1. Introduction
JustNewMe ("we," "us," or "our") is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and protect your information in compliance with Indonesia's Personal Data Protection Law (UU No. 27/2022) ("UU PDP").
2. Data We Collect
We collect the following categories of data:
- Wallet Address: Your Solana public key, collected when you connect your wallet. This serves as your unique identifier on the platform.
- Behavioral Data: Game scores, article reading history, AI companion chat history, reflection entries, XP/progress data, and Risk Rating results.
- Onboarding Responses: Answers to the risk assessment questionnaire submitted during account creation.
- Technical Data: Device type, browser, IP address, and platform usage analytics (collected via standard server logs).
We do NOT collect: Private keys, seed phrases, wallet passwords, financial account information, or real-name identification data.
3. Purpose of Data Collection
We collect and use your data for the following purposes:
- Creating and managing your user account
- Tracking your behavioral progress and XP
- Providing personalized AI companion coaching
- Generating behavioral insights and pattern recognition
- Issuing Soulbound Credentials (SBTs) as proof of milestones
- Improving platform functionality and user experience
- Communicating with you about your account or platform updates
4. Legal Basis for Processing
Under UU PDP, our legal basis for processing your personal data is consent. You provide consent when you agree to this Privacy Policy during the wallet connection flow. You may withdraw your consent at any time by disconnecting your wallet and requesting data deletion.
5. Data Retention
We retain your personal data for as long as your account is active. If you request account deletion, we will delete or anonymize your data within 30 days, except where retention is required by applicable law. On-chain SBTs on the Solana blockchain cannot be deleted by JustNewMe once minted — you control your own wallet.
6. Data Sharing
We do not sell, rent, or trade your personal data. We may share data with:
- Supabase: Our database provider, used to store user profiles, chat history, and progress data. They are obligated to handle your data securely and in accordance with our instructions.
- Solana RPC Providers: Infrastructure providers (such as Helius or QuickNode) used to read wallet and on-chain data. Data handled per their own privacy policies.
- AI API Providers: MiniMax (for AI companion responses) and Anthropic — chat messages are processed for AI generation only.
- Legal Requirements: We may disclose data if required by Indonesian law, court order, or governmental authority.
7. Data Security
We implement reasonable technical and organizational security measures to protect your data against unauthorized access, alteration, disclosure, or destruction. These include encryption in transit (HTTPS), access controls on our database, and secure storage practices. No system is 100% secure — we encourage users to also protect their own wallet security.
8. Your Rights Under UU PDP
As a user, you have the following rights:
Access
Request a copy of all personal data we hold about you.
Correction
Request correction of inaccurate or incomplete personal data.
Deletion
Request deletion of your account and associated personal data ("Right to be Forgotten").
Withdrawal of Consent
Withdraw consent at any time. Note: this may result in loss of access to your account.
Data Portability
Request your data in a structured, machine-readable format.
Object to Processing
Object to processing of your data for specific purposes.
9. Cookies & Tracking
JustNewMe uses minimal browser cookies for authentication and session management only. We use standard server analytics to understand aggregate platform usage. We do not use third-party advertising cookies or tracking pixels.
10. Third-Party Links
The JustNewMe platform may contain links to external websites or services not operated by us. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you use.
11. Children's Privacy
JustNewMe is not intended for users under the age of 18. We do not knowingly collect personal data from minors. If we become aware that data has been collected from a minor, we will take steps to delete that data.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify users of material changes by posting the updated policy on this page and updating the "Last updated" date. Continued use of the platform constitutes acceptance of the updated policy.
13. Contact Us
To exercise your data rights or to make any privacy-related inquiries:
Email: privacy@justnewme.com
Response Time: We aim to respond to all privacy requests within 14 days under UU PDP requirements.