This agreement is part of our terms of service. It applies when you add LaunchPal’s tracking script to your app. For the data the script collects about your app’s visitors, you are the controller and MN Ventures, MB, company code 306686908, V. Nagevičiaus g. 3, LT-08237 Vilnius, Lithuania (“we”), is your processor under Article 28 of the GDPR.
1. What we process
- Whose data: people who visit your app.
- What data: the pages they view, how long they spend and how far they scroll, the site they came from, campaign tags, which ad or social platform a link came from, their country, device type, operating system and browser, and the events your app sends, such as a sign-up.
- What we don’t keep: no cookies, no IP addresses and no names or emails. Visitors are counted with a code made from their IP address and browser with a secret that we delete every day, so the same person can’t be followed from one day to the next.
Don’t send us more than that. Event names must not contain personal data such as names or email addresses, and your page addresses shouldn’t either.
2. Why, and on whose instructions
We process this data only to show you your results in LaunchPal and to tailor your plan to them. Your instructions are these terms, this agreement and what you set in your account. We don’t sell it or use it for advertising. We may learn from totals across all apps that identify no visitor and no app, to improve the plans your Pal suggests. If we think an instruction breaks data protection law, we’ll tell you.
3. How long we keep it
We keep each event for up to 24 months. When you remove your app or delete your account, we delete its visitor data straight away. Copies in our database backups expire within 7 days.
4. How we protect it
- The data is stored in the EU (Frankfurt), encrypted at rest and sent only over HTTPS.
- Only the people who run LaunchPal can reach it, and they’re bound to keep it confidential.
- You see your own app’s data only. Other accounts can’t read it.
5. Who helps us
You allow us to use these subprocessors for this data:
- Amazon Web Services: hosting and the database, in the EU (Frankfurt).
- Cloudflare: our network and protection against attacks. Requests to our API pass through it.
We’ll email you before we add or replace one, so you can object. If you do, you can remove our script, and we’ll delete your visitor data. Cloudflare may process data outside the EU, bound by the EU’s standard contractual clauses or the EU–US Data Privacy Framework.
6. Helping you
- We help you answer your visitors’ requests to see or delete their data, as far as our records allow. We can’t link events to a named person, because we don’t store who anyone is.
- If we find a breach that affects this data, we tell you without undue delay, and within 48 hours, with what we know.
- We give you the information you need to show you comply, and help with impact assessments where the law requires one. If you need an audit, ask us at hello@launchpal.app and we’ll agree a reasonable time and scope.
7. Your part
You tell your visitors about the script in your own privacy policy and make sure you may collect this data. Our script uses no cookies, but your app’s other tools may need a consent banner.
8. When it ends
This agreement lasts as long as our script sends us data for your app. When you remove your app or close your account, we delete its visitor data as described above.