Courtesy translation. The Portuguese (pt-BR) text is the authoritative version. Read the Portuguese version
Sections
- 1. Who controls the data
- 2. In short
- 3. Which data we handle
- 4. Why we use data and the legal basis
- 5. Children's data (art. 14 of the LGPD)
- 6. Who we share data with
- 7. International transfer
- 8. No ads
- 9. Cookies, SDKs and identifiers
- 10. How long we keep data
- 11. Security
- 12. Your rights (art. 18 of the LGPD)
- 13. How to exercise your rights in the app
- 14. Data protection officer (DPO) and ANPD
- 15. Changes to this Policy
Here we explain, in plain words, which data NEAR handles, why, who we share it with and how you exercise your rights, under the Brazilian General Data Protection Law (LGPD, Law No. 13,709/2018).
1. Who controls the data
The controller, who decides how your personal data is handled in NEAR, is Liga Labs (DAVISON PATROCINIO CARDOSO, MEI), registered under CNPJ No. 69.627.558/0001-06, headquartered at Ipatinga, MG, Brazil (website: ligalabs.com/near).
The data protection officer (DPO) is Davison Patrocinio Cardoso, reachable at contato@ligalabs.com.
2. In short
What you should know right away:
- Children's profiles (name, age and optional photo) stay only on your device. We do not send them to our servers or to third parties.
- Favorites, history and saved tips also stay only on the device.
- We use your name and e-mail to create and protect your account and to send important e-mails.
- We measure app usage with pseudonymous statistics. You can turn this off at any time in Privacy and data.
- You can download your data and delete your account inside the app.
- We do not sell personal data.
3. Which data we handle
We handle the categories of data below, depending on how you use the app.
- Guardian account data: name, e-mail and, if you provide it, phone. The password is managed by the authentication service and is never visible to us. When you sign in with Google we receive the name and e-mail of your Google account. The phone, when provided, stays only on the device.
- Children's profiles: first name, age and optional photo, kept only on the device.
- Use of the app on the device: favorites, activity history, saved tips, language, theme (light or dark) and preferences.
- Usage statistics (Google Firebase Analytics): a pseudonymous identifier (the account code, never the e-mail), screens visited, taps and usage events (such as opening an activity), language, theme, NEAR Access status and validity, number of child profiles and a local technical code for each profile, without name, age or photo. We do not send your e-mail or the text of your searches.
- NEAR Access purchase: using NEAR requires NEAR Access, bought on the Bigbot platform (ligalabs.bigbot.com.br) either directly or bundled with a course/e-book. Bigbot charges and processes the payment. Bigbot shares with us the data needed to identify the purchase and release access, such as name, e-mail and payment status, and we keep the access status and its validity period. We do not receive your card data.
- Technical data: device type, system, app version, IP address and access logs generated when the app talks to our servers.
- E-mails we send: welcome, address verification, password reset, NEAR Access confirmation, new-device sign-in notice and account deletion confirmation.
4. Why we use data and the legal basis
Each use has a purpose and a legal basis under the LGPD (art. 7):
- Create and keep your account, authenticate access and provide the service: performance of a contract (art. 7, V).
- Send service e-mails (welcome, verification, password reset, new-device sign-in notice, NEAR Access activated, account deleted): performance of a contract and, for security notices, legitimate interest (art. 7, V and IX).
- Identify your NEAR Access purchase on Bigbot and unlock its features for the period purchased: performance of a contract (art. 7, V). Keep transaction records for tax and accounting purposes: compliance with a legal obligation (art. 7, II).
- Keep children's profiles on the device to personalize activities: specific consent of the guardian (art. 14, § 1), given when the profile is created, with handling in the best interest of the child.
- Usage statistics to understand what works, fix errors and improve the app: legitimate interest (art. 7, IX). It is on by default and you can object by turning off "Allow usage statistics" in Privacy and data.
- Prevent fraud, abuse and security incidents and comply with orders from authorities: legitimate interest and compliance with a legal or regulatory obligation (art. 7, II and IX).
- Answer your requests: performance of a contract and compliance with a legal obligation (art. 7, II and V).
- Keep the record of your acceptance of the Terms and of this Policy (date and time, versions accepted and IP address) as proof that you accepted: compliance with a legal obligation and regular exercise of rights (art. 7, II and VI).
5. Children's data (art. 14 of the LGPD)
NEAR is meant for adults. Children do not create accounts, do not sign up and do not use the app alone.
The guardian may create profiles to personalize activities with a first name, age and optional photo. This data is kept only on the device, is not sent to our servers or shared with third parties, and is erased when you remove the profile, clear the app data or delete your account.
