1. Introduction

Catarina International LLLC ("we," "our," or "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, and safeguard your information when you use our mobile applications, web applications, games, and services (collectively, the "Services").

This policy applies to all users of our Services, including consumers (B2C) and business clients (B2B), and complies with applicable data protection laws including the General Data Protection Regulation (GDPR), Lei Geral de Proteção de Dados (LGPD), and California Consumer Privacy Act (CCPA).

Company Information:
Catarina International LLLC
15815 Shaddock Dr, Ste 120
Winter Garden, FL, USA

2. Information We Collect

2.1 Information You Provide

• Account Information: Name, email address, username, password, profile picture
• Contact Information: Phone number, mailing address
• Payment Information: Billing address, payment method details (processed by third-party payment processors)
• Communications: Messages, feedback, support requests, survey responses
• Business Information: Company name, business address, tax identification numbers (for B2B clients)

2.2 Information Automatically Collected

• Device Information: Device type, operating system, unique device identifiers, mobile network information
• Usage Data: App interactions, features used, time spent, session duration, crash reports
• Location Data: Approximate location based on IP address; precise location if you grant permission
• Log Data: IP address, browser type, access times, pages viewed, referring URLs
• Game Data: Gameplay statistics, achievements, leaderboards, in-game purchases

2.3 Information from Third Parties

• Social media platforms (when you connect your accounts)
• Analytics and advertising partners
• Business partners and service providers
• Public databases and data aggregators

3. How We Use Your Information

We use your information for the following purposes:

• Service Provision: Deliver, maintain, and improve our Services
• Account Management: Create and manage your account, authenticate users
• Communication: Send updates, notifications, marketing communications, and customer support
• Personalization: Customize content, recommendations, and user experience
• Analytics: Analyze usage patterns, performance metrics, and user behavior
• Security: Detect fraud, prevent abuse, and ensure platform security
• Legal Compliance: Comply with legal obligations and enforce our terms
• Business Operations: Process payments, manage subscriptions, provide customer support
• Marketing: Send promotional materials and targeted advertisements (with consent where required)

4. Legal Basis for Processing (GDPR/LGPD)

We process your personal data based on the following legal grounds:

• Consent: When you have given explicit consent for specific processing activities
• Contract Performance: To fulfill our contractual obligations to provide Services
• Legal Obligation: To comply with applicable laws and regulations
• Legitimate Interest: For analytics, security, fraud prevention, and business operations
• Vital Interests: To protect the safety and security of users

5. Information Sharing and Disclosure

We may share your information in the following circumstances:

5.1 Service Providers

Third-party vendors who provide services on our behalf, including:

• Cloud hosting and data storage providers
• Payment processors and billing services
• Analytics and marketing platforms
• Customer support and communication tools
• Security and fraud prevention services

5.2 Business Transfers

In connection with mergers, acquisitions, or sale of company assets

5.3 Legal Requirements

When required by law, court order, or government investigation

5.4 Safety and Security

To protect rights, property, or safety of our users or others

5.5 With Your Consent

Any other sharing with your explicit consent

6. Data Security

We implement appropriate technical and organizational measures to protect your personal data:

• Encryption in transit and at rest
• Regular security assessments and penetration testing
• Access controls and authentication mechanisms
• Employee training and confidentiality agreements
• Incident response and breach notification procedures
• Compliance with industry security standards

However, no system is completely secure, and we cannot guarantee absolute security of your data.

7. Data Retention

We retain your personal data for as long as necessary to:

• Provide our Services and maintain your account
• Comply with legal, regulatory, or contractual obligations
• Resolve disputes and enforce agreements
• Prevent fraud and abuse

Account data is typically retained for the duration of your account plus 3 years after deletion. Marketing data may be retained for up to 7 years. Game data and analytics may be retained for up to 5 years.

8. Your Rights and Choices

8.1 GDPR Rights (EU Residents)

• Access: Request copies of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your personal data
• Restriction: Limit processing of your data
• Portability: Receive your data in a structured format
• Object: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent for specific processing

8.2 LGPD Rights (Brazil Residents)

Similar rights as GDPR, including:

• Confirmation of processing and access to data
• Correction of incomplete or inaccurate data
• Anonymization, blocking, or deletion of data
• Data portability to another service provider
• Information about public and private entities with shared data

8.3 CCPA Rights (California Residents)

• Know: What personal information is collected and how it's used
• Delete: Request deletion of personal information
• Opt-Out: Opt-out of sale or sharing of personal information
• Non-Discrimination: Not be discriminated against for exercising rights

8.4 How to Exercise Your Rights

To exercise your rights, contact us at:

• Email: privacy@intercode.dev
• Through your account settings
• By contacting customer support

We will respond to requests within 30 days (or as required by applicable law).

9. International Data Transfers

Your data may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place:

• European Commission adequacy decisions
• Standard Contractual Clauses (SCCs)
• Binding Corporate Rules
• Certification schemes and codes of conduct

10. Children's Privacy

Our Services are not intended for children under 13 (or 16 in the EU). We do not knowingly collect personal information from children. If we become aware that we have collected data from a child without parental consent, we will delete it promptly.

For games or services that may be used by children, we implement additional protections and may require parental consent where legally required.

11. Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to:

• Remember your preferences and settings
• Analyze usage patterns and improve Services
• Provide personalized content and advertisements
• Ensure security and prevent fraud

You can control cookies through your browser settings or opt-out tools provided by advertising networks.

12. Third-Party Services

Our Services may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

We may integrate with third-party services such as:

• Social media platforms
• Payment processors
• Analytics providers
• Advertising networks
• Customer support tools

13. Marketing Communications

We may send you marketing communications about our Services, updates, and promotions. You can:

• Opt-out of marketing emails by clicking unsubscribe links
• Adjust notification preferences in your account settings
• Contact us to update your communication preferences

Transactional communications (account notifications, security alerts) cannot be opted out of while you maintain an account.

14. Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will:

• Notify relevant supervisory authorities within 72 hours (where required)
• Inform affected users without undue delay
• Provide clear information about the breach and recommended actions
• Take immediate steps to contain and remedy the breach

15. Updates to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices, Services, or legal requirements. We will:

• Post the updated policy on our Services
• Notify you of material changes via email or in-app notification
• Update the "Last updated" date at the top of this policy

Your continued use of our Services after changes become effective constitutes acceptance of the updated policy.

16. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Supervisory Authorities

You have the right to lodge a complaint with your local data protection authority:

• EU: Your local Data Protection Authority
• Brazil: Autoridade Nacional de Proteção de Dados (ANPD)
• California: California Attorney General's Office