Privacy policy

1. Introduction & Identity

The Robin App, Inc. ("Robin" or "we") is committed to protecting your privacy in accordance with applicable U.S., Canadian, and Mexican law. This policy is effective October 27, 2025 and applies to the Robin mobile app (the "App") used in the U.S., Canada, and Mexico. It explains what information we collect, how we use and share it, and your rights. For questions or requests, please contact us at support@therobinapp.com. This Privacy Policy complements our Terms of Service and adheres to requirements such as the California Consumer Privacy Act (CCPA), COPPA, Canada's PIPEDA, and Mexico's data protection laws (FLPPDHPP).

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2. Information We Collect

A. Directly from Users

• Account and Profile Data: We collect your name, email address, chosen password, and any profile details you provide when creating an account.
• Giveaway Participation: We record which giveaways you enter, entries earned, and related actions (likes, comments, shares, etc.).
• Referrals: If you use a referral or invite feature, we collect referral codes or identifiers and any contacts you choose to invite. If you grant permission, we may access your device contacts only to send invites or friend requests. We do not access your contacts unless you explicitly allow it.
• Automated Forms (Opt-In): If you opt-in, the App can automatically fill or submit giveaway entry forms with your personal information. This is done only with your explicit consent.
• Subscriptions and Billing: If you subscribe to premium services, we collect payment details via our payment processor. We will clearly disclose any recurring billing, renewal frequency, and price changes and obtain your express consent (as required by law). You can cancel any subscription at any time as described in the app and Terms.

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B. Automatically Collected Data

• Device and Connection Information: We automatically gather device data (e.g. model, operating system, device identifiers) and connection data (IP address, browser or app version) to help run and secure the App.
• Usage and Analytics: We use analytics tools (e.g. Firebase Analytics, Amplitude, Mixpanel) to track your in-app activity, feature usage, and app performance. These tools use cookies and similar technologies to record events (like app opens, clicks, sessions) and may collect hashed or pseudonymous identifiers. This data helps us improve the app and detect issues. We use standard technologies (cookies, web beacons, pixel tags) to measure traffic and user engagement.
• Localization: If you grant permission, we may collect GPS or location data to personalize content (e.g. show local giveaways). We will disclose when location is collected and require your express consent. You can disable location tracking at any time in your device settings.

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C. Data from Third Parties

• Social and Host Data: With your permission, the App may connect to social APIs (e.g. Instagram, TikTok, Reddit) or logins. We may receive information (user ID, profile info, mutual friends) from those services as you authorize. We have no control over data hosts may provide, so we make no guarantee of its accuracy.
• Marketing and Referrals: If you use referral links or share links to others, we collect and track referral codes and related metrics (e.g. number of friends joined). We also record whether you opt into email newsletters during account creation, and track your subscription status.

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3. How We Use Information

We use collected information for legitimate business purposes to operate and improve the App:

• App Operation: We use your data to create and manage your account, authenticate you, provide customer support, and send essential notices (e.g. password resets, security alerts).
• Giveaway Management: We use your participation data to conduct and administer giveaways (select winners, allocate entries, verify eligibility). For example, if you refer friends, we automatically credit referral entries according to the App's entry allocation logic (to ensure fairness and transparency).
• Service Improvement: We analyze usage and feedback to optimize giveaway recommendations and improve discovery. We may use AI or machine learning to curate and rank giveaways and personalize your experience.
• Fraud Prevention and Security: We use data to detect and prevent fraudulent or suspicious activity (such as bots entering many giveaways) and to secure the App. For instance, if we see unusual entry patterns, we may investigate to protect users.
• Communications: When you opt in, we send marketing emails or push notifications about new giveaways or features. You can unsubscribe at any time. We also send legal notices or policy changes via email or in-app notification as required.
• Payments and Billing: We use your payment information only to process transactions with our payment processors. We clearly disclose any auto-renewal terms in advance and obtain your consent as required by law. You may cancel subscriptions through your account settings.

