Privacy Policy

1.About this Policy

This Privacy Policy explains how LivePapo collects, uses, discloses, stores and protects personal data when you use the application, the websites, the payment pages, the support channels and other official services that reference this Policy (together, the “Services”).

This Policy was drafted for an international operation. Certain rules may vary depending on the country or region where you live. Where local law grants additional rights or sets more protective requirements, that law will prevail.

By using the Services, you acknowledge that you have read this Policy. Where the law requires consent, we will ask for specific, separate authorization for the corresponding processing.

2.Who is responsible for your data

The controller responsible for the personal data processed through the Services is Social Media Solutions Ltda., incorporated under the laws of Brazil, with address at Avenida Ephigenio Salles, 1299, Aleixo, Manaus/AM (“LivePapo”, “we” or “our”).

Privacy and data protection contact:

team@livepapo.com

Data Protection Officer, where applicable:

team@livepapo.com

Local representative in the EEA, United Kingdom and Brazil, where required:

team@livepapo.com

3.Who can use LivePapo

LivePapo is intended exclusively for people aged 18 or over who have legal capacity to accept the General Terms. We do not allow anyone under 18 to create or use an account.

If we find that an account belongs to a person under 18, we may restrict or terminate the account and delete the associated data, except for information that must be preserved for security, investigation, legal compliance or protection of the child or adolescent.

4.Personal data we collect

The data actually processed depends on the features used, the permissions granted, the country, the device and the account settings.

4.1 Data you provide

• Account and registration: name, nickname, date of birth, stated gender, country, language, email, phone, protected password and account identifiers.
• Profile: photograph, avatar, biography, voice introduction, city, nationality, languages, interests, preferences and other information you choose to add.
• Content and communications: messages, comments, posts, photographs, videos, audio, broadcasts, calls, reactions, reports and files submitted.
• Verification and security: selfie, photograph of an identity document, identity information, age, verification results and data needed to prevent fraud, impersonation or abuse.
• Purchases and monetization: orders, virtual items, balance, subscriptions, transaction history, refunds, chargebacks, tax data, identity verification information and data needed for eligible payments or withdrawals.
• Support and surveys: communications with customer service, complaints, appeals, survey responses and attachments submitted voluntarily.

4.2 Data collected automatically

• Device and network: IP address, device or installation identifiers, model, operating system, language, time zone, application version, carrier, connection type and integrity signals.
• Use and interaction: screens accessed, searches, profiles viewed, follows, blocks, likes, gifts, calls, rooms, time spent, clicks, crashes and technical events.
• Location: approximate location derived from the IP address and, with your permission, precise or approximate location provided by the device for proximity-based features.
• Cookies and similar technologies: cookies, local storage, pixels, SDKs and equivalent technologies used on websites, embedded pages and in the application.

4.3 Data received from other sources

We may receive data from:

• social login services, according to your settings and the authorization granted;
• app stores, financial institutions, payment processors and verification providers;
• other users, including when they post content about you, send you a message or file a report;
• providers of security, fraud prevention, technical analysis and customer service;
• public authorities or legally available sources, where permitted.

4.4 Sensitive data

Some information may be considered sensitive or receive heightened protection in certain jurisdictions, including precise location, identity documents, biometric or facial data, private content and information that may reveal intimate aspects of a person.

We process such data only where necessary for a disclosed purpose and with a valid legal basis. Where required, we will present a prominent notice and request explicit consent. We do not use biometric data to identify you outside the verification, security and fraud prevention purposes disclosed at the time of collection.

5.How we use data

We may use personal data to:

• create, authenticate, maintain and protect your account;
• provide profiles, discovery, messages, content, rooms and calls;
• personalize the experience, rank content and recommend profiles or features;
• process purchases, subscriptions, virtual items, refunds and eligible payments;
• verify age, identity, authenticity and eligibility;
• detect spam, fraud, impersonation, abuse, illegal content and rule violations;
• receive reports, moderate content, apply measures and review appeals;
• provide support, respond to requests and send operational communications;
• measure performance, fix failures, develop and improve the Services;
• carry out aggregate analysis, research and testing, preferably with de-identified data;
• comply with legal, regulatory, tax, accounting and security obligations;
• exercise, establish or defend rights and protect users, third parties and LivePapo;
• send marketing, promotions or surveys where permitted and in line with your choices.

