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Privacy Policy

Last updated: June 11, 2026

1. Introduction

Napoleon is a product of Average Joe Technology OÜ ("we", "our", or "us"). We respect your privacy and are committed to protecting your personal data. This privacy policy explains how we collect, use, and protect your information when you visit this website, request early access, or use the Napoleon platform.

We are based in Estonia and operate under EU GDPR regulations.

2. Data Controller

Company: Average Joe Technology OÜ (registered in Estonia)

Website: https://www.averagejoe-technology.com

Email: [email protected]

3. Data We Collect

Information you provide:

  • Account information: Name, email address, and profile details when you create an account or request early access
  • GitHub identity: Your GitHub username, email, and avatar when you sign in with GitHub or connect the GitHub integration
  • Workspace content: Projects, issues, comments, and other content you create in the platform
  • Communications: Messages you send us by email

Information collected automatically:

  • Technical data: IP address, browser type, device information
  • Usage data: Pages visited, features used, interaction patterns
  • Error and diagnostics data: Crash reports and performance data collected through error monitoring tools (Sentry) to keep the service reliable
  • Cookies: Session and preference cookies (see our Cookie Policy)

4. Legal Basis for Processing

We process your personal data under the following legal bases:

  • Contract performance: To provide the Napoleon platform and fulfil agreed-upon services
  • Legitimate interests: To respond to your inquiries, secure and improve our services, and prevent abuse
  • Consent: For marketing communications and non-essential cookies
  • Legal obligation: To comply with applicable laws and regulations

5. How We Use Your Data

  • Provide, operate, and maintain the Napoleon platform
  • Process early-access requests and manage your account
  • Respond to your inquiries and provide customer support
  • Monitor errors and improve performance, reliability, and usability
  • Send service-related communications
  • Comply with legal obligations
  • Protect against fraud and security threats

6. Data Sharing and Disclosure

We do not sell your personal data. We may share your information only in these limited circumstances:

  • Service providers: Trusted third parties who assist with our operations, such as hosting, email delivery, and error monitoring
  • GitHub: When you connect the GitHub integration, data is exchanged with GitHub according to the permissions you grant; GitHub's own privacy policy applies to its processing
  • Legal requirements: When required by law or to protect our rights
  • Business transfers: In the event of a merger or acquisition
  • With your consent: When you explicitly agree to sharing

7. Data Retention

We retain your personal data only as long as necessary:

  • Account data: For the duration of your account, then deleted or anonymized within 90 days of account closure
  • Contact inquiries: 3 years from last contact
  • Billing and contractual records: 7 years (tax and accounting requirements)
  • Error and diagnostics data: Up to 90 days
  • Marketing data: Until you opt out or 3 years of inactivity

8. Your Rights

Under GDPR, you have the following rights:

  • Access: Request copies of your personal data
  • Rectification: Correct inaccurate personal data
  • Erasure: Request deletion of your personal data
  • Restriction: Limit how we process your data
  • Portability: Transfer your data to another service
  • Objection: Object to processing based on legitimate interests
  • Withdraw consent: Revoke consent for processing

To exercise these rights, contact us at [email protected].

9. Data Security

We implement appropriate security measures, including:

  • SSL/TLS encryption for data transmission
  • Access controls and authentication procedures
  • Regular security assessments and updates
  • Data backup and recovery procedures

10. International Transfers

We primarily process data within the EU. Any transfers outside the EU (for example, to service providers such as GitHub or Sentry) are protected by appropriate safeguards, such as Standard Contractual Clauses or adequacy decisions.

11. Children's Privacy

Our services are not directed to children under 16. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately.

12. Changes to This Policy

We may update this privacy policy to reflect changes in our practices or applicable laws. We will notify you of significant changes by posting the updated policy on this website.

13. Contact Us

If you have questions about this privacy policy or our data practices, please contact us:

Legal and privacy matters: [email protected]

General inquiries: [email protected]

Address: Average Joe Technology OÜ (registered in Estonia)

You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate if you believe we have violated your privacy rights.

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Privacy Policy · Napoleon