Privacy Policy

This Privacy Notice for 9555-2972 Québec inc. (doing business as OTB solutions) ("we," "us," or "our") describes how and why we may access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

• Visit our website at https://frugio.co or any website of ours that links to this Privacy Notice
• Download and use our mobile application (frugio), or any other application of ours that links to this Privacy Notice
• Engage with us in other related ways, including marketing or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. You may contact us at otbsols@gmail.com.

Summary of Key Points

This summary provides key points from our Privacy Notice. You can find more details using the table of contents below.

• What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services.
• Do we process sensitive personal information? We do not process sensitive personal information.
• Do we collect information from third parties? We may receive campaign attribution, purchase, and subscription information from service providers such as AppsFlyer, RevenueCat, app stores, and payment processors.
• How do we process your information? We process information to provide, improve, and administer our Services, communicate with you, protect security, prevent fraud, and comply with law.
• When do we share personal information? We may share information in specific situations and with specific third parties, as described below.
• How do we keep your information safe? We use organizational and technical safeguards, but no electronic transmission or storage technology can be guaranteed 100% secure.
• What are your rights? Depending on where you are located, applicable privacy law may give you rights over your personal information.
• How do you exercise your rights? The easiest way is by visiting your profile or contacting us.

Table of Contents

1. What information do we collect?
2. How do we process your information?
3. What legal bases do we rely on to process your personal information?
4. When and with whom do we share your personal information?
5. Do we offer artificial intelligence-based products?
6. How do we handle your social logins?
7. How long do we keep your information?
8. How do we keep your information safe?
9. Do we collect information from minors?
10. What are your privacy rights?
11. Controls for Do-Not-Track features
12. Do United States residents have specific privacy rights?
13. Do we make updates to this notice?
14. How can you contact us about this notice?
15. How can you review, update, or delete the data we collect from you?

1. What information do we collect?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide when you register on the Services, express interest in our products or Services, participate in activities on the Services, or contact us.

Personal Information Provided by You. The personal information we collect may include names, phone numbers, email addresses, usernames, passwords, country, and date of birth.

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process payments and subscriptions, including transaction identifiers and purchase history. Payment data is handled by providers such as Stripe, Apple, Google Play, and RevenueCat. You may find Stripe's privacy notice at https://stripe.com/en-ca/privacy.

Social Media Login Data. If you register using a social media account, we may collect certain profile information from that provider, as described below.

Application and Attribution Data. If you use our application(s), we may collect device and advertising identifiers, IP address, app launches, in-app events, campaign attribution, purchase events, and mobile device feature permissions such as camera access. We use this data to operate the app, measure campaign performance, attribute subscriptions to campaigns, prevent fraud, troubleshoot issues, and support analytics and reporting. You may change device permissions in your device settings.

Google API

Our use of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

2. How do we process your information?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, protect security, prevent fraud, and comply with law.

We process personal information to facilitate account creation and authentication, manage user accounts, provide and improve Services, communicate with you, protect vital interests, and meet legal obligations.

3. What legal bases do we rely on to process your personal information?

In Short: We process personal information only when we believe it is necessary and we have a valid legal reason to do so.

If you are located in the EU or UK, this section applies to you. We may rely on consent, legal obligations, and vital interests. You may withdraw your consent at any time.

If you are located in Canada, this section applies to you. We may process your information with express or implied consent. In limited cases, we may be legally permitted to process information without consent, including for fraud prevention, investigations, business transactions, legal compliance, emergencies, publicly available information, or approved research/statistics projects.

4. When and with whom do we share your personal information?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

Business Transfers. We may share or transfer information in connection with a merger, sale of company assets, financing, or acquisition of all or part of our business.

Service providers and analytics partners. We may share information with providers that support hosting, authentication, payments, subscriptions, analytics, attribution, advertising measurement, fraud prevention, customer support, and AI features, including Supabase, Stripe, RevenueCat, AppsFlyer, PostHog, Apple, Google Play, Google Cloud AI, and OpenAI.

5. Do we offer artificial intelligence-based products?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

Our Services include AI-powered products, features, or tools ("AI Products"). We provide these through third-party service providers, including Google Cloud AI and OpenAI. Your input, output, and personal information may be shared with and processed by these providers. You must not use AI Products in a way that violates any provider's terms or policies.

