Privacy policy
This policy covers the Pendi Android application. It is written to match what the app actually does; every claim below is grounded in the shipped behavior.
The short version
Your data lives on your device and the app works without you signing in. Sharing a space with your family syncs that space's content through Google Firebase, and you can separately turn on a backup of your Personal space, which uploads it to the same place. Neither happens unless you ask for it. Bank notifications are read on your device, and nothing is read at all until you grant notification access; once you do, the app your phone uses for SMS and the messaging and mail apps named in the app's own list start active as channels and pass on only what carries an amount and a money word, the bank and wallet apps found installed from a recognised store start active under that same rule until one tap widens them, and an app identified only by what it can do rather than by name, or installed from somewhere other than a recognised store, stays listed and off until you switch it on; every source can be switched off, one by one or all at once. The AI assistant is offered during setup and is active once you accept it there, after which a reduced fragment of a captured notification can leave the phone without you tapping anything each time; personal and sensitive data never leaves the phone, only minimized masked fragments do, and you can turn the assistant off at any time. Nothing is sold, there are no ads, and no advertising identifiers are collected.
Who is responsible for your data
Pendi is developed and published by Elkin Eduardo Cardoso Leyton, a natural person working as an independent developer in Ibagué, Colombia. There is no company behind it. He is the data controller for the processing described in this policy, the same one for anyone using Pendi from any country, and he has no offices in other countries. His address is Carrera 4c Bis #39-24, Ibagué, Tolima, 730006, Colombia, and his phone is +573134681880. The route for any question or request about your data is [email protected], the same address shown on Support and on Delete your account.
Pendi is published from Colombia, so Colombian data-protection law applies to your personal data: Ley 1581 de 2012 and Decreto 1377 de 2013. If you live in Brazil, Brazil's data-protection law applies as well, and the section “If you live in Brazil”, below, says what it adds.
What we use your data for, and on what basis
Each use has its reason. The ones that rest on your consent are switched on by you and off whenever you like; the rest are what it takes to give you what you asked for.
- Making the app work on your phone. What you keep stays on your phone and does not reach us.
- Spotting your expenses in notifications. This includes money details from your banks and wallets. Basis: your express consent, when you accept the terms of use and grant notification access. You switch it off in Settings.
- The AI assistant. Basis: your express consent on the AI help screen, which includes fragments being processed outside your country. You withdraw it under Settings > AI.
- The shop directory. Basis: what a company prints on its receipt describes the company, not a person. The directory admits a shop only when the receipt prints a company form and a Colombian company tax ID that checks out, so every shop it admits is, on its receipt, a company in Colombia, whose data-protection law covers information of natural persons. The app is built never to send a shop that belongs to a person; if a misread of the paper still makes one pass for a company, correcting the shop in the app removes the whole company, by its tax number, from Pendi's directory for 90 days (see Shop details from your receipts). The directory holds the company's printed details and nothing about its owners or staff; where a person's own name or phone number is printed as the company's, that person can ask us to take it out by writing to the contact address at the top of this policy, with no Pendi account, and a company taken out on a written request, whether that person's or the company's own, stays out of the directory for good. The weekly contributor mark, which keeps a report of yours from counting twice in one week, is there to keep the directory free of abuse, and it rests on your authorization when you accept the terms of use, which name the directory report it travels with.
- Shared spaces and the Personal-space backup. Basis: you ask for it when you create or join a space, or turn the backup on, and you accept it on the notice the app shows you first. It stops when you leave the space or turn the backup off.
- Your account, the anonymous session, AI quotas and push registration. Basis: they are needed to give you the features you use.
- The free trial and your purchases. Basis: the contract you accept with the terms of use and when you buy.
- Crash reports. Basis: keeping the app working for everyone, and your authorization when you accept the terms of use, which mention them. They have no switch of their own (see Your rights over your data).
- Feedback, dictations and formats you share. Basis: your consent, each time you write feedback, turn on dictation sharing or confirm sharing a format.
- Link previews. Basis: you ask for it when you save the link.
None of these uses is for advertising, and we neither sell nor rent data.
Data stored on your device
Tasks, lists, budgets, accounts, movements, categories, people, reminders and settings are stored locally in the app's private storage. Backups are user-initiated, encrypted, and saved where you choose. Uninstalling the app deletes its local data.
