Brazil privacy notice (LGPD)

The controller — the company that makes the decisions about processing your personal data — is Omnibus, Ltd., postal address available on request at the email below, established in the country where Omnibus, Ltd. is registered. The LGPD applies to us because we offer the service to people in Brazil (Art. 3).

The full list of what we collect is in the privacy policy. This notice does not repeat it; it adds what the LGPD requires.

The encarregado is the contact point between you, Omnibus, Ltd. and Brazil's National Data Protection Authority (ANPD) (Art. 41).

The LGPD allows processing only on a legal basis (Art. 7) and, for sensitive personal data such as health data, only under one of the cases in Art. 11. Here is ours for each purpose.

Where we rely on legitimate interest, we use only the data strictly needed and take your rights and expectations into account (Art. 10). We never rely on legitimate interest for sensitive data.

Listening levels, sound dose and posture state can tell something about a person's health, so we treat them as sensitive personal data (Art. 5(II)) — even though Earbunny is not a medical device and never diagnoses anything.

• We ask for consent on its own screen, separately from the terms, with a box that is not pre-ticked.
• Apple Health access is read-only and covers only headphone and environmental audio levels. We write nothing to Health.
• Without this consent the measurement features stay off; the rest of the app keeps working.
• You can revoke consent at any time (Art. 8 §5): turn off the permission in iOS Settings or in the app, or delete the account. Revocation does not affect processing done before it.

We always process children's and teenagers' data in their best interest (Art. 14). For children, we ask for specific and highlighted consent from at least one parent or the legal guardian (Art. 14 §1).

• Only a parent or guardian can create a child's profile. Children have no email or password and cannot sign up alone.
• The parent gives consent before the child's phone is paired, and we record who consented and when. For children under 13, no pairing code can be created without it.
• We collect only what the features need and do not make games or activities depend on giving more data than that (Art. 14 §4).
• There is no hidden mode: the child always sees, in simple language, that monitoring is on and who can see their data (Art. 14 §6).
• No ads, no profiling and no third-party analytics in children's accounts.

What we process and how to exercise rights is published in the children's privacy notice (Art. 14 §2).

A person's data is visible only to that person and the parents linked to them. Schools that a parent invites see only anonymous class averages, and only when at least 10 students report.

We use processors (operadores) — companies that process data only on our instructions and under contract — for hosting in the European Union, the website, push notifications, sign-in, App Store billing, email delivery and crash and log monitoring. They are listed with their location in the subprocessor list. We may also give data to authorities where the law requires it. We do not sell data and do not use it for advertising.

Our servers and backups are in the European Union, and some processors may access data from the United States or other countries, so your data is transferred out of Brazil. We do this only in the cases allowed by Art. 33 LGPD:

• to countries or international organisations that the ANPD recognises as providing an adequate level of protection (Art. 33(I)), where such a decision exists; or
• under the standard contractual clauses approved by the ANPD in its International Data Transfer Regulation (Resolution CD/ANPD No. 19/2024) (Art. 33(II)(b)).

You can ask about these safeguards at privacy [at] earbunny.app.

We keep data only as long as the purpose needs it: raw samples 30 days, minute summaries 90 days, events 90 days, event location 7 days, daily summaries and reports until the account is deleted, encrypted backups 30 days. After that, data is deleted (Art. 16) unless the law requires us to keep it. The full table is in the privacy policy.

Under Art. 18 LGPD, you have the right to:

• confirmation that we process your data;
• access to your data — in the app: Settings → Download my data;
• correction of incomplete, inaccurate or out-of-date data;
• anonymisation, blocking or deletion of unnecessary or excessive data, or data processed in breach of the LGPD;
• portability of your data to another provider, in a machine-readable format (JSON);
• deletion of data processed with your consent — in the app: Settings → Delete account;
• information about the public and private entities we share data with;
• information about the option of not giving consent and what happens if you refuse (the features that need it stay off);
• revocation of consent, at any time.

You may also object to processing done without consent if it breaches the LGPD (Art. 18 §2), and ask for a review of decisions made solely by automated processing (Art. 20) — see section 10.

Write to privacy [at] earbunny.app or use the contact form. It is free of charge. Confirmation and access are given immediately in a simplified format or, as a clear and complete statement, within 15 days (Art. 19). We may ask you to confirm your identity. Parents and guardians can exercise these rights for their children.

Complaints. You can petition the ANPD (gov.br/anpd) (Art. 18 §1) or consumer protection bodies such as Procon (Art. 18 §8). We would appreciate the chance to fix things first.

Earbunny calculates things automatically: sound dose, alerts, posture nudges, goal progress and streaks. None of this defines your personal, professional, consumer or credit profile or has legal or similarly significant effects. You can still ask about the criteria used and request a review of any result (Art. 20). We do no profiling for advertising or marketing.

The site stores only what is needed — your theme, language and cookie choice — and loads cookieless, aggregated analytics only after you say yes. Bot protection on forms is strictly necessary. Details and choices are in the cookie policy.

We use technical and administrative measures to protect data (Art. 46): encryption in transit and at rest, restricted and logged access, and two-step verification for staff. If a security incident may cause relevant risk or harm, we notify the ANPD and the people affected (Art. 48) within the deadlines set by ANPD regulation.

We announce material changes in the app and by email before they take effect, and ask for consent again if we add a purpose that needs it (Art. 8 §6). The date at the top shows the current version.