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4. How We Share Information

We share your information only in limited circumstances:

• Service Providers: We disclose data to trusted third-party vendors and sub-processors who perform services on our behalf. For example, we use AWS and Firebase for hosting and data storage, payment processors for transactions, and analytics providers (Amplitude, Mixpanel) for metrics. These providers are authorized to use your data only as needed to provide their services, and they must protect your data on our behalf. A current list of key sub-processors (e.g. Amazon Web Services, Google/Firebase, Stripe, Amplitude, Mixpanel) is available upon request.
• Giveaway Hosts: With your consent, we share limited information (e.g. your username or proof of entry) with giveaway sponsors or hosts when required to validate or award a prize. Otherwise, hosts do not receive your personal email or password unless you explicitly provide it.
• Legal Compliance: We may share your data if required by law (e.g. a subpoena or government request), to enforce our rights, or to protect the safety of users. For instance, if a legal authority requests winner information, we will comply as permitted by law. We also share data to prevent fraud or investigate violations of our rules.
• Referral Tracking: When you share a referral link, the referral tracking data (such as your referral code and who clicked it) is processed to credit referrals. This data may be stored by our analytics partners solely to track successful referrals.
• No Sale of Personal Data: We do not sell your personal information under any circumstances. We only disclose your data as described above.
• SMS & Phone Number Data: We do not share, sell, or rent mobile phone numbers to third parties for marketing or promotional purposes. Phone numbers submitted on our website are used solely to deliver a one-time SMS containing an app download link, as requested by the user.

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5. Data Retention & Deletion

We keep your data only as long as needed for the purposes outlined above. Generally, we retain information for as long as your account is active and as required to provide the App's services. After you close your account or complete a giveaway, we delete or anonymize data related to draws (for example, we erase entry records once a giveaway is finalized). For payment data, we retain records only as needed for transaction processing and legal compliance, then we remove them.

If you wish to delete your account, please use the in-app Delete Account feature or contact us at support@therobinapp.com. Upon request, we will de-activate your account and erase your personal information from our systems, except for any data we are legally required to retain. We will confirm when your deletion request has been completed.

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6. Cookies & Tracking

We use standard cookies and tracking technologies to operate the App and improve user experience:

• Analytics SDKs: We use Firebase (Google), Amplitude, and Mixpanel SDKs to collect anonymized analytics (app usage, engagement statistics). These SDKs collect device info, usage events, and optionally user-defined properties. This helps us understand performance and fix issues.
• Push Notification Tracking: We may track when push notifications are delivered and opened to optimize notification timing. This data is not shared with third parties except as needed for delivery.
• Referral Attribution: To credit referrals, we place tracking cookies or use URL parameters when you click or share links, so we can recognize successful referrals. You can disable cookies in your device settings, but note some App features (like referral tracking) may not work if cookies are blocked.
• Opt-Out: You can opt out of analytics by disabling tracking in your device settings (for example, by revoking analytics permissions) or by contacting us to deactivate your account. We do not use fingerprinting or any invisible tracking outside what is described.

Location Tracking

If you allow it, the App may collect your device's location (GPS) to enhance functionality (for example, showing nearby giveaways). We will explicitly ask for permission before collecting location and will not track you in the background without disclosure. You may disable location access at any time in your phone's privacy settings.

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SMS Messaging

If you provide your mobile phone number on our website to request an app download link, you will receive a single, one-time SMS text message containing that link. No recurring, promotional, or marketing messages will be sent. Standard message and data rates may apply. You may reply STOP to opt out or HELP for assistance at any time. Your phone number will not be shared with or sold to third parties for marketing purposes.