Transaction detection (notification access)
If you enable detection, the app reads system notifications from the sources that are active, to recognize payment notifications and turn them into movements you confirm. Which sources start active depends on how the app identifies each one, and on whether you have ever chosen sources yourself. On a phone where you have not, the app your phone uses for SMS and the messaging and mail apps named in the app's own list start active; on a phone where you have, that same change is offered to you as one tap instead of being made for you. Those are CHANNELS: they carry somebody else's message and hold no free pass, so a notification from one of them is only ever processed when it carries both an amount and a money word, and an ordinary text or mail is discarded without being stored. The bank and wallet apps the app finds installed from a recognised store start active as well, held to that same money rule, until one tap widens that row to the rest of its notifications, including the ones with no figure. Any other app the list names, found installed from a recognised store, starts active under the money rule too. An app identified only by what it can do rather than by name, and any app installed from somewhere other than a recognised store, are listed and off until you switch them on, as is the rest of the list. A bank or wallet app the list names and you switch on yourself is read whether or not its notifications look like money, because that is what you asked for by turning it on. Every source can be switched off, one by one or all at once. Reading and interpreting happen on your device, and the full text of the notification never leaves the phone.
Here is what can leave it. Once you accept the assistant during setup, and while it is on, the app sends a reduced fragment of the notification to ask for the category of the expense, and it does so on its own, without you tapping anything, as soon as the capture reaches the inbox. Before that fragment goes out, the phone removes email addresses, masked account or card tails, and any run of four digits or more, so account numbers and card numbers do not leave. What travels is that cleaned text: whole when it is 280 characters or less, and when it is longer, only the piece around the merchant; and on the category question the amount is masked to its shape ($###.###) instead of being sent, because that answer never needed the real figure. Your category names travel with it as the list of options to choose from, ordered from the one you use most, and that ordering is itself information about what you spend on. You can disable any source, or detection entirely, at any time.
Optional account and shared spaces
The app can operate a lightweight anonymous session (no email, no password) to enable its managed AI tier and shared content. If you share a space with family members, the content of that shared space (its tasks, lists, budgets and movements) syncs through Google Firebase (Firestore) so members see the same data. Your Personal space is not uploaded unless you turn on Settings > Account > Back up the Personal space. When you do, its content is uploaded to Firestore under your own account, where only that account can read it, and it stays there until you delete the account. Google's infrastructure processes this data as our provider; we do not sell it or use it for advertising.
AI features
There are two tiers. They are used to suggest the category of an expense, parse what you dictate by voice, and help you create a rule.
Pendi AI (managed). The reduced fragments described above travel to a service of our own hosted on Cloudflare Workers, which passes them to the language model that processes them. Requests carry a daily quota, we do not use them to train models, and they carry no account or card numbers.
Bring your own key (Gemini). If you connect a Gemini API key of your own, the fragment goes straight from your device to Google, under the agreement you hold with Google for that key. We do not receive that fragment, we never see your key in our services, and the key is stored encrypted on the device, protected by the Android keystore. Note that Google's Gemini API terms say that with a key that has no billing, Google may use what you send to improve its products and people on its team may read it, and they ask that no personal data be sent that way. If that matters to you, use a key with billing turned on, after checking Google's terms, or the managed tier.
Who processes the managed tier's fragments
This is the processor the managed tier routes to, with the company and the jurisdiction it operates from. It can process your fragments outside Colombia.
- Cloudflare, Inc. (United States): operates Workers AI, the model that serves the managed tier's requests.
Which processor serves the requests is decided server-side and can change without a new app release, which is why this list, and not the app's screens, is where it is kept current; if a change alters what this policy says, we announce it in the app's changelog first.
Who else receives data, which countries it travels to, and under what safeguard
Besides the assistant's processors, these third parties receive data when you use the feature that needs them, each with the jurisdiction it operates from.
- Google LLC, Firebase (United States and other countries where Google has data centers): your session and your account, which Google processes only in the United States; the content of shared spaces and of the Personal-space backup; crash reports; and your phone's registration for notifications. Firestore data is stored in the central United States (Google's nam5 multi-region). It acts as our provider.
