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PRIVACY POLICY

Last updated: October 10, 2026

1. Our Principle of Not Collecting Sensitive Data

VÉRTZ was built with privacy by default and Privacy by Design:

• We DO NOT collect your CPF, RG, CNH, or personal identity documents.
• We DO NOT ask for bank passwords, card numbers, CVVs, or billing statements.
• We DO NOT run credit checks in your name with Brazilian credit bureaus (Serasa, SPC, or Boa Vista).

2. Information We Collect

We collect only the information necessary to operate, personalize, and improve the service:

A. Information You Provide Directly (Optional)

• Google or email sign-in: Your display name, email address, and profile photo, when you choose to create an account to sync saved cards and history in the cloud. If you use Guest/Anonymous mode, we do not collect a personal email address.
• Profile quiz answers: The estimated income range and spending habits you voluntarily enter in the quiz are used to build your profile and show how catalog cards match your filters. When you sign in to a registered account, your answers—including income range, self-reported credit status, and answers along the questionnaire path—are synced and stored in Firebase to restore your preferences. This profile storage is separate from the temporary Score calculation processing described below. Suggestions rely on your stated answers and catalog information; they are not a credit assessment, do not calculate approval odds, and do not guarantee that you can obtain a product.
• VÉRTZ Score: To calculate this internal assessment, the app temporarily sends a protected Google/Firebase service the model version and the categories you entered for payments, income commitments, credit restrictions, income stability, and credit experience. It does not send exact income amounts, CPF numbers, or card details. The service requires authentication, including for anonymous guests, and app verification; it does not save these answers in a database or include them in application logs or Analytics events. Drafts and results remain in secure storage on your device. VÉRTZ Score is not a credit bureau score or a probability of approval.
• MoneyLab simulations: When calculating arbitrage, returns, or a card for a spending category, we send the protected service only the hypothetical values you enter, the selected category, and the card identifiers needed for comparison. Calculations use confirmed catalog terms on the server. The calculation service does not record these inputs in application logs, Analytics, or a database. Request counters tied to the account identifier, without answers or financial values, are retained to limit abuse. Saving a simulation does not require an account: without one, saved simulations stay only on your device, are not synced, and may be lost if app data is removed. With an account (sign-in with Google or email), the full content of each saved simulation — entered values, calculated results and, when included in it, monthly spending, subscriptions and points — is stored in your account on our servers (Firebase) for automatic restoration across devices. This data is encrypted in transit (HTTPS/TLS) and at rest, with provider-managed keys; authorized services can process it to save and restore your simulations. This is not end-to-end encryption. This content is never sold or shared with advertising or analytics partners and is deleted when you delete your account. To count free saves, our servers keep, separately from the saved content, only an identifier for each simulation, tied to your account or anonymous ID and deleted with the account; this counting record contains no financial values. Reminders remain local to your device.
• Subscription data (VÉRTZ CTRL): The app uses RevenueCat to manage purchases, restorations, and subscription status. Your Firebase account identifier associates your subscription access with your account. The service processes product and plan identifiers, store receipts and transaction information, and subscription status and dates. Our server checks RevenueCat to verify access to paid features. Google Play processes payments; VÉRTZ does not receive card numbers, CVVs, or bank details. Deleting your VÉRTZ account does not automatically cancel your Google Play subscription.

B. Information Collected Automatically

• Advertising identifier (Advertising ID / AD_ID): The Google Mobile Ads (AdMob), Meta Audience Network, and Unity Ads mediation SDKs may collect your device’s advertising identifier to serve contextual or personalized ads, subject to your consent obtained through the User Messaging Platform (UMP).
• Catalog country and loan access: See Country by IP, retention, and fallback below. This functional verification is separate from Analytics and advertising preferences.
• Approximate location and ad data: Google Mobile Ads may process your IP address to estimate general location, along with ad interactions, identifiers, and diagnostics, for advertising, measurement, and fraud prevention. Firebase Analytics may also derive approximate location from a masked IP address. This does not require permission to access precise GPS location.
• Crash reports: In production, Firebase Crashlytics receives the error type and technical stack trace to identify and fix crashes. The app removes the original exception message and does not add form answers or user identifiers to the report. This technical collection is separate from the usage Analytics setting.
• Diagnostics, performance, and usage data: Firebase Analytics may process interaction events, device model, and operating system and app versions to understand user journeys and stability. VÉRTZ does not send search text, financial values from forms, names, email addresses, CPF numbers, or card numbers in custom events. The Analytics SDK may automatically record purchase and subscription events with the product and purchase price. You can turn Analytics off at any time in Settings > Usage analytics, separately from ad preferences.
• Notification tokens (FCM): A technical Firebase Cloud Messaging identifier may be stored and linked to your account to deliver silent catalog updates. Marketing and journey-resumption messages are optional, use direct tokens, and are enabled only after your express authorization in Settings; we do not use a marketing topic.
• Journey resumption (optional): If you authorize marketing notifications and save answers to a routed quiz, the app stores a secure episode descriptor on your device, without answers, score, income, or product details. It may register a recovery opportunity on the server with your account UID, minimal flow state, and expiration dates. The purpose is to offer resumption of a checkpoint you actually saved; we do not create generic reminders based on inactivity alone.
• Experimental measurement (optional): When Analytics collection is also authorized, the client may associate opportunity events with a random, opaque identifier specific to the experiment. This identifier is not a UID, email address, token, or reversible hash, and is not sent when Analytics is off. Experiment associations and server-side opportunities are retained for the documented technical period, currently up to 90 days after the opportunity expires, unless retention is legally required.

