Privacy Policy

Introduction

This Privacy Policy applies to all mobile applications published by Thiago Centurion Apps ("we," "us," or "our"). We are committed to protecting your privacy and being transparent about how we handle your data.

This policy covers all current and future apps under the Thiago Centurion Apps brand. By using any of our apps, you agree to the practices described in this policy.

Data Controller

The data controller responsible for your personal data is:

Thiago Centurion Apps (Thiago R. Centurion)

Location: Portugal (EU)

Contact: support@thiagocenturion.com

Information We Collect

App Usage Information

We collect information about how you use our apps to improve functionality and user experience. This includes:

• App features you interact with and how often
• In-app events and actions you perform
• Session duration and frequency
• App settings and preferences

Device Information

To provide technical support and ensure compatibility, we collect:

• Device type, model, and operating system version
• Unique device identifiers (for analytics purposes only)
• App version and build number
• General location information (country/region level only, never precise location)

Purchase and Subscription Data

For apps with in-app purchases or subscriptions, we process:

• Purchase history and subscription status
• Transaction identifiers (not payment card details)
• Subscription renewal and cancellation events

Note: All payment processing is handled securely by Apple through the App Store. We never have access to your credit card or payment information.

Crash Reports and Diagnostics

When our apps crash or experience errors, we automatically collect diagnostic information to fix bugs and improve stability. This includes:

• Crash logs and stack traces
• Device state at time of crash
• Error messages and codes

AI Feature Data (if applicable)

Some of our apps may include AI-powered features (such as image generation, text processing, or intelligent recommendations). For these features:

• User inputs may be processed by third-party AI services
• Generated outputs are stored locally on your device by default
• We may collect anonymized usage metrics for feature improvement
• Personal content is never used to train AI models without explicit consent

Information We Do NOT Collect

We are committed to minimal data collection. We do not collect:

• Your name, email address, or contact information (unless you contact support)
• Precise location data or GPS coordinates
• Photos, videos, or other media from your device (unless explicitly shared through app features)
• Contacts, messages, or other personal data unrelated to app functionality

How We Use Your Information

We use the collected information for the following purposes:

• Providing and improving app functionality
• Analyzing usage patterns to enhance user experience
• Identifying and fixing bugs and crashes
• Managing subscriptions and in-app purchases
• Sending important service notifications (e.g., subscription expiry)
• Developing new features based on user behavior
• Ensuring app security and preventing fraud

We do NOT use your data for advertising or sell it to third parties.

Legal Bases for Processing (GDPR)

For users in the European Economic Area (EEA), UK, and Switzerland, we process your personal data based on the following legal grounds:

• Performance of a Contract: We process data necessary to provide core app functionality, manage subscriptions, and deliver support services you request.
• Legitimate Interests: We process data for app improvement, basic analytics, fraud prevention, and security monitoring. We balance these interests against your rights and only process data when our interests do not override your fundamental rights.
• Consent: Where required, we obtain your explicit consent for certain processing activities (e.g., marketing communications or optional tracking features). You may withdraw consent at any time through app settings or by contacting us.
• Legal Obligation: We process data when required by law, such as for tax compliance, responding to legal requests, or fulfilling accounting obligations.

Service Providers

We use trusted third-party service providers who act as data processors on our behalf. These providers only process data according to our instructions and are contractually obligated to protect your information:

Note: All payment processing is handled directly by Apple through the App Store. We never have access to your full payment card details.

AI Features and Cloud Processing (When Applicable)

Some of our apps may offer AI-powered features (such as image generation, text processing, or intelligent recommendations). When you use these features:

• Your inputs (text prompts, uploaded content, etc.) may be sent to third-party AI service providers to generate outputs
• Content is processed only to provide the requested feature and may be stored temporarily for reliability and security purposes
• We do not use your content to train third-party AI models unless explicitly disclosed within the app and with your consent
• Generated outputs are typically stored locally on your device by default
• We select AI providers with strong privacy commitments and data protection practices

For apps with backend services (cloud sync, data backup, or real-time features), data is hosted on secure cloud infrastructure and follows the same privacy principles outlined in this policy.

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal obligations. Our retention practices include:

• Analytics data: Retained for up to 2 years to enable trend analysis and product improvement
• Crash reports: Retained until the issue is resolved, typically no longer than 90 days
• Purchase and subscription data: Retained as required by applicable tax, accounting, and consumer protection laws (typically 7-10 years)
• Account data (if applicable): Retained until you request account deletion or as required by law
• Support correspondence: Retained for up to 3 years to maintain service quality and handle follow-up inquiries

When data is no longer needed for its original purpose and we are not legally required to retain it, we securely delete or anonymize it. Anonymized data may be retained indefinitely for statistical and research purposes.

Your Rights (EEA, UK, and Switzerland)

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have the following rights under GDPR and equivalent laws:

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete personal data
• Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data, subject to legal retention requirements
• Right to Restriction of Processing: Request that we limit how we use your data in certain circumstances
• Right to Data Portability: Request your data in a structured, commonly used, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for direct marketing purposes
• Right to Withdraw Consent: Where processing is based on consent, withdraw it at any time without affecting prior processing

How to Exercise Your Rights

To exercise any of these rights, please contact us at support@thiagocenturion.com with your request. Please include:

• Your app name or device identifier (if applicable)
• A clear description of your request
• Any information that helps us verify your identity

We will respond to your request within 30 days. If we need additional time, we will notify you of the extension and the reasons for it. We do not charge a fee for processing valid requests unless they are excessive or unfounded.

Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority in your country of residence, place of work, or place of alleged infringement if you believe we have violated your data protection rights.

For users in Portugal, the supervisory authority is the Comissão Nacional de Proteção de Dados (CNPD). For users in other EEA countries, please contact your local data protection authority.

Data Security

We implement industry-standard security measures to protect your data:

• Encryption in transit (HTTPS/TLS)
• Encryption at rest for sensitive data
• Regular security audits and updates
• Limited employee access to user data
• Secure cloud infrastructure with reputable providers

However, no system is 100% secure. We cannot guarantee absolute security but continuously work to protect your information.

Children's Privacy

Our apps are not intended for use by children under the age of 13 (or the minimum age required in your jurisdiction). We do not knowingly collect personal information from children.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us at support@thiagocenturion.com and we will promptly delete such information from our systems.

International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States, where our service providers operate. These countries may have different data protection laws than your jurisdiction.

When we transfer personal data outside the EEA, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions by the European Commission recognizing equivalent data protection
• Service provider certifications and binding corporate rules where applicable

You may contact us to obtain more information about the safeguards we use for international transfers or to request a copy of relevant documentation.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make significant changes, we will:

• Update the "Effective Date" at the top of this page
• Notify you through the app or via email (if we have your email)
• Post the updated policy on this website

Continued use of our apps after changes constitutes acceptance of the updated policy.

Contact Us

If you have questions about this Privacy Policy or how we handle your data, please contact us:

Email: support@thiagocenturion.com

We aim to respond to all inquiries within 48 hours.