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 (Party, Lifetime and scan packs): processed by Google Play. We do not have access to your payment data. To confirm the purchase and unlock what you bought, we store on our server the receipt identifier (purchase token) linked to a pseudonymized device identifier — never your name, email or card details. Legal basis: performance of a contract (LGPD, art. 7, V).
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 and balance (anti-abuse and contract performance): so that Scanner limits cannot be bypassed by clearing app data or reinstalling, 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, associated solely with usage counters and the balance of purchased scans. This hash is kept for as long as the free monthly quota cycle or the validity of the purchased balance (24 months from purchase) lasts, whichever ends last; we do not use it for advertising, profiling or to identify you outside that purpose, and it is not linked to your advertising identifier. Legal basis: performance of a contract (LGPD art. 7, V) for the purchased balance, and legitimate interest (LGPD art. 7, IX and art. 10) for anti-abuse control.
Genuine app verification (anti-abuse): when you use the Scanner, the app asks Google Play for a signed attestation confirming that the request came from the official app, on its published version, on a legitimate device. That attestation is sent to Google to be checked and contains no name, email, phone number or the content of your photo. We keep only aggregate counters of the result (how many checks passed or failed each day), with no identifier of yours. Its purpose is to stop third parties from using our card-reading service outside the app, at our expense. Legal basis: legitimate interest in security (art. 7, IX 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 scan quota and balance — device hash, the month's counters and the purchased balance with its validity).
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) — purchase processing and receipt verification.
Google Play Integrity (United States) — verification that card reading came from the official app, on a legitimate device. It receives only the device's signed attestation; none of your data and no photo.
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).

3.1

Links to third-party sites

The website and the app may contain links and buttons leading to third-party sites — for example, stores and marketplaces (such as Etsy) where we sell printable cards, and our social networks. When you click, you leave our website or app and become subject to the privacy policy and terms of the destination site. We do not control and are not responsible for the privacy practices of these third parties — we recommend reading each one's policy.

To measure where visits come from, some of these links use campaign parameters (UTM) in the address. These parameters are just campaign labels, read by the same measurement tools already described in section 2 (Vercel Analytics and, subject to consent, Google Analytics), and do not collect any additional personal data.

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 (Party 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: the receipt identifier (purchase token) and the pseudonymised device identifier are kept for as long as the acquired right lasts — Party and Lifetime are permanent, and the scan balance is valid for 24 months from purchase — because deleting that record would take away what you already paid for (LGPD, art. 16, I). Accounting/tax records follow their own legal retention periods.
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 and balance (device hash + counters + balance): monthly counters reset at the turn of the month and records from previous months are discarded; the purchased balance and its associated hash are kept until the end of the 24-month validity and deleted afterwards.

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 14+ and is not directed to children under 14. 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.

Bingo Pé Quente

bingopequente.com.br