C. Country by IP, Retention, and Fallback

When the app starts, we contact Country.is over HTTPS. The service receives the connection’s public IP address and infers the country. The IP is transmitted as part of the network connection; we do not need GPS access. This automatic lookup also runs in guest and paid modes, independently of Analytics, advertising, or notification preferences.

• Purpose: Select the catalog country and apply loan-access restrictions. We use only the country, without coordinates, a home address, or precise location. An IP address does not prove residency or credit approval; VPNs and intermediary networks may change the inferred country.
• Information sent: Country.is receives the connection’s IP. We do not send account identifiers, onboarding answers, financial information, advertising identifiers, or purchase data to this endpoint.
• IP and verification: The app immediately discards the returned IP field. Country verification and its validity remain in memory for no more than five minutes and are invalidated when the app leaves the foreground. We check again when you return, when verification expires, and before opening a loan issuer’s website. This process does not save the IP on the device, in Firebase, or in Analytics events.
• Saved flow country: A country code may accompany onboarding answers and metadata saved on your device and, when answers are synced, in your Firebase account. This lets you resume a questionnaire for the same country. The widget may also save the current country locally to show appropriate features. These records follow the preference and answer retention described in this policy; they are not an IP address, valid loan verification, or a history of network lookups.
• Provider: Country.is states that it does not log requests and uses GeoLite2/MaxMind and infrastructure geolocation when available. This is the provider’s statement, not a guarantee that all network infrastructure stops processing technical data. See the service information linked above.
• Fallback and controls: If the lookup fails, an explicitly configured device region may select the catalog, but cannot authorize loans. Restricted flows remain unavailable without a resolved country. There is no manual country selector. Changing the app language (Portuguese, English, Spanish, French, Arabic, Japanese, Vietnamese, Swahili, Traditional Chinese, Filipino, Afrikaans, or Zulu) changes only the language. The current version has no setting to disable only the country lookup; turning off Analytics, personalized ads, or notifications does not disable it.

This page’s language: On the site’s main pages, your browser contacts Country.is over HTTPS to suggest a language based on the connection’s country. The provider receives the public IP; the page uses only the country and does not save the IP or country in your browser. If the lookup fails, we use the language and region reported by your browser. A language specified by the app or link takes priority. Your manual language choice is saved only in this browser, can be changed in the selector, and does not change the catalog country or grant loan access. Direct language versions do not need an IP lookup.

3. Why We Process Data

We use the collected data exclusively for these purposes:

1. Run the credit card catalog comparison and filtering engine, showing your filter results and how products match your filters.
2. Keep your favorite cards and simulations synced with your account.
3. Maintain app security, fraud prevention, and stability.
4. Show relevant ads that keep the app free for people who do not subscribe to VÉRTZ CTRL, an optional subscription with no ads and all features unlocked.
5. Verify subscription status with RevenueCat and Google Play, grant, maintain, or end VÉRTZ CTRL access in your account, and provide subscription support.
6. Only with your marketing authorization, send a contextual opportunity to resume an interrupted routed quiz and measure, in aggregate, whether that recovery leads to a useful session. You may revoke authorization at any time; the app disables it locally immediately and syncs the revocation when connected.
7. Adapt the catalog to the connection’s country, restrict loans without a verified country, and meet applicable market and store requirements.

4. Sharing Data with Third Parties

VÉRTZ does not sell, rent, or trade your personal data with third parties. We use the following providers for the purposes described in this policy:

• Country.is and its network infrastructure: Process the connection’s IP to determine the catalog country. Country.is states that it does not log lookups. We do not send form answers, financial data, or account identifiers to this endpoint. Country.is service and request-processing information.
• Google Firebase / Google Cloud Platform: Cloud hosting, encrypted database (Firestore), Firebase Cloud Messaging, and user authentication. Firebase Privacy Information.
• Google AdMob (Google LLC): Ads in the mobile app. Google Advertising Policy.
• Meta Audience Network (Meta Platforms, Inc.): An ad network that competes through Google AdMob mediation to display ads in the app. The Meta SDK may process advertising identifiers, IP addresses, device data, and ad interactions for ad delivery, measurement, and fraud prevention, subject to consent obtained through UMP. Meta Privacy Policy.
• Unity Ads (Unity Technologies): An ad network that competes through Google AdMob mediation to display rewarded video ads in the app. The Unity SDK may process advertising identifiers, IP addresses, device data, and ad interactions for ad delivery, measurement, and fraud prevention, subject to consent obtained through UMP. Unity Privacy Policy.
• RevenueCat: Subscription management and validation, purchase restoration, and access checks using account identifiers and purchase and subscription information. RevenueCat Privacy Policy.
• Google Play / Google LLC: Payment processing, billing, renewal, and cancellation of VÉRTZ CTRL, and verification of purchase receipts sent by the app. Manage your plan under Subscriptions in your Google Play account. Google Privacy Policy.

