Privacy Policy

About this Policy

Viibe App GmbH (“we,” “us,” or “our”), headquartered at Industrieplatz 5, 8212 Neuhausen am Rheinfall, Switzerland, values your privacy and is committed to protecting your personal data.

This Privacy Policy (“Policy”) explains how we collect, use, store, and share your information when you use the Pagaê mobile application (“Application”). This platform is built utilizing the Base44 development framework, and its data infrastructure is hosted in the United States.

By creating an account and using Pagaê, you acknowledge the data practices described in this Policy.

1. Legal framework and compliance

We process your personal data in strict compliance with the core data protection regulations applicable to our global users:

• LGPD (Lei Geral de Proteção de Dados - Lei nº 13.709/2018) for users located in Brazil.
• GDPR (General Data Protection Regulation - Regulation EU 2016/679) for users located in the European Union.
• FADP (Federal Act on Data Protection) for users located in Switzerland.

2. Data we collect

To provide our expense-splitting and debt-simplification features, Pagaê collects the following categories of data:

• Account Information: name, email address, phone number, and Pix key provided upon registration.
• Financial Transaction Records: descriptions of expenses, dates, amounts, currencies, and group names manually entered into the platform.
• Technical and Usage Data: IP address, device type, operating system version, app performance logs, and local cache tokens required for offline functionality.

3. How we use your data

We only process your personal data when we have a valid legal basis. The purposes include:

• Performance of a Contract: managing your account, executing our debt-simplification algorithms, and synchronizing shared expenses among group members.
• Legitimate Interests: enhancing application performance, debugging code, and optimizing the Base44 framework architecture.
• Legal Compliance: fulfilling any statutory obligations or responding to legal requests from competent public authorities.

4. Data infrastructure and international transfers

4.1. Base44 Architecture: The Pagaê platform is developed on top of the Base44 framework, which utilizes optimized APIs for cloud data management and secure client-side caching.

4.2. Hosting in the United States: All databases and user information are hosted on secure cloud servers located in the United States.

4.3. Legal Safeguards for Transfers: Because your data is transferred from Brazil, the EU, or Switzerland to the United States, we implement strict safeguards to ensure an equivalent level of data protection. This includes utilizing Standard Contractual Clauses (SCCs) approved by the European Commission, the Swiss Federal Data Protection and Information Commissioner (FDPIC), and requirements mandated under the Brazilian LGPD.

5. Data sharing and visibility

5.1. Visibility within Groups: Pagaê is a collaborative app. Your name, profile picture, and the financial expenses you register will be visible to the other members of the specific groups you choose to join.

5.2. Service Providers: We do not sell or monetize your personal data. We only share information with trusted third-party infrastructure providers, such as cloud hosting and push notification services, strictly necessary to run the Application, all of whom are contractually bound by confidentiality clauses.

6. Data retention

We store your personal data only for as long as your account remains active or as required to fulfill the purposes outlined in this Policy. You may request the deletion of your account and all associated data at any time directly through the Application settings.

7. Your data privacy rights

Regardless of your location, you have extensive rights over your data under the LGPD, GDPR, and Swiss FADP:

• Access and Rectification: the right to confirm we process your data and to correct inaccurate information.
• Erasure (“Right to be Forgotten”): the right to request the total deletion of your personal data from our servers and Base44 infrastructure.
• Portability: the right to receive your personal and expense data in a structured, commonly used format.
• Withdrawal of Consent: the right to withdraw consent for any processing activity based on your prior authorization.

To exercise any of these rights, you can submit a direct request via our support channels or our official privacy email address.

8. Information and data removal requests

You can request the information we store and ask us to delete all data. Send an email to explore@appviibe.com with one of the following subject lines:

• GDPR - Delete: within a few days, we will remove all data stored about you.
• GDPR - Information: within a few days, you will receive the data we have stored about you.
• GDPR - Opt-out: you will be excluded from all marketing communications regarding the Application, but not from essential communications.

In the body of the email, we ask you to send a photo of a document so that we can validate your identity. This protects our users by preventing unknown people from obtaining information that does not belong to them. These files will be deleted as soon as we process your request.

If the registered email is different from the email from which you sent the request, also provide the email or phone number registered in our system so that we can locate the correct data.

For marketing opt-out, user identification is not required. Please provide the email or phone number registered in the account if it differs from the one used to send the request.

9. Security measures

We implement robust technical and organizational security measures to protect your data against unauthorized access, alteration, disclosure, or destruction. This includes end-to-end HTTPS encryption for all API traffic, strict access controls within the Base44 architecture, and regular security patches.

10. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to align with new features or legal updates. When changes are made, we will update the “Last Updated” date at the top of this document and provide a notice within the Pagaê Application.