Privacy Policy

Last Updated On 10-Feb-2022


This privacy policy ("Policy") explains how we process your personal data, incl. what we use it for and how we store and protect it. Furthermore, the Policy explains the rights that you have when we process your personal data. Why? Because we care about your privacy.

By accessing or using this website, you are consenting to the collection, use and disclosure of your information in accordance with this Policy. If you do not consent to the same, please do not access or use this website.

Who are we

We are the entity responsible for the processing of your personal data in accordance with this Policy.

(We are not a company and this is a personal website) Here is our information and contact details:

Jonathan Eduardo Freire Espinoza
Ansbacher Str. 41,
10777 Berlin, Germany
phone: +49 15205960935

To make the Policy more user friendly we use “we”, “us”, “our” etc. to refer to Jonathan Freire, the owner of this website. We are the data controller of the data collected through the use of cookies on our website.

Our "website" is, incl. our sub-domains, we own and operate.

When we refer to “you” we mean you as a user of our website, apps or our online services.

Links to other websites etc.

On our website, in our emails and on our social-media profiles, we may have links to other companies, apps or websites (“other websites”) that aren’t ours. This Policy doesn’t cover how those other websites process your data. We encourage you to read the privacy notices on the other websites you visit.

Information we may collect about you

We may collect and process personal data about you. Personal data, or personally identifiable information, means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data). We collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  1. Identity Data: includes first name, maiden name, last name, username or similar identifier.
  2. Contact Data: includes email address and telephone numbers, company name or website.
  3. Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  4. Profile Data: includes your username and password, your interests, preferences, feedback and survey responses.
  5. Usage Data: includes information about how you use our website, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
  6. Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  7. Aggregated Data: We also collect, use and share statistical or demographic data for any purpose. This Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

Personal data we collect from other sources

We work with third parties (including, for example, analytics providers and search information providers) and may receive the following personal data about you from them:

  1. Technical Data: from analytics providers and search information providers such as Google, Vercel, Cloudinary and Cloudflare.
  2. Identity and Contact Data: from providers of chat/communication services between/with users including via email such as Pusher.
  3. Email Communications and Contact Data: from providers of email communications service providers such as Sendgrid and Mailchimp.

How We Collect Your Information

We collect/receive information about you in the following manner:

  1. Direct Interactions. You may give us your Identity and Contact Data when you fill in forms or correspond with us by post, phone, email or otherwise. This includes personal data you provide when you register to use our website or to receive our newsletter, subscribe to use our services, request marketing to be sent to you, participate in discussion boards or other social media functions on our website, enter a competition, promotion or survey, give us feedback or contact us and when you report a problem with our website.
  2. Automated Technologies or Interactions. As you interact with our website and emails, we automatically collect Technical Information about your device, browsing actions, patterns, Location Data and Usage Data. We collect this personal data by using cookies, server logs, web beacons, pixels, and similar technologies about your device, and your use of our website. We may also receive Technical Data and Location Data about you if you visit other websites employment our cookies. Please see the Cookie section below for further details.

How We Use Your Information

We will only use your personal data when the law allows us to. Most commonly we will use the information that we collect about you for the following purposes:

  1. Marketing/ Promotional
  2. Creating user account
  3. Support
  4. Website protection
  5. User to user comments
  6. Manage user account
  7. To comply with a legal obligation.

If we want to use your information for any other purpose, we will ask you for consent and will use your information only on receiving your consent and then, only for the purpose(s) for which grant consent unless we are required to do otherwise by law.

Additional information:

We do not sell or rent your data to marketers or third parties.

If you would like more information about our legal basis for processing your data, feel free to contact us (see our details in the beginning of the Policy).

How We Share Your Information

We will not transfer your personal information to any third party without seeking your consent, except in limited circumstances as described below:

  1. Data collection & process

We may also disclose your personal information for the following:

  • to comply with applicable law, regulation, court order or other legal process
  • to enforce your agreements with us, including this Policy
  • to respond to claims that your use of this website violates any third-party rights.

Third parties and processors

We use companies (processors) to help us deliver our services to you, e.g. to provide the hosting environment for our product, send out newsletters, to help us run our website, etc.

We require such processors to use the personal information we transfer to them only for the purpose for which it was transferred and not to retain it for longer than is required for fulfilling the said purpose.

We share your personal data with:

  • Suppliers and vendors that we work with to assist our company (meaning service providers, technical support and supply services).
  • Group entities
  • Public authorities

Here’s are some of the suppliers we use:

  • Vercel as our hosting and analytics system.
  • Sendgrid for sending out emails to us through the contact form.
  • Pusher as our hosted Websockets solution. It is a communication service between users.
  • Cloudinary as our end-to-end image- and video-management solution.

