PRIVACY POLICY

Itinerama

Last updated: April 1, 2026

1. Data controller

The controller of the personal data processed through Itinerama is:

Jonathan Rodriguez Ruiz
Self-employed professional established in Ireland
General email: jrodriguezruiz@itinerama.app
Privacy and support email: support@itinerama.app
Website: https://itinerama.app

2. Scope of this policy

This Privacy Policy explains what personal data we may process when users use Itinerama, for what purposes, on what legal bases, for how long, with which third parties it may be shared, and which rights users may exercise.

3. Data we may collect

Depending on how the App is used, we may process the following categories of data:

a) Account and profile data

b) Data generated within the App

c) Technical and diagnostic data

d) Purchase and subscription data

e) Data derived from specific features

4. Optional data and anonymous access

Access to certain features may be possible anonymously. Much of the processed data depends on how the user uses the App and which features they decide to activate.

As a general rule, data is collected only when necessary to provide a specific feature or when the user decides to use it voluntarily.

5. Device permissions

The App may request certain device permissions:

Location

For maps, routes, and navigation features.

Camera

For features such as expense OCR.

Photos or gallery

To change the avatar or upload expenses via OCR.

Microphone or voice

To ask the assistant questions by voice, where that feature is available.

Notifications

At present, the App does not request notification permissions.

Users may manage these permissions through their device settings. If a permission is denied or revoked, certain features may become unavailable or work only in a limited manner.

6. Purposes of processing

We may process personal data for the following purposes:

7. Legal bases for processing

We process personal data on the following legal bases, depending on the case:

8. Artificial intelligence

Itinerama uses artificial intelligence systems to respond to user queries and to enable certain automated functions, such as interpretation of information through OCR.

Under the current service configuration, content sent to these systems may include:

According to the information currently provided by the owner, no personal data is intentionally sent beyond the content strictly necessary to provide the feature. However, the content entered by the user may itself contain personal data if the user chooses to include it.

The generated results are automated, do not produce legal or similarly significant effects, and may be inaccurate, incomplete, or outdated.

9. Analytics, profiling, and advertising

The App uses analytics tools to measure the use of certain screens and improve the overall experience.

The App may also perform limited personalization based on use of the assistant and on user interaction with the App, with the aim of offering a more relevant experience.

The App may display third-party advertising, including native ads and rewarded ads.

Where processing is based on consent, users may withdraw that consent at any time. On iOS, certain permissions and ad tracking settings may also be managed through device settings.

10. Purchases, subscriptions, and virtual currency

The App offers in-app purchases, subscriptions, and virtual currency (iticoins).

To manage these services, data related to the following may be processed:

Payment transactions are processed through Apple and technical providers used for subscription and purchase management. Itinerama does not directly store the user’s full bank card number.

11. Providers and third parties

The App may use third-party providers, platforms, or services to deliver features, host infrastructure, display advertising, provide maps, process authentication, manage subscriptions, provide content, or run artificial intelligence functions.

Depending on the active service configuration, these may include:

Some of these third parties may act as processors and others as independent controllers, depending on the nature of the service provided.

12. Infrastructure and data location

According to the information currently provided by the owner:

13. International transfers

Although the main data directly managed by Itinerama is hosted in the European Union, certain providers or services integrated into the App may process data outside the European Economic Area or carry out international transfers.

In such cases, these transfers will be carried out on the basis of mechanisms permitted under applicable law, where relevant, including adequacy decisions or standard contractual clauses.

14. Data retention

We will retain personal data for as long as necessary to provide the App, fulfill the purposes described in this Policy, and comply with legal, regulatory, security, or defense obligations.

As a general rule:

15. Account deletion

Users may delete their account through the features made available within the App itself.

When an account is deleted:

16. User rights

Where applicable, users may exercise the rights recognized under data protection law, including:

Users may exercise their rights:

Requests will be handled without undue delay and, in any event, within the maximum period established by applicable law.

If the user believes that the processing of their data does not comply with the law, they may also lodge a complaint with the competent supervisory authority, including the Data Protection Commission in Ireland.

17. Minors

Itinerama is not intended for children under 13 years of age.

We do not intentionally collect personal data from children under 13. If we detect that a child under 13 has provided personal data through the App, we may take reasonable steps to delete that data and, where appropriate, restrict or terminate the related account.

18. Security

We apply reasonable technical and organizational measures to protect personal data against unauthorized access, alteration, loss, destruction, or improper disclosure.

However, no system can guarantee absolute security.

19. Changes to this policy

We may update this Privacy Policy at any time.

When changes are material, we will try to inform the user through the App or other appropriate means. The “Last updated” date will indicate the current version.

Where necessary, we may request a new express acceptance of the updated policy. We may retain evidence of acceptance, including the accepted version, the date, and the IP address where necessary to demonstrate that acceptance.

20. Contact

For any questions related to privacy or data protection, you may contact: