Privacy Policy

1. Introduction and Scope

This Privacy Policy explains how Pipoll S.A. ("we," "us," "our") collects, uses, discloses, and protects your personal information when you use the Pipoll mobile application ("the App"). This policy applies to all users worldwide, regardless of age or location.

Age Limit: The App is accessible to users aged 13 and older. Users under 13 are strictly prohibited from using the App. Users between 13 and 17 must obtain verifiable parental consent.

2. Data Controller

Company: Pipoll S.A.
Address: BMW Plaza, Piso 9, Calle 50, Panama City, Republic of Panama
Email: lifeline@pipoll.live, privacy@pipoll.live, dpo@pipoll.live
Website: https://pipoll.live

3. Data Collection

We collect the following categories of personal data:

• Account Information: Name, email address, password (bcrypt hashed), profile picture
• Goal Data: Goals you create, progress updates, completion status
• Device Information: Device model, operating system, unique device identifiers
• IP Address and Country: Automatically collected to determine the country associated with your account (see Section 4)
• Location Data: Approximate location for local peer matching (with your consent)
• Usage Analytics: App interactions, session duration, feature usage
• Identity Verification Documents: Only if you voluntarily request identity verification (see Section 9)

Exclusion: Pipoll does NOT collect payment card numbers, bank account details, Social Security numbers, or any sensitive financial information. Government-issued identification documents are collected only when you voluntarily request identity verification, as described in Section 9.

4. IP Address and Country Information

When you use the App, we may automatically collect your IP address. We use your IP address to determine the country associated with your account. Your country is then stored in your account information and may be displayed publicly on your profile and in other areas of the App where your profile is shown.

The country information is used to provide location-related features and information within the App, including displaying the country associated with users. We do not use your IP address to publicly display your exact location.

5. Legal Basis for Processing (GDPR)

We process your personal data based on:

• Contractual Necessity: To provide the App and its features
• Legitimate Interests: To improve the App, prevent fraud, and communicate with you
• Consent: For location services, identity verification, and optional third-party API integrations
• Legal Obligation: To comply with applicable laws

6. How We Use Your Data

We use your personal data to:

• Create and manage your account
• Publish your goals to the social feed
• Operate the virtual token system
• Match you with local peers for accountability
• Display the country associated with your account
• Verify your identity when you request verification
• Analyze usage patterns to improve the App
• Send system notifications about your goals

7. Third-Party APIs

Pipoll offers optional integration with third-party APIs (e.g., fitness apps, health platforms) for goal verification purposes. Connecting a third-party API is always voluntary. When you choose to connect an API, you authorize Pipoll to access data necessary for goal verification. Your use of third-party APIs is subject to their respective privacy policies.

8. Sensitive Data Protection

Goals you create may contain sensitive personal information. All goal data is encrypted in transit (TLS 1.3) and at rest (AES-256). Pipoll employees do not have access to your goal data without your explicit consent or a valid legal order.

9. Identity Verification

If you choose to request identity verification, we may ask you to provide a government-issued identification document, such as a passport, national identity card, or other legally valid identification document. We use this information solely for the purpose of verifying your identity and determining whether your account qualifies for identity verification.

Access to identity verification information is limited to those who need it to perform the verification process. Verification documents are retained only for as long as reasonably necessary for the verification process, security purposes, dispute resolution, or other legitimate or legal purposes, after which they may be deleted or securely disposed of.

10. Public Goals — Critical Notice

By default, all goals you create on Pipoll are visible to all Pipoll users globally. Do not include sensitive personal information (financial data, health information, precise location, contact details) in your goals. Once published, your goals can be viewed, copied, and shared by other users. You are solely responsible for the content you choose to share publicly.

11. Protection of Minors

Under 13: Pipoll does not knowingly collect personal information from children under 13. If we learn that a user is under 13, we will immediately delete their account and data.

Teens 13-17: Users between 13 and 17 years of age must obtain verifiable parental or guardian consent before using the App. Parents or guardians who believe their child has provided personal information without consent should contact us at privacy@pipoll.live.

12. Data Sharing

We share your personal data only with:

• Service Providers: Firebase (hosting, analytics), API providers for goal verification, Apple App Store and Google Play Store
• Legal Authorities: When required by law or to protect safety

We never sell your personal data to any third party.

13. International Data Transfers

Your data may be transferred to and processed in countries other than your own. We ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs), UK International Data Transfer Agreements (IDTAs), and encryption.

14. Your Rights

Depending on your location, you may have the following rights:

• Access your personal data
• Correct inaccurate data
• Request deletion of your data
• Data portability
• Withdraw consent (where processing is based on consent)

To exercise your rights, contact us at privacy@pipoll.live. We will respond within 30 days.

15. Data Retention

We retain your personal data for as long as your account is active plus 30 days. After account deletion, we retain:

• Goal data: 7 days (for recovery purposes)
• Analytics data: 14 months (aggregated and anonymized)
• Token transaction records: 3 years (for fraud prevention)
• Identity verification documents: only as long as necessary for the purposes described in Section 9

Certain information may be retained beyond these periods where legally required or permitted, as described in Section 16.

16. Account Deletion

You may request the deletion of your account through the App. Upon receiving a deletion request, we may review the account and its associated content before completing the deletion.

Where permitted by applicable law, certain information or content may be retained, anonymized, or remain publicly available when necessary to maintain the integrity and functionality of the App, preserve existing interactions or transactions between users, prevent fraud or abuse, resolve disputes, protect the rights and safety of other users, or comply with legal obligations.

If your account is eligible for deletion, we will proceed with the deletion of the information that we are required or permitted to delete. Information that we are legally or legitimately required to retain may remain stored for the applicable retention period.

17. Security Measures

We implement industry-standard security measures including encryption, access controls, and regular security audits. In the event of a data breach affecting your personal information, we will notify you and relevant authorities within 72 hours as required by GDPR.

18. Cookies and Tracking

Pipoll does not use cookies. We use Firebase SDK and Firebase Analytics to collect usage data. We do not use advertising IDs for targeted advertising—only for analytics purposes.

19. Virtual Tokens

Virtual tokens have no real-world monetary value. Token records are maintained for fraud prevention and dispute resolution purposes only.

20. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified through the App. Your continued use of the App after the effective date constitutes acceptance of the updated policy.

21. Contact Information

Entity: Pipoll S.A. — Data Protection Officer
Address: BMW Plaza, Piso 9, Calle 50, Panama City, Republic of Panama
Email: lifeline@pipoll.live, privacy@pipoll.live, dpo@pipoll.live
Web: https://pipoll.live

For EU users: You may lodge a complaint with your local data protection authority.