Retention of your information

We will retain your personal information with us for 90 days to 2 years after user accounts remain idle or for as long as we need it to fulfill the purposes for which it was collected as detailed in this Privacy Policy. We may need to retain certain information for longer periods such as record-keeping / reporting in accordance with applicable law or for other legitimate reasons like enforcement of legal rights, fraud prevention, etc. Residual anonymous information and aggregate information, neither of which identifies you (directly or indirectly), may be stored indefinitely.

Keeping your data safe

We use reasonable organisational, technical and administrative measures to protect your data within our company.

The Internet is not a 100% secure environment and that means we cannot guarantee the security of the data you transmit to us. Emails sent via the Internet might not be encrypted, so we advise you not to include any confidential or sensitive information in your emails to us.

We also recommend you to use an anonymous username to register in the apps of this website.

Email contact and contact form

You can contact us using either a contact form provided on our website or by email using the following email address:

If you contact us using the contact form, the data you enter in the input mask will be sent to us and saved when you send them. The following data will be saved:

  • Name
  • Email address
  • Free text box for the message
  • Date and time when the contact was sent
  • Date and time when the Privacy Policy was accepted
  • Sending IP address

Before you send the completed contract form, your consent to our processing the data is obtained, and reference is made to this privacy policy.

Furthermore, you can contact us using the provided email address. In this case, your personal data submitted with the email will be saved.

We are the data controller. The messages via email or using the contact form are sent, using Sendgrid as our service of email delivery, to our Gmail account. Read the Sendgrid's privacy policy

Your data will be processed exclusively to handle your concern. In the event that you contact us by email, this also comprises the required legitimate interest in processing the data. The other personal data processed when you send your query are used to prevent any abuse of the contact form and ensure the security of our information technology systems.

The data will be erased when they are no longer required to achieve the purpose for which they were collected, in other words when the conversation with you, the user, is ended or the matter has been fully clarified.

You have the opportunity at any time to revoke your consent for processing the personal data. In this case, please contact us by using the contact details in this Policy

Chat app for users (

You can communicate with other users using the chat in the app located at

In this app, you can play the game of questions with other users. The purpose of the chat is to talk about the category of questions. Also, you can talk about the answers or the points. We encourage you not to use this chat for other cases and not share personal data.

We are the data controller. The shared messages through this chat are not stored in any database. We use secure connections provided by Pusher as our real-time messaging service. Pusher processes the encrypted data according to our processing criteria. Read the Pusher's privacy policy

Your rights:

You have these rights:

  1. Your right of access and rectification - You have the right to ask us for copies of your personal data or ask us to rectify information you think is inaccurate. There are some exemptions, which means you may not always receive all the information we process but as a main rule you can always contact us and ask for your information.
  2. Your right to erasure - You can ask us to erase your personal information in certain circumstances.
  3. Your right to withdraw your consent: If processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. Your withdrawal will not affect the lawfulness of the processing carried out before you withdrew your consent. You may withdraw your consent by sending an email to
  4. Your right to restriction of processing and object to processing - You have the right to ask us to restrict the processing of your information and a similar right to object to processing.
  5. Your right to data portability: You have the right to receive your personal information in a structured, commonly used and machine-readable format (data portability).
  6. Where your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing of personal data about you for such marketing.

We will make sure to answer your request without undue delay and in any event within one month of receiving your request. It can be that the period will be extended by two further months if your request is very complex.

There may be conditions or limitations on these rights. It is therefore not certain e.g. you have the right of data portability in a specific case - this depends on the specific circumstances of the processing activity. You are always welcome to contact us and ask. The same goes for some of the other rights.

Do note that if you do not allow us to collect or process the required personal information or withdraw the consent to process the same for the required purposes, you may not be able to access or use the services for which your information was sought.


You can always lodge a complaint with a European data protection authority, for example the Berlin Commissioner for Data Protection and Freedom of Information

Assistance and additional information

You can take steps to exercise your rights by using the contact details above. If you have questions about the Policy, feel free to contact us by using the contact details in this Policy.

Third party links and use of your information

Our website may contain links to other websites that are not operated by us. This Policy does not address the privacy policy and other practices of any third parties, including any third party operating any website or service that may be accessible via a link on this website. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.


  1. Consent

    By accepting our use of cookies, apart from necessary cookies, you consent to our use of cookies as described under "Types of cookies and how we use them" below. You may at any time change or withdraw your cookie consent - See the section “How you can change your cookie settings, incl. opting out” below.

  2. What do I need to know about cookies?

    There are different types of cookies and they are used for different purposes.

    Below you can read about what a cookie is, the difference between first and third party cookies and session cookies vs. persistent cookies and what types of cookies we use on our website and why.

  3. What is a cookie?

    A cookie is a small piece of data that a website stores on your device when you visit it and which is then read when you later revisit the site. The word "cookies" in this policy and the consent also refers to other forms of automatic collection of data, e.g. Flash-cookies (Local Shared Objects), Web Storage (HTML5), Javascripts or cookies placed by other software.

    A cookie may contain information about the website itself, a unique identifier that allows the site to recognise your web browser when you return to the website, additional data that serves the purpose of the cookie, and the lifespan of the cookie itself.

