Privacy Policy

1. Introduction

Jynx ("we", "our", "the application") is a social gaming platform that allows players to connect, form teams and play together.

For the purposes of the LGPD, Jynx Group is the controller (controlador) of your personal data. Our Data Protection Officer acts as the encarregado (DPO) and may be reached at [email protected] for any request relating to the LGPD. Although Jynx qualifies as a pequeno agente de tratamento de dados pessoais (small-scale agent) under ANPD Resolution CD/ANPD nº 2/2022, which exempts Jynx from the obligatory appointment of an encarregado, Jynx voluntarily maintains this published communication channel.

This privacy policy describes how we collect, use, share and protect your personal data when you use our application.

2. Minimum Age and Verification

Our application is reserved for users aged 18 and over.

When creating your account, we ask you to provide your date of birth. If you are under 18, you will not be able to create an account or use our services.

Marketing to minors. Jynx is restricted to users aged 18 and over and applies an automated age gate. If we subsequently identify that a user is under 18 (LGPD Art. 14; GDPR Art. 8), we will immediately terminate the account, exclude the user from all marketing, re-engagement, and survey communications, and delete the associated marketing data. We never knowingly collect marketing consent from a minor.

3. Data Collected

3.1. Registration and Profile Data

We collect the following information when creating and managing your account:

Authentication Information:

• Email (for email/password accounts)
• Username/nickname
• Profile photo (optional)
• Social login identifiers (Google, Apple) if you use these methods

Profile Information:

• Date of birth (for age verification)
• Country and timezone
• Languages spoken
• Biography (optional)
• Gaming preferences and availability
• Unique handle (automatically generated for private friend discovery)

3.2. Gaming Data

To help you find compatible teammates, we collect:

Game Profiles:

• Games you play
• Levels, ranks and game statistics
• Favorite champions/characters
• Play style

Riot Games API Integration:

We retrieve from the Riot Games API (with your consent):

• Summoner name and Riot ID
• Rank and match history (League of Legends, Valorant, etc.)
• Champion statistics
• Recent match history

Collection Reason: Display your player profile and improve matching with other players.

3.3. Usage and Technical Data

We automatically collect certain technical data:

Analytics and Performance:

• Firebase Performance Monitoring: App startup time, interface fluidity
• Sentry: Error and performance reports (with personal data anonymization)
• Firebase Crashlytics: Crash reports

Device Information:

• Device type and model
• Operating system version
• Application version

User Behavior:

• Screens visited and features used
• Time spent in the application
• Interface interactions

You can disable analytics data collection in Settings > Privacy > "Enable Analytics".

3.4. Communication Data

• Messages: Messages in community chats, private messages between users, conversation history
• Notifications: FCM tokens (Firebase Cloud Messaging) for push notifications

3.5. User Generated Content

• Uploaded photos (profile pictures, additional photos)
• Security and moderation reports
• Cosmetic preferences (avatars, badges)

3.6. Voice Room Audio Data

Jynx offers real-time voice rooms that let you talk with the other participants while you play. Voice-room audio is captured from your microphone only after you grant the operating-system microphone permission and explicitly join a room; no audio is captured before both of those steps.

Jynx does not enable LiveKit's recording, transcription, Agent Insights, or Egress features. Voice-room audio is routed in real time by the LiveKit SFU (Selective Forwarding Unit) and is not recorded, stored, or persisted by Jynx or by LiveKit.

When you speak in a voice room, your audio is transmitted in real time to the other participants in that room, similar to how voice works in other voice-chat apps.

Voice-room audio is processed with your consent: you grant microphone permission and explicitly join a room before any audio is captured. You can withdraw consent at any time by leaving the room or by revoking microphone permission in your device settings.

