Jolvi Privacy Policy
1. Scope
This Privacy Policy explains how Jolvi ("we", "us", or "our") processes personal data when you use the Jolvi mobile application and related services (the "Service"). It is intended for users in Germany, the European Union, and other regions where the Service is offered.
2. Contact Details
Data controller: Jolvi
Location: Germany
Email: [email protected]
If you would like to exercise your privacy rights, ask a question, or submit a complaint directly to us, please use the email above.
3. What Data We Process
| Category | Examples |
|---|---|
| Account and profile data | Nickname, internal user ID, login status, and profile data created within the app. |
| User content | Notes, photos, captions, stories, event posts, reports, saved routes, app progress, and other content you create or choose to process in the app. |
| Purchase and entitlement data | Transaction IDs, product IDs, signed transaction payloads, purchase history, and virtual balance or entitlement records. |
| Location data | Precise device location while using location-based features, route or activity tracking data, and approximate public IP geolocation when relevant features request it. |
| Audio and speech data | Microphone input and speech-to-text results when you use voice input or dictation features. |
| Device and technical data | Persistent device identifier stored in secure storage, device model, operating system version, app version, hashed device ID in network user-agent strings, IP address, and general request metadata. |
| Advertising attribution data | App Tracking Transparency status and, if you grant permission on iOS, advertising identifier and attribution-related information used for campaign measurement. |
4. How We Collect Data
We collect data in the following ways:
- Directly from you when you create content, use features, contact us, or make purchases.
- Automatically from your device and app usage, such as device information, app version, network request metadata, and permission status.
- From platform providers and service providers, such as Apple for in-app purchases, attribution SDKs, speech frameworks, or geolocation-related services.
5. Why We Process Personal Data and Legal Bases
| Purpose | Legal basis under GDPR |
|---|---|
| Provide the core app, save your data, keep your content available on your device, and maintain app state. | Article 6(1)(b) GDPR, performance of a contract or steps requested by you. |
| Process in-app purchases, validate transactions, manage entitlements, and prevent purchase fraud or abuse. | Article 6(1)(b) and Article 6(1)(f) GDPR, contract performance and our legitimate interests in secure operations. |
| Enable optional features that require camera, photos, microphone, speech recognition, or location. | Article 6(1)(b) GDPR when necessary for the feature you use, and Article 6(1)(a) GDPR where consent or device permission is required. |
| Measure advertising attribution on iOS with tracking authorization. | Article 6(1)(a) GDPR, consent, where App Tracking Transparency or similar rules require it. |
| Secure the Service, debug issues, monitor reliability, enforce terms, and defend legal claims. | Article 6(1)(f) GDPR, our legitimate interests in security, support, and legal compliance. |
| Comply with legal obligations, tax, accounting, consumer, or law-enforcement requests that apply to us. | Article 6(1)(c) GDPR, compliance with a legal obligation. |
6. App Permissions and Related Processing
| Permission | Why it is requested |
|---|---|
| Camera | To capture images or other visual content within the app. |
| Photo Library | To select existing images and, where supported, save generated or processed images. |
| Microphone | To record voice input for dictation and voice-enabled features. |
| Speech Recognition | To convert your spoken words into text for captions, notes, posts, or similar content. |
| Location When In Use | To support location-based discovery, mapping, or context-aware features while you are actively using the app. |
| Background Location | For supported live activity or tracking features that continue updating route, timing, or distance after you leave the main recording screen. |
| App Tracking Transparency | To request permission to access advertising attribution data on iOS for campaign measurement and optimization. |
You can withdraw device permissions at any time in your operating system settings. Withdrawing a permission will not affect the lawfulness of processing that took place before withdrawal, but some app features may no longer function.
7. Where Data Is Stored
Most content is stored locally on your device, including notes, stories, event posts, saved routes, purchase history caches, preferences, and a persistent device identifier saved in secure storage. Data is transmitted to remote services only when you explicitly use features that require it, such as AI image scoring or in-app purchase validation.
8. When Data Is Shared With Third Parties
We may share data with service providers and processors only as needed to operate the Service, including:
- App marketplace and payment providers such as Apple for billing and transaction handling.
- Backend infrastructure used to authenticate users, validate purchases, and respond to app requests.
- Attribution and analytics providers used to measure installs and campaign performance when legally permitted.
- Speech, mapping, geolocation, or other platform-level frameworks invoked by device features you choose to use.
- AI or image-processing service providers when you ask the app to analyze a selected image or similar content.
- Public IP geolocation providers if the app requests approximate location from IP-based lookup.
We may also disclose personal data where required by law, court order, or regulatory request, or where reasonably necessary to establish, exercise, or defend legal claims.
9. International Transfers
Some service providers may process data outside Germany or the European Economic Area. Where required, we will rely on appropriate safeguards, such as adequacy decisions, standard contractual clauses, or another valid transfer mechanism under applicable law.
10. Retention
We retain personal data only for as long as necessary for the purposes described in this Privacy Policy, including to provide the Service, maintain records, comply with legal obligations, resolve disputes, and enforce agreements. Locally stored content may remain on your device until you delete it, clear app data, use deletion tools, or uninstall the app.
11. Your GDPR Rights
Depending on your circumstances and applicable law, you may have the right to request access, rectification, erasure, restriction, objection, and data portability, as well as the right to withdraw consent at any time where processing is based on consent.
You also have the right to lodge a complaint with a supervisory authority, including in Germany or in the EU member state of your habitual residence, place of work, or the place of the alleged infringement.
12. Children's Privacy
The Service is not intended for children where parental consent is required under applicable law and has not been obtained. If you believe a child has provided personal data unlawfully, please contact us so we can review and take appropriate action.
13. Security
We use reasonable technical and organizational measures intended to protect personal data against unauthorized access, loss, misuse, and alteration. However, no system can be guaranteed to be completely secure.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we do, we will publish the revised version with a new effective date. If required by law, we will provide additional notice.
15. Contact
For privacy requests or questions, contact:
Jolvi
Germany
[email protected]