We handle this data in the best interest of the child, with the specific and prominent consent of one of the parents or the legal guardian, which is given when the profile is created. You can withdraw the consent at any time by removing the profile.
NEAR shows no ads, and children's data is never used for advertising. Statistics and e-mails never use the children's name, age or photo. Statistics only receive the number of profiles and a local technical code with no personal meaning. If you believe a child sent us data on their own, contact us so we can delete it.
6. Who we share data with
We do not sell your data. We share what is needed with suppliers that help us run the app (processors) and with platforms that provide services on their own:
- Google Firebase (Authentication, Analytics, Firestore and Storage): sign-in (e-mail and password, Google), usage statistics, the record of your acceptance of the Terms and the Policy, and delivery of the app catalog and photos.
- Resend: delivery of service e-mails (receives your e-mail, name and the message content).
- Bigbot: sale and payment processing of NEAR Access; shares with us the data needed to identify the purchase and release access (such as name, e-mail and payment status).
- Hosting providers: running our e-mail API.
- Public authorities, when there is a legal obligation or a court order.
7. International transfer
Some of these suppliers (for example, Google and Resend) process data in other countries, such as the United States. When this happens, we make the transfer under art. 33 of the LGPD, using suppliers that offer compatible safeguards, such as contractual clauses and certifications, and, when necessary, with your consent.
8. No ads
The NEAR app shows no ads and does not use the device advertising identifier. App usage data and your children's data are never used for advertising.
9. Cookies, SDKs and identifiers
The app uses third-party SDKs (software kits), such as Firebase, and local storage on the device to work. In the web version we also use browser storage and cookie-like technologies.
They are used to keep you signed in, save preferences and local data, and measure usage (if you allow it). You control statistics in Privacy and data and can clear local data in your device or browser settings.
On this website (ligalabs.com), Google Analytics (visit measurement) and the Meta Pixel (measurement of our ads on Facebook and Instagram) are only loaded if you accept the cookie notice. Without consent, nothing is loaded. You can change your choice under “Cookies” in the footer.
10. How long we keep data
- Account data (e-mail, name, identifier) and acceptance records: while the account exists. When you delete the account in the app, they are erased right away.
- Data kept on the device (children's profiles, favorites, history): until you remove it, clear the app data or delete your account.
- Usage statistics: for the period configured in Firebase Analytics (14 months), without identifying you by name or e-mail.
- Records of e-mails sent: for the retention period of the e-mail provider, for security and support purposes.
- Internet application access logs: for 6 months, where applicable, under the Brazilian Internet Civil Framework (art. 15).
- Purchase records and tax data: for the period required by tax law, by us and by Bigbot under its own policy.
- After these periods, we delete or anonymize the data, unless the law allows or requires keeping it to comply with a legal obligation, exercise rights or defend ourselves in proceedings.
11. Security
We adopt technical and administrative measures to protect data against unauthorized access, loss and misuse, such as encrypted connections (HTTPS), authentication run by a specialized service, restricted access to systems and storage of children's data only on the device.
No system is completely secure. Protect your device (screen lock) and your password. In case of an incident that may bring relevant risk or harm, we will notify you and the Brazilian National Data Protection Authority (ANPD), as the law requires.
12. Your rights (art. 18 of the LGPD)
At any time and free of charge, you can ask for:
- confirmation that we handle your data;
- access to the data;
- correction of incomplete, inaccurate or outdated data;
- anonymization, blocking or deletion of unnecessary or excessive data, or data handled in breach of the law;
- data portability;
- deletion of data handled based on your consent;
- information about who we share data with;
- information about the possibility of not giving consent and the consequences of refusing;
- withdrawal of consent;
- objection to handling based on legitimate interest.
13. How to exercise your rights in the app
Under Profile › Privacy and data you will find:
- Allow usage statistics: turns statistics on or off (objection and withdrawal).
- Download my data: generates a file with your account data and the data kept on the device (access and portability).
- Delete account: requires a code sent to your e-mail and erases everything: the account, the data on our servers (including acceptance records) and the data on this device (deletion). Deleting the account ends NEAR Access.
- Under Profile › My account you correct your name and phone.
- For other requests, write to contato@ligalabs.com. We answer immediately, in simplified form, or within 15 days, by full declaration, under art. 19 of the LGPD.
- Purchase records may be kept by Bigbot and by us for the period required by tax law.
14. Data protection officer (DPO) and ANPD
To talk about privacy, use the officer's e-mail: Davison Patrocinio Cardoso, contato@ligalabs.com.
You may also file a complaint with the Brazilian National Data Protection Authority (ANPD), at www.gov.br/anpd, after contacting us.
15. Changes to this Policy
We may update this Policy. The date at the top of the document shows the current version. For relevant changes, we will notify you in the app and ask you to read and accept again.