Privacy Policy

1. Scope and Updates to This Privacy Policy

This Privacy Policy applies to personal information processed by ROUVEO LTDA ("Rouveo," "we," "us," or "our"), including on our websites, mobile applications ("apps"), and other online or offline offerings. To make this Privacy Policy easier to read, our websites, apps, and other offerings are collectively referred to as the "Services."

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes, we will notify you as required by applicable law. Your continued use of our Services after any changes constitutes your acceptance of the updated Privacy Policy.

2. Personal Information We Collect

The types of personal information we collect depend on how you interact with us and our Services. Generally, we collect information you provide directly, information collected automatically, and information from third-party sources.

A. Information You Provide to Us Directly

We may collect personal information that you choose to provide to us.

• Profile Information. You may create a display name or other profile details within our apps. This information is stored locally on your device unless you use features that share it with other users.
• Interactive Features. If our Services include social or interactive features (such as messaging, chat, comments, or forums), we may collect personal information that you submit or make available through these features. Any information you share through public features will be considered "public" and is not subject to the privacy protections in this policy. Please exercise caution before revealing any personally identifying information to other users.
• Your Communications with Us. We may collect personal information such as your name and email address when you contact us for customer or technical support, or otherwise communicate with us.
• Surveys. We may contact you to participate in surveys to help us improve our Services. If you choose to participate, we may collect personal information from you in connection with the survey.
• Job Applications. We may post job openings on our websites. If you apply for a position, we may collect your name, email address, resume/CV, cover letter, and any other information you provide in your application.

B. Information Collected Automatically

We collect certain information automatically when you use our Services. This helps us operate, improve, and protect our Services.

• Device Information. We may collect your IP address, device identifiers (such as advertising ID), device model, operating system version, browser type, language settings, and app version.
• Usage Data. We may collect information about how you interact with our Services, such as features used, pages visited, session duration, and in-app events.
• Approximate Location. We derive approximate location (country or region level) from your IP address for analytics purposes. We do not collect precise GPS location.
• Diagnostic Data. If our Services crash or encounter an error, we may collect diagnostic information to help identify and fix issues.
• Purchase and Transaction History. When you make a purchase or subscribe through our Services, we may receive information about your transaction from the platform provider (such as Apple), including what was purchased, when, and your subscription status. We do not receive or store your payment card information.
• Cookies and Similar Technologies. Our websites may use cookies, pixel tags, and similar technologies to collect information about your browsing activity. See Section 7 (Cookies and Similar Technologies) for more details.

C. Information We Do NOT Collect

We want to be clear about data we do not collect:

• We do not collect your real name, phone number, or physical address (unless you provide it to us directly, such as when applying for a job).
• We do not collect or store payment card information (subscriptions and purchases are processed entirely by Apple).
• We do not collect precise GPS location.
• We do not access your contacts, calendar, or other personal data on your device without your explicit permission.

D. Information Collected with Your Permission

Depending on the features you use, we may request access to:

• Camera. To allow you to capture photos for use within the app.
• Photo Library. To allow you to import images for use within the app.
• Microphone. To enable voice-related features, if applicable.

These permissions are optional. You can deny or revoke them at any time through your device settings, though this may limit certain features.

E. Information from Third-Party Sources

We may obtain information about you from third-party sources, such as:

• App Stores. If you download our apps through Apple's App Store, we may receive certain information related to your download and subscription status.
• Third-Party Login Services. If we offer login through third-party services (such as Apple, Google, or Facebook) in the future, we may collect information from those services that you have made available via your privacy settings.

3. How We Use Your Information

We use your personal information to operate our Services, improve your experience, display advertising, and protect our users.

A. Provide Our Services

We use your information to fulfill our contract with you and provide our Services, such as:

• Managing your information and app progress
• Providing access to features and functionalities of our Services
• Processing subscriptions through Apple's in-app purchase system
• Answering requests for customer or technical support
• Communicating with you about your account or policy changes

B. Administrative Purposes

We use your information for various administrative purposes, such as:

• Improving, upgrading, and enhancing our Services
• Developing new products and features
• Detecting security incidents and protecting against malicious, deceptive, or fraudulent activity
• Debugging to identify and repair errors
• Measuring interest and engagement in our Services
• Enforcing our agreements and policies
• Complying with our legal obligations

C. Advertising

We may display advertisements to users on the free plan. We currently use non-personalized ads, which do not use your personal data for ad targeting. However, advertising partners may still collect certain information for purposes such as frequency capping, aggregated reporting, and fraud prevention.

