Privacy Policy

1. Data Controller

AUDORA TECH SAS, domiciled in Argentina, is the data controller responsible for the personal data collected through the RUTHY mobile application. Full corporate details are provided upon request via ruthy@audoratech.com.

Contact: ruthy@audoratech.com

Right to information: In accordance with Argentina's Law 25.326, you have the right to be informed about the existence of databases, their purpose, and the identity of the controller. This policy fulfills that right.

2. Personal Data We Process

In RUTHY, we process the following personal data when you use our application:

2.1. Authentication Data

When you sign in via Google, Apple, or Facebook, we receive and store:

• Email address
• Full name
• Profile image (optional)
• Unique identifier from the authentication provider

This data is provided directly by the identity provider you choose and is necessary to create and maintain your account.

2.2. Geolocation Data

RUTHY uses your real-time location exclusively at the device level to:

• Identify nearby points of interest and display them on the map
• Automatically activate audio guides when you approach historical sites
• Enhance your urban exploration experience

Important: We do not save or store your location. Real-time location is used exclusively on your device to guide you through the city. Your location does not reach our servers and is not stored anywhere.

User control: You can disable location access at any time from your device settings. If you disable geolocation, audio guides must be activated manually.

2.3. In-App Purchases

When you make in-app purchases to unlock cities:

• Transactions are processed entirely by the Apple App Store or Google Play Store
• We do not store or have access to credit card or payment method information
• We only receive purchase confirmation and transaction ID to activate the corresponding content

2.4. Usage and Analytics Data

We collect aggregated and anonymous information about app usage to improve our service:

• Pages and sections visited
• App usage time
• Interactions with audio guides and maps
• Device information (model, operating system, version)
• Performance data and technical errors

This data is processed in aggregate form and does not allow for individual identification.

Automated decision-making and profiling: RUTHY does not use fully automated decision-making or profiling that produces legal effects or significantly affects users. All service-related decisions are supervised and controlled by human personnel.

2.5. Offline Content

When you unlock a city, audio files, images, and map data are downloaded and stored locally on your device to allow offline access. This data remains solely on your device and is not shared with third parties.

3. Legal Basis and Processing Purposes

We process your personal data on the following legal bases:

• Contract performance: Authentication, geolocation, and purchase data are necessary to provide the service you requested when using RUTHY.
• Consent: We request your explicit consent to access your location and for the use of cookies and tracking technologies.
• Legitimate interest: We process aggregated usage and analytics data to improve the app, fix bugs, and develop new features.
• Legal compliance: We retain transaction records as required by applicable tax and commercial laws.

4. Data Retention

We retain your personal data for the following periods:

• Account data: While your account is active or as necessary to provide you the service. If you delete your account, we will erase your data within 30 days.
• Geolocation data: Processed in real-time and not stored on our servers.
• Purchase records: Retained for 10 years in accordance with Argentine tax and accounting obligations.
• Analytics data: Retained in aggregated and anonymous form without time limit.

5. Sharing Data with Third Parties

We share your data only with:

• Authentication providers: Google, Apple, Facebook (solely for the sign-in process).
• Payment platforms: Apple App Store and Google Play Store (to process in-app purchases).
• Service providers: Hosting, analytics, and technical support services acting as data processors under strict confidentiality agreements.

We do not sell or share your personal data with third parties for marketing purposes.

6. International Transfers

Some of our service providers may be located outside Argentina. In these cases, we ensure adequate protection mechanisms are in place, such as:

• Approved standard contractual clauses
• Recognized privacy certifications
• Adequacy decisions issued by competent authorities

All international transfers of personal data are conducted under adequate protection mechanisms, including Standard Contractual Clauses (SCC) approved by the European Commission or other equivalent mechanisms recognized by data protection authorities, ensuring that your personal data receives an adequate level of protection in accordance with GDPR and Law 25.326.

6.5. EU Representative

In accordance with GDPR Article 27, AUDORA TECH SAS, being established outside the European Union but offering services to EU residents, is in the process of designating an EU Representative. Once designated, the representative's contact information will be published in this privacy policy and updated in the mobile application.

In the meantime, for any inquiries related to the processing of EU residents' data, you may contact us directly at ruthy@audoratech.com.

7. Your Rights

In accordance with Argentina's Law 25.326 on Personal Data Protection and GDPR (if applicable), you have the following rights:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Correct inaccurate or incomplete data.
• Erasure: Request deletion of your personal data.
• Objection: Object to the processing of your data for specific purposes.
• Restriction: Request limitation of processing under certain circumstances.
• Portability: Receive your data in a structured, commonly used format.
• Withdrawal of consent: Withdraw your consent at any time for processing based on this legal basis.

To exercise your rights, write to us at: ruthy@audoratech.com

Response times: We commit to responding to your requests within a maximum of 30 days according to Argentina's Law 25.326, or 1 month according to GDPR if applicable. In complex cases, we may extend this period up to 2 months, informing you in advance.

Right to lodge complaints:

• In Argentina: You may file a complaint with Argentina's Agency for Access to Public Information (AAIP) if you believe your rights have been violated.
• In the European Union: If you are an EU resident, you have the right to lodge a complaint with the data protection supervisory authority of your country of residence or the place where the alleged infringement occurred.

8. Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or alteration, including:

• Encryption of data in transit and at rest
• Role-based access controls
• Security audits and monitoring
• Strong password policies
• Regular system updates and security patches

9. Cookies and Tracking Technologies

This website does not use tracking or analytics cookies. Only strictly necessary cookies may exist for the basic functionality of the site, which do not require consent under GDPR.

If we implement additional cookies in the future, we will update this privacy policy and request your consent when required by law.

10. Minors

RUTHY is not directed at minors. In accordance with GDPR, we do not process personal data of children under 16 without verifiable consent from parents or legal guardians. In Argentina, Law 25.326 establishes special protections for minors under 18.

We do not knowingly collect personal data from minors. If we discover we have collected data from a minor without proper consent, we will delete such information immediately and take necessary measures to prevent future collection.

11. Changes to This Policy

We may update this Privacy Policy occasionally. We will notify you of significant changes through an in-app notice or email. We recommend reviewing this policy periodically.

12. Contact

For any questions, requests, or complaints related to this Privacy Policy or the processing of your personal data, contact us:

AUDORA TECH SAS
Email: ruthy@audoratech.com
Additional legal information available upon request.