Privacy Policy

Last updated: February 19, 2026

1. Data Controller

The data controller responsible for processing your personal data is:

RJ DIGITAL HUB (trading as Undercover Lab)
NRT: L-713047-Z
C/ de la Sardana 3, altell escala B
AD500 Andorra la Vella, Principat d’Andorra
General enquiries: social@continuumreader.app
Data Protection Officer: dpo@undercoverlab.com

This Privacy Policy is governed by the Llei 29/2021, del 28 d’octubre, qualificada de protecció de dades personals (LQPD) of the Principality of Andorra, and, where applicable, by the General Data Protection Regulation (EU) 2016/679 (GDPR).

2. Data Processed by the Continuum App

Continuum is designed with privacy as a core principle. The App does not collect, store, or transmit any personal data to our servers or to third parties. Specifically:

  • No account creation or login is required.
  • No names, email addresses, or personally identifiable information is collected.
  • No reading or listening habits are tracked.
  • No analytics, crash reporting, or tracking SDKs are integrated in the App.

All data generated by the App (imported books, audiobooks, reading positions, settings, and sync configurations) is stored exclusively on your device. The files you import into Continuum (EPUB, MP3, M4B) remain on your device and are processed locally to provide the App’s functionality.

3. Data Processed by This Website

This website (continuum.undercoverlab.com) uses the following services that may process personal data:

  • Google Tag Manager & Google Analytics 4 — We use Google Analytics to understand how visitors interact with our website (pages visited, session duration, approximate geographic region, device type). Google Analytics uses cookies to collect this information in an aggregated and anonymised manner. IP addresses are anonymised before storage. The legal basis is your consent (Art. 6 LQPD).
  • Google Ads — We may use Google Ads conversion tracking and remarketing cookies to measure the effectiveness of our advertising campaigns and to show you relevant ads on Google’s network. The legal basis is your consent (Art. 6 LQPD).
  • Meta Pixel (Facebook) — We may use the Meta Pixel to measure advertising effectiveness, build targeted audiences, and optimise ad delivery on Meta platforms (Facebook, Instagram). The legal basis is your consent (Art. 6 LQPD).

If you decline non-essential cookies, no analytics or advertising data is collected. For a detailed breakdown of each cookie, see our Cookie Policy.

4. Purchases

Purchases are handled exclusively by Apple through the App Store and StoreKit. We do not process, store, or have access to any payment information. Apple’s own privacy policy governs purchase transactions. For more information, see Apple’s Privacy Policy.

5. Legal Basis for Processing

Where personal data is processed, the legal bases are:

  • Consent (Art. 6 LQPD) — for analytics cookies on this website. You may withdraw consent at any time by clearing cookies or adjusting your preferences via the cookie banner.
  • Legitimate interest (Art. 6 LQPD) — for basic website operation and security (e.g., server logs maintained by our hosting provider).

6. Cookies

This website uses cookies grouped into three categories: essential (strictly necessary), analytics, and advertising. When you first visit, a consent banner allows you to accept or decline non-essential cookies. You may change your preferences at any time. For a full list of cookies, their providers, purposes, and durations, see our Cookie Policy.

7. International Data Transfers

If you consent to analytics cookies, data collected by Google Analytics may be transferred to Google servers located outside the Principality of Andorra and the European Economic Area. Google LLC adheres to the EU–US Data Privacy Framework, and Google’s data processing terms include Standard Contractual Clauses as safeguards. For more information, see Google’s data transfer frameworks.

The Continuum App does not perform any international data transfers, as no data leaves your device.

8. Data Retention

  • App data — Stored on your device for as long as you keep the App installed. Uninstalling the App deletes all local data.
  • Analytics data — Google Analytics data is retained for 14 months, after which it is automatically deleted. Aggregated reports may be retained indefinitely.
  • Server logs — Basic access logs maintained by our hosting provider are retained for up to 30 days.

9. Your Rights

Under the LQPD (Llei 29/2021), you have the following rights regarding your personal data:

  • Right of access (Art. 18) — To know whether we are processing your data and to obtain a copy.
  • Right to rectification (Art. 19) — To correct inaccurate or incomplete data.
  • Right to erasure (Art. 20) — To request the deletion of your data when it is no longer necessary for the purposes for which it was collected.
  • Right to restriction of processing (Art. 22) — To request the limitation of processing under certain circumstances.
  • Right to data portability (Art. 23) — To receive your data in a structured, commonly used and machine-readable format.
  • Right to object (Art. 24) — To object to the processing of your data.
  • Digital rights guarantee (Art. 21) — Data protection of natural persons applies fully to the digital environment.

To exercise any of these rights, contact our Data Protection Officer at dpo@undercoverlab.com. We will respond within one month of receiving your request. If we cannot fulfil your request, we will provide a reasoned explanation.

Since the Continuum App collects no personal data, most of these rights apply primarily to data processed through this website (analytics cookies).

10. Right to Lodge a Complaint

If you consider that the processing of your personal data infringes the LQPD, you have the right to lodge a complaint with the Andorran Data Protection Agency (APDA):

Agència Andorrana de Protecció de Dades (APDA)
Website: www.apda.ad
C/ Prat de la Creu 59-65, Esc. A, 3r pis
AD500 Andorra la Vella, Principat d’Andorra

11. Third-Party Services

The Continuum App does not integrate any third-party services, SDKs, or APIs. The App operates entirely offline and does not make network requests except for purchase verification through Apple’s StoreKit (managed by iOS, not by our code).

This website integrates Google Tag Manager and Google Analytics 4, subject to your cookie consent.

12. Children’s Privacy

Continuum does not collect personal information from anyone, including children under 14 years of age. If you are under 14 in Andorra (or under the applicable age in your jurisdiction), please ask a parent or guardian before using this website with analytics cookies enabled.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically.

14. Contact

If you have questions about this Privacy Policy or wish to exercise your data protection rights, contact us at:

RJ DIGITAL HUB (Undercover Lab)
social@continuumreader.app
C/ de la Sardana 3, altell escala B
AD500 Andorra la Vella, Principat d’Andorra