D. Marketing Communications

If you sign up for our newsletter or provide your email address to us, we may send you promotional communications about our Services. You can opt out of marketing emails at any time by using the unsubscribe link in the email or by contacting us. Note that even if you opt out of marketing communications, we may still send you non-promotional messages, such as those related to your account or our ongoing business relationship.

E. Job Applications

If you apply for a job with us, we use your information to evaluate your application and communicate with you about the hiring process.

F. Automated Decision Making

We may use automated systems to personalize your experience, such as recommending content or adjusting gameplay. These automated decisions are made to improve our Services and your experience.

If we make any automated decisions that have a significant legal or similar effect on you, we will ensure that a human is involved in the process, unless otherwise permitted by law or you have provided your consent. If you have questions about our automated decision making, please contact us.

G. De-identified and Aggregated Information

We may use personal information to create de-identified and/or aggregated information, such as statistics about how users interact with our Services. De-identified information cannot reasonably be used to identify you. If we create or receive de-identified information, we will not attempt to re-identify it, except to comply with applicable law.

4. How We Share Your Information

We share your personal information with third parties only to provide our Services, display advertising, or as required by law. We do not sell your personal data.

A. Service Providers

We share your information with third-party service providers who assist us in operating our Services. These providers are contractually obligated to use your data only for the purposes we specify.

B. APIs and SDKs

We use third-party application program interfaces ("APIs") and software development kits ("SDKs") as part of the functionality of our Services. These tools help us provide features such as analytics, error tracking, and advertising. The third-party providers of these APIs and SDKs may collect information as described in their respective privacy policies. If you have questions about our use of third-party APIs or SDKs, please contact us.

C. Other Users

If you use social or interactive features in our Services, other users may see information you choose to share, such as your display name or content you post.

D. Legal Requirements and Protection

We may disclose your information if required by law, legal process, or governmental request, or if we believe in good faith that disclosure is necessary to:

• Comply with applicable laws or regulations
• Protect the rights, property, or safety of Rouveo, our users, or others
• Detect, prevent, or address fraud, security, or technical issues
• Enforce our Terms of Service or other agreements

E. Business Transfers

If Rouveo is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.

5. Legal Basis for Processing (EEA/UK Users)

If you are located in the European Economic Area (EEA) or the United Kingdom (UK), we are required to inform you of the legal basis for processing your personal data.

• Legitimate Interest. To operate, maintain, and improve our Services; to provide customer support; to display non-personalized advertising; and to ensure the security and integrity of our Services.
• Contract Performance. To process subscriptions and provide the Services you have requested.
• Consent. Where you have provided consent for specific processing activities, such as optional permissions or marketing communications.
• Legal Obligation. To comply with applicable laws and regulations.

6. Your Privacy Choices and Rights

You have control over your personal information. Depending on where you live, you may have additional rights under applicable law.

Your Privacy Choices

• Device Permissions. You can manage camera, photo library, and other permissions in your device settings.
• Advertising Controls. You can reset your advertising identifier or enable "Limit Ad Tracking" (iOS) in your device settings.
• Push Notifications. You can opt out of push notifications by changing the settings on your mobile device.
• Email Communications. If you receive marketing emails from us, you can opt out by using the unsubscribe link in the email. Note that you may still receive non-promotional communications from us.
• Delete Local Data. You can delete all locally stored data by uninstalling the app.
• Do Not Track / Global Privacy Control. Some browsers or extensions transmit "Do Not Track" (DNT) or "Global Privacy Control" (GPC) signals. While we do not currently respond to DNT signals, if we detect a GPC signal from your device, we will interpret it as a request to opt out of any sale or sharing of personal information for targeted advertising, where required by applicable law.

Your Privacy Rights

In accordance with applicable law, you may have the right to:

• Access your personal information and obtain a copy
• Correct inaccurate personal information
• Delete your personal information
• Restrict processing of your personal information
• Data Portability — receive your data in a structured, machine-readable format
• Object to processing based on legitimate interest
• Withdraw Consent at any time where processing is based on consent
• Opt-Out of the sale or sharing of personal information (note: we do not sell your data)

For California Residents (CCPA/CPRA): You have the right to know what personal information we collect and how we use it, to request deletion, to opt-out of sales or sharing (we do not sell your data), and to not be discriminated against for exercising your rights.

