Privacy Policy

This Privacy Policy explains how we collect, use, and protect information when you use the Jingool mobile app (iOS and Android), our websites at jingool.com and app.jingool.com, and related services (together, the "Service").

Jingool is a free, curated Persian-language audio app offering live radio channels and podcasts for the global Iranian diaspora. You can listen as a guest — no account, login, name, or email is required.

We have written this policy in plain language. Where something is a legal requirement under the EU General Data Protection Regulation (GDPR), we have tried to say so clearly.

1. Who we are (Data Controller)

The data controller responsible for your personal data is:

We have not appointed a Data Protection Officer (DPO), as we are not legally required to do so. For any privacy question or request, please use the contact email above.

2. The short version

• You do not need an account to listen. We do not collect your name or email when you use the app to listen.
• We create a random, app-generated ID stored on your device (we call it a "User ID") to remember your favorites and your listening history, and to understand how the Service is used. This ID is not your device ID or an advertising ID.
• Our servers automatically receive your IP address (this is normal for any internet service) and use it to estimate your country. We do not store your full IP address as part of our analytics; we store an approximate country.
• Some settings (resume position, theme, language, data-saver) stay only on your device.
• We do not currently use third-party advertising, third-party trackers, or third-party analytics SDKs. Advertising is planned for the future; see Section 7.
• We are an EU (Czech) company and our servers are in the EU (Germany).

3. Information we collect

a) Information you do not have to give us

You can listen without registering. We do not ask listeners for a name, email, phone number, or password.

b) A device-generated User ID (pseudonymous)

When you first install the app, it generates a random identifier (a 122-bit value created using a cryptographically secure random generator). This ID:

• is generated on your device, locally;
• is not derived from any device identifier, hardware identifier, or advertising identifier (it is not your IDFV, Android ID, or Ad ID);
• is not used for cross-app or cross-service tracking, and we do not use Apple's App Tracking Transparency tracking;
• is per-install: it is reset and replaced if you delete and reinstall the app.

Under the GDPR, this ID is treated as personal data because, although it does not identify you by name, it is a persistent identifier linked to your activity (a "pseudonymous identifier"). We explain how we use it below.

c) Favorites and listening history

We store, against your User ID: the channels and podcasts you mark as favorites; and your "play events" — what you played, when, the device type (phone or car), and your approximate country.

d) IP address and approximate location

When your device connects to our servers, our servers automatically receive your IP address — this is an unavoidable part of how the internet works. We use the IP address to estimate your country only (coarse, country-level location). We log this approximate country alongside play events. We do not use precise GPS location, and we do not build a detailed location history.

e) Information stored only on your device

The following stay on your device and are not sent to our servers: playback position (so audio can resume where you left off); theme and language preferences; data-saver preference.

f) Information from broadcasters, podcasters, and website visitors

If you are a broadcaster or podcaster submitting content, or if you sign up to the waitlist on our website, we collect the information you provide — typically your name and email address — so we can respond to you and manage your submission or signup. See Section 8.

g) Third-party audio streams

The app streams audio from third-party hosting services (such as AzuraCast, RadioJar, radio.co) and from podcast RSS feeds. When you play a stream, your device connects to that third party to receive the audio, and that third party may receive technical connection data (such as your IP address) as a normal part of delivering the stream. Artwork images may likewise be loaded directly from these content hosts. These third parties are independent and have their own privacy practices, which we do not control.

4. How we use your information and our legal basis (GDPR Article 6)

Where we rely on legitimate interest, we have considered your rights and freedoms. Because we use a pseudonymous identifier (not your name or email) and only coarse, country-level location, we believe the impact on your privacy is low. You can object to processing based on legitimate interest — see Section 9.

5. We do not sell your data

We do not sell your personal data, and we do not share it for advertising or marketing by other companies.

6. How long we keep data (retention)

• Raw play events and (future) ad impressions: retained for approximately 12 months, then deleted.
• Aggregated / anonymized statistics (for example daily rollups that can no longer be linked to a single User ID): retained for longer as non-personal, aggregate data.
• Favorites and listening history: retained while the app remains installed and associated with your User ID. Because the User ID resets when you delete and reinstall the app, deleting the app effectively disconnects you from this data going forward (see Section 9).
• Broadcaster/podcaster and waitlist information: retained while relevant to the relationship or until you ask us to delete it.

7. Advertising (planned — not yet active)

The app does not currently show ads and does not currently use any third-party advertising SDK or ad network.

We plan to introduce advertising in the future. Our current intention is to use contextual advertising based on content category and approximate country, not profiling of individuals. Before advertising launches, we will update this policy, and — where the law requires consent for any tracking technologies or for personalized advertising — we will ask for your consent at that time.

8. The websites (jingool.com and app.jingool.com)

Our websites collect limited information:

• Waitlist signups: your email (and name, if you provide it), used only to contact you about Jingool. Legal basis: consent. You can unsubscribe or ask us to delete this at any time.
• Strictly necessary cookies and local storage: our websites use a small number of strictly necessary cookies and limited local storage needed for the site to function — for example, a session identifier to maintain your browsing session and a deployment/routing cookie to keep you on a consistent version of the site. These are essential to operate the website and are not used for advertising, profiling, or third-party tracking. Because they are strictly necessary, they do not require consent.
• We do not currently use third-party web analytics (such as Google Analytics), advertising pixels, or tracking cookies on our websites. If we add any non-essential cookies or analytics in the future, we will update this policy and, where required, ask for your consent.

9. Your rights under the GDPR

If you are in the EU/EEA, you have the right to:

• Access the personal data we hold about you;
• Rectify inaccurate data;
• Erase your data ("right to be forgotten");
• Restrict or object to processing (including processing based on legitimate interest);
• Data portability — receive your data in a portable format;
• Withdraw consent at any time, where we rely on consent (this does not affect processing done before withdrawal).

A note on how erasure works for listeners: because we do not know your name or email, we cannot search for "you" by identity. Your data is linked only to your device-generated User ID.

• Deleting the app resets the User ID and disconnects your device from your favorites and history going forward. Raw play events already collected are deleted automatically within approximately 12 months (see Section 6).
• If you want us to delete specific data sooner and can provide your User ID, contact us at jingoolprivacy@amination.digital and we will do our best to locate and delete it.

To exercise any right, email jingoolprivacy@amination.digital. We will respond within the time limits set by the GDPR (normally one month).

You also have the right to lodge a complaint with a supervisory authority. In the Czech Republic, this is the Office for Personal Data Protection (Úřad pro ochranu osobních údajů, uoou.gov.cz). You may also contact the authority in your own EU country.

10. Where your data is processed (international transfers)

Our backend servers are hosted with Hetzner in Germany (EU). We do not transfer listener personal data outside the EU/EEA as part of our own processing.

When you play a third-party audio stream or podcast (Section 3g), your device connects directly to that provider, which may be located outside the EU. That connection is between your device and the provider; we do not control where those providers are located or how they handle the technical connection data they receive.

11. Children

Jingool is a general-audience service and is not directed at children. We do not knowingly collect personal data from children under the age of 15 (the age of digital consent in the Czech Republic). If you believe a child has provided us personal data, contact us and we will delete it.

12. Security

We take reasonable technical and organizational measures to protect your data, including hosting on EU infrastructure and limiting the data we collect in the first place. No system is perfectly secure, but we work to keep risk low — in part by collecting as little identifying information as possible.

13. Changes to this policy

We may update this policy from time to time. When we make material changes (for example, when we launch advertising), we will update the "Last updated" date and, where appropriate, notify you in the app or on our website.

14. Contact us