4. Third-Party Services and Data Sharing

4.1. Firebase Services (Google)

We use the following Firebase services, all GDPR compliant:

• Firebase Authentication: Secure user account management
• Cloud Firestore: Storage of your profile and game data
• Firebase Storage: Hosting your profile images
• Cloud Functions: Secure backend logic execution
• Firebase Cloud Messaging: Push notifications
• Firebase App Check: Protection against abuse and bots
• Firebase Performance Monitoring: App performance monitoring
• Firebase Crashlytics: Crash reports

Firebase Privacy Policy: https://firebase.google.com/support/privacy

4.2. Sentry (Error Monitoring)

We use Sentry for error and performance tracking. Collected data includes:

• Error traces
• Technical context (OS, app version)

Sentry Privacy Policy: https://sentry.io/privacy/

4.3. Riot Games API

When you link your Riot Games account, we retrieve your game statistics via the official Riot Games API. This data is used only to display your profile and improve matching.

Riot Games Privacy Policy: https://www.riotgames.com/en/privacy-notice

4.4. Email Service Provider (Marketing & Survey Communications)

To deliver the marketing, re-engagement, and uninstall/churn-survey emails described in §5.6, Jynx uses a third-party email service provider (ESP) acting as a processor (GDPR Art. 28; LGPD Art. 39 — operador). The ESP processes your email address and minimal delivery data (e.g., send/bounce status) solely on Jynx's documented instructions, under a signed Data Processing Agreement.

• ESP identity, role, and location: Brevo (Brevo SAS, Paris, France) — our Email Service Provider and data processor under a signed Data Processing Agreement. Brevo Privacy Policy: https://www.brevo.com/legal/privacypolicy/
• Sub-processors: Brevo's current list of sub-processors is published in its Data Processing Agreement (Terms of Use): https://www.brevo.com/legal/termsofuse/
• International transfer basis: See §9. Brevo is headquartered in France (EU). Transfers to Brevo therefore benefit from the EU's protection regime under GDPR and, for Brazilian users, the ANPD adequacy decision for the EU (Resolution nº 32/2026) — no SCCs or additional mechanism are required.

We do not sell your personal data. No tracking pixels or hidden analytics are embedded in marketing emails without a separate legal basis disclosed in §5.6.

4.5. LiveKit Cloud (Real-Time Voice)

Jynx uses LiveKit Cloud as a processor (GDPR Art. 28; LGPD Art. 39 — operador) under a signed Data Processing Agreement to operate the real-time media infrastructure that routes voice-room audio between participants. LiveKit runs the Selective Forwarding Unit (SFU) that forwards each participant's audio stream to the others in real time.

Jynx does not enable LiveKit's recording, transcription, Agent Insights, or Egress features. Voice-room audio is routed in real time by the LiveKit SFU (Selective Forwarding Unit) and is not recorded, stored, or persisted by Jynx or by LiveKit.

LiveKit does retain operational session metadata — such as participant identities, room identifiers, connection timings, and quality metrics — for billing, abuse-prevention, and operational purposes under its Data Processing Addendum. This metadata is not used to identify you off-platform or for advertising.

5. Data Usage

We use your data to:

1. Provide Our Services:

• Create and manage your account
• Allow you to connect with other players
• Facilitate team creation and gaming session organization

2. Personalization:

• Recommend compatible teammates (game-based, rank, style matching)
• Display relevant content

3. Communication (operational / transactional):

• Send you important service notifications (matches found, messages received, account-security alerts, and policy-change notices under §11)

Marketing, re-engagement, and uninstall/churn-survey emails are described separately in §5.6 Marketing Communications and are not covered by this transactional category.

4. Service Improvement:

• Analyze usage to improve features
• Identify and fix bugs
• Optimize performance

5. Security and Compliance:

• Prevent fraud and abuse
• Enforce our terms of use
• Comply with legal obligations

5.6. Marketing Communications

In addition to the operational notifications described in §5.3, we may send you marketing and re-engagement communications by email, including: product updates and feature announcements about the Jynx app; newsletters; re-engagement messages inviting you back to the app; and short uninstall or churn feedback surveys (e.g., "Why did you stop using Jynx?"). These communications are distinct from transactional/service notifications.

