Ponte11
Privacy Policy
This Policy explains how we process personal data when you use the Ponte11 mobile application, its public pages, and related services (collectively, the "Service"). Ponte11 lets you discover nearby merchants and coupons, follow merchants, and claim or redeem coupons.
This Policy applies without prejudice to the mandatory rights granted to you by the law of your place of residence. If a local rule grants greater protection, we will apply that protection.
1. Who is responsible for your data
FORTGEST decides for what and how the personal data described in this Policy are processed and acts as the data controller.
You may send inquiries, rights requests, or complaints to info@fortgest.com, with the subject "Privacy — Ponte11". We do not state that we have appointed a data protection officer or a regional representative unless their details are expressly published in an update to this Policy.
2. Personal data we process
Depending on the features you use and the permissions you grant, we may process:
- Account and identity: name, email address, optional phone number, internal user identifier, and account status. If you create a password, we process the credentials necessary to authenticate you; we do not display or store passwords in readable text.
- External sign-in: if you choose Google or Apple, we receive the account identifier, name, and email or alias you authorize. Apple may provide us with a private relay address.
- Location: precise coordinates while you use the features that require them, plus city, country, and inferred time zone. We do not request location in the background.
- Activity in Ponte11: searches, interests, and preferences; followed merchants; coupons viewed, claimed, or redeemed; and data needed to validate proximity and prevent misuse.
- Device and operation: model, operating system, application version, language, technical identifiers, IP address, and logs of connections, errors, security, and requests to our systems.
- Communications and notifications: push notification token, preferences by category, and communications you send us.
- Data stored locally: session, preferences, consent indicators, recent location, and cached files needed for the operation and performance of the application.
Ponte11 does not process payments or card data within the application. The evaluated version of the Service also does not request access to contacts, microphone, health data, or biometrics to identify you, and does not sell data or use behavioral advertising SDKs. If we incorporate new categories or purposes, we will update this Policy and the in-app notices before starting the processing when the law so requires.
3. Where we obtain the data
We obtain data directly from you, from your device, and from your use of the Service. We also receive data from Google or Apple when you choose to sign in with those providers, and from participating merchants when an interaction or redemption must be associated with their establishment.
4. What we use the data for and the legal basis
The exact legal basis depends on your jurisdiction. When laws such as the GDPR, the UK GDPR, or equivalent rules require it to be identified, we rely on the following:
| Purpose | Main data | Legal basis |
|---|---|---|
| Create, authenticate, and administer your account | Account, credentials, and external sign-in | Performance of the contract or pre-contractual measures |
| Show nearby merchants and coupons | Location and preferences | Your consent to access location; performance of the requested service |
| Claim and validate redemptions | Account, coupon, merchant, date, and location when necessary | Performance of the contract; legitimate interest in verifying redemption |
| Save preferences, followed merchants, and functional history | Account, activity, and preferences | Performance of the contract |
| Send operational alerts and optional notifications | Account, token, and preferences | Performance of the contract for essential alerts; consent for optional or promotional notifications |
| Protect the Service and prevent fraud, abuse, or unauthorized access | Account, device, logs, activity, and event-related location | Legitimate interest in security, subject to balancing of rights; legal obligation where applicable |
| Handle support, rights, and complaints | Account, contact, and request content | Performance of the contract, legal obligation, and legitimate interest in managing and evidencing the response |
| Comply with valid orders and regulatory obligations | Data required in each case | Legal obligation or defense of rights |
| Maintain and improve stability and performance | Minimized or aggregated technical and usage data | Legitimate interest in operating and improving the Service |
Where processing is based on your consent, you may withdraw it at any time from Ponte11 settings or the device, or by writing to us. Withdrawal does not affect the lawfulness of prior processing. Refusing to provide optional data does not prevent you from using features that do not need it; without location, notifications, or certain account data, some features may not be available.
We may convert data into aggregated or anonymized statistics that do not allow a person to be reasonably identified. We use that information to measure the operation, security, and general use of the Service. We will not attempt to re-identify anonymized data, except to verify that the anonymization process works or when the law permits.
5. Device permissions
- Location: is requested only when using proximity features. You may disable the permission or the "Share location" option; when you do, Ponte11 may show a saved city or limit nearby features.
- Notifications: you may accept or decline the permission and modify categories from Ponte11 or the operating system.
