Privacy Policy

Privacy is core to JyvGaming. The Software is local-first: your recordings, audio captures, and gameplay audio remain on your device. Limited, anonymized audio frames may be sent to our cloud GPU service for inference and are deleted within ten (10) minutes of completion.

1. Who We Are

JyvGaming is operated by JYV STREAM LLC, a Florida limited liability company. Our principal place of business is 7901 4th St N, Suite 33883, St. Petersburg, FL 33702, USA. For users in the European Union and United Kingdom, JYV STREAM LLC acts as the data controller for the personal data described in this Policy.

EU & UK Representatives (Article 27 GDPR / UK GDPR)

As a company established outside the EU and UK, JYV STREAM LLC has appointed representatives pursuant to Article 27 of the GDPR and UK GDPR respectively. Data subjects and supervisory authorities may direct inquiries to these representatives.

EU Representative: Prighter Group GmbH, Schellinggasse 3/10, 1010 Vienna, Austria

UK Representative: Prighter Ltd, 20 Mortlake High Street, London, SW14 8JN, United Kingdom

EU and UK data subjects may submit privacy requests directly at: https://app.prighter.com/portal/11199242890

2. Scope

This Policy applies to JyvGaming (the "Software"), our website https://jyvgaming.gg, and any related services. It does not apply to third-party websites, services, or products linked from ours.

3. Categories of Data

3.1 Data You Provide

• Account: name, email address, country, billing details (collected and tokenized by Stripe; we do not store full card numbers).
• Support: messages and attachments you send to us.

3.2 Data Generated by the Software

• Anonymized audio frames sent to the AI Service for inference (Section 5).
• Anonymized telemetry: feature usage counts, performance metrics, crash reports, and gameplay-feature events used to improve the Software.
• License and device metadata: license key, device hash, operating system version, application version.

3.3 Data We Do NOT Collect

• Raw user audio recordings, microphone captures, or note-taker outputs (these stay on your device unless you export them).
• Voiceprints or biometric identifiers.
• Contents of your screen, keystrokes, or browsing.
• Children’s data (the Software is not directed to anyone under 18).

4. How We Use Data

5. AI / GPU Processing (Modal Labs)

Certain features require GPU inference. To support them, the Software sends anonymized, ephemeral audio frames to Modal Labs, Inc. ("Modal"), our cloud GPU sub-processor. The following protections apply:

• Frames are anonymized client-side before transmission and contain no account identifier.
• Processing occurs in volatile memory; raw inputs are deleted within ten (10) minutes of completion.
• EU/UK users are routed to EU-based infrastructure, including GPU processing and supporting services.
• Modal retains operational error logs (timestamps, request IDs) for up to 30 days.
• Modal does not train its own models on your data.

6. Model Improvement and Opt-Out

7. Retention

8. Sharing

We share data only with the following categories of recipients, under written contracts that restrict their use of the data:

• Sub-processors listed in our Sub-Processor List (Stripe, Modal Labs, hosting/CDN providers, support tooling).
• Professional advisors (lawyers, accountants, auditors) under confidentiality.
• Authorities, where required by law, court order, or to protect rights and safety.
• A successor in connection with a merger, acquisition, or sale of assets, subject to this Policy.

9. International Transfers

The table below summarizes how personal data is handled when transferred outside the country of collection. All transfers are protected through the security measures described in Section 10 and contractual obligations with our sub-processors.

EU / UK

Personal data of EU and UK users is processed in EU regions. If we ever transfer this data outside the EEA or UK, we rely on the European Commission Standard Contractual Clauses and the UK International Data Transfer Addendum as appropriate safeguards, and we conduct transfer impact assessments prior to any such transfer.

Brazil

Personal data of Brazilian users may be transferred to the United States for processing. This transfer is governed by standard contractual clauses consistent with the Lei Geral de Proteção de Dados (LGPD). Our Encarregado (Data Protection Officer contact) for Brazilian users is privacy@jyvstream.com .

Japan

By using the Software, Japanese users consent to the transfer of their personal information to the United States for processing, in accordance with the Act on the Protection of Personal Information (APPI). The United States has not been recognized by Japan’s Personal Information Protection Commission as providing an equivalent level of protection. We protect transferred data through contractual obligations with our sub-processors.

