This Privacy Policy applies to data processed by RB SERVICOS EM TECNOLOGIA DA INFORMACAO LTDA, a Brazilian company (CNPJ 61.189.543/0001-93, Curitiba/PR, Brazil). It references Brazilian data-protection law (LGPD — Law 13.709/2018). Where mandatorily applicable, data-protection laws of your jurisdiction (such as GDPR in the European Union, PIPEDA in Canada, or CCPA in California) shall prevail over conflicting provisions herein.
Who we are
Bingo Pé Quente is a recreational bingo app (75-ball version) intended for family and social use. This policy describes how we process personal data, in compliance with the Brazilian LGPD (Law 13.709/2018) and the Brazilian Civil Internet Framework (Law 12.965/2014).
What data we collect
2.1. On the website (bingopequente.com.br)
- Browsing data: IP address, browser type, operating system, pages visited and time spent — collected automatically in server logs. Legal basis: legitimate interest (art. 7, IX of LGPD), for statistical analysis and improvement of the site.
- Vercel Analytics: cookieless and anonymous statistical measurement system provided by Vercel Inc. (United States). It does not use cookies, does not assign persistent identifiers to visitors and does not perform individual profiling. Because it is anonymous and cookieless, it is active for all visitors. Legal basis: legitimate interest (art. 7, IX of LGPD).
- Google Analytics (GA4): audience-measurement tool by Google LLC (United States), enabled only after your explicit consent in the cookie banner. When enabled, it uses cookies (_ga, _ga_*) and processes your IP address in anonymized form to understand how the site is used and improve it. Data is processed by Google in the United States (international transfer — art. 33 of LGPD) and retained for up to 14 months. Legal basis: consent (art. 7, I of LGPD), revocable at any time by declining or clearing the site's cookies. If you do not accept, Google Analytics is not loaded and none of its cookies are created.
- The site does not use advertising pixels (Meta, TikTok, Google Ads) or individual profiling tools.
2.2. In the application
- No account and no sign-up: the app does not require login nor collect email, phone, ID, or address. You may enter a name or nickname and choose an avatar to personalize the experience — stored only on your device, never sent to our servers, and which you can leave blank, change, or delete at any time.
- Device data: advertising identifier (AAID/IDFA) and anonymous error reports via Sentry — legal basis: legitimate interest.
- Internal authentication: the app authenticates calls to internal Edge Functions using the project's public (publishable) key. No personal identification data is sent or stored in Supabase.
- Paid purchases (Turbo/Pass/Lifetime): processed by Google Play. We do not have access to your payment data.
- Card scanner: the photo you capture is sent to an external AI service (Mistral AI, headquartered in France) only to extract the numbers. We do not store your photo; processing by Mistral AI follows Mistral's own privacy policy. Legal basis: execution of service at the data subject's request (art. 7, V and art. 33, IX of LGPD).
- Voice number entry (optional): when you tap the microphone to speak a number, the audio is captured and sent to your device's speech recognition service (on Android, usually Google) to convert speech to text. Bingo Pé Quente does not record or store the audio and uses it only to mark the spoken number; depending on the device, the audio may be processed on the speech recognition provider's servers. You can always type the numbers manually. Legal basis: execution of service at the data subject's request (art. 7, V of LGPD).
- Scanner usage control (anti-abuse): to prevent abusive use, we generate an irreversible technical identifier (a daily hash) derived from your IP, used only to count daily uses. For this control, we do not store your IP address and you cannot be identified from this value. Discarded within 7 days. Legal basis: legitimate interest in security (art. 7, IX and art. 10 of LGPD).
- Application access log (legal obligation): each time the app is opened, we securely record the date and time of access and your IP address in encrypted form, solely to comply with the mandatory retention of internet application access records required by art. 15 of the Brazilian Civil Internet Framework (Law 12.965/2014). The IP address is encrypted on the server and can only be disclosed under a court order (art. 22 of the same law); we do not use it for profiling or to identify you in ordinary use of the app. Legal basis: compliance with a legal obligation (art. 7, II of LGPD).
- Per-device scan quota (anti-abuse): so that the free monthly Scanner limit cannot be circumvented by clearing the app's data or reinstalling it, we generate a technical identifier of your device (on Android, the system identifier) and store it on the server only as a hash protected by a secret key, linked solely to the month's usage counters. This hash stays stable while the monthly quota cycle is in effect; we do not use it for advertising, profiling or to identify you outside this purpose, and it is not linked to your advertising identifier. Legal basis: legitimate interest (art. 7, IX and art. 10 of LGPD).
International data transfer
Scanner's technical chain — Supabase + Mistral AI
For the Scanner to work, your photo passes through two operators:
1. Supabase (AWS infrastructure configured for the project), acting as a technical proxy for internal Edge Functions;
2. Mistral AI (the analysis controller, France — European Union), performing number recognition.
Supabase does not retain your photo after the response. Processing by Mistral AI follows Mistral's own privacy policy. The transfer is necessary to execute the service you requested (art. 33, IX, LGPD). You can avoid it by typing the numbers manually instead of using the Scanner.
Other services with possible international transfer:
- Vercel Inc. (United States) — website hosting and Vercel Analytics (cookieless, anonymous measurement, with no cookies or personal identifiers).
- Google LLC (United States) — Google Analytics (GA4), audience measurement enabled only after your explicit consent. When active, it processes browsing data via cookies on Google's servers in the United States.
