Privacy Policy

This Policy explains how Resolve Programming LTDA, registered under CNPJ 47.240.722/0001-87, with its registered office at QR 201, Conjunto F, Lote 16, Santa Maria, Brasília, DF, CEP 72501-406, Brazil ("we"), processes the personal data of those who use PocketCounter in the Android and iOS apps and in the Web version ("you"), in accordance with the Brazilian General Data Protection Law (Law No. 13,709/2018, the "LGPD").

1. Who we are

Resolve Programming LTDA is the developer of PocketCounter and the controller of the personal data processed in the service. Our data protection officer can be reached at privacidade@pocket-counter.com.br.

2. Data we collect

• Registration: name, e-mail and access credentials.
• Financial data you enter or import: transactions (amount, date, description, merchant, type, status), categories, contexts, tags, categorization rules, fixed bills and the statement files you choose to import.
• Cards and accounts: nickname, card network, last 4 digits, limit, and closing and due dates. We do not collect the full card number, CVV or passwords.
• Notification and SMS content (Android only, with permission): see section 3.
• Questions to the assistant: the text of the questions sent and the answers generated.
• Technical data: device and app identifiers, model, operating system, app version, IP address, access date and time, and error logs.

We do not collect location, contacts, photos, audio or your bank's access credentials.

3. Notifications and SMS (Android)

If you enable it, the Android app may read the content of notifications and SMS messages received on the device in order to identify financial transactions, such as purchases, Pix and transfers, and to extract the amount, date, merchant and payment method.

• These permissions are optional and are requested with a prior explanation inside the app.
• The content is used exclusively to create and categorize your transactions and to learn your categorization rules.
• We do not use this content for advertising, marketing profiles or sale to third parties.
• You may revoke the permissions at any time in the Android settings, without losing access to the rest of the app.

On iOS and on the Web there is no reading of notifications or SMS.

4. What we use the data for

• Providing the service: recording, categorizing, grouping into statements and displaying your transactions and reports.
• Syncing your account across Android, iOS and Web.
• Answering the questions you ask the assistant.
• Authenticating your access, preventing fraud and protecting your account.
• Fixing errors and improving the performance of the service.
• Sending operational messages and, if you agree to it, product news.
• Complying with legal and regulatory obligations.

5. Legal bases

We process data on the basis of performance of the contract with you (art. 7, V, LGPD), your consent for the reading of notifications and SMS and for marketing communications (art. 7, I), compliance with a legal obligation (art. 7, II), the regular exercise of rights (art. 7, VI) and legitimate interest for security and improvement of the service (art. 7, IX). Consent may be withdrawn at any time.

6. Sharing

We do not sell or rent your personal data. We may share it only with:

• Processors that provide services on our behalf, such as cloud hosting, e-mail delivery, error monitoring and the artificial intelligence providers used by the assistant, under contract and limited to what is necessary;
• Public authorities, when required by law or court order;
• Successors, in the event of a merger, acquisition or corporate reorganization, with the safeguards of this Policy maintained.

7. International transfer

Some processors may store or process data outside Brazil. In those cases we adopt the safeguards set out in art. 33 of the LGPD, such as specific contractual clauses.

8. Retention and deletion

We keep your data for as long as your account is active. When you delete your account, we erase or anonymize your personal data within 30 days, except for data we must keep in order to comply with a legal obligation or to exercise rights, for the period required. See how to request it on Delete account.

9. Your rights

Under art. 18 of the LGPD, you may request: confirmation that processing takes place; access to the data; correction of incomplete, inaccurate or out-of-date data; anonymization, blocking or deletion of unnecessary or non-compliant data; portability; deletion of data processed on the basis of consent; information about sharing; information about the possibility of withholding consent and the consequences of doing so; and withdrawal of consent. Send your request to privacidade@pocket-counter.com.br. You may also lodge a complaint with the Brazilian National Data Protection Authority (ANPD).

10. Security

We adopt technical and administrative measures to protect your data, such as encryption of the communication between the app and our servers, authentication and access control. No system is entirely immune to failure. In the event of an incident that may create relevant risk or harm, we will notify you and the ANPD as the law requires.

11. Minors

PocketCounter is not intended for people under 18 and we do not knowingly collect data from minors.

12. Changes

We may update this Policy. Relevant changes will be communicated in the app or by e-mail before they take effect. The date at the top indicates the last update.

13. Contact

Resolve Programming LTDA · CNPJ 47.240.722/0001-87
QR 201, Conjunto F, Lote 16, Santa Maria, Brasília, DF, CEP 72501-406
Data protection officer: privacidade@pocket-counter.com.br