Legal basis — European Union / EEA users (GDPR + ePrivacy). Because the Service is currently provided without remuneration (no paid tier is purchasable at the date of this Policy), marketing and re-engagement emails to EU/EEA users are sent only on the basis of your prior explicit opt-in consent (ePrivacy Directive Art. 13(1), transposed in France by Article L. 34-5 of the Code des postes et des communications électroniques; GDPR Art. 6(1)(a) and Art. 7). We do not rely on the "soft opt-in" exception of ePrivacy Art. 13(2) at this time, because that exception requires a "sale" within the meaning of the CJEU judgment C-654/23 (13 Nov 2025) and the Service is not yet remunerated. We will re-assess this analysis if and when a paid premium tier or any other monetization (in-app purchases, advertising, data licensing) goes live, and this Policy will be updated accordingly.

Legal basis — Brazilian users (LGPD). For Brazilian users, marketing and re-engagement communications rely on two alternative legal bases:

1. Consent (LGPD Art. 7, I and Art. 8) — captured as a separate, un-ticked, purpose-specific opt-in at signup or in-app, recorded with date, form version, and language; you may withdraw it at any time, free of charge, without losing access to the Service (Art. 8 §5). Consent is the basis used for any communication to prospects, cold outreach, or cross-sell/partner offers beyond the core Jynx app.
2. Legitimate interest (LGPD Art. 7, IX, elaborated by Art. 10) — used only for existing or recently-lapsed users receiving re-engagement messages, product updates about the same Jynx app, or a single short churn/uninstall feedback survey. Before relying on this basis, Jynx conducts and documents a Legitimate Interests Assessment (LIA) following the three-phase test of the ANPD Legitimate Interest Guide (2 Feb 2024): (i) purpose, (ii) necessity, and (iii) balancing and safeguards. The LIA records the prior relationship, the user's reasonable expectations, the purpose, the least-intrusive means chosen, and the opt-out channel. Legitimate interest is not used for cold/unsolicited email, unrelated cross-sell, purchased lists, or persistent messaging to departed users after the relationship has clearly ended.

Right to object / opt-out. Brazilian users may at any time oppose this processing and opt out via the mechanisms in §7.5 and §7.6 (one-click unsubscribe in every email, or the in-app communications-preferences toggle), without cost and without terminating the account. We honor opt-out requests in real time. The Brazilian Consumer Defense Code (CDC, Law 8.078/90, in particular Art. 39 III) prohibits unsolicited or abusive commercial messaging; we therefore strictly respect opt-outs and apply frequency caps, since persistent or ignored-opt-out sending may be treated as an abusive practice.

Uninstall / churn surveys. Wherever operationally feasible we ask uninstall/churn questions in-app at the uninstall moment (no email retention required). Where an email survey is sent, the survey contains no promotional or re-engagement content; we send a maximum of one (1) survey per user within approximately 60 days of account deletion or uninstall; the email address is then deleted or anonymized in accordance with §6; and users who have submitted an erasure / right-to-be-forgotten request (§7.3) are never re-contacted and are placed on a permanent suppression list (see §6 and the Terms of Service §7.2).

Email tracking. Marketing emails do not embed tracking pixels or hidden analytics that process personal data without a separate legal basis. Where any open/click tracking is introduced, it will be disclosed here and based on consent (LGPD Art. 8; ePrivacy Art. 5(3)), consistent with the ANPD guidance on tracking technologies (18 Oct 2022).

Frequency. Marketing emails are subject to internal frequency caps; you can reduce or turn them off at any time via the in-app communications-preferences toggle or by clicking unsubscribe in any message.

