Privacy Policy

Introduction

This Privacy Policy explains how JR NETMEDIA, with registered address at Carrer dels Avellaners, Ed. Griu, Pis 5 Pta 3, AD200, AD, telephone +376 62 60 15, and registration or tax number 927824-G, collects, uses, discloses, retains, and protects personal data when you access or use Couponswe and related services (the “Website”). JR NETMEDIA is the data controller for personal data processed in connection with the Website, unless this Policy expressly states otherwise.

The Website is an app discovery and review directory. We index information about mobile applications, publish descriptions, editorial content and reviews, and provide links to the official Google Play and Apple App Store pages where applications may be obtained. We do not host, distribute, or provide APK, IPA, or other application installation files. The Website is funded in part by advertising, and advertising, analytics, and related measurement technologies may process information about your use of the Website as described below.

Because JR NETMEDIA is established in Andorra, this Policy is intended to comply with applicable Andorran data-protection legislation, including Law 29/2021, of 28 October, qualified as the Protection of Personal Data Law, as amended or replaced from time to time, together with other applicable Andorran privacy, electronic communications, consumer-protection, and civil laws. The competent data-protection supervisory authority in Andorra is the Andorran Data Protection Agency (Agència Andorrana de Protecció de Dades, “APDA”). Where applicable to a particular processing activity or individual, we also seek to respect principles reflected in internationally recognized data-protection standards, including transparency, purpose limitation, data minimization, accuracy, security, and accountability.

By accessing or using the Website, you acknowledge that you have had the opportunity to read this Privacy Policy. If you do not agree with the practices described here, you should not use the Website or submit personal data to us. This Policy should be read together with our Cookie Policy and Terms of Use, where applicable.

Information We Collect

Information You Provide to Us

We collect information that you voluntarily provide when you communicate with us or use features that permit submissions. The amount and type of information collected depends on the nature of your interaction and the information you choose to include.

Contact forms. If you contact us through a contact form, we may collect your name, email address, the subject and contents of your message, and any other information you choose to provide. We may also collect information needed to prevent spam or abuse, such as a submission timestamp, IP address, or security-related metadata.
Email communications. If you email us, we collect your email address, email headers, message contents, attachments, and any personal information contained in your correspondence. We may retain correspondence to respond to your request, administer the Website, document our communications, and protect our legal rights.
DMCA notices and copyright complaints. Although the Website does not host application installation files, a rights holder or authorized representative may contact us regarding descriptions, reviews, images, links, or other indexed material. A notice may include the complainant’s name, organization, contact details, identification of the allegedly infringing material, statements concerning ownership or authorization, and other information required to assess the complaint. We process this information to investigate and respond to the notice, communicate with relevant parties, and comply with applicable law. Please do not include unnecessary sensitive personal data in a notice.
Feedback, reviews, and other submissions. If you provide feedback, corrections, suggestions, ratings, or other information about an application or the Website, we collect the content of your submission and any contact details you provide. If content is published, it may be displayed publicly in accordance with the applicable terms and may be associated with a username, display name, or other identifier that you choose to provide.

You should provide only information that is relevant to your request. We do not generally require special categories of personal data, such as health information, biometric information, political opinions, religious beliefs, or information concerning criminal convictions. Please avoid sending such information unless it is strictly necessary and specifically requested by us.

Information Collected Automatically

When you visit or use the Website, certain information may be collected automatically through server logs, cookies, pixels, tags, software development tools, and similar technologies. Some technologies are necessary for the Website to operate, while others are used only where permitted by law and, where required, after you provide consent through our consent-management platform or cookie banner.

