Legal

Privacy Policy

1. Data Controller Identity

Spotinerary is a travel-planning app organized around Destinations and Trips. Destinations can contain covers, tags, notes, saved spots, bookmark folders, and supported social links. Trips can contain Destinations, spots scheduled by date, and transfers. This policy describes how we handle data during your use of the app.

2. Data Collected

2.1 Data We Do NOT Collect

Spotinerary does not collect:

• Names, emails, or phone numbers through the app account flow. Sign in with Apple is requested without name or email scopes
• We do not access your real-time location (no location permission is requested)
• We do not access your camera (no camera permission is requested)
• Photos used as Destination covers are selected by you through the system picker (PhotosPicker). The app receives only the images you choose and does not receive access to your full photo library
• Payment-card details, billing addresses, or financial-account information

2.2 Account, Entitlement, and Quota Data

Creating an account is optional for limited local browsing and required before starting a trial, subscribing, restoring a subscription, or using server-funded features. We process:

2.3 Data Collected Automatically

Firebase Analytics (Google)

When you consent to analytics data collection, the following data is collected:

Categories of tracked events include:

• Screen visits and interactions with maps, place search, and directions
• Creation, deletion, sharing, and organization actions for Destinations, Trips, tags, and saved spots
• Supported-import source category, route, outcome, and saved-item counts, without logging source URLs or extracted content
• AI action type, filter and saved-item counts, metered usage units, and usage-threshold notices
• Paywall display, product selection, conversion, and restoration actions, including product identifiers
• Onboarding, language, theme, and issue-report categories

Firebase Crashlytics (Google)

When you consent to analytics and diagnostics, the following data may be collected for issue resolution:

Firebase account security, service configuration, and server records

Firebase Authentication and Cloud Functions may process IP-address and user-agent security metadata when you sign in or make a server request. The app and backend also use the following services:

Temporary provider results stored in Cloud Firestore can contain generated or extracted content until automatic deletion. The general travel library is not stored in Cloud Firestore; it remains local and in iCloud. Structured backend logs exclude prompts, source URLs, provider payloads, credentials, Firebase user identifiers, Apple subjects, and provider job identifiers.

iCloud / CloudKit (Apple)

Your travel data, including Destinations, Trips, covers you choose, tags, notes, saved spots and links, dates, and transfers, is synchronized through iCloud/CloudKit when iCloud is enabled. Apple manages this storage, which makes the data available to Spotinerary on compatible iPhones signed in to the same iCloud account.

Map and place services (Apple MapKit)

When you search for or view places, request a country lookup, or estimate a route, Apple may receive search terms or places viewed, map viewport and request/device metadata, saved or planning coordinates, and route origin, destination, transport mode, and departure time. Spotinerary does not request permission to access your live device location. We do not separately retain raw MapKit requests; places and route information you choose to save become part of your local/iCloud travel data. Apple handles these requests under Apple Maps & Privacy.

AI and social-content processing

When you request AI discovery, planning, or import processing, the following data may be sent to Google:

AI requests are sent through Spotinerary's Firebase Cloud Functions and processed by Gemini on Google Cloud Vertex AI. When you import supported social-media links, the source URL and the source's public media are also processed by Supadata to retrieve metadata and extract the travel content you requested. Google and Supadata may retain data according to their processing terms.

Unsplash API

When the app searches for a Destination cover image, the Destination name or cover-search terms are sent to the Unsplash API.

2.4 Purchase Data

All in-app purchases (monthly and annual subscriptions) are processed exclusively by Apple through StoreKit. Spotinerary:

• Receives the subscription and transaction information needed to determine access
• Verifies purchase authenticity server-side using information provided by Apple
• Never has access to payment-card details, billing addresses, or financial-account information

3. Purpose of Processing

4. Legal Basis for Processing

GDPR (EU Regulation 2016/679, Art. 6)

• Consent (Art. 6(1)(a)): For analytics data collection (Firebase Analytics) and crash reporting (Crashlytics). This consent is requested on first app use and can be withdrawn at any time through Settings > About > Help Improve Spotinerary. Separately, when you explicitly request a supported AI or social-content feature, that affirmative request provides consent for the specific processing; it is not controlled by this setting.
• Performance of contract (Art. 6(1)(b)): For iCloud sync, MapKit requests, Unsplash image search, Remote Config, account authentication, subscription verification, and delivery of requested server-funded features.
• Legitimate interests (Art. 6(1)(f)): For App Check security and the minimum transaction, request, and quota records needed to prevent replay, duplicate subscription claims, repeated quota resets, fraud, and service abuse.

