01 Introduction
This Privacy Policy explains how cje, operated by cje — Consiliul Județean al Elevilor ("we", "our", or "us"), collects, uses, stores, and protects personal information when users access the cje mobile application (the "App").
The App is designed to support student representation, communication, and access to county-level information. We aim to collect only the minimum personal information necessary for account creation and basic app functionality.
A dedicated Account and Data Deletion section is included below to explain how users, parents, legal guardians, or authorized representatives can request deletion of an account or associated personal data.
02 Data Controller
For the purposes of this Privacy Policy, the data controller is cje — Consiliul Județean al Elevilor, Romania.
Privacy-related questions and requests can be submitted by email at app.consiliulelevilor@gmail.com or by phone at +40 784 953 870.
03 Information We Collect
We collect only the minimum information needed to create and manage a user account in the App. The personal information collected is provided directly by the user during registration or account use.
We collect:
- First name and last name — used to identify the user account.
- Email address — used as the account login identifier and for account-related identification.
- Selected county / regional affiliation — used to associate the user account with the appropriate county-level content and regional section of the App. This is provided manually by the user and is not collected from the device’s GPS, network location, or background location services.
We do not collect:
- Device location collected from GPS, network location, or background location services
- Contacts, phone book, call logs, or SMS data
- Camera, microphone, photos, videos, or media files
- Payment, billing, card, banking, or transaction information
- Advertising identifiers
- Analytics data, behavioural tracking data, profiling data, or heatmap data
- Health data, biometric data, or government identification numbers
04 App Permissions
The App does not request or use permissions for device location, contacts, camera, microphone, phone calls, SMS, external storage, photos, videos, or payment/billing access.
If future versions of the App require additional permissions, this Privacy Policy and the Google Play Data Safety information will be updated before or at the time such features are released.
05 How We Use Your Information
We use the information collected only for the following purposes:
- To create and maintain the user account.
- To identify the user inside the App where account identification is necessary.
- To associate the account with the correct county-level content and regional section of the App.
- To respond to privacy, account, support, or deletion requests submitted by the user, parent, guardian, or authorized representative.
- To maintain the basic security and integrity of the App.
The App does not use personal information for automated decision-making, scoring, behavioural profiling, or decisions that produce legal or similarly significant effects.
We do not use personal information for marketing emails, promotional messages, behavioural advertising, remarketing, retargeting, or selling or renting user data.
06 No Ads, Tracking, Analytics, or Payments
The App does not display advertisements and does not use advertising SDKs.
The App does not use analytics, behavioural tracking, heatmap, remarketing, retargeting, customer profiling, or advertising tools. This includes, but is not limited to, Google Analytics, Firebase Analytics, Facebook SDK, AdMob, Mouseflow, Freshdesk, reCAPTCHA, and Google Places.
The App does not allow users to purchase products or services and does not collect payment, billing, card, banking, or transaction information.
07 Service Providers and Data Sharing
The App uses Supabase for authentication and database storage. Supabase processes personal information only as necessary to provide the App’s core functionality, such as account creation, authentication, secure database storage, security, and maintenance.
This service is not used for advertising, behavioural tracking, remarketing, or profiling.
We do not sell, rent, or share personal information for advertising or commercial resale.
We may disclose personal information only if:
- it is necessary to operate, secure, or maintain the App;
- it is required by applicable law or a competent authority;
- it is necessary to protect the rights, safety, or security of users or the organization;
- it is necessary to process an account deletion or data deletion request.
08 Data Retention
We retain personal information only for as long as the user account remains active or as long as necessary for the purposes described in this Privacy Policy.
If an account is deleted or a deletion request is received, we will delete the associated personal data within 30 days, unless limited retention is required by applicable law.
Where retention is required by law or reasonably necessary to address a security, integrity, or legal issue, the retained information will be limited to what is necessary for that purpose.
09 Account and Data Deletion
Users may request deletion of their cje account and associated personal data at any time. Deleting an account means deleting the personal data associated with that account, unless limited retention is required by applicable law.
Deletion requests can be submitted by contacting us at:
Email:
app.consiliulelevilor@gmail.com
Phone:
+40 784 953 870
To help us identify the account, the request should include the email address used for the cje account. Parents, legal guardians, or authorized representatives may also request deletion of a minor’s account.
We will process deletion requests within 30 days, unless a longer retention period is required by applicable law. Temporary account deactivation, suspension, or disabling is not considered account deletion.
The App provides a readily discoverable in-app path for account deletion or account deletion requests through the account or privacy settings.
10 GDPR and Rights of EEA and UK Users
If you are located in the European Economic Area, the United Kingdom, or another jurisdiction with similar data protection rights, you may have certain rights regarding your personal data.
Depending on the circumstances, these rights may include:
- the right to access the personal data we hold about you;
- the right to correct inaccurate or incomplete personal data;
- the right to request deletion of your personal data;
- the right to restrict or object to certain processing;
- the right to data portability, where applicable;
- the right to withdraw consent where processing is based on consent;
- the right to lodge a complaint with a competent data protection authority.