5. Data Security and Storage

Your data is transmitted over encrypted HTTPS/TLS connections and processed and stored by the providers listed above according to each service’s purpose and security controls. Transport encryption is not a promise of end-to-end encryption: authorized services process the data needed to operate. The local journey-resumption descriptor is kept in secure device storage; server-side opportunities have an expiresAt field for eligibility and a separate deleteAfter field for limited technical retention (currently 90 days), including cleanup of receipt subcollections. Account deletion triggers removal of associated jobs and tokens. The opaque experimental identifier is used only for the authorized measurement described above.

6. Guest Use and Data Retention

If you use the app without registering: You can use VÉRTZ without creating an account. We create a random code, without a name, email address, or CPF, to send notifications and reminders. If you do not open the app for 90 days, we delete that code and everything associated with it on our servers, unless you have an active VÉRTZ CTRL subscription: then we keep it while the subscription lasts. Data saved on your phone remains until you uninstall the app. Your Google Play subscription is not lost.

Usage measurement: We use Google Analytics for Firebase to understand which screens and features are used and to fix errors. We do not record names, email addresses, CPF numbers, financial values, or answers in that measurement. You can turn it off in Settings > Usage analytics.

Ads: The free version displays ads from Google AdMob, Meta Audience Network, and Unity Ads. To select and measure ads, these companies collect device data such as advertising ID, device model, IP address, and ad interactions under their policies. We do not send them your personal details or answers. You can reset the advertising ID in Android settings; VÉRTZ CTRL subscribers do not see ads.

If you have registered: Your account is retained until you request deletion in Settings > DELETE ACCOUNT.

We do this to provide the app and keep it free (performance of the service and legitimate interest, LGPD Article 7, V and IX).

Country by IP: We do not retain the returned IP or a history of these lookups. In-memory verification expires within five minutes. The country associated with synced answers is processed with account data and removed upon account deletion as described below; widget preferences remain on your device until replaced or their local data is removed.

7. Your Rights under the LGPD and Local Law, and Account Deletion

Under Article 18 of Brazil’s Law No. 13.709/2018 (LGPD), you have the right to:

• Confirm that processing takes place and access your data.
• Revoke consent at any time.
• Request complete and permanent deletion of your account and all associated personal data.

If you live outside Brazil: besides the LGPD, you keep the rights granted by the data protection law of your country of residence, and you can also contact the data protection authority of that country. To exercise any of these rights with VÉRTZ, write to us at the email address in section 8.

You can delete your data at any time in the app under Settings > DELETE ACCOUNT, or through our public web request page:

Deletion in the app removes your account and associated data held by VÉRTZ in Firebase after the authenticated procedure is completed. Google Play and RevenueCat handle purchase and subscription data separately; Firebase deletion does not automatically delete records in those services. To request handling of those records, contact us at the email address below. We will explain which records can be deleted and any retention that applies to your request. Cancel your subscription separately in Google Play.

For users outside Brazil

• Legal basis: Outside Brazil, we process data to provide the service you use in the app and, where your country requires it, with your consent (for example, for personalized ads, marketing notifications, and usage Analytics). You can withdraw consent at any time in the app settings.
• Where your data goes: VÉRTZ is run from Brazil. Your data is processed in Brazil and by the providers listed in section 4, mainly in the United States (Google/Firebase, RevenueCat, and the ad networks), under the data processing terms each provider offers.
• Your rights: You can ask to access, correct, or delete your data, receive a copy of it, object to its processing, withdraw your consent, and ask for a human review of the VÉRTZ Score result. Write to the email address in section 8; we reply within 30 days.
• How long we keep data: Without a registered account, the random code described in section 6 and the data linked to it are deleted after 90 days without use, unless you have an active VÉRTZ CTRL subscription. With a registered account, your data is kept until you request deletion. Data saved on your phone remains until you uninstall the app.
• Security incidents: If an incident affects your personal data and may harm you, we will notify you and, where the law requires it, the competent authority within 72 hours of becoming aware of it.
• Age: VÉRTZ is intended for people aged 18 or older.
• Complaints: You can also complain to the data protection authority of your country.

After deleting account content, we temporarily retain a minimal technical record containing only the random account identifier and the deletion and cleanup-eligibility timestamps, with no scenarios or financial values, to prevent old requests from recreating deleted data. This record becomes eligible for removal after 24 hours and is removed by the daily cleanup routine; backlogs or failures may defer removal to later runs.

8. Contact the Data Protection Officer (DPO)

For questions, comments, or requests about this Privacy Policy, contact the person responsible: