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PRIVACY POLICY
Last updated: July 19, 2025
This Privacy Policy forJDM DIGITAL(acting for the mobile applicationBeard Up) (“we”, “us” or “our”) describes how and why we may collect, store, use and/or share (“process”) your information when you use our services (“Services”), for example when you:
Download and use our mobile appBeard Up, or any other application published byJDM DIGITALrelated to this Privacy Policy;
Interact with us in other related ways, including through our news pages, social media, marketing campaigns, or direct contact.
Questions or concerns? Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you have any questions, you can contact us at contact@jdmdigitalapp.com.
SUMMARY OF KEY POINTS
In short: This summary outlines the key aspects of our privacy policy. For detailed information, please see the table of contents below and refer to the relevant section.
What personal information do we process?
We collect personal information that you provide directly to us, such as your first name, last name, email address, date of birth, photo, and responses to our questionnaire. If you make a purchase through Apple, payment data is processed exclusively by Apple.
Do we process sensitive personal information?
No. We do not collect or process sensitive data such as health, ethnicity, religion, or biometric information.
Do we receive information from third parties?
No. We do not receive any personal data from third parties.
How do we process your information?
We use your data to personalize your experience on the application, improve our Services, track your progress, and generate internal statistics. We strictly adhere to the legal framework applicable to data protection.
In what situations and with what types of third parties do we share personal information?Your data is not shared with third parties. No data is shared with partners, advertising platforms, or service providers unless necessary and within a framework.
How do we protect your information?
Your data is hosted in the European Union and secured by Firebase (authentication, analytics, storage). Appropriate technical and organizational measures are in place to protect your data. However, since no system is infallible, we cannot guarantee absolute security against any malicious intrusion.
TABLE OF CONTENTS
WHAT INFORMATION DO WE COLLECT?
HOW DO WE PROCESS YOUR INFORMATION?
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
WHAT IS OUR POSITION ON THIRD-PARTY WEBSITES?
IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
HOW LONG DO WE KEEP YOUR INFORMATION?
HOW DO WE PROTECT YOUR INFORMATION?
DO WE COLLECT INFORMATION FROM MINORS?
WHAT ARE YOUR PRIVACY RIGHTS?
CONTROLS FOR DO-NOT-TRACKING FEATURES
DO U.S. RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
ARE WE UPDATING THIS NOTICE?
HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you provide to us
In short: We collect personal information that you voluntarily provide to us when you use the Beard Up app.
We collect personal information that you choose to provide to us directly when you:
create an account or complete a form in the app;
answer our personalization questionnaire;
communicate with us via email or integrated support services
Participate in activities offered in the app.
Progress photos (before/after)
Personal information provided by you
The personal data we collect depends on the context of your interaction with the application and the choices you make. It may include the following:
First name
E-mail address
Age or date of birth
Genre
User photo (taken at the beginning and end of each week to track progress;
Responses to the start-up questionnaire (e.g., current condition of beard, growth goals, desired frequency of care)
Data on lifestyle habits: diet, physical activity
Family history (e.g., presence of beards in the family)
Sensitive information
We do not collect or process sensitive personal information, such as health data, sexual orientation, religion, biometric recognition or racial origin, as defined by the GDPR.
Photos you import into the app (for example to track your beard growth) arestored in Firebase, a secure cloud service provided by Google. They are not visible to other users unless you voluntarily share them.
Payment data
Payments in Beard Up are processed through the Apple (App Store) and Google (Play Store) platforms. We do not directly collect or store your banking data. Payment data is managed exclusively by the relevant payment providers and is subject to their respective privacy policies.
Apple Privacy Policy
Google Privacy Policy
Application data
If you use our application(s), we may also collect the following information if you choose to give us access or permission:
Notifications push.We may ask to send you push notifications about your account or certain features of the app. If you wish to opt out of these types of communications, you can disable them in your device settings.
Information collected automatically
In Short: Certain information such as your Internet Protocol (IP) address and/or browser and device characteristics is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, and navigate the Services. This information does not reveal your identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about your usage patterns on our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for internal analytics and reporting purposes.
The information we collect includes: Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information that our servers automatically collect when you access or use our Services and that we record in log files. Depending on your interactions with us, this log data may include your IP address, device information, browser type and settings, and information about your activity within the Services (such as date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take, such as the features you use), and device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
2. HOW DO WE PROCESS YOUR INFORMATION?
In short: We process your information to provide, improve and administer our services, communicate with you, ensure security, prevent fraud and comply with applicable law.
We may process your personal information for various reasons, depending on how you interact with our Beard Up app, including:
To generate a personalized beard growth program based on the personal data you provide to us (age, goal, genetics, habits, etc.)
To improve the functionality and user experience of the application through statistical analysis of the use of our Services
To ensure the proper technical functioning of the application, correct bugs, optimize performance and guarantee data security
To communicate with you, including to send push notifications if you have consented to this
To process subscriptions and payments made through the App Store or Play Store
To comply with our legal obligations, respond to administrative or judicial requests, or protect our rights
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
In short: We only process your data when we have a valid legal basis under the laws in force in your country. These bases may include your consent, the performance of a contract, legal obligations, or our legitimate interests.