6. Data Retention

6.1. Retention Periods

• Profile Data: Retained as long as your account is active
• Logs and Analytics: Firebase Analytics: 14 months (Firebase policy)
• Marketing email addresses (consent-based): Retained for as long as you have not opted out or deleted your account, plus a hashed record on the suppression list (see below) to ensure we do not re-contact you
• Uninstall / churn survey email addresses: Retained for a maximum of 60 days after the survey is sent (or, if no survey is sent, 60 days after uninstall/deletion), after which the address is deleted or irreversibly anonymized. No more than one (1) survey email is sent per user
• Re-engagement of recently-lapsed accounts (LGPD legitimate-interest basis, Brazilian users only): Consistent with CNIL guidance and the reasonable-expectations test, Jynx may use the email address of a recently-lapsed (non-erasure) account for re-engagement for up to 3 years after the last meaningful interaction, after which it is deleted or anonymized

6.2. Data Deletion

You can request deletion of your account at any time (see Section 7).

Legal Retention: Some data may be retained longer to comply with our legal obligations (e.g., security reports, financial transactions).

When you delete your account, we purge your email address from our marketing CRM and email service provider. If you exercise the right to erasure (§7.3 / GDPR Art. 17 / LGPD Art. 18(VI) for consent-based data), your email address is added to a permanent hashed suppression list so that it is never re-used for marketing, re-engagement, or surveys — including protection against re-import via any third-party or purchased list. Note: under the LGPD, Art. 18(VI) deletion applies to data processed on the basis of consent; data processed on the basis of legitimate interest (Art. 7 IX) is instead governed by the purpose-limitation principle (Art. 6 II and §2) and your right to request cessation of processing (Art. 18 §2).

7. Your Rights (GDPR and LGPD)

Depending on where you are located, you have rights under the GDPR (EU/EEA) and/or the Brazilian LGPD (Lei Geral de Proteção de Dados, Law 13.709/2018).

7.1. Right of Access

You can request a copy of all data we hold about you.

How to exercise this right: Settings > Privacy > "Export My Data"

The process generates a JSON file containing all your data (profile, messages, statistics, etc.). The download link is valid for 7 days.

7.2. Right of Rectification

You can modify your profile information at any time from the application (username, bio, preferences, etc.).

7.3. Right to Erasure ("Right to be Forgotten")

You can request deletion of your account.

How to exercise this right: Settings > Danger Zone > "Delete My Account"

Automated Deletion Process:

1. Two-step confirmation to prevent accidental deletions
2. Immediate anonymization of your personal data (Firestore)
3. Deletion of your Firebase Authentication account (automatically revokes all OAuth tokens)
4. An anonymized ID is provided as reference
5. Option to delete your messages and generated content

Important: Deletion is irreversible. Some anonymized data may be retained for statistical purposes (GDPR-compliant).

Manual Deletion Requests: For specific data deletion requests (e.g., delete only messages from a specific community, delete Storage images, or other edge cases), please contact our Data Protection Officer at [email protected]. We will process manual requests within 30 days as required by GDPR.

7.4. Right to Data Portability

The data export (Section 7.1) allows you to retrieve your data in a structured, machine-readable format (JSON).

7.5. Right to Object / Opt Out of Marketing

You can object to the processing of your data for direct-marketing purposes at any time, free of charge and without giving reasons. Under GDPR Art. 21(2) this right is absolute for EU/EEA users: we will stop all marketing processing on receipt of your objection. For Brazilian users, you may oppose marketing processing via the opt-out mechanisms below (LGPD Art. 8 §5; Art. 18 §2).

• One-click unsubscribe: every marketing email includes a one-click unsubscribe link (RFC 8058 List-Unsubscribe-Post) honored in real time
• In-app toggle: Settings > Privacy > Communications Preferences
• Email: [email protected]

7.6. Right to Withdraw Consent

You can withdraw your consent for:

• Analytics: Settings > Privacy > Disable "Enable Analytics"
• Push Notifications: Device settings
• Marketing Communications: Newsletter, product updates, re-engagement, and uninstall/churn surveys — withdrawable via one-click unsubscribe, the in-app communications-preferences toggle, or [email protected], without terminating your account

Note: OAuth tokens (Google, Apple) are automatically revoked when you delete your account (Section 7.3).