- Cloudflare, Inc. (United States): besides serving the assistant, it hosts our own service, which keeps your feedback, the dictation texts you choose to share, format reports (a notification's template with its variable parts removed, the app it came from and your account identifier), your phone's registration for notifications, your purchase status, the date your free trial started, the shop directory (the details companies print on their receipts, with nothing of anyone's purchases, and, for a company taken out of it, its tax number alone, with no name and no phone, kept 90 days after a correction from the app and with no end after a written request) and the weekly contributor mark. It acts as our provider.
- Google, Google Play: when you buy, Google Play charges as our agent and our service asks it whether the purchase is valid. Payment details are handled by Google Play under its own terms; we never see them.
- Google, Gemini, only if you use your own key: the fragment goes from your phone to Google under the agreement you accepted when you created the key. Those terms say that on unpaid use Google may use what you send to improve its products and that people may review it.
- Your phone's speech provider: when your phone has no offline pack, the audio goes to that provider, as “Voice dictation” explains. We never receive it.
- The sites your links point to: when you save a YouTube or TikTok link in a link list, or one arrives by sync, your phone follows its redirects if it is a short link and contacts that platform's preview service and its thumbnail, to show you the title and the picture. Those sites, and the server of any link you save, with its redirects, see the link's address and your phone's IP address. We receive none of it.
- Wikimedia Foundation, Inc. (United States): when you open the page of an ephemeris on this site that shows a picture from Wikimedia Commons, your browser fetches that picture straight from Wikimedia's servers, without going through us. Those servers see your device's IP address, the type of your device and its operating system, the type and version of your browser, its language preference, the picture asked for and the time of the request, as with any picture a browser loads. The app does not load these pictures itself: it opens these pages in your browser. That data is handled by Wikimedia under its own privacy policy. We receive nothing from that request.
Google, with Firebase, and Cloudflare process it as processors: only on our behalf and on our instructions, under their data-processing terms. Google Play handles your payment under its own terms, as the store you buy from. The United States may protect your data differently from the law of your country; that is why fragments leave minimized, and why the app asks for your authorization before sending them abroad and tells you before uploading a space or your backup to the cloud.
What each law asks before your data leaves the country, and how we meet it: in Colombia, Argentina, Costa Rica, Ecuador, Nicaragua, Panama, the Dominican Republic and Uruguay, your express authorization, on the AI help screen and on the notice for shared spaces and the backup; in Mexico, Google and Cloudflare are processors and there is no transfer; in Peru, and in Paraguay once its law takes effect, what is needed to give you the service you asked for, or your express authorization.
In El Salvador, the law asks that the country receiving your data protect it at least as well as the law does. Your data goes to Google and Cloudflare, United States companies, which process it as processors under their data-processing terms.
What is sent, on each of the three paths
The assistant makes three kinds of request, and what leaves the phone is different on each. Personal and sensitive data never leaves the phone; what travels is minimized and masked. Your family's names are replaced with opaque tokens before any request is built, and email addresses, card tails and any run of four digits or more are stripped.
- The category question, from a captured notification: the cleaned message, whole when it is short (up to 280 characters) or the piece around the merchant when it is longer, with the amount masked to its shape, plus your category names as the list of options, ordered from the one you use most.
- A difficult dictation: the sentence you dictated, with names tokenized and identifiers stripped, plus your category names.
- Creating a rule: the message template with its variable parts removed, never the raw notification, plus your category names.
The weekly summary is not one of them: it is computed on your phone and asks the AI for nothing, so nothing leaves the phone for it.
When it starts, and how to stop it
A fresh install starts on Pendi AI rather than on no assistant at all, so the managed tier is the one selected for you, and the app asks you to authorize the transfer during first-run setup, on a screen that shows what would be sent and states that it can be processed outside Colombia. The assistant is active once you accept it there. If you decline, or leave setup without accepting, nothing is sent: the request stops on the phone, no session is created, and the app keeps working on its own rules. If you are updating from an earlier version of the app, you do not walk that setup screen again, and an answer you gave to an older version of this disclosure does not carry over to a changed one: it reads as no answer at all, the assistant stays silent, and the question is put to you again either when a feature next needs it or from the Settings > AI row you open yourself. Once you accept, the app signs in anonymously to Firebase (no email, no password) so the requests can be attributed to a quota. You can withdraw that authorization, or turn the assistant off, under Settings > AI; with it off detection keeps working with the app's local rules, the rest of the app is fully functional, and the other things this policy describes (sync, backup, push registration) are unaffected because they were never part of the assistant.
