pixels (consent, Art. 6(1)(a) GDPR).
Security, abuse prevention and rate limiting (legitimate interest, Art. 6(1)(f) GDPR).
4. Processors and recipients
Supabase (database & authentication), Vercel (hosting), Resend (transactional e-mail), Google (analytics, AdMob), Meta and TikTok (marketing pixels, only with consent).
A current list of processors is available on request at [CONTACT_EMAIL].
5. Transfers outside the EU
Where processors operate outside the EU/EEA, transfers rely on adequacy decisions or EU Standard Contractual Clauses. Details: [TRANSFER_DETAILS].
6. Retention
Beta signups: until launch + [RETENTION_MONTHS] months or until you withdraw.
Account data: for the lifetime of the account; deleted within [DELETION_DAYS] days of account deletion.
7. Your rights
You have the right of access, rectification, erasure, restriction, portability and objection, and the right to lodge a complaint with a supervisory authority ([SUPERVISORY_AUTHORITY]).
To delete your account and data, see the Delete account page.
8. Children
Jolt is intended for users aged 16 and over. We do not knowingly process data of younger children; parental consent applies where required.
9. Changes
We will announce material changes to this policy in the app or by e-mail.