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1. Introduction

River Beaches ("we", "us", "our") is committed to protecting your personal data. This Privacy Policy explains what information we collect, how we use it, and your rights under the General Data Protection Regulation (GDPR) and applicable Portuguese law. By using the App, you agree to the practices described in this policy.

The data controller is the individual operating River Beaches, based in Portugal, contactable at inforiverbeaches@gmail.com.

2. Data We Collect

2.1 Account Data

When you create an account, we collect:

• Email address
• Username (chosen by you)
• Password (stored securely via our authentication provider; we do not have access to your plain-text password)

2.2 Content You Submit

When you interact with the App, we may collect:

• Reviews, ratings, and comments you post
• Photos you upload
• Beach suggestions you submit
• Beaches you save to your favourites

2.3 Location Data

The App may request access to your device's location in order to show your position on the map relative to nearby beaches. Location data is used solely for in-app navigation and is not stored on our servers beyond the active session unless you explicitly submit content tied to a location.

2.4 Usage & Analytics Data

We use Mixpanel, a third-party analytics provider with EU data residency, to understand how the App is used and to improve the user experience. This includes data such as which screens and features are used, filters applied, and general app interactions.

If you are signed in, this analytics data is linked to your account (via a unique identifier) so we can understand usage patterns across sessions. If you are using the App as a guest, analytics data is tied to an anonymous device identifier rather than an account. Analytics data is not sold or shared with any party other than Mixpanel as our processor, and is not used for advertising.

2.5 Technical Data

Standard technical information may be collected automatically, including device type, operating system version, and app version. This data is used for troubleshooting and compatibility purposes.

3. How We Use Your Data

We use your data for the following purposes:

• To create and manage your account.
• To display content you have posted (reviews, saved beaches, etc.).
• To show your location on the in-app map when you grant location permission.
• To respond to your enquiries and support requests.
• To comply with legal obligations, including cooperation with law enforcement where required by law.
• To improve and develop the App, including through the use of analytics (see Section 2.4).
• To send you occasional communications about new features or important changes to the App. You can opt out of these at any time.

4. Legal Basis for Processing

We process your personal data under the following legal bases:

• Contract: Processing necessary to provide the service you signed up for (account management, content display).
• Legitimate interests: Improving the App, preventing abuse, maintaining security, and understanding usage patterns through analytics.
• Legal obligation: Retaining data where required by applicable law, including cooperation with law enforcement.
• Consent: For any future processing not covered above, we will request your explicit consent and allow you to withdraw it at any time.

5. Data Retention

We retain your account data for as long as your account is active. If you delete your account, your public profile and content will be removed from view. However, content that may be relevant to a legal investigation will be retained as described in the Terms & Conditions.

Anonymised data may be retained indefinitely as it cannot be linked back to you.

6. Sharing Your Data

We do not sell your personal data. We may share your data in the following limited circumstances:

• Service providers: Our authentication provider (Clerk) processes your login credentials on our behalf. They are bound by their own privacy policy and GDPR-compliant data processing terms.
• Analytics provider: Mixpanel processes usage data on our behalf, with EU data residency, as described in Section 2.4.
• Law enforcement: Where required by law or court order.
• Future integrations: If we introduce additional third-party tools (such as advertising), this policy will be updated and, where required, your consent will be sought.

7. Your Rights Under GDPR

As a user based in the EU, you have the following rights regarding your personal data:

• Right of access: Request a copy of the data we hold about you.
• Right to rectification: Request correction of inaccurate data.
• Right to erasure: Request deletion of your data (subject to legal retention obligations).
• Right to restriction: Request that we limit processing of your data.
• Right to data portability: Request your data in a machine-readable format.
• Right to object: Object to processing based on legitimate interests, including analytics and feature update communications.
• Right to withdraw consent: Where processing is based on consent, withdraw it at any time without affecting prior processing.

To exercise any of these rights, contact us at inforiverbeaches@gmail.com. We will respond within 30 days.

8. Cookies & Local Storage

The App does not use browser cookies. We may use local device storage (e.g. secure on-device storage) to maintain your session and preferences. This data remains on your device and is not transmitted to our servers unless you take an action that submits content.

9. Security

We take reasonable technical and organisational measures to protect your data. Passwords are handled by our authentication provider (Clerk) using industry-standard secure storage practices. However, no system is completely secure, and we cannot guarantee the absolute security of your data.

10. Children's Privacy

The App is not directed at children under 13. We do not knowingly collect personal data from children under 13. If you believe a child under 13 has provided us with personal data, please contact us and we will delete the account and associated data promptly.

11. Changes to this Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top of this document. For material changes, we will endeavour to notify users through the App. Continued use of the App after changes are posted constitutes acceptance of the updated policy.

12. Contact & Complaints

For any privacy-related questions or to exercise your rights, contact us at inforiverbeaches@gmail.com.

You also have the right to lodge a complaint with the Portuguese data protection authority, the Comissão Nacional de Proteção de Dados (CNPD), at www.cnpd.pt.