LGPD (Brazil Law 13.709/2018, Art. 7)

• Consent (Art. 7, I): For Analytics and Crashlytics. This consent is freely given, specific, informed, and unambiguous, requested on first app use, and may be withdrawn through Settings > About > Help Improve Spotinerary. Separately, when you explicitly request a supported AI or social-content feature, that affirmative request provides consent for the specific processing; it is not controlled by this setting.
• Performance of contract (Art. 7, V): For iCloud sync, MapKit requests, Unsplash image search, Remote Config, account authentication, subscription verification, and delivery of requested server-funded features.
• Legitimate interests (Art. 7, IX): For App Check security and the minimum transaction, request, and quota records needed to prevent replay, fraud, and service abuse, subject to applicable necessity and balancing requirements.

5. Third-Party Data Sharing

We do not sell, rent, or share your data with third parties for marketing or advertising purposes.

6. International Data Transfers

Data processed by Firebase Authentication, App Check, Cloud Functions, Cloud Firestore, Remote Config, Analytics, Crashlytics, and Vertex AI may be handled on Google infrastructure outside the European Economic Area and Brazil, including in the United States. Firebase Authentication operates from United States data centers; the other listed Firebase services may use global Google infrastructure.

Transfers Between Brazil and the European Union

Data transfers between Brazil and EU member states are supported by the mutual adequacy decision between Brazil and the EU (Resolution CD/ANPD No. 32/2026, January 2026), which recognizes the adequate level of data protection between both jurisdictions.

Transfers to the United States

For transfers to the United States, Google operates under its Data Processing Terms, which include Standard Contractual Clauses approved by the European Commission and protection mechanisms recognized by the ANPD.

iCloud Data

iCloud sync is managed by Apple, which processes data in its global data centers in accordance with Apple's Privacy Policy and in compliance with both GDPR and LGPD.

7. Data Retention

8. Your Rights

Rights Under the GDPR (Arts. 15-22)

You have the right to:

1. Access (Art. 15) your personal data
2. Rectification (Art. 16) of inaccurate data
3. Erasure (Art. 17) of your data ("right to be forgotten")
4. Restriction (Art. 18) of processing
5. Data portability (Art. 20)
6. Object (Art. 21) to processing
7. Not be subject (Art. 22) to automated decision-making

Response timeframe: We respond without undue delay and in any event within one month, as provided by Article 12(3) GDPR. Where permitted due to the complexity or number of requests, this period may be extended by two further months, and we will notify you within the first month.

Rights Under the LGPD (Art. 18)

You have the right to:

1. Confirmation of the existence of data processing
2. Access to data collected about you
3. Correction of incomplete, inaccurate, or outdated data
4. Anonymization, blocking, or deletion of unnecessary or non-compliant data
5. Data portability to another service provider
6. Deletion of data processed based on consent
7. Information about third parties with whom your data has been shared
8. Information about the possibility of not providing consent and its consequences
9. Withdrawal of consent at any time

Response timeframe: For confirmation and access requests, the LGPD provides an immediate simplified response or a complete response within 15 days under Article 19. Other requests are handled within the periods required by applicable law and ANPD guidance.

9. How to Exercise Your Rights

In the App

• Privacy Settings: Go to Settings > About > Help Improve Spotinerary to enable or disable analytics data collection and crash reporting.
• Account Deletion: Go to Settings > Account > Delete Account. A fresh Sign in with Apple confirmation revokes the authorization and deletes the Firebase account. This does not cancel an App Store subscription; the app provides a separate Manage Subscription link. Local travel data remains on the iPhone while the app is installed, and iCloud-synced copies are managed separately through Apple's iCloud storage controls.

By Email

Send your request to: support@spotinerary.com.br

Please include in your request:

• Description of the right you wish to exercise
• Sufficient information to locate your data (for example, your operating system and device model)

Supervisory Authority

If you believe your rights have not been addressed, you may file a complaint with:

• Brazil: ANPD (National Data Protection Authority) - www.gov.br/anpd
• European Union: The supervisory authority of your country of residence

10. Security Measures

We implement the following technical measures to protect your data:

11. Children's Data

Spotinerary is not directed at children under 13 years of age (per COPPA) or under 18 years of age (per LGPD, Art. 14).

We do not knowingly collect data from children or minors. If we become aware that data has been collected from a minor without appropriate parental consent, we will take immediate steps to delete such data.

In compliance with Brazil's Law 15.211/2025 (Digital Framework for Children and Adolescents), we reaffirm our commitment to protecting minors' data and to transparency in data processing.

If you are a parent or guardian and believe your child has provided data to the app, please contact us at support@spotinerary.com.br.

12. Policy Updates

This policy may be updated periodically to reflect changes in the app, applicable legislation, or our data processing practices.

How you will be notified:

• Significant changes will be communicated in the app's update notes on the App Store.
• The "last updated" date at the top of this policy will be changed.
• When applicable, a notice will be displayed in the app requesting renewed consent.

We recommend that you review this policy periodically.

13. Contact

For questions, requests, or complaints about this policy or about the processing of your data:

This privacy policy was drafted in compliance with the General Data Protection Regulation (EU Regulation 2016/679), Brazil's General Data Protection Law (Law 13.709/2018), and Brazil's Law 15.211/2025.