- Promotional emails: when offered, you may unsubscribe using the link included in the message or by writing to us. Even if you unsubscribe, we may send you communications that are indispensable regarding your account, security, legal changes, or requests initiated by you.
- Account and profile: you may view or update certain data and preferences from the application. For changes not available there, you may use the privacy channel.
- Google or Apple sign-in: you may withdraw the connection from the provider's settings. Doing so does not automatically delete your Ponte11 account and may prevent access until you configure another authentication method.
- Local storage: you may delete local data by logging out where the feature allows it, clearing the application data, or uninstalling it. Uninstalling does not automatically delete the information associated with your account on our systems.
6. Providers and other disclosures
We do not sell or rent personal data and do not share it for cross-context behavioral advertising. We may disclose the minimum necessary data to:
- Google Firebase: authentication, Cloud Messaging, Remote Config, and storage of files or content necessary for the Service.
- Google Maps Platform and geocoding services: maps, computation or display of locations, and conversion of coordinates into geographical references.
- Google and Apple: authentication when you choose to sign in with one of those accounts, and their own platform services.
- Infrastructure, hosting, communications, support, and security providers: to operate the API, databases, networks, and technical support under contractual instructions.
- Participating merchants: the minimum necessary information to validate a coupon or resolve an incident related to that merchant. We do not provide them your precise location for their own independent purposes unless you are informed and there is a valid legal basis.
- Authorities, courts, or advisors: when reasonably necessary to comply with the law, respond to a valid request, protect rights, or investigate fraud and security threats.
- A successor entity: in a merger, financing, reorganization, or sale, subject to confidentiality and the continuation of applicable protections.
Providers act as processors or as independent controllers depending on the function they perform. Their services may also be subject to their own privacy policies.
When you choose to communicate directly with a merchant, visit its website, use its services outside Ponte11, or provide it additional information, that merchant may process the data as an independent controller under its own policy. Ponte11 does not control that independent processing.
7. International transfers
FORTGEST is established in the United States and some providers operate globally. As a result, data may be processed in countries other than the one where you reside, whose laws may offer different levels of protection.
When an international transfer requires safeguards, we use the legal mechanism that corresponds to the specific flow, such as adequacy decisions, approved contractual clauses, UK addenda, binding corporate rules, or another permitted exception. We also apply proportionate contractual, technical, and organizational measures. You may request information about the applicable mechanism and a copy of the safeguards, subject to redaction of confidential information, by writing to info@fortgest.com.
8. Retention and deletion
We do not retain personal data longer than necessary. We apply these periods or criteria:
| Data | Period or criterion |
|---|---|
| Account, profile, and preferences | While the account is active; afterward, during the deletion process described below |
| Notification token | While associated with an active installation or account, until replaced, no longer valid, or the account is deleted |
| Location and functional activity | Only for the time needed to provide the feature, record the redemption, or resolve incidents; thereafter deleted, aggregated, or unlinked when no longer needed |
| Security, fraud, and operation logs | The minimum period reasonably necessary for security, incident investigation, and defense of claims, applying restricted access and periodic rotation |
| Support and rights requests | While the request is handled and afterward for the period necessary to evidence its handling and comply with legal obligations |
| Backups | Until their secure rotation according to the applicable technical cycle; they remain isolated and are not restored for ordinary use |
We may retain minimal information when a law requires it or when necessary to prevent fraud, resolve disputes, or exercise and defend claims. In those cases we block or restrict it, do not use it for other purposes, and delete or anonymize it when the obligation ends.
9. How to delete your account
You can initiate deletion:
- In the application: Profile → Settings → Deactivate or delete account → Delete account.
- Outside the application: visit ponte11.app/delete-account or write from the email associated with the account to info@fortgest.com with the subject "Delete Ponte11 account".
The account enters a recovery period of up to 30 days. During that period it is deactivated and not used to provide the Service, unless you decide to reactivate it. At the end, we permanently delete the account and request providers to delete the associated data, except for the minimal information we must retain for the reasons indicated in section 8. Deleting the application from the device is not equivalent to deleting the account.
10. Your rights and how to exercise them
Depending on where you reside, you may have the right to:
- know whether we process your data and access it;
- obtain a copy and, where applicable, request its portability;
- correct, update, delete, or anonymize data;
- object to or request the restriction or suspension of certain processing;
- withdraw consent without retroactive effect;
- request information about recipients and transfers;
- not receive discriminatory treatment for exercising rights;
- limit certain uses of sensitive information or opt out of sales, targeted advertising, or profiling where those activities exist;
- challenge a decision made exclusively by automated means when it produces legal or similar effects; and
- lodge a complaint with the competent data protection authority.