6.Legal bases

Depending on the jurisdiction and the activity, we process data on the basis of one or more of the following:

• performance of a contract: to provide the requested features, operate the account and process transactions;
• consent: for precise location, certain verifications, marketing and other processing where the law requires it;
• legitimate interests: for security, fraud prevention, support, improvement, personalization and protection of the Services, provided those interests are not unduly overridden by your rights;
• legal or regulatory obligation: for records, taxes, prevention of unlawful acts, responses to authorities and other applicable duties;
• protection of rights and safety: to establish, exercise or defend rights and to protect people in situations permitted by law;
• other bases authorized by local law, including fraud prevention and data subject safety in relation to sensitive data, where applicable.

Where processing is based on consent, you may withdraw it at any time. Withdrawal does not affect processing carried out previously or operations supported by another legal basis.

7.Public information and interactions with other users

Your profile name, avatar, biography, public content, status, interactions and other fields set as public may be seen by other users and, depending on the settings, by people outside LivePapo.

Messages, audio, video, calls, room content and items sent are shared with the recipients or participants you choose. Although we provide privacy controls, other people may copy, record, photograph or redistribute content. Use the blocking and reporting features and avoid sharing information that could put you or others at risk.

Identity documents, full payment details, credentials, exact location and internal security tools are not displayed publicly by LivePapo.

8.How we share data

We may disclose personal data in the following situations:

• other users and the public: according to your posts, interactions, settings and choices;
• service providers: cloud hosting, storage, content delivery, real-time communication, support, moderation, technical analysis, security and notifications;
• login, verification and payments: authentication providers, app stores, payment processors, financial institutions, identity verification and fraud prevention;
• companies in the same group: for operations, security, support and administration, subject to this Policy and to internal controls;
• professional advisers and partners: auditors, lawyers, insurers and consultants under confidentiality duties;
• authorities and protection of rights: where required by law, valid order, emergency, investigation or to protect rights, safety and integrity;
• corporate transactions: in a merger, acquisition, reorganization, financing or sale of assets, with appropriate safeguards.

Service providers and commercial partners

We may share personal data with service providers and partners that help us operate LivePapo, including cloud hosting and storage services, payment processing, identity verification, user support, sending notifications, data analysis, security and fraud prevention.

Those providers may process the data only to perform the contracted services, in accordance with our instructions, their confidentiality duties and applicable law.

We do not sell personal data for money. As of the effective date of this Policy, we do not share personal data for cross-context behavioral advertising. If this practice changes, we will update this Policy and provide the required notices and opt-out mechanisms.

9.International transfers

LivePapo operates with infrastructure and providers located in different countries. As a result, your data may be stored or processed outside the country where you live.

Where the law requires it, we use recognized mechanisms for international transfers, such as adequacy decisions, standard contractual clauses, clauses approved by authorities, binding corporate rules or other legal safeguards. We also assess providers, limit access and apply technical and contractual measures proportionate to the risk.

For data subject to Brazilian law, we will adopt valid mechanisms provided for in the LGPD and in ANPD regulations. For data subject to the GDPR or the UK GDPR, we may use the applicable standard contractual clauses and supplementary measures. You can request information about the relevant mechanism through the privacy channel, subject to trade secrets and security requirements.

10.Retention and deletion

We keep data for as long as necessary for the purposes described in this Policy. The criteria include the duration of the account, the nature of the data, operational need, risk of fraud or abuse, legal deadlines, dispute resolution and defense of rights.

In general:

• account and profile data are kept while the account is active and for a reasonable period after termination;
• content is kept while it is published or necessary to provide the service, without prejudice to copies received by other users;
• records of purchases, payments, verification, fraud and tax obligations may be kept for the applicable legal periods;
• reports, decisions and evidence may be kept for the period necessary for security, investigation, appeal and legal compliance;
• backup copies are replaced on regular cycles and are kept isolated from ordinary use;
• de-identified or aggregated data that does not reasonably identify a person may be kept for analysis and improvement.

When the applicable period ends, we will delete, anonymize or securely isolate the data, unless retention remains authorized or required by law.

11.Automated decisions and personalization

We may use automated systems to recommend content or profiles, rank results, identify suspicious behavior, support moderation, verify authenticity and assess eligibility for certain features.

These systems may consider profile information, interactions, activity, approximate location, security signals and transaction history. We do not use sensitive categories to produce unlawful discrimination.

Where a solely automated decision produces a legal effect or a similarly significant impact and the law grants that right, you may request an explanation, contest the outcome and ask for human review at team@livepapo.com.

