This Privacy Policy describes how Iulian Gabriel Florea ("we," "us," or "our") collects, uses, and shares information when you use the JollyTrack mobile application and website (collectively, the "Service"). We are committed to protecting your privacy and ensuring you understand how your data is handled.
1. Data Controller
The data controller responsible for your personal data is:
Account Information: Email address when you create an account or subscribe to notifications
Communications: Information you provide when contacting us for support
User Content: Any content you create within the app (e.g., personalized cards)
2.2 Information Collected Automatically
Location Data: With your explicit permission, we collect your device location to calculate distance to Santa and provide localized content. You can disable this at any time in your device settings.
Device Information: Device type, operating system version, unique device identifiers, and app version
Usage Data: Features used, time spent in app, interactions, and navigation patterns
Analytics Data: Crash reports, performance data, and general usage statistics
2.3 Information from Third Parties
We may receive information from analytics providers, advertising partners (if applicable), and app stores regarding your subscription status and app usage.
3. Legal Basis for Processing (GDPR)
Under the General Data Protection Regulation (GDPR), we process your personal data based on:
Consent: For location data collection, marketing communications, and optional analytics
Contract: To provide the Service you requested and manage your account
Legitimate Interests: For security, fraud prevention, and improving our Service
Legal Obligation: To comply with applicable laws and regulations
4. How We Use Your Information
We use the information we collect to:
Provide, maintain, and improve the JollyTrack Service
Calculate distances between your location and Santa's tracked location
Send you notifications about Santa's journey (with your consent)
Process and manage subscriptions and in-app purchases
Respond to your comments, questions, and support requests
Monitor and analyze usage patterns and trends
Detect, investigate, and prevent fraudulent or unauthorized activity
Personalize your experience and provide content relevant to your location
Send promotional communications (only with your explicit consent)
5. Information Sharing and Disclosure
We do not sell your personal information. We may share information in the following circumstances:
Service Providers: With vendors who assist us in operating the Service (hosting, analytics, payment processing), bound by data processing agreements
Legal Requirements: When required by law, court order, or governmental authority
Protection of Rights: To protect the rights, property, or safety of JollyTrack, our users, or others
Business Transfers: In connection with a merger, acquisition, or sale of assets (you will be notified)
With Your Consent: When you explicitly authorize sharing
6. Cookies and Tracking Technologies
We use cookies and similar technologies to:
Essential Cookies: Required for the Service to function properly
Preference Cookies: Remember your settings (e.g., theme, snow animations)
Analytics Cookies: Help us understand how the Service is used
You can manage cookie preferences through your browser settings. Note that disabling certain cookies may affect Service functionality.
7. Data Retention
We retain your personal data only for as long as necessary to:
Provide the Service to you
Comply with legal obligations
Resolve disputes and enforce agreements
Account data is retained until you request deletion. Analytics data is typically retained for up to 26 months. Location data is processed in real-time and not stored permanently.
8. Your Rights Under GDPR
As a resident of the European Union, you have the following rights:
Right of Access: Request a copy of your personal data
Right to Rectification: Request correction of inaccurate data
Right to Erasure: Request deletion of your data ("right to be forgotten")
Right to Restrict Processing: Request limitation of data processing
Right to Data Portability: Receive your data in a machine-readable format
Right to Object: Object to processing based on legitimate interests
Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
Right to Lodge a Complaint: File a complaint with your local data protection authority
To exercise these rights, contact us at hola@jollytrack.app. We will respond within 30 days.
9. International Data Transfers
Your data may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer data outside the EEA, we ensure appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission or transfers to countries with adequate data protection laws.
10. Data Security
We implement appropriate technical and organizational measures to protect your data:
SSL/TLS encryption for all data transmission
Secure cloud infrastructure with access controls
Regular security assessments and updates
Limited employee access to personal data
Data encryption at rest where applicable
While we strive to protect your data, no method of transmission over the Internet is 100% secure. We cannot guarantee absolute security.
11. Children's Privacy
JollyTrack is designed to be family-friendly and suitable for all ages. However:
We do not knowingly collect personal information from children under 16 without verifiable parental consent
Parents/guardians can contact us to review, delete, or stop the collection of their child's data
If we learn we have collected data from a child under 16 without proper consent, we will delete it promptly
If you believe we have collected information from a child without proper consent, please contact us immediately at hola@jollytrack.app.
12. Third-Party Services
Our Service may contain links to or integrate with third-party services. We may use the following:
Apple App Store / Google Play: For app distribution and in-app purchases
Analytics Providers: For understanding app usage
Cloud Hosting: For Service infrastructure
These third parties have their own privacy policies. We encourage you to review them.
13. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by:
Posting the new Privacy Policy on this page
Updating the "Last updated" date at the top
Sending you an email notification for significant changes (if we have your email)
Displaying a notice in the app
14. Contact Us
If you have questions about this Privacy Policy, your data, or wish to exercise your rights, please contact us:
You also have the right to lodge a complaint with the Spanish Data Protection Authority (AEPD) at www.aepd.es or your local supervisory authority.
By using JollyTrack, you acknowledge that you have read and understood this Privacy Policy. Your continued use of the Service after any changes indicates your acceptance of the updated policy.