For Brazilian Residents (LGPD): You have the right to access, correct, delete, and port your data, to be informed about third parties with whom your data is shared, and to withdraw consent at any time.

Verification Process

To protect your privacy and security, we may need to verify your identity before fulfilling your request. This may include asking you to provide information that matches the information we have on file, or asking you to verify ownership of your device or account. If we cannot verify your identity, we may not be able to fulfill your request.

Authorized Agents

Depending on where you live, you may designate an authorized agent to make a request on your behalf. If you use an authorized agent, we may require proof that you have authorized the agent to act on your behalf, as well as verification of your own identity.

Exercising Your Rights

To exercise any of these rights, please contact us at privacy@rouveo.com. We will respond to your request in accordance with applicable law.

If you believe we have not adequately addressed your concerns, you have the right to lodge a complaint with your local data protection authority:

• Brazil: Autoridade Nacional de Proteção de Dados (ANPD)
• EEA: Your local Data Protection Authority
• UK: Information Commissioner's Office (ICO)

7. Cookies and Similar Technologies

Our websites may use cookies and similar technologies to collect information and improve your experience.

Cookies are small text files placed on your device that store preferences and enable certain functionality.

Pixel Tags/Web Beacons are pieces of code that collect information about engagement, such as whether an email was opened.

We may use these technologies for the following purposes:

• Required/Necessary. To enable core functionality, prevent fraud, and maintain security.
• Analytics. To understand how visitors interact with our websites and to improve our Services.
• Functionality. To remember your preferences and enhance your experience.

You can control cookies through your browser settings. Please note that disabling cookies may affect the functionality of our websites.

For more information about opting out of interest-based advertising, you can visit:

• Network Advertising Initiative
• Digital Advertising Alliance
• European Digital Advertising Alliance

8. Data Retention

We retain your information only for as long as necessary to fulfill the purposes described in this policy.

• Local Data. Data stored on your device is retained until you delete it or uninstall the app.
• Analytics and Error Tracking. Data collected by our third-party partners is retained according to their respective data retention policies.
• Job Applications. We retain job application data for as long as necessary to evaluate your application and comply with legal obligations.
• Transaction History. We retain transaction and subscription information for as long as necessary to provide our Services and comply with legal and financial reporting obligations.

Since we do not maintain our own servers for user data, we do not directly control the retention of data collected by third-party services.

9. Data Security

We take reasonable measures to protect your information, but no system is 100% secure.

We implement appropriate technical and organizational measures to protect your personal information from unauthorized access, loss, misuse, or alteration.

Unfortunately, no method of electronic transmission or storage is completely secure. While we strive to protect your information, we cannot guarantee its absolute security.

If we learn of a security breach that affects your personal information, we will notify you as required by applicable law.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your own.

Rouveo is based in Brazil, and our third-party service providers operate in various countries, including the United States. Your information may be transferred to, stored, and processed in countries that may have different data protection laws than your own.

When we transfer personal information outside of the European Economic Area, Switzerland, or the United Kingdom, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission or other lawful transfer mechanisms.

11. Children's Privacy

Our Services are not directed at children under 13, and we do not knowingly collect personal information from children.

Our Services are designed for a general audience and are not directed at children under the age of 13 (or the applicable age of digital consent in your jurisdiction, such as 16 in some EU countries).

We do not knowingly collect personal information from children under this age. If our Services include features that may appeal to children, we may take additional steps such as disabling social features or limiting data collection.

If we become aware that we have inadvertently collected personal information from a child, we will take steps to delete such information as soon as possible and terminate the child's account or revert them to an age-appropriate experience, if applicable.

If you are a parent or guardian and believe your child has provided personal information through our Services, please contact us immediately at privacy@rouveo.com.

We encourage parents and guardians to monitor their children's online activities.

12. Third-Party Websites and Services

Our Services may contain links to third-party websites or services that are not controlled by us.

Our Services may contain links to other websites, apps, or services operated by third parties. We do not control these third-party services and are not responsible for their privacy practices or content.

We encourage you to read the privacy policies of any third-party services you interact with. Providing personal information to third-party services is at your own risk.

13. Contact Us

ROUVEO LTDA is the controller of the personal information we process under this Privacy Policy.

If you have any questions about this Privacy Policy, wish to exercise your rights, or have concerns about our data practices, please contact us at: