Privacy Policy | Ventrue Technologies

1. Who we are and what this policy covers

Ventrue Technologies is the trade name of Erick Escobar, a sole proprietor registered in Quito, Ecuador, who is the data controller for the data described here ("Ventrue", "we").

This policy covers:

The website ventrue.com.ec and its forms.
Our apps ("the Apps"): those published on Google Play and those used in a browser, whether free with ads, paid, or with in-app purchases. They include Zercoppy, The Daily Dao, AI Coach, Orb Finance, Housing Scout, Prediction Pool and Dao of Chaos.
The professional services we provide to companies and institutions.

An App may also have its own privacy annex, linked from its Google Play listing, with details specific to that App. Where the annex and this policy differ, the annex prevails for that App.

2. What data we collect

2.1 On the website

Contact form: name, email, phone (optional), company, service of interest and your message.
Browsing: pages visited, device, browser and approximate location (country or city), only if you accept analytics cookies.

2.2 In the Apps

Each App collects only what its features need. Depending on the App, it may process:

Account: an anonymous identifier or, if you sign in with Google, your name, email and profile photo.
Content and preferences: what you record or configure in the App (for example, your trade and provinces in Zercoppy, your sessions in The Daily Dao or your workouts in AI Coach).
Health and fitness: only with your explicit permission (for example, steps from Health Connect, or weight and workouts you log). See section 6.
Financial information you enter or connect in personal-finance apps. See section 6.
Device and diagnostic data: model, OS version, language, crash and performance logs.
Advertising ID and ad interactions: in ad-supported versions. See section 4.
Purchases: the record that you bought or subscribed. Payment is processed by Google Play; we never receive your card details.

2.3 In client services

Business and billing data: company name, tax ID, contacts, billing address and payments.
Project data: information a client entrusts to us to do the work. For that data we act as a data processor, under the contract and its confidentiality terms.

3. Why we use data and on what legal basis

To provide the service or App you asked for: create your account, store and sync your information, show results. Basis: performance of a contract or the terms of use.
To show and measure ads in free versions. Basis: consent where the law requires it for personalised ads; legitimate interest for non-personalised ads.
To fix bugs, measure performance and improve the Apps. Basis: legitimate interest.
Security: preventing fraud, abuse and unauthorised access. Basis: legitimate interest.
To answer enquiries and provide support. Basis: your request and our legitimate interest.
To meet legal obligations, including tax obligations. Basis: legal obligation.
To send you news, only if you opt in, and you can unsubscribe at any time. Basis: consent.

We do not sell your personal data.

4. Advertising in the Apps

Free versions of some Apps show ads through Google AdMob. To show and measure ads, AdMob may collect the device advertising ID, IP address, device information and your interaction with ads. Google processes that data under its advertising policy and privacy policy.

Personalised ads: where the law requires your consent, we ask for it when you open the App and you can change your choice in its settings. Without consent, ads are non-personalised.
You can limit advertising on Android under Settings → Privacy → Ads, where you can reset or delete your advertising ID.
We never use health or financial data to show ads, and we never share it with advertisers.
Minors: we do not show personalised ads to users we know to be minors.
Some Apps offer a purchase or subscription to remove ads.

5. Who we share data with

Only with those needed to provide the service, under contracts or terms that protect the data:

Google: Google Play (distribution and payments), Firebase (authentication, app analytics and crash reporting), Sign in with Google, Health Connect (only with your permission) and AdMob (ads).
Cloud hosting and database providers that store information on our behalf.
Artificial-intelligence model providers, only when you use an AI feature and only with the content that feature needs. See section 7.
Email services to send you notices you asked for.
Authorities, when a law or a competent order requires it.

6. Health data and financial data

These are sensitive categories and get stricter treatment:

We process them only with your explicit permission, which you can withdraw at any time in the App or in your phone settings.
We use them only for the feature you see in the App (for example, turning steps into progress or adjusting your training).
We do not use them for advertising, we do not sell them, and we do not share them with advertisers or third parties for their own purposes.
Data read from Health Connect is used in line with the Health Connect permissions policy, including its limited-use requirements.

7. Artificial-intelligence features

Some Apps generate results with AI models (for example, a workout or a document summary). To do so, we send the model provider the content that task needs. Where the provider allows it, we choose settings under which the provider does not use that content to train its models. AI results can contain errors: review them before acting on them and avoid entering data that is not needed.

8. International transfers

Some of our providers process data outside Ecuador, for example in the United States. When that happens, we use providers that offer adequate safeguards, in line with Ecuador's Organic Law on Personal Data Protection (LOPDP).

9. How long we keep data

App account and content: while your account is active. When you delete it, we erase your personal data within 30 days.
Technical and security logs: up to 90 days.
Website enquiries: up to 24 months after the last contact.
Billing and accounting: as long as Ecuadorian tax law requires.
Aggregated, anonymous data that no longer identifies you may be kept for statistics.

10. Security

We encrypt data in transit, limit access to the people and systems that need it, and review our measures periodically. No system is infallible: if a breach affecting your data occurs, we will tell you and notify the authority within the time limits set by law.

11. Your rights

Under the LOPDP you can:

Access your data and learn how we process it;
Rectify data that is incomplete or inaccurate;
Erase your data;
Object to processing or ask us to suspend it;
Receive your data in a portable format;
Not be subject to decisions based solely on automated processing that significantly affect you;
Withdraw your consent at any time;
Lodge a complaint with Ecuador's Superintendency of Personal Data Protection.

Email info@ventrue.com.ec with the subject "Data protection". We reply within 15 days at most.

12. Deleting your account and data

You can delete your account from the App's settings where the option is available, or by following the steps at ventrue.com.ec/en/delete-account. You can also ask us to erase some data without closing your account.

13. Children

Our Apps are not directed at children under 13 and we do not knowingly collect their data. Teenagers should use them with the knowledge of a parent or guardian where the law requires it. If we learn that we collected a minor's data without the necessary authorisation, we delete it. If you believe this happened, contact us.

14. Website cookies

Essential: remember your language and your cookie choice. No consent required.
Analytics: only enabled if you accept them in the cookie banner, and you can change your choice at any time.

15. Changes to this policy

If we change this policy in a meaningful way, we will update the date above and let you know in the App or by email before the change takes effect.

16. Contact

Controller: Erick Escobar — Ventrue Technologies
Email: info@ventrue.com.ec
City: Quito, Ecuador