Withdrawal does not affect the lawfulness of processing carried out before withdrawal (GDPR Art. 7(3); LGPD Art. 8 §5), and withdrawing consent never requires you to delete your account.

7.7. Additional LGPD Rights (Brazilian Users)

In addition to the rights above, data subjects located in Brazil have the following rights under LGPD Art. 18: confirmation of the existence of processing; access to the data; correction of incomplete, inaccurate, or out-of-date data; anonymization, blocking, or deletion of unnecessary or excessive data (Art. 18(VI) applies to data processed on the basis of consent); portability to another service or product provider, upon request; deletion of personal data processed with consent; and information about the possibility of denying consent and the consequences of doing so.

You may exercise these rights via Settings > Privacy or by contacting the encarregado at [email protected]. You may also lodge a complaint with the Brazilian data protection authority — the Autoridade Nacional de Proteção de Dados (ANPD) — at https://www.gov.br/anpd.

8. Data Security

We implement technical and organizational security measures to protect your data:

• Encryption: Secure communication via HTTPS
• Firebase Security Rules: Strict access control to Firestore data
• Authentication: Secure session management via Firebase Auth
• Input Validation: XSS injection prevention via SecureTextInput
• Rate Limiting: Protection against abuse (spam messages, automated actions)
• Moderation: Content reporting and moderation system
• Real-time voice: Voice-room media is encrypted in transit using WebRTC DTLS-SRTP, the same standard used by mainstream voice apps; signaling between the app and our servers is over HTTPS/TLS.

No system is 100% secure. In case of a data breach, we will notify you in compliance with GDPR (within 72 hours).

9. International Data Transfers

Your data may be transferred to and stored on servers located outside your jurisdiction, including:

• Google Cloud / Firebase: Global infrastructure, under GDPR standard contractual clauses and equivalent safeguards
• Sentry: U.S.-based servers; transfers from the EU/EEA rely on the EU-US Data Privacy Framework (in force July 2023, replacing the invalidated Privacy Shield) for Sentry entities self-certified under the DPF, or on standard contractual clauses where the DPF does not apply
• Email Service Provider (ESP): Used to deliver the marketing, re-engagement, and survey communications described in §5.6. The ESP is named in §4.4 and acts as a processor under a signed Data Processing Agreement
• LiveKit (real-time voice): LiveKit is our processor for voice-room audio under a signed Data Processing Agreement (see §4.5). As described in §3.6 and §4.5, voice-room audio is routed in real time and is not recorded, stored, or persisted by Jynx or by LiveKit. The applicable international-transfer mechanism for LiveKit will be confirmed before the voice feature is enabled for users. Accordingly, the general EU/EEA and Brazilian transfer guarantees set out below do not yet extend to LiveKit; they will be updated to reflect the confirmed mechanism before voice launches.

Guarantees (GDPR, EU/EEA). All transfers from the EU/EEA are covered by an adequacy decision, the EU-US Data Privacy Framework, or standard contractual clauses, together with supplementary measures where required.

Guarantees (LGPD, Brazil). Transfers of Brazilian users' personal data are governed by LGPD Art. 33:

• To Jynx Group in France (controller): Lawful under LGPD Art. 33(I) by virtue of ANPD Resolution CD/ANPD nº 32/2026 (in force 26 January 2026), which recognizes the European Union — including France — as providing an adequate level of protection. No additional transfer mechanism is required for this leg. (This adequacy decision is subject to reassessment by the ANPD within four years; if suspended, Jynx will implement an alternative Art. 33 mechanism such as the ANPD standard contractual clauses.)
• To Brevo in France (email ESP, processor): Lawful under LGPD Art. 33(I) by virtue of the same ANPD Resolution CD/ANPD nº 32/2026 (in force 26 January 2026), which recognizes the European Union — including France — as providing an adequate level of protection. No additional transfer mechanism is required for this leg. (Subject to the same ANPD reassessment described above; if the adequacy decision is suspended, Jynx will implement an alternative Art. 33 mechanism such as the ANPD standard contractual clauses with Brevo.)