Voice dictation
Dictation runs on your device. The audio is handled by Android's own speech recognizer and the app never records it to a file, never stores it and never uploads it. Pendi asks for the offline pack first, and when your phone does not have one for that language the recognizer answers over the network instead, the same way your keyboard's microphone does: the audio goes to your phone's speech provider under their terms, and never to us. Pendi does not receive that audio and has no agreement with that provider: the provider processes it, under the agreement you hold with it on your phone. Under Settings > Voice you can ask Pendi to start with the online recognizer and skip the offline attempt.
Under Settings > Voice there is one switch, “Improve Pendi with my dictations”, and it is off unless you turn it on. With it on, two things happen together. Your dictations are kept on the phone with what the app understood from them, which is what lets a misreading be reproduced and fixed. And the TEXT the recognizer produced, together with the language it was spoken in, is queued and sent to us so the parser can be improved with real phrasing instead of invented examples. Nothing else travels with it: not the audio, not what the app parsed out of the sentence, not where it was saved. The upload waits for a network, so being offline delays it and never loses it, and it is attributed to your account the same way the feedback channel is.
Turning the switch off stops the sharing, deletes the dictations kept on the phone, and discards anything still waiting to be sent. It does not delete what already arrived; write to the contact address above for that. The setting is deliberately left out of backup files, so restoring a backup onto a new phone never turns sharing on for you.
Contacts
Only if you use the contact import feature, and only at the moment you pick a contact, the app reads that entry's name, phone number and photo to create a person in your space. The photo needs the Contacts permission and the app asks for it right there; the name and the phone number are imported without any permission at all. There is no background contacts access and no bulk read of your address book. If you later save that person into a shared space, their name, phone number and any email you typed sync to Firestore with the rest of the space, and the photo stays on your device.
Link previews
When you save a link in a link list, the app tries to show you its preview, and to do that your phone may connect directly, without going through us, to the link's server and to every server the link redirects to. If the link is a YouTube or TikTok link, it also asks that platform for the title and thumbnail (www.youtube.com/oembed and www.tiktok.com/oembed) and downloads the thumbnail from the server the platform names. Those servers see the link's address and your phone's IP address, as when you open a link in a browser, and handle them under their own policies. We receive none of this.
Notification formats you share
After you create a rule for a notification the app did not recognise, the app may offer to share that format so Pendi can learn it. It is optional, never on by default, and before sending it shows you exactly what leaves: the message template, with amounts, names, digits and dates replaced by placeholders, the app it came from and the shape of your rule. It is kept in our service together with your account identifier, to count how many different people shared the same format. If you delete your account, that identifier is replaced by a random one that does not lead to you, and the template stays, because it no longer says anything about you.
Shop details from your receipts
When you read a receipt that prints a company form (such as S.A.S. or LTDA) and a company tax ID that checks out against its check digit, Pendi sends its own service the public details that company printed on it (name, legal name, tax ID, address, city and phone) to build a shared directory of shops; if either is missing, nothing of the shop leaves the phone. It sends nothing of what you bought, no amount and no photo. The app is built never to send a shop that belongs to a person; if a misread of the paper still makes one pass for a company, correcting the shop in the app removes it from Pendi's directory, and no shop in the directory is shared with anyone while a single install of the app has reported it. The report travels with your sign-in, like every AI help request: the service uses it to check the request and notes that a report of yours arrived, without the shop. The shop directory keeps the shop without your account and, so that your report is not counted twice in one week, a one-way mark that changes every week, with every shop and with every place; the week is counted in universal time and the report names the week of its mark; the service keeps the report only when that is the current or the previous week, and that mark is deleted after the week ends: normally within the following eight days, at the latest a few days later if the daily task fails, and the database's backup keeps it up to 30 days more; the shop's record stays. The company's details stay if you delete your account, your data or the app.
The shop's record stays in the directory until a correction from the app deletes it. The weekly contributor mark is deleted after its week.
Crash reporting
Production builds send anonymous crash reports (stack traces, device model, OS version) through Firebase Crashlytics so defects can be fixed. Crash reports contain no financial content and no notification text. Google documents that Crashlytics keeps crash stack traces and the associated identifiers for 90 days, and then starts removing them from live and backup systems. You can read that in Privacy and Security in Firebase.
