PRIVACY POLICY - LEITNER BOLT

Last update: December 15, 2025

1. Preamble

The purpose of this Privacy Policy is to inform users of the Leitner Bolt application (hereinafter the "Application") about how their personal data is collected, processed, and protected.

Respect for your privacy and your data is a priority for us. We are committed to complying with the provisions of the amended Law No. 78-17 of January 6, 1978, known as "Informatique et Libertés", and Regulation (EU) 2016/679 (GDPR).

2. Identity of the Data Controller

Data is collected by:

Publisher / Company Name: Fabrice Jeannet
Address: 9 rue de Conde, 33000 Bordeaux, France
DPO Contact Email (Data Protection Officer): hello@leitnerbolt.com

3. Collected Data

In the context of using the Application, we may collect the following data:

3.1. Data you provide to us directly

To create an account (mandatory), you must provide us with:

Email address: Necessary for identification, password recovery, and important communication.
Password (encrypted): To secure access to your account.
Username / Nickname: To personalize the interface.

3.2. Automatically collected data (Usage and Technical)

Learning data: Content of your Flashcards, progress in Leitner boxes, scores, review time. (These data are necessary for the algorithm to function).
Purchase history: List of purchased decks (to allow you to restore or access them).
Technical data: IP address, device type, operating system version (iOS/Android), crash reports (bugs).

3.3. Payment data

Important: We do not collect any banking data (card number, security code). Financial transactions are entirely processed by the secure platforms of Apple (App Store) and Google (Play Store). We only receive a digital confirmation of the purchase (transaction receipt) to unlock the content.

4. Purposes of Processing

Your data is collected for the following reasons:

Account management: Creation, authentication, and security of your personal space.
App operation: Saving your cards and synchronizing your learning progress (Leitner Method).
Delivery of purchases: Unlocking card decks purchased in the shop.
Customer support: Responding to your requests for technical assistance.
Service improvement: Anonymous analysis of usage statistics to fix bugs and improve the experience (e.g., identifying a rarely used feature).

5. Legal Basis for Processing

The processing of your data is justified by:

Execution of the contract (Terms of Service): Account creation is necessary to provide the synchronization and backup service.
Consent: Particularly for the potential sending of newsletters (if you check a specific box) or for the processing of minors' data.

6. Protection of Minors

The Application is likely to be used by minors.

Parental Consent: If the user is under 15 years of age (age of digital consent in France), the processing of their personal data requires the consent of the holder of parental authority. By creating an account, the user confirms being over 15 years old or having obtained authorization from their parents.
Parents' Rights: Parents may at any time request access to, rectification of, or deletion of their child's account by contacting the Publisher at: hello@leitnerbolt.com.

7. Data Recipients

Your data is strictly confidential. It is transmitted only:

To the Publisher: For service management.
To our technical subcontractors (Hosting): Data is stored on secure servers (e.g., AWS, Google Cloud, Firebase) that comply with current security standards.
To authorities: Only if the law requires us to do so.

We never sell, rent, or exchange your personal data with third parties for commercial or advertising purposes.

8. Data Retention

Active account: Your data is kept as long as your account is active to allow you to use the Application.
Inactive account: If you do not use the Application for a period of 3 years, we will delete your account and your data after sending you a notification.
Deletion request: In the event of an account deletion request, your data is immediately erased from our active databases (except for legal obligations to retain certain transaction proofs for the statutory period, e.g., 10 years for accounting).

9. Data Security

We implement technical and organizational security measures to protect your data (password encryption, HTTPS protocol, restricted server access). However, no system is infallible. In the event of a detected security breach likely to result in a high risk to your rights and freedoms, we undertake to inform you as soon as possible.

10. Your Rights

In accordance with the GDPR, you have the following rights regarding your data:

Right of access and rectification: To view and modify your information.
Right to erasure (Right to be forgotten): To request the deletion of your account.
Right to portability: To retrieve your data in a structured format.
Right to object: To object to certain processing operations.

How to exercise these rights?

The easiest way is to use the "Delete my account" or "Export my data" functions in the Application settings.

You can also contact us by email at: hello@leitnerbolt.com.

If you believe, after contacting us, that your rights are not being respected, you can address a complaint to the CNIL (Commission Nationale de l'Informatique et des Libertés).

11. Changes to the Policy

We reserve the right to modify this Privacy Policy. Any substantial modification will be notified within the Application. The most recent version is always available in the Application settings.