Jordin - Privacy Policy

Last update: 22 Aug 2023

1. Introduction

This Privacy Notice is intended to describe the details of data processing in relation to “Jordin” application (“Service”) with respect to the privacy of all individuals whose personal data is processed in relation to the performance of the Service

Pontly Solutions Kft. (having its registered seat at 1138 Budapest, Sólyatér utca 11., 2/3, Hungary, registered in the Hungarian company registry under the number 01-09-400216; hereinafter referred to as: “we” or “Data Controller”) is the data controller for the data processing activity taking place during the provision of the Service and is responsible for the processing and storage of your personal data.

We are authorised to modify this Privacy Notice at any time, without prior notice.

2. Why do we need your personal data?

The main purpose of the Service is to motivate people to walk more. This extra motivation is achieved by generating personalised step goals for our users, indicating steps related statistics for them, and (with an active subscription) converting every step they take to climate actions.

Carbon offsetting is fulfilled using carbon credits purchased from verified climate action platforms. We are only able to provide such a Service if we keep a register of such data (steps taken) you voluntarily provide during the use of the Service.

Either on our website or at the time of registration, you can also subscribe to our updates and newsletter. You will receive a confirmation email at the same time as you subscribe to the newsletter.

You also have the possibility to contact us or register your interest towards a potential partnership by submitting your email address using the form(s) on our website.

3. What type of information do we process?

We process the following categories of personal data:
- name (first, last),
- gender (for a customised user-experience),
- date of birth (to ensure we comply with the applicable minimum age requirement),
- email address,
- usage data,
- country name (where you will be using the Service),
- payment data (e.g. date and value of transaction made for subscribing to the Service).

Before using the Service, you have to complete the registration process as described in the Terms of Service. During this registration, you will be required to allow access to the Apple Health application. Without providing this access, you will not be able to register or use the Service.

The following data is synchronised from the Apple Health application:
- Data regarding number of steps (pedometer).

We do not synchronise any other data accessible or available in the Apple Health application.

We do not consider the above data as health data. No sensitive personal data is collected and processed by using the Service.

4. Who can access your personal data?

We disclose some personal data we collect to the following third party service providers that we use as subcontractors to support the provision of our Service. These third party service providers shall be considered either as data processors or as joint controllers as the case may be, according to the privacy policies, notices or other terms of use disclosed by the third party service provider concerned:

We engage subcontractors to provide website and application development services (,,,,,; domain and webpage management services (;,; codebase management services (; cookie consent management platform services (; marketing initiatives, email delivery services (; use analytics and statistic reporting services ( /, Meta Pixel); research services (Typeform); billing services (; subscription management services (

The third party service providers that we use are bound to maintain appropriate levels of data protection, security and confidentiality, and have to comply with applicable legal requirements if they transfer personal data outside the jurisdiction in which the data was originally collected.

5. Cookies

Cookies are small text files that we or the third party service providers that we use place on your computer or device to allow us or the third party service provider to track your usage in relation to the Service.

We use third party service providers to track our website’s usage and traffic, including providing analysis regarding how users use the Service, like that of Google Analytics. The information collected by the technology will be disclosed to or collected directly by these third party service providers.

The code running during usage of the Service currently stores the following cookies in your browser. Cookies marked with (*) are considered necessary for the running the code provided by the third party providers creating the individual codes running. With regard to all other cookies not marked with (*), the legal basis for our processing is your consent to the use of the cookie by way of using cookie consent mechanism:

6. Data retention

Our policy is to retain personal data only for as long as it is needed for the purposes described in the section “Why do we need your personal data” above, so your personal data will be retained in compliance with privacy laws and regulations and will not be retained for longer than required.

Based on this policy in the previous paragraph, in the event of termination of the Service, we will retain your name, email address and payment data for 5 years after this termination, which is the period for claims arising from our contractual relationship.

In order to comply with the Hungarian financial, tax and accounting regulations, we shall retain your data regarding your name and your payment transactions for 8 years after your last payment.

All other personal data is deleted when you either terminate the use of the Service (closing your account) or, with regard to data regarding the number of steps (pedometer), when you use the function to erase all such recorded data.

At the end of the data retention period, your personal data will be deleted.

If you have subscribed to the newsletter, you may unsubscribe from the newsletter at any time by clicking on the "Unsubscribe" button in any of the emails received from us, or adjusting your preferences in the “Jordin” application. In this case, we will no longer process your data to provide you with newsletters and will delete such data.

7. Security

We protect the confidentiality and security of information we obtain in the course of our business. Access to such information is limited, and policies and procedures are in place that are designed to safeguard the information from loss, misuse and improper disclosure.

8. Controlling your personal data

We will not transfer your personal data to third parties other than any subcontractors referred to in section “Who can access your personal data?” above.

To confirm whether your personal data is processed or to access your personal data to withdraw your consent, contact us by sending a message using our contact form.

9. Object, rectification, erasure, restriction of processing or data portability

You can confirm your personal data is accurate and current. You can object to the processing of your personal data or request rectification, erasure, restriction of processing or a readily portable copy of your personal data by contacting us by sending a message using our contact form.

10. Complaints

If you are concerned about an alleged breach of privacy law or any other regulation, contact us by sending a message using our contact form.

If you are not satisfied with how we resolved your complaint, you have the right to complain to the HungarianNational Authority for Data Protection and Freedom of Information.

Name: Nemzeti Adatvédelmi és Információszabadság Hatóság
Post address: 1374 Budapest, Pf. 603.
Address: 1055 Budapest, Falk Miksa utca 9-11.
Phone: +36 (1) 391-1400

You can also refer the matter to a court of competent jurisdiction.

11. Contact us

If you have additional questions or concerns, contact us:

Name: Pontly Solutions Kft
Address: Hungary, 1138 Budapest, Sólyatér utca 11, 2/3
Contact Form