The Firebase Analytics library travels inside the app because it is the companion piece Crashlytics ships with, but its collection is off in the app's manifest, the advertising-identifier permissions it would otherwise contribute are stripped from the build, and the app logs no analytics events. In other words: no usage metrics and no app-instance identifier are collected. Crashlytics is a separate product and it does work: the crash reports described in the paragraph above are sent.
What we never do
- No ads.
- No sale of personal data.
- No use of your notification content for advertising.
- No advertising identifiers.
- No usage analytics.
- No reading of SMS.
- No access to any notification before you grant notification access, and none from a source you switched off.
- No collection of your precise location.
- No upload of the raw text of your notifications.
- No upload of your voice to us, under any setting (see “Voice dictation” above for what your phone's own speech provider does when it has no offline pack).
Data deletion
Local data: use Settings > Account > Erase the data on this device, which erases everything the app keeps on that phone in one action and signs you out first so nothing downloads again, or uninstall the app, which does the same. You can also still delete in parts: the captured text under Settings > Movement detection, the sample data, and the contents of the Vault. Shared-space data: a space you own is erased with everything in it when you delete it in the app or delete your account; what you added to someone else's space stays there (see How long we keep your data). Turning the Personal-space backup off stops further uploads but does not remove what is already there; deleting your account does. Anonymous session data and AI quota counters: request deletion by email and include your space identifier from Settings. We answer deletion requests at the contact address above. The complete account deletion steps are on Delete your account.
How long we keep your data
- On your phone: until you delete it, use Erase the data on this device or uninstall the app.
- Shared-space content: until the space is deleted. A space that is yours is erased with everything in it when you delete it or delete your account. What you added to someone else's space stays in that space: if you leave, it is no longer on your phone and the previews of your notes' files leave the space; if you delete your account, it stays there without your name or email.
- Personal-space backup: until you delete the account. Turning the backup off stops new uploads but does not remove what is already there.
- Your account or anonymous session: until you delete the account in the app; if you ask by email, we delete it within 30 days at most.
- Feedback you write to us: until you delete the account, which deletes it, or ask us to delete it.
- Dictations you send us with “Improve Pendi with my dictations”: until you delete the account, which deletes them, or ask us to delete them.
- Formats you share: no limit; when you delete the account, your identifier is replaced by a random one that does not lead to you.
- Shop details from your receipts: the shop's record stays in the directory until a correction from the app deletes it, and the database's backup keeps a deleted record up to 30 days more; when a company is taken out, the service keeps its tax number alone, with no name and no phone, for 90 days after a correction from the app and with no end after a written request; the weekly contributor mark is deleted after its week, normally within the following eight days, and the database's backup keeps it up to 30 days more.
- AI quota counters: they delete themselves after 48 hours.
- Free-trial start date, kept against a one-way digest of the phone's identifier: no limit, because its only use is keeping the trial from starting over when you reinstall.
- Crash reports: Google documents that it keeps them for 90 days.
- Fragments sent to the assistant: we do not keep them. Our service passes them to the AI engine and only writes the technical record in the next line.
- The technical record of each request (your identifier, the time, the function used, the outcome, how many tokens were used, your plan, the engine used and sizes; never the content): our service does not keep it and stores it nowhere: log storage is switched off for our service at Cloudflare, so the record exists only while the request is being answered.
- Push registration: up to 60 days after the last time your phone renewed it.
- Your purchase state (the plan, until when it runs and when we verified it): no limit; a new purchase replaces it. Deleting the account does not remove it, but it stays tied to an identifier nobody can sign in with any more.
Your rights over your data
You hold these rights from any country where you use Pendi, and the same person handles them through the same route. If you live in Latin America, the legal deadlines and the authority you complain to are your country's, in its section below; from any other country, they are Colombia's. You can:
- Know and access, free of charge, the data of yours we process, what we use it for and whom we have given it to.
- Ask for proof of your authorization: we send you the text of each version with its date. The app only lets you past its terms screen once you have accepted the current version, so you use Pendi under the version in force since the date we send you.
- Update and rectify data that is out of date, incomplete or wrong.
- Delete your data, with the steps and limits described in Data deletion and How long we keep your data. Deleting your account erases the spaces that are yours; what you added to someone else's space stays there, without your name or email.
- Revoke your authorization or object to a use. The AI assistant, detection, the Personal-space backup and dictation sharing are switched off in Settings. Crash reports have no switch of their own today: the only way to stop them is to uninstall the app.
