Privacy Policy

Last updated: October 11, 2026 · Effective: October 11, 2026

This Privacy Policy describes how Gino Falcone, operating as Road to Jesus Ministry("Rivalto," "we," "us," or "our") collects, uses, discloses, and safeguards your personal information when you use the Rivalto mobile application and rivalto.app website(together, the "Service"). It also explains the choices and rights you have in relation to that information under the laws of California, United States, other United States jurisdictions, the European Union / United Kingdom General Data Protection Regulation ("GDPR"), the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), the Children's Online Privacy Protection Act ("COPPA"), and other applicable laws.

By creating an account, downloading the app, or otherwise using the Service, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree, do not use the Service.

1. Summary of Our Practices

• We collect the minimum information needed to run a daily-habit tracking, duel, and milestone-sharing social app.
• We do not sell personal information for money.
• We do not share personal information with advertisers.
• We do not use third-party analytics or tracking SDKs inside the app.
• You can delete your account at any time; the deletion is permanent and cascades through our database.
• Payment processing happens through Apple App Store or Google Play — we never see your card number.
• Our only sub-processors are listed in Section 7.

2. Scope and Definitions

• Service means the Rivalto mobile application and rivalto.app website, together with any related services we operate (such as transactional email, push notifications, and the administrative interface used by our team).
• Personal information(or "personal data") means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.
• Processing means any operation performed on personal information, including collection, storage, use, disclosure, transfer, and deletion.
• You means the natural person using the Service.

3. Information We Collect

3.1 Information you provide to us

• Account identifiers: email address (used as your sign-in identifier and for account recovery), username, display name, country code, timezone band, selected app language, and a password that we store only as a secure hash (we never see or log the plaintext).
• Profile content: optional profile photo (avatar), optional short bio, chosen visual theme (such as a shimmer color), and category sub-names you give your habit pillars (cardio, strength, nutrition, study, detox, sleep).
• Habit and activity data: habits you create or save from community templates, daily completion marks, missed days, streak counters (per habit template and per category), shield uses, milestone achievements, and category badge progress.
• Duel data:which timezone band you have joined, your duel participation preference (enabled or paused), per-day duel score, wins/losses/win-streak totals, and the opponent identifier for each day's matchup.
• Social content: milestone posts you publish or share, feed reactions and emoji responses, saved community templates, friend/connection requests, direct challenges you send to specific friends, bulletin-board posts and comments you write, feature-idea votes, user-submitted support tickets, debug reports you choose to send, and any photos you attach to a shared milestone artwork.
• Photo Log content: daily progress photos you choose to upload (a Pro-tier feature). These are stored in our private Supabase Storage bucket and linked to your account. You control whether to upload any photo at all.
• Communication preferences: whether you opted in to receive marketing email, and the language that was active on your device when you opted in (so we can send email in your preferred language).
• Support correspondence: the content of any ticket, bug report, or message you send us.

3.2 Information we collect automatically

• Device and build info: device model, operating system and version, app version and build number, locale, and the Expo update channel your install is on. Used for compatibility, debugging, and shipping over-the-air updates.
• Diagnostic events: if the app encounters an unhandled error, limited diagnostic context (stack trace, user id, screen name) is written to a private crash_logs table so we can reproduce and fix the bug. We do not use a third-party crash SDK for this.
• Push notification token: a device-specific token issued by Apple Push Notification Service (APNs) or Firebase Cloud Messaging (FCM), used only to deliver notifications you have enabled.
• Authentication session: secure session tokens issued by Supabase Auth and stored locally on your device so you do not have to sign in repeatedly.

3.3 Information from third parties

• Apple and Google: when you purchase a Pro subscription, Apple or Google provides us with a receipt and subscription status so we can grant or revoke Pro access. We never receive your payment card number or billing address through this flow.
• RevenueCat: we use RevenueCat to validate and manage subscription state. RevenueCat processes the Apple/Google receipt on our behalf and returns entitlement information. See their privacy policy at revenuecat.com/privacy.
• Referrals:if you join via a friend's referral link, we record which referral code was used so credit can be applied to the referring account.

3.4 Information we do NOT collect

• Precise geolocation (we only derive a country code from your IP and store a self-selected timezone band).
• Contact list, calendar, SMS, call log, or microphone data.
• Health, biometric, or wearable-device data.
• Advertising identifiers (IDFA on iOS or GAID on Android). We do not request App Tracking Transparency because we do not track across apps or websites.
• Third-party analytics or behavioral tracking beacons.