Send your request to info@fortgest.com. State the right you wish to exercise and the email associated with your account. We will verify your identity proportionately and may ask for additional information; we will never ask for your password. You may also act through an authorized representative where the law permits.
We will handle the request free of charge and within the applicable legal period. We may refuse or charge a reasonable cost only where the law permits, for example in the case of manifestly unfounded, excessive, or unverifiable requests, explaining our decision and the available remedies.
11. Regional information
European Economic Area, United Kingdom, and Switzerland
You may exercise access, rectification, erasure, restriction, portability, objection, and withdrawal of consent. When we rely on a legitimate interest, you may request information about our balancing analysis. You may also lodge a complaint with the authority of your residence, place of work, or the alleged infringement. If the law requires appointing a representative or officer, we will publish their details before offering the Service in the corresponding territory.
California and other states of the United States
In the past 12 months we may have collected the categories described in section 2: identifiers; account and commercial activity information; internet or application activity; precise geolocation; technical information; and basic inferences about preferences. The sources, purposes, and recipients are described in sections 3, 4, and 6.
We do not sell personal information or share it for cross-context behavioral advertising, including information of minors that we become aware of. We use precise location solely to provide the requested features, security, and fraud prevention. Where applicable state law recognizes it, you may request access/knowledge, correction, deletion, portability, limitation of sensitive data, and opt-out of sale, targeted advertising, or profiling, and appeal a denial. Since we do not currently engage in sale, targeted advertising, or sharing for cross-context advertising, no opt-out needs to be activated for those practices.
Brazil
Persons protected by the Lei Geral de Proteção de Dados (LGPD) may request confirmation and access, correction, anonymization, blocking, or deletion in the legal cases, portability, information about sharing, revocation of consent, and review of automated decisions. They may also lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD).
Ecuador and other Latin American countries
Persons protected by the Ley Orgánica de Protección de Datos Personales of Ecuador may exercise, as applicable, information, access, rectification and updating, deletion, objection, portability, suspension, and rights in relation to automated decisions, and may lodge a complaint with the Superintendencia de Protección de Datos Personales. In other countries we will apply the mandatory rights and procedures of local legislation.
12. Automated decisions
Ponte11 may apply automatic rules of proximity, availability, and detection of unusual patterns to show content, validate redemptions, and flag potential abuse. We do not make decisions exclusively by automated means that produce legal or similarly significant effects on you. If you believe a measure was applied incorrectly, you may request human review through the contact channel.
13. Security
We apply reasonable and proportionate technical and organizational measures, including encryption in transit via HTTPS/TLS, access controls, minimization, credential management, and storage of session tokens using the operating system's secure mechanisms, such as Keychain or Keystore. No system is completely secure; notify us of any suspected unauthorized access and use a unique, strong password.
We maintain procedures to assess and respond to incidents. If a personal data breach poses a risk that must be notified, we will inform the competent authority and the affected individuals within the deadlines and with the content required by applicable law.
14. Minors
Ponte11 is a general-audience service intended exclusively for persons who have reached the age of majority in their place of residence. We do not knowingly collect data from minors. If we learn that a minor created an account, we will take reasonable steps to close it and delete their data, except for legally required retention. Parents or guardians may contact info@fortgest.com.
15. Websites, cookies, and external links
The mobile application does not use browser cookies or behavioral advertising SDKs. Ponte11's public web pages may generate standard technical logs — such as IP address, date, browser, and requests — through the hosting provider for security and availability. If in the future we use non-essential cookies, we will offer the required notice and consent options.
The Service may contain links or content from merchants and third parties. We do not control their independent practices; review their policies before providing them data.
16. Changes to this Policy
We may update this Policy to reflect operational, legal, or technological changes. We will publish the current version with its date and, when the change is substantial or the law so requires, we will communicate it within the application or by another appropriate means and request new consent where applicable.
17. Contact and complaints
For privacy-related questions or requests:
FORTGEST LLC
30 N Gould St Ste N, Sheridan, WY 82801, United States
info@fortgest.com
Recommended subject: "Privacy — Ponte11"
We will try to resolve your concern directly. You may also lodge a complaint with the competent data protection authority in your place of residence.