Beard Up is accessible to users worldwide. Depending on your location, we process your personal data in accordance with applicable laws, such as theGeneral Data Protection Regulation (GDPR)for the European Union, theUK GDPR, the California Consumer Privacy Act (CCPA), or other local privacy laws.
We rely in particular on the following legal bases:
Consent: We process certain personal data only after obtaining your explicit consent (e.g., storing your before/after photos, personalizing your program, sending push notifications). You can withdraw this consent at any time in the application settings or by contacting us at the address indicated in this policy.
Execution of a contract: processing is necessary to provide you with the services you have subscribed to, in particular as part of your subscription (access to personalized content, progress monitoring, reminders, etc.).
Legal obligation: certain data may be processed to meet our legal obligations, for example in accounting, tax or regulatory matters.
Legitimate interests: we may also process your data in our legitimate interest to:
improve and secure the application, understand user behavior in order to optimize features, prevent fraud, abuse or security breaches.
We always ensure that we balance our interests with your fundamental rights and freedoms.
If you are located in a specific jurisdiction: European Union / United Kingdom: We comply with the GDPR and the UK GDPR. You have enhanced rights (access, rectification, erasure, opposition, etc.).
United States (e.g., California): We comply with applicable provisions such as the CCPA. You can request to review, delete, or limit the use of your data.
Other countries: if you reside outside the EU, the UK or the US, we apply the equivalent principles provided for in your country of residence to the extent possible, and implement the necessary safeguards to ensure adequate protection of your personal data.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In short: we only share your data when necessary, with contractually supervised service providers, and in specific situations such as legal obligations or management operations.
We do not sellno personal datato third parties. However, as part of the operation of the applicationBeard Up, certain data may be shared with third parties acting on our behalf.
Suppliers, subcontractors and service providers
We share your data with technical service providers strictly necessary for the proper functioning of the application, in particular:
Firebase (Google)– hosting, database, authentication and analytics;
Apple (App Store)– processing payments and subscriptions for iOS users;
Google (Play Store)– processing payments and subscriptions for Android users (if applicable);
Analysis tools(eg: Firebase Analytics) – tracking application usage for continuous improvement.
All these service providers are contractually bound to respect the confidentiality, security and processing limitations defined by JDM DIGITAL. Theycannot use your data for other purposesthan those we have entrusted to them, nor transmit them to third parties without our agreement.
Retention by third parties
The data processed by our service providers is storedonly for the duration necessary for the service, then deleted or anonymized. By default, retention is limited to12 months maximumunless otherwise required by law.
Other situations in which sharing may occur:
Legal obligations: in the event of a request from a judicial, administrative or tax authority, we may be required to transmit certain data under the conditions provided for by law.
Transfer of activity: in the event of a merger, acquisition, sale of all or part of JDM DIGITAL’s assets, or change of control, the data may be transferred to the purchaser, while respecting the rights of users.
No public sharing or sharing with ad networks
We do not share your data with advertising platformslike Facebook Ads, Google Ads, TikTok Ads, etc. (no active interconnection to date).
We do not make your contributions public., unless you expressly authorize us to do so (e.g. shared testimonials).
5. WHAT IS OUR POSITION ON THIRD-PARTY WEBSITES AND SERVICES?
In short: We are not responsible for the security or processing of data you share with third-party services accessible through our app.
L’application Beard Upmay contain or redirect to external links, embedded content or third-party services (e.g., links to partner products, video content, social networks, analytics or payment tools).
These services tiersoperate completely independently and are notnot under our control. Therefore :
We do not guarantee reliability, the security or compliance of these third-party services with applicable legislation (e.g. GDPR);
We we have no controlon their practices regarding the collection, processing or sharing of your personal data;
We we decline all responsibilityin the event of loss, data breach, misuse or damage related to the use of these third-party services.
The inclusion of an external link or tool inBeard Updoes not constitutenot an approval or validationof its content, practices or general conditions.
Data collected by these third parties is not covered by this Privacy Policy.We strongly recommend that you review the privacy and security policies of each third-party service before interacting with or transmitting personal data.
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In short: Yes, your information may be transferred, stored and processed outside your country of residence.
L’application Beard Up, operated byJDM DIGITAL, is accessible from anywhere in the world. Your personal information may be transferred to and processed in third countries, particularly when we use international technical service providers.
Data hosting: Data collected in connection with the use of Beard Up (including photos and information related to your account) arehosted within the European Union, via the platform servicesFirebase (Google), which guarantees a high level of security and compliance.
Transfers outside the European Union: If data were to be transferred to countries outside the European Economic Area (EEA), we would ensure thatappropriate legal guaranteesare put in place. This includes in particular:
the use ofstandard contractual clausesapproved by the European Commission;
and, where applicable,additional security measures(encryption, anonymization, etc.).