Our AI Products

• AI applications
• Image generation
• Image analysis

All personal information processed using our AI Products is handled in line with this Privacy Notice and our agreements with third parties.

6. How do we handle your social logins?

In Short: If you register or log in using a social media account, we may have access to certain information about you.

If you use third-party social login, we may receive profile information from that provider, often including your name, email address, friends list, and profile picture. We use this information only for the purposes described in this Privacy Notice and do not control how the provider uses your information.

7. How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfill the purposes in this Privacy Notice unless otherwise required by law.

No purpose in this notice will require us to keep personal information for longer than twelve (12) months after account termination. When we no longer have a legitimate business need, we will delete or anonymize the information or securely store it until deletion is possible.

8. How do we keep your information safe?

In Short: We aim to protect your personal information through organizational and technical security measures.

We use appropriate and reasonable safeguards to protect personal information. However, no electronic transmission or storage technology can be guaranteed 100% secure. Transmission of personal information to and from our Services is at your own risk.

9. Do we collect information from minors?

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age required by law.

By using the Services, you represent that you are at least 18 or that you are the parent or guardian of a minor and consent to the minor's use of the Services. If we learn that we collected personal information from a user under 18, we will deactivate the account and take reasonable steps to delete the data. Contact us at otbsols@gmail.com if you believe this occurred.

10. What are your privacy rights?

In Short: Depending on your location, you may have rights that allow access to and control over your personal information.

You may have rights to request access, correction, deletion, restriction of processing, portability, and protection from certain automated decision-making. You may withdraw consent at any time by contacting us.

You can unsubscribe from marketing communications by using an unsubscribe link in our emails or by contacting us.

Account Information

You may update your account by logging into account settings or visiting your profile. Upon request to terminate your account, we will deactivate or delete your account and information from active databases, subject to limited retention for fraud prevention, troubleshooting, investigations, and legal compliance.

11. Controls for Do-Not-Track features

Most browsers and some mobile operating systems include a Do-Not-Track ("DNT") feature. No uniform technology standard for recognizing DNT signals has been finalized, so we do not currently respond to DNT browser signals.

California law requires us to disclose how we respond to DNT signals. Because there is no industry or legal standard, we do not respond to them at this time.

12. Do United States residents have specific privacy rights?

In Short: Residents of certain US states may have rights to request access to and details about the personal information we maintain.

Categories of Personal Information We Collect

The table below shows categories of personal information we have collected in the past twelve (12) months.

We use and retain collected personal information as needed to provide the Services. Categories A, B, and C are retained as long as the user has an account with us.

Sources, Use, and Sharing

We collect personal information from the sources described in section 1 and use it as described in section 2. We may disclose personal information to service providers and analytics or attribution partners for app functionality, payment processing, subscription management, campaign measurement, security, fraud prevention, and reporting. We have not sold personal information for money in the preceding twelve (12) months.

Your Rights

• Right to know whether we process your personal data
• Right to access, correct, or delete personal data
• Right to obtain a copy of personal data you shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of targeted advertising, sale of personal data, or profiling where applicable

To exercise these rights, visit your profile, email otbsols@gmail.com, or use the contact details below. We may need to verify your identity before acting on a request.

If we decline your request, you may appeal by emailing us. If your appeal is denied, you may submit a complaint to your state attorney general.

California "Shine The Light" Law

California Civil Code Section 1798.83 permits California residents to request, once per year and free of charge, information about categories of personal information disclosed to third parties for direct marketing purposes. Submit such requests using the contact details in section 14.

13. Do we make updates to this notice?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will show an updated "Last updated" date. We encourage you to review this notice frequently.

14. How can you contact us about this notice?

If you have questions or comments about this notice, email otbsols@gmail.com or contact us by post at:

You can also reach us through our Contact page.

15. How can you review, update, or delete the data we collect from you?

Based on applicable laws in your country or US state of residence, you may have the right to request access to the personal information we collect, details about how we processed it, correction of inaccuracies, deletion, or withdrawal of consent. To request review, update, or deletion, please visit your profile.