    The word "cookies" or "cookie data" also covers information about IP and MAC addresses and other information about your device collected by said technologies.

    Cookies are used to enable certain features (e.g. logging in), to track site usage (e.g. analytics), to store your user settings (e.g. timezone, notification preferences), and to personalise your content (e.g. advertising, language).

  4. Session cookies vs. persistent cookies

    Session cookies only last as long as your online session. This means that they will disappear from your computer or device when you close your browser. They are therefore also sometimes referred to as temporary cookies. For example, session cookies are used to remember what a user put in their basket when they are browsing a website.

    Persistent cookies are different. These cookies are sometimes called permanent cookies. They will stay on your computer or device after you close your browser. These types of cookies will expire according to the time specified in the cookie. You can see the specific duration of each persistent cookie below.

  5. What’s the difference between first and third party cookies?

    First party cookies are cookies that are set by the website that you are visiting and it's only this website that can access and read these cookies.

    Third party cookies are set by someone other than the owner of the website you’re visiting. As an example, some pages have content from other sites like YouTube. YouTube may set their own cookies on your browser when you play the video from YouTube. Cookies set by other sites and companies (i.e. third parties) can be used to track you on other websites that use the same third-party service.

    We may engage third parties to assist with maintenance, operation, creation or functionality of our website, e.g. analytics providers and content partners. We grant these third parties’ access to selected information to perform specific tasks on our behalf.

    We are, as a general rule, joint controller with providers of third-party cookies for the collection of personal data via such cookies and the disclosure to the provider. The provider of third-party cookies is data controller for the processing taking place after receiving the personal data from us.

    We recommend reading the provider's privacy policy which can be found through links in the tables below, where you can also see which cookies on our website are first party cookies and third-party cookies.

  6. Types of cookies and how we use them
    • Necessary cookies

      Necessary cookies are required to provide core functionality. The website won't function properly without these cookies and they are enabled by default and cannot be disabled.


      Ensures visitor browsing-security by preventing cross-site request forgery. This cookie is essential for the security of the website and visitor.

      Used in order to detect spam and improve the website's security.


      Preserves users states across page requests.

      Ensures visitor browsing-security by preventing cross-site request forgery. This cookie is essential for the security of the website and visitor.

      Used in order to detect spam and improve the website's security.


      Technical cookie that synchronizes the website and the CMS. This is used to update the website.


      Preserves users states across page requests. days

      Used by CookieHub to store information about whether visitors have given or declined the use of cookie categories used on the site.

    • Preferences cookies

      Preference cookies enables the web site to remember information to customize how the web site looks or behaves for each user. This may include storing selected currency, region, language or color theme.

      Currently, we do not use cookies in this cookie category.

    • Analytical cookies

      Analytical cookies gather statistics. We use this information to make our website even better. The information collected via the analytical cookies track how you use our website during your visit. It helps us understand visitor usage patterns, identify, and diagnose problems or errors you may encounter, and make better strategic decisions in improving the website experience.

      We will only set analytical cookies on your device if you give us your consent.

      Currently, we do not use cookies in this cookie category.

    • Marketing cookies

      Marketing cookies are used in determining what promotional content is more relevant and appropriate to you and your interests. Websites may use them to deliver targeted advertising or to limit the number of times you see an advertisement. This helps companies improve the effectiveness of their campaigns, and the quality of content presented to you. These cookies may be set by the website you’re visiting (first party) or by third-party services. Marketing cookies set by a third-party service may be used to track you on other websites that use the same third-party service.

      Currently, we do not use cookies in this cookie category.

    • Other cookies

      The cookies in this category have not yet been categorized and the purpose may be unknown at this time.

      Currently, we do not use cookies in this cookie category.

  7. How you can change your cookie settings, incl. opting out

    As part of our cookie solution, we always ask for your consent to cookies, except for necessary cookies, before placing cookies on your device.

    We also always give you the option to change your consent. If you at one point gave consent to non-necessary cookies on our website, you can always change which cookies you will give consent to. Just look for the "Cookie settings" on the footer of our website or the following link. If you press "Cookie settings", your cookie settings will appear, allowing you to always change your settings and reject cookies.

    Cookie settings

    Listed below are the links to the support documents on how to manage and delete cookies from the major web browsers.




    Internet Explorer:

    If you are using any other web browser, please visit your browser’s official support documents.

  8. How often will we update this Cookie Notice?

    We may update this Cookie section from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Policy regularly to stay informed about our use of cookies and related technologies. The date at the top of this Policy indicates when it was last updated.

Children and our services

Our services and website aren’t directed to children, and you can’t use our website if you are under the age of 16.

Changes to the Policy

Sometimes we need to make changes to this Policy to reflect our current practices. We will take reasonable steps to let you know about changes via our website.

If you continue to use our website or services after the notification, we will regard this as your acceptance of our privacy practices.