These transfers are always carried out in compliance with applicable data protection regulations, such as theGDPR(General Data Protection Regulation) or other equivalent local legislation.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
In short: We retain your information for as long as necessary to fulfill the purposes outlined in this policy, unless otherwise required by law.
We retain your personal information only for as long as is strictly necessary to fulfill the purposes for which it was collected, as set out in this Privacy Policy, unless a longer retention period is required or permitted by law (e.g. tax, accounting or regulatory obligations).
Retention periods by data type:
User account data(name, email, survey responses, photos, etc.): retained for as long as your account is active. In the event of account deletion, all associated data will be permanently deleted within 30 days.
Personal photos: Stored via Firebase for progress tracking. Deleted along with the user account or at your request.
Payment data : Beard Up ne conserve no bank or credit card details. Payments are processed directly byApple App Store And Google Play Store, in accordance with their respective policies.
Technical and analytical data(logs, activity, performance, usage): kept for a maximum period of12 months, for security, diagnostic, performance and service improvement purposes.
Once the retention period has expired, the data is: securely deleted, or made anonymous and irreversible, if used for statistical or research purposes.
8. HOW DO WE PROTECT YOUR INFORMATION?
In short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risks associated with the processing of your personal data. These measures aim to prevent unauthorized access, disclosure, loss, theft, alteration, or destruction of data collected through the application.Beard UpThese include the use of encryption, access control, the installation of firewalls and the continuous monitoring of our systems to identify any potential vulnerabilities.
However, despite our efforts, no transmission or storage technology over the Internet can guarantee absolute security. Consequently, we cannot guarantee that malicious third parties, such as hackers or cybercriminals, will not be able to access your data illegitimately.
Transmission of your information to and from our application is at your own risk. We recommend that you adopt responsible digital security practices, such as using strong passwords, regularly updating your devices, and not sharing your login details with others. Finally, we encourage you to regularly review our official communications for any updates regarding the security of your data.
9. DO WE COLLECT INFORMATION FROM MINORS?
Our Beard Up app is intended for a general audience, but access is strictly restricted to people aged13 years and older.
We do not knowingly collect personal information from children under the age of 13, in accordance with applicable laws, including theChildren's Online Privacy Protection Act (COPPA)in the United States. If we discover that a child under the age of 13 has provided us with personal information without verifiable parental consent, we will immediately delete that data from our servers.
Beard Up does not target children or offer content specifically intended for minors. We encourageparents and legal guardiansto monitor their children's use of the application and to report any unauthorized use to us.
If you believe that your child has provided us with personal data without your consent, please contact us immediately atcontact@jdmdigitalapp.comWe will process your request as soon as possible and take appropriate steps to delete the relevant data.
10. WHAT ARE YOUR PRIVACY RIGHTS?
In short:If you are located in the European Economic Area (EEA), the United Kingdom, or a region with data protection laws, you have specific rights regarding your personal data.
In accordance with theGeneral Data Protection Regulation (GDPR), you have the following rights: The right to access your personal data and obtain a copy thereof, the right to request the rectification of inaccurate or incomplete data, the right to request the erasure of your data (“right to be forgotten”), the right to temporarily or permanently limit the processing of your data, the right to object to the processing of your personal data, in particular for direct marketing purposes or based on a legitimate interest, the right to data portability, when the processing is based on consent or a contract and carried out by automated means, the right not to be subject to a decision based exclusively on automated processing, including profiling, except for exceptions provided for by law.
If you believe that your rights have not been respected, you also have the right tofile a complaintwith the competent data protection authority in Francethe CNIL(National Commission for Information Technology and Civil Liberties) or in your country of residence.
11. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a “Do-Not-Track” (“DNT”) feature or setting you can activate to signal your privacy preference and opt-out of having your online browsing activities monitored and collected. Currently, no uniform standard for recognizing and implementing DNT signals has been adopted, and we do not currently respond to browser DNT signals or other mechanisms that automatically communicate your choice not to be tracked. However, if such a standard is adopted, we will update this Privacy Policy and provide you with detailed information on how we are complying with any such changes. We encourage users to periodically review this policy to stay informed about our online tracking practices.
12. DO U.S. RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you have specific rights regarding access to your personal information. We comply with the California Consumer Privacy Act (CCPA) and other applicable laws that provide specific privacy rights to U.S. residents.
13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
In short: You may have additional rights depending on the country you reside in.
If you reside in other regions, including Australia, New Zealand, or South Africa, we collect and process your personal information in accordance with the specific legal requirements of your country. You have the right to request access to, rectification of, or deletion of your personal data. If you believe your data has been unlawfully processed, you may lodge a complaint with the relevant data protection authority in your country.
14. DO WE UPDATE THIS NOTICE?
In short: Yes, we will update this notice as needed to remain compliant with applicable laws.
We may update this Privacy Policy from time to time. The updated version will be indicated by a “Revised” date and will be effective immediately upon posting. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice or by directly sending you a notification. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting your information.
5. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have any questions, requests or comments regarding this Privacy Policy or the processing of your personal data, you can contact us at the following address:
By email: contact@jdmdigitalapp.com
JDM DIGITAL