PRIVACY POLICY


Last update: 02/06/2026
This Privacy Policy describes how RhumbLabs, RUT 19.524.712-9 (the "Company"), collects, uses, stores, and protects the personal data of users of the Pogo (the "Application").
This Privacy Policy should be read in conjunction with the Terms of Use of the Application. By using the Application, the User agrees to the practices described in this document.
This policy is governed by Chilean Law N° 19.628 on the Protection of Privacy, Law N° 19.496 on Consumer Protection, and Law N° 21.719 on the Protection and Processing of Personal Data.
The Company is the data controller responsible for the personal data processed through the Application and can be contacted at: support@rhumblabs.com
By using the Application, the User acknowledges having read and understood this Privacy Policy. This Privacy Policy forms an integral part of the Terms of Use of the Application.
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1. Data We Collect


The Application collects only the data necessary to provide its core functionalities. Depending on how the User interacts with the Application, the following categories of personal data may be collected:
- Account Data: Email address and, where applicable, name and profile information provided through Google Sign-In at the time of registration. - Profile and Preferences: Display name, avatar, skill level, personal goals, session type preferences, language, theme, and dashboard configuration set by the User within the Application. Certain profile information, including display name, avatar, skill level, statistics, achievements, and rankings, may be visible to other users of the Application when the User shares their profile via QR code. - Gym Data: Name, location, coordinates, type, and difficulty levels of climbing gyms associated with the User's account. - Support Data: Email address and content of messages sent voluntarily by the User to RhumbLabs support. - Legal Acceptances: Record of the version of the Terms and Privacy Policy accepted by the User, including date and time of acceptance. - Session Data: Climbing session records entered by the User, including routes, difficulty levels, gym visited, dates, and personal notes. - Location Data: Geographic coordinates of the device collected solely when the User enables the gym proximity feature. This data is used exclusively to identify nearby climbing gyms within a 200-meter radius and is not stored permanently. - Camera Data: The device camera is accessed solely for QR code scanning, to allow the User to view other users' profiles. No images or videos are captured, stored, or transmitted. - Usage and Technical Data: Information about how the User interacts with the Application, crash reports, and technical diagnostics, collected through Firebase Analytics and Firebase Crashlytics. - Advertising Data: If the User is on the free version of the Application, Google AdMob may collect data related to ad interactions and device identifiers in accordance with Google's advertising policies.
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2. How We Collect Data


Data is collected through the following means:
- Directly from the User, when registering an account, logging climbing sessions, or interacting with Application features. - Automatically, through Firebase services integrated into the Application, which collect technical and usage data during normal use. - Through third-party authentication, when the User chooses to sign in via Google.
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3. Purpose of Data Processing


The personal data collected is used exclusively for the following purposes:
- To create and manage the User's account. - To enable the core features of the Application, including session logging, gym proximity detection, and profile sharing via QR code. - To synchronize, back up, and protect User data stored in the Application. - To analyze usage patterns and improve Application performance and user experience. - To detect and resolve technical errors and crashes. - To display personalized or contextual advertising in the free version of the Application. - To process and validate the one-time in-app purchase for the ad-free version. - To respond to User support requests and inquiries.
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4. Legal Basis for Processing


In accordance with Chilean Law N° 19.628 and Law N° 21.719, the processing of personal data is carried out on the following legal bases:
- Consent: The User actively accepts these terms upon first use of the Application. Location and camera access require explicit permission granted by the User through the device's operating system. - Contractual necessity: Processing is necessary to provide the services described in the Terms of Use. - Legitimate interest: Technical data and crash reports are processed to maintain the security and proper functioning of the Application. - Legal obligation: Where required by applicable Chilean law.
Users may withdraw their consent at any time by contacting RhumbLabs at support@rhumblabs.com or by revoking the relevant device permissions through their device settings. Withdrawal of consent does not affect the lawfulness of processing carried out prior to its withdrawal. Withdrawal of consent for optional features, such as location access, usage analytics, crash reporting, or personalized advertising, will not prevent the User from accessing the core functionalities of the Application. Only those features that strictly depend on the revoked permission will be affected.
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5. Third-Party Services and Data Processors