4. How We Use Information

• Provide the Service — authenticate you, run habit tracking and streak math, match you into a daily duel against another user in your timezone band, surface milestone badges, fan out milestone posts into the global and friends feeds in your chosen language, and keep your profile stats accurate.
• Deliver notifications you have enabled: duel start/finish, milestone achievements, challenge receipt, friend requests, and daily reset reminders.
• Manage subscriptions — grant or revoke Pro-tier features based on your subscription state as reported by Apple, Google, and RevenueCat.
• Communicate with you about your account (service email such as password reset, security alerts, and essential changes to this Policy or the Terms). Marketing email only when you have opted in; you can opt out at any time from the Profile toggle or the unsubscribe link in any marketing email.
• Keep the Service safe — enforce rate limits on comments, ticket submission, and habit-template creation; detect automation or abuse; investigate reports of harmful content; preserve audit trails of moderation actions.
• Debug and improve the Service — reproduce user-reported bugs using diagnostic context, measure which features are used so we know where to invest, run database maintenance.
• Comply with the law — respond to lawful requests, enforce our Terms, and protect our rights, your rights, and the rights of other users.

5. Legal Bases for Processing (GDPR / UK GDPR)

If you are in the European Economic Area, the United Kingdom, or Switzerland, our legal bases are:

• Contract (Art. 6(1)(b)): processing necessary to deliver the Service you asked us to provide — account creation, habit tracking, duel matching, subscription management, feed delivery.
• Legitimate interests (Art. 6(1)(f)): keeping the Service secure, preventing abuse, debugging, and limited internal analytics on aggregate feature usage. We balance these interests against your rights.
• Consent (Art. 6(1)(a)): marketing email, optional push notifications, uploading a progress photo, and any sensitive processing. You can withdraw consent at any time without affecting the lawfulness of prior processing.
• Legal obligation (Art. 6(1)(c)): responding to valid legal requests and meeting tax, consumer-protection, or accessibility requirements.

6. How We Share Information

We share personal information only in the limited circumstances listed below. We do not sell your personal information for money and do not disclose it to advertisers.

• With other users, when you choose to share: your username, display name, avatar, country flag, chosen theme, Pro status (as a badge), and public-facing counters (duel wins/losses, streaks, perfect weeks) are visible to other users of the Service. Content you post to the global feed, friends feed, or bulletin board is visible to users with access to those surfaces. You control what you post.
• With our sub-processors (Section 7), strictly to operate the Service.
• In response to lawful process: subpoenas, court orders, or other legal requirements we are compelled to comply with. We will push back on overbroad requests and where legally permitted will notify you.
• To protect rights and safety: if we reasonably believe disclosure is necessary to prevent fraud, harm to a user, or violations of our Terms.
• In a corporate transaction: if we transfer the Service, we may transfer your personal information to the acquirer under equivalent protections. We will give you notice before any such transfer takes effect.
• With your consent, for any purpose not described above.

7. Sub-processors

The following vendors process personal information on our behalf. We review each annually.

• Supabase (Supabase Inc.) — hosts our Postgres database, authentication, file storage, and edge functions. Data is stored in the United States (region us-east-1). Privacy: supabase.com/privacy.
• RevenueCat (RevenueCat, Inc.) — validates App Store and Play Store subscription receipts and reports entitlement state back to the app. Privacy: revenuecat.com/privacy.
• Apple and Google — process in-app subscription payments and deliver the receipt to RevenueCat / our server. See the respective store privacy pages.
• Apple Push Notification Service and Firebase Cloud Messaging— deliver push notifications to your device when you have notifications enabled.
• Expo (Expo, Inc.) — hosts the EAS build infrastructure, delivers over-the-air JavaScript updates, and provides the Expo Push gateway we use to send notifications through APNs/FCM. Privacy: expo.dev/privacy.
• Email transactional provider — used only to send account-service and opted-in marketing email. If and when we add a provider for this, it will be listed here with the date added.

8. International Data Transfers

Our primary infrastructure is located in the United States. If you access the Service from outside the United States, your information will be transferred to and processed in the United States, which may have data-protection laws different from those of your country. For transfers out of the European Economic Area, United Kingdom, or Switzerland, we rely on the European Commission's Standard Contractual Clauses with each sub-processor, together with any additional safeguards those sub-processors have in place (such as encryption in transit and at rest).

9. Data Retention

• Account data is retained for as long as your account is active. If you delete your account, we delete associated personal data within 30 days, except where we are legally required to retain it (for example, limited financial records for tax audit).
• Transactional subscription records may be retained up to 7 years to meet tax and audit obligations.
• Backups are retained in encrypted form by Supabase on a rolling 7-day schedule and will overwrite your deleted data in the normal rotation.
• Aggregated or de-identified data that cannot reasonably be used to identify you may be retained indefinitely.
• Content you shared with other users(such as a bulletin-board comment on another user's post) may remain visible after your account is deleted, but will be disassociated from your profile.