- Take your data with you: your movements come out as a CSV file from Export movements, and everything in the app as an encrypted backup you keep. What we keep in our services we send you as a JSON file if you ask.
- Not be subject to automated decisions: no suggestion in the app is applied on its own; you always confirm it.
- Complain to the data-protection authority of your country where this policy names one below, and otherwise to Colombia's, the Superintendencia de Industria y Comercio.
There is a single route for all of it: write to [email protected] from the address you use with Pendi, or include your space identifier from Settings. Queries, complaints and deletion requests all go there. Exercising a right costs you nothing.
Response time. We answer any request within five business days of receiving it. If a complaint needs more time to be resolved, within those five days we tell you why and by what date, and that date never goes past the maximum your country's law sets.
If you live in Colombia
Ley 1581 de 2012 and Decreto 1377 de 2013 apply. Our five business days are shorter than the law's, and these are the law's maximums: a query (consulta) is answered within ten business days, and if we cannot, we tell you why and by what date, and answer within five more business days at most. A complaint (reclamo) is handled within fifteen business days, and if we cannot, we tell you why and by what date, and handle it within eight more business days at most. If you believe a request was not handled properly, you can file a complaint with the Superintendencia de Industria y Comercio, Colombia's personal-data protection authority. The databases this policy describes stay in force while Pendi is offered, and each item is kept for the time How long we keep your data states.
If you live elsewhere in Latin America
We give you what your country's data-protection law asks for, as if Pendi were there. This list names that law and where you can complain; where your law gives you more than this policy, your law applies.
- Argentina: Ley 25.326. You can complain to the supervisory body that law sets up. The law's maximums: ten calendar days to give you access and five business days to rectify or delete.
- Chile: Ley 19.628 and, from December 1, 2026, Ley 21.719, which also protects people in Chile using a service offered from abroad; under it you also have a right to portability, and the maximum to answer you is thirty calendar days.
- Costa Rica: Ley 8968. You can complain to the Prodhab. The law's maximum for access: five business days.
- Ecuador: Ley Orgánica de Protección de Datos Personales, which protects you even though Pendi is not in Ecuador, with a right to portability. You can complain to the Autoridad de Protección de Datos Personales. The law's maximum for access: fifteen days.
- El Salvador: Ley para la Protección de Datos Personales of 2024. You can complain to the Agencia de Ciberseguridad del Estado. That law also recognizes erasure (the right to be forgotten) and restriction of processing; you ask for them through the same route. The law's maximum: twenty business days to answer you, extendable by twenty more for a justified cause.
- Mexico: Ley Federal de Protección de Datos Personales en Posesión de los Particulares. You exercise your rights of access, rectification, cancellation and objection through the route above, and you can complain to the Secretaría Anticorrupción y Buen Gobierno. The law's maximums: twenty days to answer you and fifteen more to carry the answer out.
- Nicaragua: Ley 787. You can complain to the Dirección de Protección de Datos Personales.
- Panama: Ley 81 de 2019 and its regulation, Decreto Ejecutivo 285 de 2021. You can complain to the Autoridad Nacional de Transparencia y Acceso a la Información. The law's maximums: ten business days to give you access and five business days to correct your data.
- Paraguay: Ley 7593 de 2025, from its entry into force on November 27, 2027. From then on you can complain to the Agencia Nacional de Protección de Datos Personales.
- Peru: Ley 29733. You can complain to the Autoridad Nacional de Protección de Datos Personales.
- Dominican Republic: Ley 172-13. If we do not handle your request, you can bring the habeas data action that law provides before the courts. The law's maximums: five business days to give you access and ten business days to rectify or delete.
- Uruguay: Ley 18.331, which under Ley 19.670 also governs a service offered from abroad to people living in Uruguay. You can complain to the Unidad Reguladora y de Control de Datos Personales. The law's maximum for access: five business days.
- Bolivia, Guatemala, Honduras and Venezuela: we offer you everything in this policy, and you can turn to your country's authorities.
This section is a summary. For users in Colombia the governing text is the Spanish version of this policy, Política de privacidad, because that is the language the law is written and enforced in.