All Other Users

If you are located outside the jurisdictions listed above, your personal data may be transferred to and processed in the United States, where our servers and primary infrastructure are located. By using the Software, you consent to this transfer. We protect all transferred data through the security measures described in Section 10 and contractual obligations with our sub-processors as listed in our Sub-Processor List.

10. Security

We use TLS 1.2+ in transit, AES-256 at rest where applicable, signed binaries, scoped credentials, principle-of-least-privilege access, and continuous vulnerability scanning. No system is perfectly secure; we cannot guarantee absolute security.

11. Your Rights

Depending on where you are located, you may have specific rights regarding the personal data we hold about you. These rights are set out by jurisdiction below. To exercise any right, contact us at privacy@jyvstream.com unless a jurisdiction-specific contact is noted.

EU / UK (GDPR & UK GDPR)

Subject to applicable law, you have the right to access, rectify, erase, restrict, or port your personal data, to object to processing, and to withdraw consent at any time. You also have the right to lodge a complaint with your local supervisory authority. EU and UK data subjects may submit requests via our representative at https://app.prighter.com/portal/11199242890 .

California, USA (CCPA / CPRA)

California residents have the right to know what personal data we collect, to request deletion, to correct inaccurate data, and to opt out of the sale or sharing of personal data for cross-context behavioral advertising. We do not sell or share personal data for such purposes. To exercise these rights, email privacy@jyvstream.com .

Brazil (LGPD)

Brazilian users have rights under the Lei Geral de Proteção de Dados (LGPD), including the right to confirmation of processing, access, correction, anonymization, portability, deletion, information about third-party sharing, and withdrawal of consent. To exercise these rights, contact our Encarregado at privacy@jyvstream.com .

Canada (PIPEDA / Quebec Law 25)

Canadian users have the right to access and correct their personal information under the Personal Information Protection and Electronic Documents Act (PIPEDA). Quebec residents have additional rights under Quebec Law 25, including the right to data portability. Our privacy contact for Canadian inquiries is privacy@jyvstream.com .

Australia (Privacy Act 1988)

Australian users have the right to access and correct their personal information and to lodge a complaint with the Office of the Australian Information Commissioner (OAIC). Nothing in this Policy excludes, restricts, or modifies any right or remedy that cannot be excluded under Australian law, including the Australian Consumer Law.

India (DPDPA 2023)

Indian users may have rights under the Digital Personal Data Protection Act, 2023 (DPDPA), including the right to access, correction, and erasure of personal data. Our grievance officer for Indian users can be reached at privacy@jyvstream.com . We continue to monitor DPDPA implementation rules as they are finalized.

All Other Users

Regardless of where you are located, you may contact us at privacy@jyvstream.com to request access to, correction of, or deletion of your personal data, or to ask questions about how we process it. We will acknowledge your request promptly and respond within 30 days, or no later than 45 days where additional time is required. Prighter is our representative for EU and UK data subjects only; all other privacy inquiries are handled directly by JYV STREAM LLC at the contact details in Section 16.

12. Cookies

Our website uses strictly-necessary cookies and, with consent in EU/UK, limited analytics cookies. See our Cookie Policy. The desktop Software does not use cookies.

13. Children

The Software is not directed to and not intended for children under 18. We do not knowingly collect data from children. If you believe a child has provided data, contact privacy@jyvstream.com and we will delete it.

14. Automated Decision-Making

We do not use Personal Data for automated decision-making producing legal or similarly significant effects on you under Art. 22 GDPR.

15. Changes to this Policy

We may update this Policy from time to time. Material changes will be notified via the Software or website at least 30 days before they take effect.

16. Contact and Data Protection Officer

JYV STREAM LLC

7901 4th St N, Suite 33883, St. Petersburg, FL 33702,

USA General: support@jyvstream.com

Legal: legal@jyvstream.com

Privacy / DPO: privacy@jyvstream.com / dpo@jyvstream.com

Abuse: abuse@jyvstream.com

Website: https://jyvgaming.gg