Privacy Policy
Last updated: 18 June 2026
1. Who is responsible for your data (Data Controller)
The data controller for the Loadia mobile application ("Loadia", "the app", "we", "us") is:
- Init Consulting
- Head office: 11 passage Marivaux, 77185 Lognes, France
- SIRET 913 339 362 00018
- Registered with the RCS of Meaux, SIREN 913 339 362
- Intra-community VAT: FR25913339362
- Share capital: €250
- Represented by: Chedli Ben Hassine
- Contact / data protection requests: contact@initconseil.com
We have not appointed a formal Data Protection Officer (DPO); privacy requests are handled by the contact above.
2. Scope and our privacy-first design
Loadia is built local-first: by default, your library, diary, ratings, reviews, lists and preferences are stored only on your device and are not transmitted to us or to any third party. We run no third-party analytics and no cross-app tracking, and we never sell your data. The free tier does show ads (see the Advertising section below); Loadia Plus removes them.
Some processing is unavoidable and is described below (for example, an in-app purchase is handled by Apple). If and when you opt into cloud sync or a cloud account, the additional processing described in Section 5 applies.
3. What personal data we process
| Data | Where it is stored | When |
|---|---|---|
| Account profile: display name, username, optional bio, optional email | On your device | When you create an account |
| Your activity: library, diary, ratings, reviews, lists, wishlist, likes, comments | On your device | As you use the app |
| App preferences: theme, notification settings | On your device | As you use the app |
| Profile picture / banner image (if you choose one) | On your device | If you set one |
| Purchase status (whether you have Loadia Plus) | On your device + Apple / RevenueCat | If you subscribe |
We do not process special-category data, location data, contacts, or biometric data. We do not knowingly collect data from children (see Section 12).
4. Purposes and lawful bases (Article 6 GDPR)
| Purpose | Lawful basis |
|---|---|
| Provide the core app (store and display your library and activity on your device) | Performance of a contract (Art. 6(1)(b)) |
| Process a Loadia Plus subscription | Performance of a contract (Art. 6(1)(b)); payment is handled by Apple |
| Cloud sync / cloud account (when enabled by you) | Your consent (Art. 6(1)(a)) and/or performance of a contract |
| Keep the app secure and prevent abuse | Our legitimate interest (Art. 6(1)(f)) |
We do not profile you or use your library or activity for advertising. The free tier does show ads, served via Google AdMob, as described in the Advertising section below.
5. Recipients and processors
We share personal data only with the processors strictly needed to run the app:
- Apple (App Store / StoreKit), processes your purchase of Loadia Plus. Apple is the merchant of record. See Apple's privacy policy.
- RevenueCat, Inc. (USA), manages subscription entitlements on our behalf. It receives a pseudonymous app user ID and purchase events, not your name or library.
- Game artwork CDN (IGDB / Twitch), game cover and hero images are loaded from a third-party image CDN. It necessarily receives your device IP address and which game's artwork is requested. No account, library, or profile data is sent there.
- Google (AdMob) serves ads in the free tier and, subject to your consent, may use your advertising identifier for personalised ads and measurement (see the Advertising section below). Google acts as an independent controller for the advertising data it collects.
- Cloud account provider (when cloud sync is enabled): Supabase, see Section 10. Until cloud sync is offered, no account data leaves your device.
- Website host for our legal pages: Vercel Inc. (340 S Lemon Ave #4133, Walnut, CA 91789, USA), hosts only these public documents, not app data.
We never sell your personal data.
6. Advertising
The free tier shows ads served by Google AdMob. With your consent, AdMob may use your advertising identifier to show more relevant (personalised) ads and to measure them. If you decline, via the consent prompt or iOS App Tracking Transparency, you still see ads, but non-personalised ones. You can remove ads entirely with a Loadia Plus subscription. Google acts as an independent controller for the advertising data it collects; see Google's privacy policy.
7. International transfers
Apple, RevenueCat and Google may process limited data in the United States. Transfers outside the EU rely on appropriate safeguards (Standard Contractual Clauses and/or the EU-US Data Privacy Framework). When cloud sync launches, we will host account data in the EU region (see Section 10).
8. Retention
- Data on your device is kept until you delete it, delete your account, or uninstall the app.
- Purchase records are retained by Apple/RevenueCat per their policies and applicable accounting law.
- Cloud account data (when applicable) is deleted within 30 days of account deletion.
9. Your rights (Articles 15-22 GDPR)
You have the right to: access, rectification, erasure ("right to be forgotten"), restriction, data portability, and objection, and to withdraw consent at any time.
Because Loadia is local-first, you can exercise most of these directly in the app:
- Access / portability: Settings → Export my data (machine-readable JSON).
- Erasure: Settings → Delete account (permanently removes your account and all on-device data).
- Rectification: edit your profile and entries at any time.
For any other request, contact contact@initconseil.com. We respond within one month (Art. 12 GDPR).
10. Cloud sync / cloud accounts (forthcoming)
When you opt into cloud sync, your account and activity will be stored with our processor Supabase in an EU data centre, protected by encryption in transit (TLS) and at rest, and by row-level security so only you can access your data. Passwords are never stored by us in readable form, authentication is handled by the provider using salted hashing. This section becomes active only if and when you enable cloud sync, and this policy will be updated before that feature ships.
11. Security
We protect your data with measures appropriate to the risk: local storage on your device, TLS for any network calls, no third-party trackers, and (for cloud accounts) encryption at rest and strict access controls. No method is 100% secure, but we work to keep your data safe.
12. Children
Loadia is intended for users aged 13 and over and is not directed at younger children. In France, users under 15 (the digital-consent age) need a parent's or guardian's consent.
13. Right to lodge a complaint
If you believe your data-protection rights have been infringed, you may lodge a complaint with the French supervisory authority:
CNIL, Commission Nationale de l'Informatique et des Libertés, 3 Place de Fontenoy, TSA 80715, 75334 Paris Cedex 07, France, www.cnil.fr
14. Changes to this policy
We may update this policy. Material changes will be notified in the app before they take effect, and the "Last updated" date above will change.
15. Contact
Questions or requests: contact@initconseil.com
Init Consulting, 11 passage Marivaux, 77185 Lognes, France.