Privacy Policy for Red Flag App

Effective Date: August 5, 2025
Last Updated: August 5, 2025

1. INTRODUCTION

This Privacy Policy explains how POCKET IMPLEMENTATION S.R.L. ("we," "us," "our," "Company") collects, uses, and protects information when you use the Red Flag App ("App" or "Services").

PRIVACY BY DESIGN: The App is built with your privacy as a fundamental principle. We do not require accounts, minimize data collection, and keep your sensitive data on your device.

2. INFORMATION WE DO NOT COLLECT

To protect your privacy, we DO NOT collect or have access to:

• Your name or identity
• Your relationship data or events
• Your personal safety scores
• Content of your relationship tracking
• Your location data
• Your contacts or social connections
• Any personally identifiable information stored in the App

3. INFORMATION STORED LOCALLY ON YOUR DEVICE

The following sensitive data remains ONLY on your device and is NEVER transmitted to us:

• All relationship events (positive and concerning)
• Event descriptions and details
• Evidence (photos, audio recordings)
• Safety scores and assessments
• Personal insights and patterns
• Relationship information
• Educational content progress
• App settings and preferences

This data is encrypted on your device and only accessible to you.

4. LIMITED INFORMATION WE PROCESS

4.1 Chat Analysis Feature (Premium)

When you use the chat analysis feature:

• Images are transmitted to our servers in the US
• Images are immediately processed by Google AI services
• Images are NOT stored - they are deleted immediately after processing
• Only the analysis results are returned to your device
• We do not retain any record of the images or analysis

4.2 Anonymous Analytics

We collect anonymous usage data through Firebase Analytics:

• App performance metrics
• Feature usage statistics (anonymous)
• Crash reports
• Device type and OS version
• General country location
• No personally identifiable information

4.3 Subscription Information

RevenueCat processes:

• Subscription status
• Purchase history
• Anonymous user ID
• No payment details (handled by Apple/Google)

5. HOW WE USE INFORMATION

The limited information we process is used to:

• Provide chat analysis results (immediately deleted)
• Improve app performance and fix bugs
• Understand feature usage patterns
• Manage subscriptions through RevenueCat
• Ensure service security

6. DATA SHARING AND DISCLOSURE

6.1 Service Providers

We share limited data with:

• Google (AI processing for chat analysis - images immediately deleted)
• Firebase (Google) for anonymous analytics
• RevenueCat for subscription management
• Apple/Google for payment processing

6.2 No Sale of Data

WE DO NOT AND WILL NEVER:

• Sell your data
• Share your personal information with third parties
• Use your data for advertising
• Create profiles about you
• Track you across apps or websites

6.3 Legal Disclosure

We may disclose information only if required by law to:

• Comply with legal process
• Protect against imminent harm
• Protect our legal rights
• Prevent fraud or security threats

7. DATA SECURITY

We implement security measures including:

• Encrypted transmission for chat analysis
• No server storage of personal data
• Secure API endpoints
• Regular security assessments
• Limited employee access

However, no system is 100% secure. You are responsible for protecting your device access.

8. DATA RETENTION

• Device data: Retained until you delete the app
• Chat analysis images: Never stored (immediate deletion)
• Analytics data: Anonymous data per Firebase policies
• Server logs: No personal data logged
• Subscription data: Per RevenueCat and platform policies

9. YOUR PRIVACY RIGHTS

9.1 Your Rights Include:

• Access: Request information about data processing
• Deletion: Delete the app to remove all local data
• Opt-out: Disable analytics in device settings
• Correction: Edit your data within the app

9.2 Exercising Rights

Since we don't collect personal data:

• Local data: Manage through the app or delete the app
• Analytics: Use device settings to limit tracking
• Subscriptions: Manage through App Store/Play Store

9.3 GDPR Rights (EU Users)

• Legal basis: Legitimate interests (app functionality)
• Data controller: POCKET IMPLEMENTATION S.R.L.
• No personal data transferred outside EU (only anonymous analytics)

9.4 CCPA Rights (California Users)

• We don't sell personal information
• We don't collect personal information beyond anonymous analytics
• Right to opt-out of analytics via device settings

10. CHILDREN'S PRIVACY

The App is not directed to children under 13. We do not knowingly collect data from children under 13. Users under 18 must have parental consent.

11. INTERNATIONAL DATA TRANSFERS

Limited data may be processed in:

• United States (chat analysis AI processing - immediately deleted)
• Your app store region (subscription data)

By using the App, you consent to these transfers.

12. THIRD-PARTY SERVICES

The App integrates with:

• Google AI (chat analysis - no data retention)
• Firebase Analytics (anonymous data)
• RevenueCat (subscription management)
• Apple App Store / Google Play Store

These services have their own privacy policies.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy. Material changes will be notified through the App. Continued use after changes indicates acceptance.

14. DATA PROTECTION

We comply with applicable data protection laws including:

• GDPR (European Union)
• CCPA (California)
• LGPD (Brazil)
• Other applicable privacy laws

15. SECURITY INCIDENTS

In the unlikely event of a data breach affecting personal data (which we don't collect), we will notify affected users as required by law.

16. DO NOT TRACK

The App does not respond to Do Not Track signals as we don't track users across websites or apps.

17. YOUR CONSENT

By using the App, you consent to:

• Processing of images for chat analysis (immediately deleted)
• Collection of anonymous analytics
• Subscription management through RevenueCat

18. CONTACT INFORMATION

For privacy inquiries or to exercise your rights:

POCKET IMPLEMENTATION S.R.L.
Data Protection Contact
Email: contact@pocketimplementation.com

For the quickest response, please include "Privacy" in your subject line.

19. LIABILITY DISCLAIMER

TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE FOR ANY DAMAGES ARISING FROM:

• Privacy breaches beyond our control
• Unauthorized access to your device
• Your sharing of device access
• Third-party actions
• Force majeure events

Remember: Your privacy is protected by keeping your sensitive data on your device. We cannot access your personal relationship information.