The Application uses the following third-party services, which may process personal data on behalf of RhumbLabs. Each service operates under its own privacy policy:
- Firebase Authentication (Google LLC): Manages user login and identity verification. - Firebase Cloud Firestore (Google LLC): Stores User session data and Application content in the cloud. - Firebase Analytics (Google LLC): Collects usage and behavioral data, which may include pseudonymous identifiers, to help improve the Application. - Firebase Crashlytics (Google LLC): Collects crash and error reports to detect and fix technical issues. - Firebase App Check (Google LLC): Verifies the authenticity of requests made to the Application's backend. - Firebase Remote Config (Google LLC): Allows remote configuration of Application features without requiring an update. - Google AdMob (Google LLC): Manages advertising in the free version of the Application.
All Firebase services are operated by Google LLC, headquartered in the United States. Users may consult Google's Privacy Policy at: https://policies.google.com/privacy
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6. Advertising and Personalization


The free version of the Application may display personalized or non-personalized advertisements through Google AdMob.
Personalized ads may be based on the User's previous behavior and interests. Non-personalized ads do not use behavioral history but may still use contextual information, approximate location, device identifiers, and technical data for purposes such as frequency capping, aggregate measurement, and fraud prevention.
Users may manage their advertising preferences through their device settings (iOS: Settings > Privacy & Security > Tracking; Android: Settings > Google > Ads).
RhumbLabs does not sell personal data. If new advertising partners or advanced personalization features are incorporated, this Privacy Policy will be updated accordingly.
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7. International Data Transfers


Some of the third-party services listed above may process personal data on servers located outside of Chile, including in the United States. Where such transfers occur, they are carried out in accordance with the data protection standards required by Chilean law and subject to the terms and data processing agreements established with each service provider.
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8. Data Retention


Personal data is retained for as long as the User's account remains active. Upon account deletion, personal data will be deleted within 30 days, except where retention is required by applicable law or for legitimate security purposes.
Session data and account information stored through Firebase Cloud Firestore will be deleted in accordance with the data deletion process initiated upon account termination.
Data files exported or backed up by the User from within the Application remain under the User's own control. RhumbLabs is not responsible for the storage, sharing, or use of files that the User saves or manages outside of the Application.
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9. Children’s Privacy


The Application is not directed at children under the age of 13. RhumbLabs does not knowingly collect personal data from users under 13 years of age. If the Company becomes aware that a user under 13 has created an account, the account and associated data will be deleted without prior notice.
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10. User Rights


Under Chilean Law N° 19.628 and Law N° 21.719, Users have the following rights regarding their personal data:
- Right of access: To request information about what personal data is held and how it is being processed. - Right of rectification: To request correction of inaccurate or incomplete data. - Right of deletion: To request the deletion of personal data, subject to legal retention obligations. - Right of opposition: To object to the processing of personal data in certain circumstances. - Right to data portability: To request a copy of personal data in a structured and commonly used format, where technically feasible.
To exercise any of these rights, Users may contact RhumbLabs at support@rhumblabs.com. Requests will be addressed within the timeframes established by applicable Chilean law.
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11. Data Security


RhumbLabs implements reasonable technical and organizational measures to protect personal data against unauthorized access, loss, alteration, or disclosure. These measures include the use of Firebase App Check for backend security, encrypted data transmission, and access controls within the Application's infrastructure.
However, no method of electronic transmission or storage is completely secure. RhumbLabs cannot guarantee absolute security of personal data.
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12. Security Incidents


RhumbLabs maintains internal procedures to detect, evaluate, contain, and document security incidents that may affect personal data. In the event of a security breach that poses a risk to Users' rights, RhumbLabs will notify affected Users through reasonable means within the timeframes required by applicable Chilean law, including the obligations established under Law N° 21.719.
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13. Modifications to this Policy


RhumbLabs may update this Privacy Policy at any time. Users will be notified of material changes through an in-app notice or by email. Continued use of the Application following such notification constitutes acceptance of the updated policy.
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14. Contact


For questions, requests, or complaints regarding this Privacy Policy or the processing of personal data, Users may contact RhumbLabs at:
Email: support@rhumblabs.com
Users also have the right to file a complaint before the relevant Chilean data protection authority or competent courts where applicable.