12.Your rights and choices

Depending on your location, you may request:

• confirmation of processing and access to the data;
• correction of incomplete, inaccurate or outdated data;
• deletion, anonymization or restriction of processing;
• portability or a copy in a usable format;
• information about purposes, sources, categories and recipients;
• objection to certain processing, including direct marketing;
• withdrawal of consent;
• limitation on the use of sensitive data, where provided by law;
• opt-out of sale, sharing for targeted advertising or profiling, where applicable;
• review of automated decisions and an appeal against a decision on your request;
• a complaint to the competent data protection authority.

You can exercise rights through the application, at www.livepapo.com or by email at team@livepapo.com. We may request reasonable information to confirm your identity and protect the account. You may use an authorized agent where the law allows.

We will not discriminate against you for exercising a privacy right. If we cannot fully satisfy a request, we will explain why and inform you of the applicable appeal options.

12.1 Permissions and controls

• Location: manage this in your device settings; proximity features may stop working.
• Camera, microphone and photos: manage these on the device; the corresponding features depend on those permissions.
• Notifications: control these in the application or in the operating system.
• Marketing: use the unsubscribe link or the account preferences; operational messages may continue.
• Profile and visibility: adjust the available privacy, blocking and discovery options.

13.Regional notices

13.1 European Economic Area, United Kingdom and Switzerland

If you are in these regions, LivePapo will process data on the basis of contract, consent, legal obligation, legitimate interests or another recognized basis. You may have rights of access, correction, erasure, restriction, portability, objection and withdrawal of consent, as well as rights relating to automated decisions.

You may also lodge a complaint with the data protection authority of the country where you live, work or where you believe an infringement has occurred. The contacts for the controller, DPO and regional representative are in Section 2.

13.2 Brazil

Where the LGPD applies, you may exercise the rights provided for in Brazilian law, including confirmation, access, correction, anonymization, blocking or deletion of unnecessary or unlawfully processed data, portability where regulated, information about sharing and consent, withdrawal of consent, objection and review of automated decisions.

You may also petition the Brazilian National Data Protection Authority (ANPD) and the competent consumer protection bodies.

13.3 United States

Residents of US states with applicable privacy laws may have rights to know, access, correct, delete, port, non-discrimination, appeal and opt out of sale, targeted advertising or certain types of profiling. They may also limit certain uses of sensitive personal information.

LivePapo does not sell personal data for monetary consideration and does not share data for cross-context behavioral advertising as of the date of this Policy. Requests and appeals can be submitted through the channels in Section 12.

13.4 Other regions

We will honor the rights and deadlines set out in the privacy laws applicable to the places where we offer the Services. If there is a conflict between this Policy and a mandatory local rule, the local rule will prevail.

14.Cookies, SDKs and similar technologies

We use technologies necessary for authentication, security, preferences, functionality, diagnostics and performance measurement. Optional technologies, including for marketing or advertising, will be used in accordance with the law and the choices available.

You can control cookies in your browser and permissions on your device. Blocking strictly necessary technologies may prevent parts of the Services from working.

15.Security and incidents

We adopt administrative, technical and organizational measures designed to protect data against unauthorized access, loss, alteration, disclosure or destruction. These measures may include encryption in transit, access controls, audit logs, credential management, monitoring, backups and provider assessment.

No system is completely secure. If an incident occurs that requires notification, we will notify the affected people and the competent authorities in accordance with applicable law.

16.Account deletion

You can request deletion in your account settings or at team@livepapo.com. We may apply a short safety period to allow the request to be cancelled and to prevent improper deletions.

After that period, we will begin deleting or anonymizing the data, subject to retention necessary for transactions, fraud prevention, security, legal obligations, disputes and content already delivered to other users.

17.Third-party links and services

The Services may contain third-party links or integrations. Those third parties' practices are governed by their own policies. We recommend that you read them before providing data directly to them.

18.Changes to this Policy

We may update this Policy to reflect changes in the Services, in our practices or in the law. The effective date will be shown at the beginning of the document. Material changes will be communicated appropriately and, where necessary, we will ask for renewed consent.

19.Contact

Controller:

Social Media Solutions Ltda.

Address:

Avenida Ephigenio Salles, 1299, Aleixo, Manaus/AM

Privacy and DPO:

team@livepapo.com

Support:

team@livepapo.com

Rights portal:

www.livepapo.com

Account deletion:

team@livepapo.com

Reports and appeals:

team@livepapo.com