Device and browser information. This may include your IP address, approximate location derived from the IP address, browser type and version, operating system, device type, screen resolution, language and time-zone settings, referring website, pages viewed, and technical identifiers associated with your browser or device. An IP address may constitute personal data under applicable law, particularly when combined with other information.
Usage and clickstream data. We may collect information about how you navigate the Website, including pages visited, search terms entered on the Website, links clicked, application pages viewed, time spent on pages, scrolling or interaction events, referring and exit pages, and the sequence of actions taken during a visit. This helps us understand which applications and content are useful and how visitors use the Website.
Cookies and similar technologies. We may use strictly necessary cookies, preference cookies, analytics cookies, advertising cookies, conversion tags, pixels, local storage, and similar technologies. These technologies may remember settings, distinguish sessions, measure traffic, attribute visits or conversions, and support interest-based advertising. The full inventory is described in our Cookie Policy.
Analytics data. Through Google Analytics and Microsoft Clarity, where enabled, we may receive information about visits, traffic sources, page views, events, device and browser characteristics, approximate geographic information, and interactions with Website content. Microsoft Clarity may also provide session recordings, heatmaps, click information, and interaction data, subject to the configuration and consent choices described in our Cookie Policy.
Advertising and conversion data. Google AdSense and Microsoft Advertising may use cookies, pixels, tags, or similar technologies to deliver, personalize, limit, measure, and attribute advertising. Depending on your choices and applicable law, this may include information about ad impressions, clicks, conversion events, browser or device identifiers, approximate location, and visits to or interactions with the Website. Advertising partners may use information collected across websites or services to help provide interest-based advertising, where permitted.
Security and server-log data. Our hosting, infrastructure, and security systems may record IP addresses, request dates and times, URLs requested, response status codes, browser and device information, referring URLs, error reports, authentication or administrative events, and indicators of suspicious or abusive activity. This information is used to operate, secure, troubleshoot, and defend the Website.

We do not use the Website to collect information from the official app stores beyond what is made available through our indexing, linking, and editorial activities. When you click a link to Google Play or the Apple App Store, you leave the Website and become subject to the destination provider’s terms and privacy practices. We do not control those third-party services or their processing of your information.

Cookies and Tracking Technologies

The Website uses cookies and similar technologies to provide core functionality, remember preferences, understand traffic, improve content and user experience, support advertising, and measure advertising performance. A cookie is a small text file placed on your browser or device. Similar technologies include pixels, tags, local storage, and scripts that recognize a browser or device or record interactions.

When required by applicable law, we use a consent banner or consent-management platform (“CMP”) to request your permission before placing or activating non-essential analytics and advertising technologies. You may accept all technologies, reject non-essential technologies, or manage categories and individual choices through the controls made available in the CMP. Strictly necessary technologies may operate without consent where they are required to provide a service you have requested, maintain security, or comply with applicable law.

Google Analytics is used for analytics and audience measurement, not for displaying advertisements on the Website. Google AdSense is used for advertising and may use cookies and similar technologies to serve and measure advertisements. Google Tag Manager is a tag-management tool that helps us deploy and manage Website tags; it may facilitate the activation of other technologies but does not, by itself, determine the purposes of those technologies. Microsoft Advertising is used for advertising, conversion measurement, and campaign attribution. Microsoft Clarity is used for analytics, including interaction analysis, heatmaps, and session recordings where enabled.

Our Cookie Policy provides the full inventory of cookies and similar technologies, including their names or categories, purposes, providers, typical retention periods, and information about managing them. This Privacy Policy explains the broader processing of personal data associated with those technologies; the Cookie Policy should be consulted for the detailed cookie inventory.

Changing your browser settings may block or delete cookies, but doing so may affect Website functionality. Where available, you may revisit the CMP to change or withdraw your consent. Withdrawal of consent does not affect processing that occurred before withdrawal and does not affect strictly necessary technologies.

How We Use Your Information

We use personal data only for appropriate, specified purposes and in a manner proportionate to those purposes. Depending on the circumstances, we may use your information for the following purposes:

To provide and maintain the Website. We use information to deliver pages and directory functions, operate links to official app stores, maintain availability, remember settings, troubleshoot technical issues, and administer the Website.
To respond to inquiries and DMCA notices. We use contact information and correspondence to answer questions, process feedback, investigate complaints, assess copyright or other rights notices, communicate with rights holders, and take appropriate action concerning indexed content or links.
To improve content and user experience. We analyze usage patterns, search activity, page performance, and feedback to improve application descriptions, reviews, navigation, search functionality, editorial quality, accessibility, and the relevance and organization of directory content.
To serve and measure advertising. We use advertising and conversion information, subject to applicable consent requirements, to display advertisements, limit repetitive advertisements, measure impressions and clicks, understand campaign performance, attribute referrals or conversions, and fund the operation of the Website.
To protect the Website and users. We use technical and usage information to detect fraud, spam, scraping, malware, unauthorized access, denial-of-service activity, abuse, and other security incidents; investigate suspected violations; and protect the rights, safety, and property of JR NETMEDIA, users, and third parties.
To comply with legal obligations. We process information to comply with applicable laws, regulations, court orders, lawful requests, tax or accounting requirements, intellectual-property procedures, data-protection obligations, and requests from competent authorities.
To enforce our Terms and defend our rights. We use information to enforce our Terms of Use and other policies, establish or defend legal claims, preserve evidence, resolve disputes, and protect our business, reputation, and legal interests.

