Privacy Policy

1. Information We Collect

• Account & contact data (collected by planB): Email address (via Privy login), or Sign in with Apple / Google identifier; optional phone number and any profile information you provide. Used for login, support, security and account-related communications.
• Technical & log data (collected by planB): IP address (used briefly for security, rate limiting and geofencing), device model, OS version, app version, language, timezone, crash reports and performance data. Used to operate, secure and debug the App. Includes product-interaction events used for analytics.
• KYC, identity & financial data: Regulated partners collect the identity documents, selfies, biometric checks, bank details and card data required for their services and control their copies. planB may process limited identifiers and metadata—including name, tax ID, KYC status, wallet addresses, transaction details, push token and Privy user ID—to operate the App. planB does not store copies of identity documents, selfies or biometric verification data, or plaintext card numbers and CVVs.
• Wallet keys & recovery data: planB does not receive or store complete private keys or wallet-recovery secrets on its servers. Privy protects wallet key material through encrypted shares and isolated execution environments. Depending on your settings, recovery material may be protected by Privy, a user passcode, iCloud or Google Drive. planB does not maintain an independent server-side signing key for your embedded wallets. If you export a key, planB does not receive it and you are responsible for the copy you create.

2. How We Use Information

• To provide, maintain, secure and improve the App and the Services.
• To enable integrations with regulated partners (PIX cash-in/out, card issuance, embedded-wallet authentication).
• To comply with legal and regulatory obligations applicable to planB or to our partners (KYC, AML/CFT, sanctions screening).
• To detect, prevent and investigate fraud, abuse, account takeover and unauthorised use.
• To respond to your support requests and to send service-related communications (security alerts, terms updates, transactional notifications).

3. Data Sharing

4. Your Control

• The wallets are designed for user self-custody. planB does not store the complete private key; Privy and your configured recovery provider handle encrypted key shares and recovery data.
• You can update your account data and request a copy or deletion of the personal data planB controls by writing to contact@planb.army.
• To access or delete KYC/identity data submitted to a regulated partner you must contact the partner directly — those records are controlled by the partner under their own privacy policy.

5. Data Security

• planB applies administrative, technical and organizational safeguards appropriate to the data it processes.
• However, no system is 100% secure. You are responsible for securing your device, wallet credentials and recovery factors.

6. Blockchain & Data Rights

Transactions executed through the App are recorded on public blockchains. By the technical design of those networks, on-chain data — including your public wallet address and transaction history — is public, immutable and outside planB's control. As a consequence, planB cannot delete, anonymise, alter or restrict on-chain records, and data-protection rights such as the LGPD right to deletion apply only to data held in planB's own systems and cannot be enforced over public-blockchain records.

7. Your Rights — LGPD (Brazil)

If you are a data subject in Brazil, the Brazilian General Data Protection Law (Law nº 13.709/2018 — "LGPD") gives you the following rights with respect to personal data planB processes about you:

• Confirmation that processing exists and access to your personal data.
• Correction of incomplete, inaccurate or out-of-date data.
• Anonymisation, blocking or deletion of unnecessary data, excessive data, or data processed in non-compliance with the law (subject to legal retention obligations).
• Portability of your data to another service provider, in accordance with ANPD regulations.
• Information on the public and private entities with which planB has shared your data.
• Information about the possibility of refusing consent and the consequences of such refusal.
• Withdrawal of consent at any time, without prejudice to processing carried out before withdrawal.

Depending on the activity, planB relies on consent, contract performance, compliance with legal obligations, legitimate interests balanced against your rights, and the exercise of rights in legal proceedings. To exercise your LGPD rights, write to contact@planb.army.

We respond within the deadlines required by law. For confirmation or access requests, LGPD provides for a simplified response promptly or a complete response within the applicable statutory period.

8. Your Rights — Other Jurisdictions

Rights outside Brazil depend on applicable local law. Partner-provided Services are also subject to the partner's privacy notice. Send requests to contact@planb.army.

9. Data Retention

planB keeps identifiable data only as needed to provide and secure the Services and to meet legal, accounting and dispute obligations:

• When deletion completes, planB deletes or de-identifies local account and operational data and retains only minimized records required for legal, security, accounting or dispute purposes.
• Avenia, Gnosis Pay, the applicable card issuer, Sumsub and Privy retain or delete data under their own legal duties and procedures. Privy may disassociate and archive embedded-wallet data to protect user assets.
• Public blockchain records are permanent and cannot be deleted by planB.
• Aggregated or de-identified data may be retained where it no longer identifies you.

10. Cookies & Web Analytics

The planb.army website uses Google Analytics and Vercel Analytics to measure site usage. These providers may process browser, device, IP-derived location and interaction data under their own privacy terms. The mobile App does not use browser cookies. You can limit analytics through your browser settings or the Google Analytics opt-out add-on at tools.google.com/dlpage/gaoptout. We do not use analytics data for third-party advertising.

11. Account Deletion

Request deletion in Settings → Security → Delete Account or at contact@planb.army. Unless you choose and verify immediate deletion, a seven-day cancellation period applies and you may cancel in the App during that period. After it ends, planB begins deleting or de-identifying data it controls, subject to funds, pending-operation, security, legal and provider checks. Partners retain or delete their data under their own procedures, and public blockchain records remain. Move your assets to another wallet before deletion; planB cannot guarantee recovery afterward.

12. Children's Privacy

The App is not intended for individuals under 18 (KYC verification requires legal majority). planB does not knowingly collect personal data from minors. If you believe a minor has provided personal data, please contact contact@planb.army so we can take appropriate action.

13. Changes

planB may update this Policy and will publish the new effective date. We will give reasonable notice of material changes when required by law.

14. Contact

Privacy questions, data-protection requests and complaints can be sent to:

📧 contact@planb.army