Privacy Policy

1. Data Controller

This website (jack.otm.ai) is operated by Oglut Srl, a company incorporated in Italy.
VAT IT15766701005
For privacy-related enquiries: privacy@oglut.com

2. Scope — website only

This policy applies exclusively to the jack.otm.ai marketing website. The JACK desktop application runs entirely on your local machine and does not send any usage data, telemetry, or personal information to Oglut Srl or any third party.

3. What data we collect

We collect website analytics data through Google Analytics 4 (GA4) only when you have given your prior consent via the cookie banner. The data collected includes:

• Pages visited and time spent on each page
• Referring website or search query that brought you here
• Approximate geographic location (country / city, derived from a truncated IP address)
• Device type, operating system, and browser
• Session and user identifiers stored in cookies (see Cookie Policy)

We do not collect your full IP address, name, email address, or any information that directly identifies you.

4. Legal basis (GDPR)

We process analytics data on the basis of your freely given, specific, informed consent (GDPR Art. 6(1)(a)). You may withdraw consent at any time by clicking "Reject Non-Essential" in the cookie banner, or by clearing your browser cookies and choosing to reject when the banner reappears.

5. Data processor — Google Analytics 4

Analytics data is processed by Google LLC (or Google Ireland Limited for EEA users) acting as our data processor under a Data Processing Agreement. Google may transfer data to servers outside the EEA; such transfers are covered by Standard Contractual Clauses. For details see Google's Privacy Policy and Google Analytics data safeguards.

6. Data retention

Analytics data is retained for 14 months in Google Analytics (the default GA4 retention setting), after which it is automatically deleted. The cookie that stores your consent preference (jack_cookie_consent) is stored in your browser's localStorage until you clear it.

7. Your rights

Under the GDPR you have the right to:

• Access — request a copy of any personal data we hold about you
• Rectification — ask us to correct inaccurate data
• Erasure — ask us to delete your data ("right to be forgotten")
• Restriction — ask us to restrict processing in certain circumstances
• Objection — object to processing based on legitimate interests
• Portability — receive your data in a structured, machine-readable format
• Withdraw consent — at any time, without affecting the lawfulness of prior processing

To exercise any of these rights, email privacy@oglut.com. We will respond within 30 days.

You also have the right to lodge a complaint with your national data protection authority.

8. Cookies

For a full list of cookies used on this website and how to manage them, see our Cookie Policy.

9. Changes to this policy

We may update this policy from time to time. Material changes will be announced by updating the "Last updated" date at the top of this page. We encourage you to review this page periodically.