Legal Bases for Processing

Where applicable under Andorran data-protection law, we process personal data on one or more of the following legal bases. The relevant basis depends on the nature of the information, the context in which it was collected, and the purpose of processing.

Consent. We rely on consent for non-essential analytics and advertising cookies and similar technologies where consent is required. We may also rely on consent where you voluntarily ask us to use your information for a particular optional purpose. You may withdraw consent at any time through the CMP or by contacting us, although withdrawal does not affect prior processing.
Legitimate interests. We may process information where necessary for our legitimate interests or those of a third party, provided those interests are not overridden by your rights and freedoms. Examples include operating and improving the app directory, responding to ordinary business correspondence, preventing abuse, securing the Website, measuring non-sensitive operational performance, maintaining records, and establishing or defending legal claims. We consider the nature of the data, your reasonable expectations, the impact of the processing, and available safeguards when relying on this basis.
Legal obligation. We may process information where necessary to comply with a legal or regulatory obligation, such as responding to a valid authority request, maintaining legally required records, handling rights complaints, or documenting consent and compliance activities.
Performance of a contract. This basis may apply where processing is necessary to provide a service or perform an agreement with you. The Website is primarily a publicly accessible directory and does not generally require a user account or paid contract. Accordingly, this basis may be limited or not applicable to ordinary browsing, but it may apply to a specific arrangement if we enter into one with you.
Public interest or official authority. This basis is generally not applicable to our ordinary commercial operation of the Website because JR NETMEDIA is not a public authority. It may apply only where a specific processing activity is required for a recognized public-interest purpose under applicable law.

Where we rely on legitimate interests, you may have the right to object to the processing. Where we rely on consent, you may withdraw it. These rights are explained below.

Sharing and Disclosure of Information

We do not sell your personal data. We may disclose or make personal data available only as reasonably necessary for the purposes described in this Policy, subject to applicable law, contractual safeguards, and your consent where required.

Service providers and processors. We may use carefully selected providers that process information on our behalf, including providers supporting hosting, infrastructure, content delivery, security, communications, analytics, advertising, consent management, and technical operations. Analytics services include Google Analytics and Microsoft Clarity. Advertising services include Google AdSense and Microsoft Advertising. Google Tag Manager may be used to manage Website tags. These providers may process technical identifiers, usage data, cookie information, advertising or conversion data, and information necessary to provide their services.
Analytics and advertising partners. Google and Microsoft may process information collected through their respective technologies for analytics, advertising, conversion measurement, fraud prevention, reporting, and related purposes, subject to their own privacy documentation and applicable consent requirements. Their processing may involve information collected across websites or services where permitted by law and your choices.
Security and infrastructure providers. We may disclose server-log, device, IP address, and security-event information to hosting, content delivery, firewall, monitoring, and security providers to deliver the Website and detect or prevent attacks, abuse, and technical failures.
Affiliated entities. If JR NETMEDIA operates with affiliated or related entities, we may share information with them for administration, technology, compliance, security, customer support, and other purposes consistent with this Policy. Any such sharing remains subject to appropriate confidentiality and data-protection safeguards.
Legal requirements and protection of rights. We may disclose information to courts, regulators, law-enforcement authorities, government bodies, rights holders, professional advisers, or other parties where reasonably necessary to comply with law, respond to lawful process, investigate suspected wrongdoing, handle copyright or other rights complaints, protect users, or establish, exercise, or defend legal rights.
Business transfers. If JR NETMEDIA is involved in a merger, acquisition, restructuring, financing, sale of assets, insolvency proceeding, or similar transaction, personal data may be transferred to relevant advisers, counterparties, or successor entities, subject to confidentiality and applicable legal requirements.
Aggregate or de-identified information. We may use and disclose statistical, aggregated, or de-identified information that cannot reasonably be used to identify you, such as general traffic trends, application popularity, or advertising performance. We do not attempt to re-identify information that has been de-identified except where necessary to test or maintain the de-identification process or where required by law.