10. Your Rights and Choices

10.1 Universal controls inside the Service

• Edit your profile, bio, avatar, display name, country, timezone band, and language at any time.
• Toggle whether your badge history and habit history are public to other users.
• Toggle email marketing opt-in from the Profile tab.
• Pause or disable duels, and change your timezone band (subject to a cooldown).
• Delete any individual bulletin post, comment, or saved template you authored.
• Request full account deletion from the Settings → Account section.

10.2 Rights under GDPR / UK GDPR

If you are a resident of the EEA, UK, or Switzerland, you have the right to:

• Access the personal information we hold about you.
• Request correction of inaccurate data.
• Request deletion of your data (right to erasure).
• Restrict or object to our processing.
• Portability — receive a machine-readable copy of your data.
• Withdraw consent, where consent is the lawful basis for processing.
• Lodge a complaint with your local supervisory authority.

10.3 Rights under CCPA / CPRA (California residents)

California residents have the right to:

• Know the categories and specific pieces of personal information we have collected about you in the preceding 12 months.
• Know the categories of sources, business/commercial purposes, and third parties with whom we share personal information.
• Request deletion of personal information we have collected from you.
• Correct inaccurate personal information.
• Opt out of the sale or sharing of personal information for cross-context behavioral advertising. We do not sell or share for cross-context advertising — but this right remains yours.
• Limit the use of sensitive personal information. We do not collect sensitive personal information for inference.
• Be free from retaliation for exercising any of these rights.

10.4 Rights under VCDPA, CPA, CTDPA, UCPA, and similar US state laws

Residents of Virginia, Colorado, Connecticut, Utah, and other states with comparable privacy laws have substantially the same rights of access, correction, deletion, portability, and opt-out as described above. Contact us using the details in Section 15.

10.5 How to exercise your rights

You may exercise most rights directly in the app. For requests we cannot complete in-app, email us at roadtojesusministry@gmail.comwith the subject line "Privacy request". We will respond within 30 days (or longer only where law permits an extension, with notice to you). We may need to verify your identity before fulfilling a request. You may use an authorized agent; we will verify the agent's authority.

11. Children's Privacy (COPPA and global minimum age)

The Service is not directed to children under the age of 13 in the United States, under 14 in Spain and South Korea, or under 16 in the European Economic Area and the United Kingdom. We do not knowingly collect personal information from children below the applicable minimum age. If we learn that we have inadvertently collected personal information from a child below the applicable minimum age, we will delete that information promptly. If you believe a child has provided us with personal information, please contact us using the details in Section 15.

12. Security

• All connections to our Service are encrypted using TLS 1.2 or higher.
• Passwords are stored only as salted hashes (bcrypt via Supabase Auth); we have no mechanism to recover a plaintext password.
• Supabase Row Level Security policies restrict database access per-user; service-role keys that could bypass RLS are kept in server-only environments.
• We have enabled HaveIBeenPwned compromised-password detection on account creation and password change.
• Database backups are encrypted at rest by Supabase.
• Internal access is limited to the operator (one person) and audited.
• No security program is perfect. If you believe you have discovered a vulnerability, please report it to the contact address in Section 15. We will acknowledge within 72 hours.

13. Push Notifications

If you grant notification permission, we send operational notifications (duel start/end, milestone earned, friend challenge, daily reset reminder). Your push token is stored on your profile row and used only to send notifications you have enabled. You can disable notifications at any time from your device settings or inside the Service.

14. Cookies and Website Analytics

The rivalto.app website uses the minimum cookies required for the site to function and does not run third-party advertising or analytics cookies. Our mobile app does not use web cookies. If we add first-party analytics in the future, we will update this Policy and give you a chance to opt out before any new category of tracking begins.

15. Contact

For any privacy question, request, or complaint, contact:

• Data Controller: Gino Falcone, operating as Road to Jesus Ministry
• Email: roadtojesusministry@gmail.com
• Subject line: "Privacy request"

If you are in the EEA or UK and we have not resolved your concern, you may contact your local data-protection supervisory authority.

16. Changes to this Policy

We may update this Policy from time to time. If we make material changes, we will notify you through the Service and update the "Last updated" and "Effective" dates at the top. Continued use of the Service after the effective date of the change constitutes your acknowledgement of the updated Policy. If the change concerns a new category of personal information or a new purpose incompatible with the original purpose, we will seek your renewed consent where legally required.

17. Automated Decision-Making

We do not use personal information to make decisions that produce legal or similarly significant effects on you through solely automated means. Features such as duel matchmaking operate on your explicit opt-in and may be paused, re-matched, or disabled by you at any time.

18. Do Not Track Signals

Because we do not track users across apps or websites, we do not currently respond to browser-level "Do Not Track" signals in a specific way. If a standard emerges that meaningfully differs from our current practice, we will update this Policy.