Privacy Policy
Last updated: 5 August 2025
1. Purpose and legal basis of processing
We process personal data of users for the following purposes:
- Authentication and user session
We use JSON Web Token (JWT) and refresh tokens to securely manage access to protected services. The legal basis is the execution of a contract (Art. 6(1)(b) GDPR) or the legitimate interest of the Controller to ensure account security (Art. 6(1)(f) GDPR).
- Website analytics
With Google Analytics we collect anonymous information about website traffic and user behavior (pages visited, time spent, geographic origin). The legal basis is explicit consent (Art. 6(1)(a) GDPR), given via the cookie banner.
2. Types of data collected
- Authentication data: email, username and hashed password (we do not store plain‐text passwords); JWT and refresh tokens.
- Navigation data (Google Analytics): anonymized IP address, entry/exit page, session duration, referral parameters, operating system and browser.
3. Processing methods and retention
Data are processed using IT and telematic tools; we implement appropriate technical and organizational measures to ensure security, confidentiality, and integrity:
- JWTs have a limited lifespan (e.g. 15 minutes) and are renewed via a refresh token valid for a longer period (e.g. 7 days), both signed with a secret key.
- Authentication logs are retained for up to 6 months for security monitoring and analysis.
- Google Analytics data are stored according to Google’s settings (typically 14 months) and anonymized (IP masked).
4. Cookies and similar technologies
- Technical cookies
Necessary for authentication (e.g. session persistence).
- Third-party cookies
Google Analytics cookies used for statistical purposes; no personally identifiable information is collected without consent.
5. Data subject rights
Under Articles 15-22 GDPR, you may at any time:
- Obtain confirmation of the existence of your data and access them.
- Request correction, restriction of processing, or deletion (“right to be forgotten”).
- Object to processing for legitimate reasons or withdraw consent.
- Request data portability (e.g. export of profile and settings).
Requests should be sent to privacy@psmjourney.com. We will respond within 30 days.
6. Data recipients
Data may be shared with:
- ICT service providers (hosting, server maintenance).
- Google Ireland Ltd. for Google Analytics, under a data processing agreement.
We do not disclose data to third parties for marketing purposes without prior consent.
7. Transfers outside the EU
Google Analytics data may be transferred to the USA based on the EU Standard Contractual Clauses approved by the European Commission.
8. Security
We implement:
- Secure HTTPS/TLS connections.
- JWT encryption and signature.
- Access controls and permissions.
- System log monitoring.
9. Changes to this policy
We may update this policy at any time. Please review it periodically for changes.
Data Controller
Vincenzo Raffa - privacy@psmjourney.com