Third-party app stores are independent services. When you follow a link to Google Play or the Apple App Store, any information you provide there is governed by the relevant provider’s privacy policy and terms. We are not responsible for the privacy practices, content, availability, or security of those external services.

International Data Transfers

Some service providers and advertising or analytics partners may process personal data outside Andorra, including in countries that may have different data-protection rules. For example, Google and Microsoft may process information through international corporate, technical, and service-provider networks in connection with Google AdSense, Google Analytics, Google Tag Manager, Microsoft Advertising, and Microsoft Clarity.

Where personal data is transferred internationally, we seek to ensure that the transfer is lawful and that appropriate safeguards are in place. Depending on the destination and applicable law, safeguards may include an adequacy decision or recognized equivalent, Standard Contractual Clauses or other approved contractual protections, binding corporate rules, technical and organizational safeguards, or another legally recognized transfer mechanism.

Where a transfer relies on contractual safeguards, we assess the relevant circumstances and seek supplementary measures where appropriate, such as access controls, encryption, pseudonymization, data minimization, and restrictions on onward disclosure. You may contact us using the details below to request further information about applicable transfer safeguards, subject to legal limitations and the protection of confidential information.

Data Retention

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including legal, accounting, security, dispute-resolution, and compliance purposes. Retention periods may vary depending on the type of information, its sensitivity, the purpose of processing, and whether a legal claim or investigation is pending.

Analytics data. Information collected through Google Analytics and Microsoft Clarity is retained according to our configuration, the applicable consent status, operational requirements, and the providers’ retention settings. We seek to use the shortest practical retention period and may aggregate or delete information when it is no longer needed for analysis.
Cookies and similar technologies. Cookies remain for the period stated in our Cookie Policy or until they expire or are deleted. Consent choices may be retained for a reasonable period so that we can remember your decision and avoid repeatedly displaying the consent banner.
Server and security logs. Server, access, error, and security logs are generally retained for a limited period appropriate to operational, troubleshooting, fraud-prevention, and security needs. Longer retention may be necessary to investigate an incident, preserve evidence, or comply with a legal obligation.
Contact and inquiry data. Contact-form submissions, emails, and feedback are retained for as long as reasonably necessary to respond, administer the relationship, improve our services, document decisions, resolve disputes, and protect our legal interests.
DMCA and legal records. Copyright notices, rights complaints, legal correspondence, and related records may be retained for as long as necessary to assess and resolve the matter, demonstrate compliance, preserve evidence, and establish or defend legal claims.
Consent records. Records of consent, withdrawal, and CMP interactions may be retained for as long as necessary to demonstrate compliance, manage preferences, and defend against complaints or claims.
Anonymized information. Information that has been irreversibly anonymized may be retained indefinitely and used for statistical, analytical, security, or business purposes because it is no longer personal data.

Information may remain temporarily in encrypted backups after deletion from active systems. Backup copies are subject to access controls and are overwritten or securely deleted according to our backup cycles. Where a legal hold, investigation, dispute, or regulatory requirement applies, we may preserve relevant information until the matter is resolved, after which it will be deleted or anonymized as appropriate.

Your Rights

Subject to applicable law and any relevant exceptions, you may have the following rights concerning your personal data:

Access. You may request confirmation of whether we process your personal data and obtain a copy of the information, together with relevant information about the processing.
Rectification. You may ask us to correct inaccurate or incomplete personal data.
Erasure. You may ask us to delete personal data where it is no longer necessary, has been unlawfully processed, or another legal ground for deletion applies. This right is not absolute, and we may retain information where required or permitted by law.
Restriction. You may ask us to restrict processing in circumstances permitted by law, such as while the accuracy of information is being contested or where you object to processing based on legitimate interests.
Portability. Where applicable, you may request personal data that you provided to us in a structured, commonly used, and machine-readable format, or ask us to transmit it to another controller where technically feasible and legally required.
Objection. You may object to processing based on legitimate interests, including certain forms of direct or interest-based advertising. You may also object to processing for direct marketing purposes at any time.
Withdrawal of consent. Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
Not to be subject to solely automated decision-making. You may have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal effects or similarly significant effects, subject to applicable exceptions. We do not intend to make decisions about users that produce such effects solely through automated processing in connection with ordinary use of the Website.

