Privacy Policy

1. Information We Collect

We collect the following categories of personal data:

• a. Personal Data: Full name, CPF, date of birth, gender, nationality, identity document, facial photo, proof of residence.
• b. Contact Data: Email, phone, residential and correspondence addresses.
• c. Technical and Device Data: Device model, browser type, OS, IP, geolocation, Wi-Fi identifiers, session logs, cookies, usage data (clickstream, session duration).
• d. Transaction and Financial Data: Card transactions, on-chain activity, Pix transactions, card usage (Apple Pay/Google Pay), merchant info, values, date/time, payment behavior.
• e. Support Data: Customer service communications, support tickets, chat logs.
• f. Employment and Income Data (BlindPay): Position, employer, income, CPF, account verification, employment identifiers (for BlindPay payment eligibility).
• g. Biometric and Verification Data: Data from partners like Persona and BlindPay, including facial biometrics and digitized documents.
• h. Marketing and Analytics Data: Preferences, referral source, website/app behavior (e.g., Mixpanel, Amplitude).

2. Purpose of Processing

• • Identity verification (KYC/AML) and fraud detection.
• • Account creation and platform access (wallets, cards, payments).
• • Execution of on-chain and fiduciary transactions (BlindPay, Pix, Rain).
• • Card provisioning (Rain Cards - Apple Pay or Google Pay).
• • Communication and customer support.
• • Platform improvements and feature development.
• • Legal compliance (LGPD, AML law, regulations).
• • Application of terms and investigation of misuse/threats.

3. Legal Basis for Processing (Art. 7, LGPD)

• • Consent.
• • Legal or regulatory obligation.
• • Contract execution.
• • Legitimate interest.

4. Data Sharing with Third Parties

We share data with the following partners and processors:

• a. Identity and Wallet Services: Persona/Sumsub, Crossmint.
• b. Payment and Card Services: BlindPay, Rain Cards (Signify Holdings Inc. & Issuing Partners).
• c. Card Provisioning Platforms: Apple Pay & Google Pay.
• d. Infrastructure and Analytics: AWS, Cloudflare, Mixpanel, session replay tools, CRM platforms.
• e. Legal and Regulatory Authorities: For compliance with financial regulations, court orders, AML/CFT rules, or government investigations.

5. Specific Data Usage for BlindPay

We collect data (employment, income, GPS) for payment eligibility, transfer data from Ruvo to BlindPay, retain data for 5-7 years or more, and you can contact us regarding BlindPay-retained data.

6. International Data Transfers

Data may be processed/stored in the United States (BlindPay, Crossmint, Rain), European Union/United Kingdom (hosting, analytics), and Brazil (local BlindPay affiliate or Pix intermediaries). All transfers are protected by encryption, SCCs, and LGPD Article 33 compliance.

7. Your Rights (LGPD - Brazil)

You have the right to:

• • Confirm processing.
• • Access/correct/update data.
• • Request anonymization/blocking/deletion.
• • Data portability.
• • Object to processing/automated decisions.
• • Revoke consent.
• • Submit ANPD complaint.

Contact email for exercising rights: ajuda@ruvo.com

8. Data Retention

Data retained for service provision, as required by AML law (5-7 years minimum for transactions), and until account deletion (with legal/partner obligations).

9. Information Security

We apply the following safeguards:

• • End-to-end encryption for sensitive data
• • Role-based access control and MFA
• • Secure cloud storage and physical infrastructure
• • Biometric verification via secure third parties
• • Regular audits, backup systems, and incident response plans

10. Children's Privacy

Our platform is not intended for users under age 18. We do not knowingly collect data from minors. If discovered, such data will be deleted.

11. Cookies and Tracking Technologies

We use:

• Session cookies
• Security cookies
• Behavior tracking (Mixpanel, session replay tools)

You may disable cookies in your browser. Some features may not function correctly if disabled.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted at www.ruvo.com, and major updates will be communicated via email or in-app notice.

13. Contact Us

📧 ajuda@ruvo.com

🌐 www.ruvo.com

Last Update: June 4, 2025