The legal bases for processing personal data are:
- performance of requested app functionality, where processing is necessary to create and maintain the user account and provide county-level app content;
- consent, where consent is required by applicable law, including where a minor’s use of the App requires parent, guardian, or legally valid educational authorization;
- legitimate interests, limited to maintaining the security, integrity, and basic operation of the App;
- legal obligation, where we are required to comply with applicable law or a competent authority.
Where personal data is processed on the basis of consent, consent may be withdrawn at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.
To exercise your rights, contact us using the details in the Contact section.
In Romania, the relevant supervisory authority is the National Supervisory Authority for Personal Data Processing (ANSPDCP).
11 California Privacy Notice (CCPA / CPRA)
To the extent the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), applies, California residents may have certain privacy rights regarding their personal information.
Categories of personal information collected:
- Identifiers, such as first name, last name, and email address.
- Geolocation-related information at county level only, meaning the user-selected county or regional affiliation. The App does not collect precise location, GPS data, or background location data.
- Account information, limited to the information needed to create and maintain the cje account.
Sources of personal information:
- Directly from the user during account registration or account use.
Purposes for collection:
- Account creation and management.
- County-level app functionality.
- Responding to account, support, privacy, or deletion requests.
- Maintaining the security and integrity of the App.
- We do not sell personal information.
- We do not share personal information for cross-context behavioural advertising.
- We do not use personal information for targeted advertising.
- We do not knowingly sell or share the personal information of users under 16.
- We do not collect sensitive personal information as defined by the CPRA, such as precise geolocation, government identification numbers, financial account information, biometric information, health information, or racial, ethnic, religious, or union membership information.
California residents may request access, correction, or deletion of their personal information by contacting us using the details in the Contact section. We will not discriminate against users for exercising their privacy rights.
12 CalOPPA Notice
In accordance with the California Online Privacy Protection Act (CalOPPA), this Privacy Policy:
- identifies the categories of personal information collected by the App;
- explains how that information is used;
- explains how users can contact us to review, correct, or delete their information;
- includes the effective date and last updated date of the policy;
- is accessible through a clearly labeled Privacy Policy link.
The App does not track users across third-party websites or online services.
The App does not respond to browser "Do Not Track" signals because the App does not engage in cross-site behavioural tracking.
We do not allow third parties to collect personally identifiable information about users’ online activities over time and across different websites or online services through the App.
13 Children’s and Minors’ Privacy
The App is intended for use in a student representation context and may be used by students and minors. Users under the age of 13 may use the App only where permitted by applicable law and only with the required consent, supervision, or authorization.
We collect only the minimum information needed for account creation and basic use of the App: first name, last name, email address, and selected county / regional affiliation.
We do not collect children’s device location data, contacts, camera data, microphone data, photos, videos, payment data, advertising identifiers, behavioural tracking data, analytics data, health data, biometric data, or government identification numbers.
Users under the age of 13 may use the App only with consent and supervision from a parent or legal guardian, or with authorization from an educational institution or authorized educational representative where such authorization is legally valid and applicable.
Where applicable law requires parental or guardian consent, we do not knowingly allow a child under 13 to create or use an account without such consent or authorization.
Parents and legal guardians may contact us at any time to request access to, correction of, or deletion of a child’s personal information. If we become aware that personal information from a child under 13 has been collected without appropriate consent or authorization where required, we will delete that information within a reasonable period.
14 International Data Transfers
If personal information is processed or stored by service providers located outside Romania or the European Economic Area, we aim to ensure that appropriate safeguards are used in accordance with applicable data protection law.
The public Privacy Policy page itself may be hosted by a third-party hosting provider. This page is used only to make the Privacy Policy publicly accessible and does not collect app account data by itself.
15 Data Security
We use reasonable technical and organizational measures to protect personal information against unauthorized access, alteration, disclosure, loss, or misuse.
Where personal information is transmitted between the App and backend infrastructure, it is transmitted using secure communication methods, such as HTTPS or equivalent modern encryption.
Access to personal information is limited to persons or service providers who need it to operate, maintain, secure, or support the App.
However, no method of electronic transmission or storage is completely secure. For this reason, we cannot guarantee absolute security, but we aim to limit the data collected and protect it appropriately.
16 Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we update it, we will revise the "Last updated" date at the top of the page.
Material changes will be reflected on this page. Users are encouraged to review this Privacy Policy periodically. Continued use of the App after an update means that the updated Privacy Policy applies to future use of the App.
17 Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy, your account, or your personal data, contact us at:
cje — Consiliul Județean al Elevilor
Email: app.consiliulelevilor@gmail.com
Phone: +40 784 953 870
Country: Romania
Privacy requests may include access, correction, deletion, account deletion, or questions about a minor’s personal data.