- Supabase (AWS infrastructure — region configured for the project) — technical proxy for Mistral AI calls and other internal Edge Functions, and storage of the technical records retained on the server (Scanner anti-abuse hash for 7 days, application access log with encrypted IP for 6 months, and the per-device monthly scan quota — device hash and the month's counters).
- Mistral AI (France, European Union) — number recognition on scanned cards. Country recognized as providing an equivalent level of protection (GDPR/EU) — art. 33, I, LGPD.
- Google AdMob (United States) — display of ads in the free version.
- Sentry (United States) — collection of anonymous error reports.
- Google Play Billing (United States) — processing of payments.
- Device speech recognition service (on Android, usually Google — United States) — used only if you choose voice number entry, to convert speech to text. The audio is not stored by us.
Standard contractual clauses and safeguards
Transfers to operators in jurisdictions without an adequacy decision are based on the safeguards in art. 33, II, of the LGPD and regulated by ANPD Resolution CD/ANPD No. 15/2024 (standard contractual clauses and binding corporate rules). Until ANPD publishes the official Brazilian template, we rely on the EU Standard Contractual Clauses (SCC) as an equivalent minimum safeguard, under the DPAs executed with each operator. Per-operator detail is recorded in the Records of Processing Activities (RoPA — LGPD art. 37 and ANPD Resolution No. 19/2024).
Advertising (free version only)
Blocked categories
The free version shows Google AdMob banners. The categories gambling, betting, alcohol and dating are blocked (via AdMob's G content rating, which limits ads to general audiences). Paid products (Turbo, Pass and Lifetime) suppress these banners.
For users in Brazil, collection of the advertising identifier (AAID/IDFA) is preceded by consent through Google's standard interface (User Messaging Platform).
Your rights (LGPD, art. 18)
You may request:
- Confirmation that processing exists
- Access to the data
- Correction of incomplete or outdated data
- Anonymization, blocking or deletion of unnecessary data
- Data portability
- Deletion of data processed with consent
- Information about sharing
- Withdrawal of consent
Because the application does not require sign-up, most data is processed anonymously. To exercise any right, please use the contact page. Data portability (art. 18, V) can be exercised directly via the app's Export Data feature, which generates a file with your data.
Retention
- Scanner photos: not stored (discarded after processing).
- Website logs: 6 months.
- Error reports (Sentry): 90 days.
- Purchases: according to legal accounting/fiscal requirements.
- Scanner technical identifier (anti-abuse hash): up to 7 days.
- Application access logs (encrypted IP + date/time): 6 months, as required by art. 15 of the Brazilian Civil Internet Framework (Law 12.965/2014).
- Per-device scan quota (device hash + counters): kept while the monthly quota cycle is in effect; the counters reset at the turn of the month and records from previous months are discarded.
Security
Technical and organizational measures
We adopt reasonable technical measures (HTTPS, encryption in transit, server-side API key separation) and organizational measures to protect your data. No system is 100% secure — in case of an incident, we will notify ANPD and the affected data subjects within a reasonable period, in accordance with art. 48 of LGPD.
Children and adolescents
Bingo Pé Quente is rated for ages 12+ and is not directed to children under 12. The app does not require sign-up and does not send to our servers personal data from children and adolescents — email, phone, ID, address or any direct personal identifier (LGPD, art. 14). Any name or nickname and avatar chosen to personalize the experience remain only on the device.
Parents and guardians must supervise children's and adolescents' access to the application and website, explicitly authorize any paid purchases processed through Google Play and ensure these Terms of Use are read.
Changes to this policy
This policy may be updated. Significant changes will be announced on the website and within the application. The date of the last update is always at the top of this document.
Data Protection Officer (DPO)
Data Protection Officer (DPO): RB SERVICOS EM TECNOLOGIA DA INFORMACAO LTDA — Brazilian Tax ID (CNPJ) 61.189.543/0001-93, headquartered in Curitiba/PR (legal entity responsible for the project, as permitted by ANPD Resolution CD/ANPD No. 18/2024, which regulates the duties of the data protection officer). Direct contact: contato@bingopequente.com.br or through the contact page.
Applicable laws and regulations
This policy is governed by Brazilian law, in particular:
- Law 13.709/2018 (LGPD) — Brazilian General Data Protection Law
- Law 12.965/2014 (Brazilian Civil Internet Framework)
- Law 8.078/1990 (Brazilian Consumer Code)
- Law 10.741/2003 (Statute of the Older Adult)
- Law 13.146/2015 (Brazilian Inclusion Act), art. 63 — accessibility of websites and apps, following WCAG 2.1 level AA guidelines
- Decree 5.296/2004 — accessibility for persons with disabilities and reduced mobility
- ANPD Resolution CD/ANPD No. 2/2022 — small-size processing agents (regime applicable to Bingo Pé Quente, declared by the controller)
- ANPD Resolution CD/ANPD No. 4/2023 — dosimetry and application of administrative sanctions
- ANPD Resolution CD/ANPD No. 15/2024 — standard contractual clauses for international data transfers
- ANPD Resolution CD/ANPD No. 18/2024 — duties of the Data Protection Officer
- ANPD Resolution CD/ANPD No. 19/2024 — Records of Processing Activities (RoPA)
By using the Bingo Pé Quente website or application, you declare that you have read and understood this Privacy Policy.