Historical note: the one-year grace period for adapting existing contracts to the ANPD SCCs ended on 23 August 2025; new processor relationships such as the ESP execute the SCCs at onboarding.

10. Cookies and Similar Technologies

Our mobile application does not use cookies in the traditional sense, but uses:

• Authentication Tokens: Stored locally in a secure manner
• Local Cache: To improve performance (profile data, recent messages)

11. Changes to This Policy

We may update this privacy policy. In case of major changes, we will notify you:

• Via an in-app notification
• By email to the address associated with your account

12. Contact Us

For any questions regarding this privacy policy or to exercise your rights:

• Email: [email protected]

Supervisory Authorities: If you believe your rights have not been respected, you may lodge a complaint:

• EU/EEA users: with the CNIL (Commission Nationale de l'Informatique et des Libertés), France — https://www.cnil.fr
• Brazilian users: with the ANPD (Autoridade Nacional de Proteção de Dados), Brazil — https://www.gov.br/anpd

Filing a complaint with a supervisory authority does not prejudice your right to seek other judicial remedies available to you, including the mandatory consumer protections that apply in your jurisdiction (e.g., the Brazilian Consumer Defense Code, Law 8.078/90).

13. Legal Bases and Consent

We process your personal data only where we have a lawful basis. The lawful bases we rely on, and where each is described in this Policy, are:

• Performance of a contract / provision of the Service (GDPR Art. 6(1)(b); LGPD Art. 7, V) — account, matching, and messaging (§5.1–5.3)
• Legitimate interests (GDPR Art. 6(1)(f); LGPD Art. 7, IX and Art. 10) — security, fraud prevention, service improvement, and (for Brazilian users) marketing/re-engagement/survey communications to existing or recently-lapsed users as described in §5.6, each supported by a documented balancing assessment
• Legal obligation (GDPR Art. 6(1)(c); LGPD Art. 7, II) — retention for legal purposes (§6)
• Consent (GDPR Art. 6(1)(a); LGPD Art. 7, I and Art. 8) — analytics where you have enabled them, push notifications, and (for EU/EEA users and for Brazilian prospects/cold/cross-sell sends) marketing communications per §5.6
• Voice-room audio is processed on the basis of your consent (GDPR Art. 6(1)(a); LGPD Art. 7, I and Art. 8) when you grant microphone permission and explicitly join a room (see §3.6); you may withdraw it at any time by leaving the room or by revoking microphone permission in your device settings.

Consent must be specific and informed. Where we rely on your consent, it is given by a clear affirmative act, refers to specified purposes, and is captured separately from your acceptance of these terms (LGPD Art. 8 §1 — cláusula destacada). Generic or bundled authorizations are void under LGPD Art. 8 §4 and invalid under GDPR Art. 4(11) and Art. 7. Using Jynx does not by itself constitute consent to marketing. The burden of proving valid consent rests with Jynx (LGPD Art. 8 §2; GDPR Art. 7(1)); we therefore record the date, form version, language, and scope of each consent we collect.

Withdrawal. You may withdraw any consent at any time, through a procedure that is as easy as giving it and that does not require you to delete your account (LGPD Art. 8 §5; GDPR Art. 7(3)) — see §7.5 and §7.6. Withdrawal does not affect the lawfulness of processing carried out before withdrawal. Deleting your account (§7.3) remains available at any time but is not the mechanism for withdrawing a specific consent.