Jonito Privacy Policy

1. Data controller

The data controller is SAS Clyb, a simplified joint stock company with capital of €100, SIRET 910 489 145 00011, intra-community VAT FR21910489145, whose head office is located at 4 chemin du Mélinais, 49220 Grez-Neuville, France.

For any questions relating to confidentiality or the exercise of your rights, you can write to contact@esimdual.com. For Jonito operational support, you can also use support@esimdual.com.

2. Scope of application and minimum age

Jonito is strictly limited to people aged 18 or over. Minors are not allowed to create an account or use the service.

Any account identified as belonging to a minor is suspended and may be closed. If there is reasonable doubt about a member’s age, Jonito may request age verification solely to confirm that the person is at least 18; this verification never allows a minor to access the service.

3. Data we may collect

The data actually collected depends on the features you use and the information you choose to provide.

• Account data: email address, nickname, internal identifier, login method, application language and information required for authentication.
• Profile data: date of birth, age, gender, sexual orientation, role or intimacy preference when this option is used, city, country, biography, interests, relationship goal, religion, languages ​​spoken and discovery preferences.
• Photos, videos, stories, posts and other content you upload. Private albums are subject to separate access rules defined by their owner.
• Location data when you grant this permission: coordinates used for proximity, map and distance calculation features.
• Communications: messages, attachments, conversation metadata, read receipts, and deletion actions.
• Security and moderation data: blocks, reports, reason for report, suspension measures, history necessary to examine abuse and information relating to moderator applications.
• Verification data when you request or must carry out verification: selfie, supporting document and information strictly necessary for the examination.
• Transaction data: product purchased, subscription or Premium entitlement status, credits, receipts or transaction identifiers provided by Apple or Google. Jonito does not receive your full credit card number.
• Advertising and Technical Data: advertising identifiers where permitted, consent choices, device and system information, IP address, technical logs, notification tokens and diagnostics necessary for security and functionality.

4. Sensitive Data You Choose to Provide

Certain profile information, including sexual orientation and possibly religion, may fall under special categories of personal data. They are only used for the profile, discovery, and compatibility features you request.

When regulations require it, their processing is based on your explicit consent. You can modify or delete this information from your profile and withdraw your consent for the future, without affecting the lawfulness of the processing already carried out.

5. Geolocation and exact location protection

When you enable proximity features, Jonito can receive the location provided by your device to calculate distances and search for profiles around you.

Another member's exact GPS location is not sent to your app for map display. For public map markers, the server creates an approximate position that is offset by approximately 2-5 km and is stable for a period of approximately 12 hours before being renewed. This measure aims to limit the risks of precise localization and triangulation.

You can refuse or remove location permission in your device settings. Certain proximity functions will then no longer be available. Invisible mode also removes the profile from the affected discovery surfaces while it is active.

6. Purposes and legal bases

We use data only for specified and proportionate purposes.

• Execution of the service and contract: account creation, profile display, discovery, matches, messaging, private albums, purchases and Premium functions.
• Consent: device permissions, geolocation when not strictly necessary, sensitive data when required, advertising personalization when consent is applicable.
• Legitimate interest: security of the service, fight against fraud, prevention of harassment, technical improvement, detection of abuse and defense of our rights, subject to your interests and freedoms.
• Legal obligations: retention or communication of certain information when required by law, court decision or legally binding request.

7. Visibility of your information by other members

The information you place in your public profile may be seen by other members depending on Jonito's settings and features. Messages are visible to conversation participants. A private album is only accessible to people to whom its owner has granted access.

Jonito can display a visual watermark on media within the app. This watermark is a deterrent and does not guarantee that a third party will never be able to reproduce content by any other means.

8. Moderation, security and reporting

Jonito provides reporting and blocking functions. Reports may be reviewed by authorized moderators. In order to quickly protect members, certain consistent signals or repeated reports may result in a hold or temporary suspension before human review.

Moderators only access the information necessary for their mission and are subject to obligations of confidentiality and impartiality. We may retain the elements necessary to document a security decision, prevent recurrences or meet a legal obligation.

9. Providers and recipients

We do not sell your personal data. We may use service providers to host or operate the Service, send emails and notifications, process purchases, display advertisements, provide authentication or secure the Platform.

Depending on the functions used, this may include Apple and Google for login and in-app purchases, Google Mobile Ads for advertising, mobile platform notification services, as well as our hosting, email and security providers. Each service provider receives only the information necessary for its mission and applies its own legal obligations.

10. Advertising and Rewarded Ads

Jonito may display advertisements, notably through Google Mobile Ads. Depending on your region, your device settings and your consent choices, these advertisements may or may not be personalized.

Certain features may be temporarily unlocked after voluntarily viewing a rewarded advertisement, for example benefits or privacy options. Viewing and validating the reward may generate technical data necessary to award the benefit and limit abuse.

11. Purchases, subscriptions and payment data

In-app purchases and mobile subscriptions are processed by the App Store or Google Play. Jonito receives the information necessary to verify the purchased product and activate the corresponding right, but does not receive the complete data of your payment method.

The applicable store's billing, renewal, cancellation and refund policies also apply.

12. International transfers

Some technical service providers may process data outside the European Economic Area. Where necessary, we rely on transfer mechanisms recognized by applicable law, such as adequacy decisions or standard contractual clauses, and on appropriate additional guarantees.

13. Retention periods and account deletion

Account data is retained for the duration of use of the service, then deleted or anonymized when its retention is no longer necessary, subject to legal and security obligations.

When you request deletion of your account, it will be hidden immediately and a 30-day reactivation period will begin. You can undo the deletion during this period using the reactivation mechanism offered by Jonito. A reminder can be sent approximately 5 days before permanent deletion.

At the end of the 30-day period, the service deletes the account and associated data provided for by the purge process, including media, publications, stories, social relationships, messages from relevant conversations, connection tokens and verification documents. Certain data strictly necessary for a legal obligation, for the prevention of fraud or for the defense of rights may be kept separately for the period required or permitted by law.

Technical backups may temporarily retain residual copies until their normal rotation, without being put back into production unless resumption is necessary.

14. Security

We implement technical and organizational measures intended to protect data against unauthorized access, loss, alteration or disclosure. Network communications use encryption mechanisms in transit where applicable, and administrative access is limited.

However, no service connected to the Internet can guarantee absolute security. We recommend that you use a unique password when the Service uses one, protect your device, and promptly report any suspicious activity to us.

15. Your rights

When the GDPR or equivalent legislation applies, you can in particular request access to your data, their rectification, their erasure, the limitation of certain processing, their portability when the conditions are met, or object to certain processing. You can also withdraw consent at any time for the future.

You can exercise these rights by writing to contact@esimdual.com. We may request reasonable information from you to verify your identity before responding.

If you believe that your rights are not respected, you can lodge a complaint with the competent supervisory authority. In France, this is the CNIL.

16. Deletion, permissions and preferences

You can change much of your information in Jonito's settings. Camera, photos, microphone and location permissions can be revoked from the system settings. Advertising preferences also depend on the consent mechanisms and settings offered by iOS or Android.

Account deletion can be requested from the application. If you can no longer access your account, contact support@esimdual.com so that we can tell you the appropriate procedure.

17. Changes to this policy

We may update this policy when Jonito evolves, when treatment changes or when regulations require it. The update date appears at the top of the document. In the event of a significant change, additional information may be displayed in the application or sent by an appropriate means.

18. Contact

Confidentiality and rights: contact@esimdual.com

Jonito Support: support@esimdual.com

Address: SAS Clyb, 4 chemin du Mélinais, 49220 Grez-Neuville, France