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Privacy Policy – Registra

Effective date: August 9, 2025
Last updated: August 9, 2025

This Privacy Policy describes how the Registra app ("Registra", "we", "us") collects, uses, and protects personal data. By using Registra (app and site), you agree to this Policy.

1. Who we are

  • Data Controller: AMC Marketing LTDA
  • CNPJ: 44.085.425/0001-16
  • Address: Av Uruguai 1076, Belo Horizonte – Minas Gerais, Brazil
  • Contact email: support@registraa.com
  • Data Protection Officer: AMC Marketing LTDA – support@registraa.com

2. Scope

This Policy applies to the Registra iOS app and the official website (support, marketing, and forms).

3. Data we collect

  • Account & Identity: name, email, authentication IDs (Apple/Google), preferred language; profile photo if you provide it.
  • Technical credentials: session tokens (Firebase Auth).
  • User content: records, notes, attachments (images/files), exported PDFs, audio recordings (if used).
  • Optional integrations:
    • Calendar/Reminders (EventKit): metadata of events you create via the app.
    • Siri Shortcuts/Intents: shortcut activities and phrases (the app does not record voice).
  • Notifications: local notification preferences and device tokens (local notifications only; no remote push by us).
  • Technical data: device and system information required for operation and diagnostics (minimum necessary).
  • Payments/Subscriptions: processed by Apple (StoreKit/App Store). We receive status/technical receipts; we do not collect card numbers.
  • Website (cookies): essential cookies only, unless otherwise indicated in a site banner.

Note: Records, attachments, and audio may contain sensitive data entered by you.

4. Legal bases and purposes

  • Contract performance: run the app, authenticate, sync/store data, generate PDFs, create events/reminders.
  • Consent: microphone, camera, photos, calendar/reminders, notifications, Siri; non‑essential cookies on the site (if any).
  • Legitimate interests: security, abuse prevention, service improvement.
  • Legal obligation: compliance with lawful requests and applicable regulations.

5. How we use your data

  • Provide and personalize the service (including language).
  • Create/manage records, attachments, and exports (PDF).
  • Record audio and associate it with records (if enabled).
  • Create calendar events/reminders (if enabled).
  • Send local notifications.
  • Customer support and transactional communications.
  • Ensure security, integrity, and improvement of the app.

6. Sharing with third parties

We share only what is necessary to operate the service:

  • Authentication & backend (Firebase – Google): Firebase Auth, Firestore, Storage. Policy: policies.google.com/privacy
  • Social login: Google Sign‑In (Google), Sign in with Apple (Apple). Apple: apple.com/legal/privacy
  • Payments: Apple App Store/StoreKit (subscription processing and management).
  • Notifications: local notifications (no push through our own servers).
  • Siri/Intents, Calendar/Reminders: executed on‑device with your consent.

We do not sell personal data. We may disclose information when required by law or to protect rights/users.

Note on remote translation: technical support exists for translation services (e.g., Google Cloud Translate), but it is off by default. If enabled in the future, text you submit for translation may be sent to the provider solely for that purpose.

7. International transfers

Data processed by Google/Firebase may be transferred outside Brazil. We adopt appropriate safeguards such as standard contractual clauses and security controls.

8. Retention

  • Account and content: while your account is active or until you request deletion.
  • Records/attachments/audio: until you delete them in the app or request removal.
  • Technical/diagnostic logs: typically up to 12–24 months unless legally required otherwise.
  • Backups: kept for limited periods for service continuity.

Upon a deletion request, we will delete or anonymize data except for legal retention.

9. Security

Encryption in transit (TLS) and, when applicable, at rest; access controls and monitoring; backups and secure development practices. No measure is 100% foolproof—please protect your device and credentials.

10. Cookies (website)

  • Essential: site operation and security.
  • Analytics/Marketing: not used by default. If implemented, we will inform you in the site consent banner.

11. Your rights (LGPD and equivalents)

Depending on your jurisdiction, you may:

  • Access, correct, update, and delete data.
  • Exercise portability, restriction, and objection rights.
  • Withdraw consent at any time (without affecting prior lawful processing).
  • Complain to the ANPD (Brazil) or your local authority.

To exercise your rights: support@registraa.com. We may request identity verification.

12. Children and teens

Not intended for children under 13. In jurisdictions with a higher age threshold, guardian consent may be required.

13. Device permissions (iOS)

  • Microphone: record audio.
  • Camera & Photos/Files: attach images/files.
  • Calendar & Reminders: create/manage events and reminders.
  • Notifications: send local reminders.
  • Siri/Shortcuts: perform voice/shortcut actions.

You can revoke permissions in iOS settings.

14. Automated decisions

We do not perform decisions with legal effects based solely on automated processing.

15. Consequences of not providing data

Without certain data/permissions (e.g., authentication, calendar, microphone), some features will not function.

16. Changes to this Policy

We may update this Policy periodically. We will publish the current version in the app/site. Material changes may be notified by email or in‑app notice.

17. Contact

Note: This document is informational and does not constitute legal advice.