Privacy Policy

• Technical access records: IP address, browser type and operating system, page requested and time. They are recorded automatically by the website host (Vercel) when it delivers each page; on the hosting plan we use, these records are deleted after 1 hour. We do not download or keep any copy of them. Legal basis: legitimate interest (art. 7, IX of LGPD), for website security and fixing errors.
• 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.

• No account and no sign-up: the application 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), used only for non-personalized ads — see section 4 — and anonymous error reports via Sentry. Legal basis: legitimate interest.
• Internal authentication: the application authenticates calls to internal Edge Functions using the project's public (publishable) key. No personally identifying data is sent to or stored at Supabase.
• Purchases (Party and Grand Bingo): processed by Google Play Billing. We do not have access to your payment data. To confirm the purchase and unlock what was bought, we store on our server the receipt identifier (purchase token) associated with a pseudonymised device identifier — never your name, email or card data. Legal basis: performance of a contract (LGPD, art. 7, V).
• Card scanner: the reading is done on the device itself, by a component that works without a connection. The photo is not sent to our servers or to third parties, is not stored and never leaves your phone.
• Reading the caller's QR code: the camera reads the code shown on the caller's screen to bring the drawn balls and the event to your device. The reading happens on the phone itself; the image is not sent to our servers or to third parties and is not stored.
• 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).
• Application access log (legal obligation): each time the app is opened, we securely record the date and time of access, your IP address in encrypted form, and your app’s technical identifier (user agent and app version), 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).
• Application usage counts (product funnel): we record, in aggregated form and without any device, person or session identifier, how many devices completed steps such as finishing the welcome screen, finishing a game, using TV Mode, the tiebreaker, an event or Watch Mode, running into a locked feature, opening the Plans screen, watching a video to unlock a feature, or completing a purchase, grouped by day, country and app version. We also count how many devices opened the app again 1, 7 and 30 days after the first time: for this, the date of the first opening is kept only on your device, and the server receives only the range (1, 7 or 30 days), never the date. And we record, in the same aggregated way, how many Scanner card readings were accepted or rejected, to measure recognition quality — never the photo, never its content, never who took it. None of these records allow us to identify you or your device. Legal basis: legitimate interest (art. 7, IX of LGPD), to understand and improve the application.

• Components that run entirely on your device and transmit nothing: Google ML Kit Text Recognition, which reads the card entirely on the device — it works offline and does not send the image to Google —, the camera's QR code reader, which also reads the code on the device itself, plus the interface, audio and local storage components.
• Components that communicate with servers: Google AdMob (ads, free version only), Google Play Billing (purchases), Google Play (review request and new-version notice, which query the store directly, without going through our servers), Sentry (error reports), Supabase (internal Edge Functions for purchase confirmation, access records and aggregated usage counts), and your device's own speech recognition service if you use voice input. What each of them processes is described in items 2.2 and 3 of this policy.
• The list of open-source components and their licenses is in item 8.1 of the Terms of Use.

• Application access log (date, time and encrypted IP): legitimate interests (art. 6(1)(f)) — service security, abuse prevention and incident investigation. Please note: section 2 of this Policy cites art. 15 of the Brazilian Civil Internet Framework as the ground for this log. That is a Brazilian statute and, for you, it does NOT serve as a legal basis — art. 6(3) GDPR requires that a legal obligation derive from Union or Member State law. For you, therefore, the basis is legitimate interests, and you may object to it at any time (art. 21).
• Crash and diagnostic reports: legitimate interests (art. 6(1)(f)) — keeping the app working and fixing failures. No direct personal identifier is involved, and sending your IP address to the diagnostics service is disabled.
• Advertising (free version only): consent (art. 6(1)(a)), collected through Google’s form (UMP) before the first ad and withdrawable at any time via the privacy options button inside the app, as easily as it was given (art. 7(3)).
• In-app purchases: performance of a contract (art. 6(1)(b)) — confirming the receipt with Google and restoring the purchased product when you change devices.

• Access to your data and to this information (art. 15)
• Rectification of inaccurate data (art. 16)
• Erasure (art. 17)
• Restriction of processing (art. 18)
• Portability (art. 20)
• Objection to processing based on legitimate interests (art. 21) — this covers the access log and the diagnostics described in 12.1
• Withdrawal of consent at any time, without affecting the lawfulness of prior processing (art. 7(3))
• Not to be subject to automated decision-making producing legal effects (art. 22) — we make none

To exercise any of them, write to contato@bingopequente.com.br. We reply within one month, extendable by two further months where the request is complex, always with prior notice (art. 12(3)). Exercising your rights is free of charge.

The data described in this Policy is processed in Brazil, on infrastructure located in the São Paulo region. Since 26 January 2026, Brazil has been the subject of a European Commission adequacy decision (Implementing Decision (EU) 2026/179, art. 45): transfers from the European Economic Area need no other instrument. The United Kingdom and Switzerland have their own rules and are not covered by that decision; for people there, the transfer relies on the Standard Contractual Clauses of Implementing Decision (EU) 2021/914 (art. 46(2)(c)). In every case we keep supplementary technical measures: the IP address is pseudonymised by a salted hash and encrypted with AES-256-GCM before being stored, and the key is kept outside the database. Where other sections of this Policy state that the data "does not leave Brazil", read: Brazil is the destination of the transfer, not a guarantee that no transfer occurs. You may request a copy of these decisions and safeguards at the contact above.

The app is not directed at children under 16 in the EEA, requires no registration, and asks for neither a date of birth nor any data that would allow us to determine your age. Precisely because we cannot determine it — and in order not to process the data of anyone below the age of consent in their country, which art. 8 GDPR sets between 13 and 16 depending on the Member State — every ad request originating in the EEA, the United Kingdom and Switzerland is tagged as "under the age of consent" and receives exclusively NON-personalised ads. We build no profiles, use no advertising identifiers for profiling, and carry out no behavioural advertising.

We have not designated a representative in the European Union because we consider the derogation in art. 27(2)(a) GDPR applicable: the processing described here is occasional, does not include special categories of data (art. 9) or data relating to criminal convictions (art. 10), involves neither profiling nor behavioural monitoring, and is unlikely to result in a risk to your rights and freedoms — the app works without an account, without registration and without any direct personal identifier. We will reassess this position if the nature or scale of the processing changes. Regardless, you may lodge a complaint with the supervisory authority in your country (art. 77) — for instance the CNIL in France, the AEPD in Spain, the BfDI in Germany, the CNPD in Portugal, the ICO in the United Kingdom or the FDPIC in Switzerland — without prejudice to contacting us first at the address above.