If you live in Brazil
This section is for people using Pendi from Brazil, and it adds to everything above without taking anything away. Because Pendi is offered to people in Brazil, Brazil's Lei Geral de Proteção de Dados Pessoais (Lei 13.709 de 2018, LGPD) and the Marco Civil da Internet (Lei 12.965 de 2014) also apply to your data. The controller is Elkin Eduardo Cardoso Leyton, named above, at Carrera 4c Bis #39-24, Ibagué, Tolima, 730006, Colombia.
Contact channel
As a small processing agent, the controller is not required to appoint an encarregado pelo tratamento de dados pessoais (data protection officer) (Resolução CD/ANPD 2 de 2022, arts. 2, I, and 11). The channel for reaching him is [email protected] (art. 11, § 1): that is where your requests and complaints go, and the communications of the Agência Nacional de Proteção de Dados (ANPD).
What for, and on what legal basis
- Your account, syncing a shared space, the Personal-space backup, push registration and checking your purchases: because they are needed to give you the service you asked for (art. 7, V).
- The AI assistant and sharing your dictations: with your consent, which you revoke whenever you like under Settings > AI and Settings > Voice (art. 7, I).
- Crash reports: if the app crashes, it sends a technical crash report to Google's crash-reporting service so the defect can be fixed, because keeping the app working is part of the service you asked for (art. 7, V). They have no switch of their own.
- The free-trial start date, format reports and your feedback: our legitimate interest in the trial not restarting on reinstall, in improving for everyone the rules that recognise notifications, and in answering you (art. 7, IX). You can object by writing to us.
- The shop directory and the weekly contributor mark: the directory holds the details companies print on their receipts, and where a paper still lets through the details of an individual entrepreneur (empresário individual or MEI), those are personal data, for which the directory rests on their having been made manifestly public by their holder (art. 7, § 4) and on our legitimate interest in a shared directory of shops (art. 7, IX), and correcting the shop in the app removes them from Pendi's directory with the whole company, by its tax number, for 90 days, while a company taken out on a written request stays out for good. The weekly contributor mark: our legitimate interest in the directory not being abused (art. 7, IX). You can object by writing to us.
- Answering your requests: to comply with the law (art. 7, II).
Your rights
You can ask us to: confirm whether we process data about you; give you access to it; correct what is incomplete, inaccurate or out of date; anonymise, block or delete what is unnecessary or not processed lawfully; port it to another provider; delete what we process with your consent; tell you whom we share it with, which is the list under “Who processes the managed tier's fragments” and “Who else receives data, which countries it travels to, and under what safeguard”; tell you that you may refuse consent and what happens if you do, which is nothing: Pendi works fully without the assistant and without sharing your dictations; and revoke your consent. All of it is free and goes through the same address.
Confirmation or access in simplified form is given immediately; the full statement, with the data's origin, the criteria and the purpose, within 15 days of your request. Where our processing rests on your consent or on the service you asked for, you can ask for a complete electronic copy. In the app you can already export your movements to a CSV file, save an encrypted backup wherever you like and delete your account; what sits on our servers we send you by email in an open-format file.
If you believe a request was not handled properly, you can petition the ANPD at gov.br/anpd, or the consumer-protection bodies.
Data leaving Brazil
- What travels to give you the service you asked for (your account, shared spaces, the backup, notifications and purchases) goes to Google and Cloudflare in the United States because it is needed to perform that service (art. 33, IX, with art. 7, V).
- The assistant's fragments go to Cloudflare in the United States. They leave with the consent you give for that sending as a choice of its own, which tells you first that they are processed outside the country (art. 33, VIII).
- Crash reports go to Google in the United States when the app crashes, because keeping it working is part of the service you asked for (art. 33, IX, with art. 7, V).
Children and adolescents
Pendi is made for adults, not for children or adolescents to use on their own. If you add a child or an adolescent to a space, do it as their mother, father or legal guardian, and only with what the space needs, such as their name. That data is processed in their best interest and for what the space does for your family, nothing else.
Children
The app is a family organization tool intended for adults and is not directed at children under 13. If you are a minor, use it with the authorization of your mother, father or legal guardian, who gives it on your behalf. When an adult adds a minor as a person in their space, they do so as that minor's representative: the name and phone number are used only so the family can organize itself, the photo stays on the phone, and the adult can delete them at any time.
Changes
Every change to this policy, large or small, carries its version and date at the top of the page, and we announce it in the app's changelog before it takes effect. If a change touches what you authorized, such as what leaves the phone, to whom or to which country, the app asks for your authorization again before applying it.