Privacy Policy

1. Data Controller and Contact

Data Controller: [LEGAL ENTITY NAME]
Registered address: [REGISTERED ADDRESS]
Email: hello@berimbolo.io
Data Protection Officer (if applicable): [DPO CONTACT]

2. Personal Data We Collect

• Account data: name, email, authentication identifiers, verification status.
• Profile data: belt, style, training goals, optional health/injury context, date of birth, weight.
• Training data: journal entries, techniques, session notes, ratings, mat time, and metadata.
• Video workflow data: saved video links, tags, notes, and learning outcomes.
• Device and technical data: platform, app version, build, locale, timezone, device model, notification tokens.
• Diagnostics and telemetry: crash reports, performance traces, and analytics events.
• Communications data: support requests and legal/compliance correspondence.

3. Purposes and Legal Bases

We process personal data for the following purposes and legal bases (as applicable):

• Contract performance: operate core app features, account access, sync, and user-requested functionality.
• Legitimate interests: service reliability, abuse prevention, fraud/security monitoring, product improvement.
• Consent: push notifications (where required), optional marketing communications (if enabled).
• Legal obligations: compliance with applicable law, audits, and law-enforcement requests.

4. Data Sharing and Disclosure

We do not sell personal data. We may disclose personal data to:

• Cloud/infrastructure and platform service providers.
• Authentication, messaging, analytics, and observability providers.
• Professional advisors (legal, audit, compliance) under confidentiality obligations.
• Authorities where required by law or legal process.
• Acquirers/successors in connection with mergers, acquisitions, or asset transfers.

Where required, we execute appropriate data processing agreements with service providers.

5. International Data Transfers

Personal data may be processed in countries other than your own. Where required by law, we rely on recognized transfer mechanisms (for example, Standard Contractual Clauses) and supplementary safeguards.

6. Data Retention

We retain personal data for as long as necessary for the purposes described in this Policy, including maintaining your account, providing requested features, resolving disputes, enforcing agreements, and complying with legal obligations.

Retention periods are determined by data type, sensitivity, legal requirements, and operational necessity. More specific schedules may be provided in internal retention policies.

7. Security Measures

We implement technical and organizational measures designed to protect personal data, including access controls, encryption in transit where applicable, logging/monitoring, and incident response processes.

No system is fully secure. You are responsible for safeguarding credentials and using secure devices/networks.

8. Your Privacy Rights

Subject to applicable law, you may have rights to:

• Access personal data we hold about you.
• Request correction of inaccurate or incomplete data.
• Request deletion of personal data.
• Request restriction of processing.
• Object to certain processing activities.
• Request data portability.
• Withdraw consent where processing is based on consent.
• Lodge complaints with supervisory authorities.

To exercise rights, contact hello@berimbolo.io. We may require identity verification before fulfilling requests.

9. Cookies and Similar Technologies

The website and app-related services may use cookies, SDKs, and similar technologies for authentication, preferences, security, analytics, and performance. Additional cookie disclosures may be provided where required.

10. Children's Privacy

The Service is not directed to children under the minimum age permitted by applicable law. If we learn that personal data was collected from a child unlawfully, we will take appropriate steps to delete such data.

11. Automated Decision-Making

Berimbolo does not currently use automated decision-making that produces legal or similarly significant effects, except as may be explicitly disclosed in future updates.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through reasonable channels (for example, in-app notice, website update, or email where required).

13. Contact and Complaints

For privacy inquiries or complaints: hello@berimbolo.io

Legal/Controller details:
Marcio Vieira
Ireland
Contact: berimbolo@twomindslab.com