This policy describes how LE2M Holding ("we"), publisher of JABAM (website jabam.fr and iOS app), collects, uses and protects your personal data when you play Petit Bac in multiplayer or Solo AI mode.
1. Data controller
LE2M Holding, SARL — RCCM CI-ABJ-03-2023-B13-02518 — Abidjan, Cocody Angré 9th district, Ivory Coast.
General contact: support@le2mholding.com
Privacy contact: privacy@le2mholding.com
2. Data we collect
2.1 Account data
- Email or phone number (depending on sign-in method)
- Display name
- Profile picture / avatar (if you upload one)
- Unique user identifier
2.2 Game data
- Games created and joined, game codes, settings (categories, letters, duration)
- Answers submitted, votes cast, scores, ranking
- Statistics (games played, wins, best score, total points)
- Invitations sent and received
2.3 Technical data
- Session identifiers, authentication tokens
- IP address, device type, app version, language, timezone
- Anonymized error logs for service stability
2.4 Advertising data (iOS, free users only)
If you are not Premium, the iOS app may display ads via Google AdMob. Ad consent is collected via Google UMP / AdMob on first launch.
- If you accept: personalized ads may be served by AdMob and its partners, per Google rules.
- If you refuse or limit consent: only non-personalized or limited ads are served, per Google / AdMob rules.
JABAM does not request Apple ATT tracking permission in the current iOS version and does not use IDFA. For mobile app analytics we use Umami, a privacy-friendly solution with no third-party cookies and no advertising identifier.
2.5 Premium payment data
- iOS: purchase handled by Apple via StoreKit. We only receive a status (active / expired) and a transaction ID. No card data passes through our servers.
- Web: purchase handled by PayDunya. We receive a transaction ID and a status. No card data passes through our servers.
2.6 Push notifications (iOS)
If you allow notifications, an APNs token is stored in the push_tokens table to notify you of invitations, game turns and results. You can disable them anytime in iOS Settings → Notifications → JABAM.
3. Purposes and legal bases (GDPR art. 6)
- Contract performance: account, game flow, leaderboard, Premium.
- Legitimate interest: security, fraud prevention, service improvement, aggregated stats.
- Consent: push notifications, personalized ads (iOS via Google UMP / AdMob), non-essential emails.
- Legal obligation: retention of Premium billing data.
4. Artificial intelligence (Solo AI & answer verification)
The Solo AI mode and automatic answer verification use a language model hosted via Lovable AI Gateway. The game answers you submit are sent to the model for evaluation (valid / invalid). No personally identifying data is transmitted beyond the game answer itself.
5. Processors and recipients
| Service | Purpose | Location |
|---|---|---|
| Supabase | Auth, database, realtime, avatar storage | European Union |
| Google AdMob | Banner and rewarded ads (free iOS) | United States (SCCs) |
| Google UMP | iOS ad consent collection | EU / US |
| Apple StoreKit & APNs | iOS Premium purchases, push notifications | EU / US |
| PayDunya | Web Premium payment | West Africa |
| Lovable (Cloudflare Workers + AI Gateway) | Hosting and AI inference | EU / global edge |
6. Retention
- Active account: as long as you use the service.
- Inactive account: automatic deletion after 36 months of inactivity.
- Game data after account deletion: anonymized within 30 days, kept in aggregated form for historical leaderboards.
- Premium billing data: 10 years (accounting obligation).
- Technical logs: 12 months maximum.
7. Your rights
You have the following rights (GDPR art. 15-22):
- Access, rectify, erase your data
- Restriction and objection to processing
- Data portability
- Withdraw consent at any time
- Lodge a complaint with a supervisory authority
To exercise: privacy@le2mholding.com from your account email. Response within 30 days.
8. Minors
JABAM is intended for users aged 13 and over. Minors must obtain parental consent. We do not knowingly collect data from children under 13.
9. Security
Hashed passwords, end-to-end TLS encryption, data access restricted by Supabase Row Level Security policies, short-lived tokens. Report any incident to privacy@le2mholding.com.
10. Changes
This policy may evolve. The last update date is shown at the top of the page. We will notify you of substantial changes via email or in-app notification.