This Policy explains what personal data we process within the Jai Tutor partner programme, for what purposes, on what legal basis, and how you can exercise your rights. It applies to programme partners and to visitors who follow partner links. Data processing inside the mobile application itself is governed by a separate document available in the app stores.
Data controller: Roman Zatolokin, a natural person carrying out individual activity (individuali veikla) in the Republic of Lithuania; Individual Activity Certificate (Pažyma) No. 1215311. Address: Bukčių g. 4-49, LT-04127 Vilnius, Lithuania.
Contact for any data-related questions and to exercise your rights: Roman@jaitutor.app.
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Partner: email address, channel name | Running the partnership, programme communication | Performance of a contract — the offer (Art. 6(1)(b) GDPR) | Duration of participation and up to 12 months thereafter |
| Partner: payout details (account holder name, IBAN, account country, and where needed BIC/SWIFT and bank name), records of accrued and paid rewards | Paying the reward; accounting and tax records | Performance of a contract (Art. 6(1)(b)); legal obligation (Art. 6(1)(c)) | As required by Lithuanian accounting and tax law (currently up to 10 years) |
| Visitor following a partner link: a pseudonymised hash of the IP address (the IP address itself is not stored), technical browser/device data (user-agent), the fact and time of the click | Attributing a referred user to a partner, protection against fraudulent inflation, click statistics | Legitimate interest (Art. 6(1)(f)): correct reward accounting and abuse protection | Up to 24 months, then deleted or anonymised |
| Purchase data of a referred user (fact, product, status, purchase time) | Accruing and verifying the partner reward | Performance of the contract with the partner (Art. 6(1)(b)); legal obligation (Art. 6(1)(c)) | With the accounting records above |
We do not process special categories of data, we do not perform device fingerprinting, and we do not make decisions producing legal effects based solely on automated processing.
We engage the following processors and recipients, each only to the extent required for its function:
We do not sell personal data and do not share it with third parties for their own marketing.
Some processors (in particular Google) may process data outside the EU/EEA. Any such transfer relies on a European Commission adequacy decision (including the EU–US Data Privacy Framework) or on Standard Contractual Clauses (SCC) ensuring an adequate level of protection.
We do not use advertising or tracking cookies. A click is attributed to a partner via the store's install-referrer label and the link parameter ?p=, not via cookies.
The IP address is stored only as an irreversible hash with a secret salt (pseudonymisation). Access to payout details and correspondence is restricted. Data is stored on servers within the EU.
In respect of your personal data you have the right to:
We may update this Policy. The current version is always available at the permanent address above; each version keeps its number and date. We notify partners of material changes in advance.
This Privacy Policy is published in English, Russian and Ukrainian. The English version is the governing version; in case of any discrepancy between versions, the English text prevails.
Data requests and exercise of rights: Roman@jaitutor.app.