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7. User Rights

Depending on your jurisdiction, you have the following rights regarding your personal information:

• Access and Portability: You can request a copy of the personal data we hold about you. You can obtain this data in a portable format.
• Correction: You can request correction of inaccurate or incomplete information.
• Deletion: You can request deletion of your personal data. California consumers have the right to delete data collected about them. We will delete your data upon request, subject to any legal exceptions (e.g. data needed for legal compliance or fraud prevention).
• Opt-Out of Sale/Sharing: California residents may request that we do not sell or share their personal data. (We do not sell data in any event.)
• Opt-Out of Marketing: You can opt out of marketing emails or newsletters at any time using the unsubscribe link in our emails. Under PIPEDA and CASL (Canada), we require your express consent for email marketing, and we provide a clear unsubscribe mechanism in each message.
• Sensitive Data Restrictions: California's CPRA allows you to limit use of sensitive personal data (e.g. geolocation). Robin does not collect sensitive data beyond what is needed to operate the App (no biometric or health data).
• No Retaliation: We will not discriminate against you for exercising any privacy rights.

To exercise any rights, you may use the in-app privacy request form (if available) or email us at support@therobinapp.com. We will verify your identity and respond within 45 days (or sooner if required by law). If we cannot comply with your request, we will explain why.

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8. Security

We implement industry-standard security measures to protect your data:

• Encryption: All data in transit between the App and our servers is encrypted (TLS/SSL). Data stored on our servers is encrypted at rest. We rely on AWS infrastructure and related services, which offer robust security controls. With AWS, you can control encryption keys and data residency. AWS services we use comply with international standards (ISO 27017, 27701, 27018) and do not use your data for advertising.
• Access Controls: We restrict access to personal data internally. Only authorized staff and approved subprocessors (who must follow our policies) can access your data. We train employees on data protection.
• Incident Response: In the event of a data breach, we have procedures to promptly contain and investigate it. We will notify affected users and authorities as required by law. (For example, we commit to notifying any customer data owner of unauthorized access within 24 hours and taking timely remedial action.)
• Monitoring: We continuously monitor systems for suspicious activity. We use secure practices for server maintenance and regularly update software to address vulnerabilities.

No system is 100% secure, but we take reasonable steps to safeguard your data. If you suspect any security issue, please contact us immediately.

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9. Children's Privacy

Robin does not knowingly collect data from children under age 13. The Children's Online Privacy Protection Act (COPPA) requires parental consent for collecting data from children under 13. Our App is designed for users 13 and older, and we require users to certify they meet this age requirement. If we learn that a child under 13 has provided personal data, we will delete it. For teens under 16 in California or Canada, additional protections apply, and we require verifiable consent from a parent or guardian if needed by law.

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10. International Data Transfers

We primarily host and process data in the United States (using AWS, Google Cloud, etc.). Data transfers from Canada or Mexico to the U.S. are governed by local laws. Mexico's law allows transfers with the user's informed consent. We may use EU "Standard Contractual Clauses" (SCCs) for any transfers involving EU residents as a data transfer safeguard. Our third-party providers (AWS, Firebase, etc.) operate globally but comply with strict data protection agreements and only process data as instructed by Robin.

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11. Changes to This Policy

We may update this Privacy Policy from time to time (for example, to reflect new legal requirements or App features). When we make material changes, we will post the new Policy on the App and notify you via email or in-app notification before it takes effect. Your continued use of the App after the effective date will constitute acceptance of the updated terms. We encourage you to review the Privacy Policy periodically.

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12. Subscription & Billing (California Automatic Renewal Law)

If the App offers any subscription or recurring payment service, we comply with applicable renewal laws. We will obtain your express consent before enrolling you in any auto-renewing subscription and clearly disclose renewal frequency, cancellation policy, and pricing beforehand. We will send reminders of renewal terms annually or when changes occur. You can cancel subscriptions at any time through your account settings; cancellation is designed to be as easy as signup, following "click-to-cancel" requirements.

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13. Contact

For privacy inquiries or to exercise your rights, please contact:

Privacy Officer – The Robin App, Inc.

Email: support@therobinapp.com

We will respond promptly to all requests. You may also find our Terms of Service and this Privacy Policy at www.therobinapp.com/terms and www.therobinapp.com/privacy.

Last updated: October 27, 2025.

References: We have implemented privacy practices in compliance with laws including COPPA, CCPA/CPRA, PIPEDA, and Mexico's FLPPDHPP, as summarized above.

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