These rights may be limited where necessary to protect the rights of others, preserve confidentiality, prevent fraud or abuse, comply with legal obligations, or establish or defend legal claims. We will generally respond to a valid request within one month of receiving it. This period may be extended by up to two additional months where permitted by law because of the complexity or number of requests; if so, we will inform you of the extension and the reasons for it.

Exercising Your Rights and Contacting Us

To exercise a privacy right or ask a question about this Policy, submit a request to [email protected] or write to JR NETMEDIA at Carrer dels Avellaners, Ed. Griu, Pis 5 Pta 3, AD200, AD. You may also contact us by telephone at +376 62 60 15. Please identify the right you wish to exercise, describe the information or processing concerned, and provide sufficient details for us to understand and respond to your request.

For security and privacy reasons, we may ask you to verify your identity before completing a request. Verification may involve confirming information already associated with your communication or providing reasonable supporting information. We will not request excessive information, and we will use verification information only to authenticate the request and protect personal data. If you submit a request through an authorized representative, we may require evidence of that authorization.

If you believe that our processing of your personal data violates applicable law, you may lodge a complaint with the competent supervisory authority. In Andorra, the relevant authority is the Andorran Data Protection Agency (Agència Andorrana de Protecció de Dades, APDA). We nevertheless encourage you to contact us first so that we can investigate and attempt to resolve your concern.

Data Security

We use reasonable technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, and unauthorized access. The measures we use may vary according to the nature and risk of the information and the services involved.

Encryption and secure connections. We use HTTPS and TLS or comparable protections for data transmitted between your browser and the Website where supported by the relevant service.
Access controls. Access to personal data and administrative systems is limited to authorized personnel and providers who need access for legitimate business purposes, with authentication and permissions designed to reduce unnecessary access.
Firewalls and network security. We use network controls, firewalls, monitoring, rate limiting, and other measures intended to detect and prevent unauthorized access, malicious traffic, and service disruption.
Data minimization. We seek to collect, use, and retain only information that is reasonably necessary for the purposes described in this Policy.
Updates and vulnerability management. We seek to maintain current software, apply security updates, monitor systems, and address vulnerabilities in a risk-based manner.
Assessments and reviews. We periodically review our processing activities, provider arrangements, access permissions, and security practices to identify and reduce risks.
Backups and recovery. We maintain backups and continuity measures appropriate to the Website’s operational needs, with access controls and retention practices intended to protect backup data.
Staff and contractor training. Personnel and relevant contractors are expected to handle personal data confidentially and receive appropriate privacy and security guidance.

No method of transmission, storage, or security control is completely secure. We cannot guarantee absolute security, particularly for information transmitted over the internet. If we become aware of a personal-data breach that is required to be notified under applicable law, we will notify the competent authority and affected individuals where legally required, within the applicable timeframes and with the information required by law.

Children's Privacy

The Website is not directed to children under 16, or the applicable local equivalent age where a different age is required by law. We do not knowingly collect personal data from children under that age for independent use of the Website. The Website is an informational app directory and does not require children to create accounts or submit personal data.

If we learn that we have collected personal data from a child below the applicable age without appropriate authorization, we will take reasonable steps to delete the information. If you believe that a child has provided personal data to us, please contact us at [email protected] with sufficient details to allow us to investigate. Parents or legal guardians should also monitor children’s use of the internet and the links provided to external app stores.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to the Website, our advertising or analytics arrangements, applicable law, regulatory guidance, security practices, or the ways in which we process personal data. The updated version will be posted on the Website with a revised “Last updated” date.

Where an update materially changes how we process personal data or affects your rights, we may provide additional notice or request consent where required. Unless a different effective date is stated, changes take effect when posted. Your continued use of the Website after an updated Policy is posted indicates that you have read and understood the updated Policy, subject to any rights you may have under applicable law.

Last updated: 08/25/2026

Contact Us

If you have questions about this Privacy Policy, our processing of personal data, cookies and tracking technologies, advertising, analytics, or your privacy rights, please contact:

JR NETMEDIA
Carrer dels Avellaners, Ed. Griu, Pis 5 Pta 3, AD200
Encamp, Andorra
AD
Email: [email protected]
Phone: +376 62 60 15
Tax or registration number: 927824-G

When contacting us about personal data, please avoid sending sensitive information unless it is necessary for your request. We will handle your communication in accordance with this Privacy Policy and applicable Andorran law.