This Privacy Policy governs your use of the Route XK Planner mobile application and our website (collectively, the “Service”) operated by Balanced Answers Unipessoal Lda, and describes the data we collect, how it is stored, how that data may be used, with whom it may be shared, and your choices about such uses and disclosures. Please read this Privacy Policy carefully before using our Service.
“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
“EEA” includes all current Member States of the European Union and the European Economic Area.
“Process”, in respect of personal data, includes to collect, store, use, and disclose to others.
Please check our Terms and Conditions (the “Terms”) for the meaning of defined words (those with capital letters) not explicitly defined in this Privacy Policy.
Balanced Answers Unipessoal Lda will be the controller of your personal data.
Contact: [email protected]
We collect data you make available to us voluntarily (for example, your email address). We also collect data automatically when you use the Service (for example, your IP address, device type).
You provide us data about yourself when you purchase a subscription or use the Service, for example when you contact our support team or report a problem. The data that you give us includes:
Profile data. This includes your email address and password, which are used to create and manage your account.
Data about how you found us. We collect data about the referring URL or source (that is, the place on the web where you were when you visited our website and made your purchase).
Cookies and similar technologies. Our website uses cookies to record data about usage and to distinguish you from other users. You can control cookies through your browser settings.
Device and browser data. We collect data from or about the devices from which you access the Service, depending on the permissions you have granted. Examples of such data include: language settings, IP address, time zone, type and model of device, device settings, operating system, Internet service provider, mobile carrier, and hardware ID.
We also collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) depending on the operating system of your device. You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).
Transaction data. When you make payments through our website, you need to provide financial account data, such as your credit card number, to our third-party payment processors. We do not collect or store full credit card number data, though we may receive credit card-related data and data about the transaction, including: date, time and amount of the transaction, and the type of payment method used.
Usage data. We record how you interact with our Service. For example, we log the features and content you interact with, how often and how long you use the Service, what sections you use, and other interactions.
We process your personal data:
This includes enabling you to use the Service in a seamless manner and preventing or addressing errors or technical issues. For example, we use your data to authenticate you and authorise access to your account and premium features.
This helps us to better understand our business, analyse our operations, maintain, improve, innovate, plan, design, and develop the Service and new products. We analyse the data we have to evaluate the Service and conduct troubleshooting activities to improve content and features. As a consequence, we often decide how to improve the Service based on the results obtained from this processing.
We select the payment processor and pricing options available to you. We may also use your data to determine your eligibility for promotions or introductory offers.
We provide paid subscription services. For this purpose, we use third-party services for payment processing. As a result of this processing, you will be able to make a payment and access the paid features of the Service.
We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud, malicious activity, and other cybercrimes, and to take legally required actions. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with the Terms).
We may communicate with you by email or through the Service, including push notifications. As a result of such processing, we may send you messages about your account, subscription status, or Service updates.
We process your personal data for our marketing campaigns. We may add your email address to our marketing list. As a result, you will receive information about the Service, features, offers, and promotions. You can opt out of commercial emails at any time by contacting us at [email protected] or by following the unsubscribe link in any marketing email.
As a result of such processing, we will send you messages about your subscription, payment transactions, legal notices, or other Service-related information, and respond to your support requests.
We and our partners use your personal data to tailor ads and show them to you at a relevant time across third-party platforms.
We may process, use, or share your data when the law requires it, in particular if a law enforcement agency requests your data by available legal means.
In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA-based users.
We process your personal data under the following legal grounds:
Where we rely on your consent as a legal basis, you have the right to withdraw your consent at any time by contacting us at [email protected] . Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
Under this legal basis we:
We rely on legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data:
To communicate with you regarding your use of the Service. This includes, for example, sending you notifications. The legitimate interest we rely on for this purpose is our interest to encourage you to use the Service more often. We also take into account the potential benefits to you.
To research and analyse your use of the Service. Our legitimate interest for this purpose is our interest in improving the Service so that we understand users’ preferences and are able to provide you with a better experience.
To send you marketing communications. The legitimate interest we rely on for this processing is our interest to promote the Service in a measured and appropriate way.
To personalise our ads. The legitimate interest we rely on for this processing is our interest to promote the Service in a reasonably targeted way.
To enforce the Terms and to prevent and combat fraud. Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, and non-compliance with the Terms.
Under this legal basis we, in particular, retain transaction and account data as required by applicable law.
This section provides additional details about how we process personal data of California consumers and the rights available to them under the California Consumer Privacy Act (“CCPA”) and California’s Shine the Light law. This section applies only to residents of California, United States.
For more details about the personal information we have collected, including the categories of sources, please see Section 2 above. We collect this information for the purposes described in Section 3 of this Privacy Policy. We do not sell (as such term is defined in the CCPA) the personal information we collect.
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at [email protected] . We will verify your request and inform you accordingly. You may also designate an authorised agent to exercise these rights on your behalf.
Access rights under California’s Shine the Light law. California also provides its residents with additional access rights. Under the Shine the Light law, residents have the right to ask companies once a year what personal information they share with third parties for those third parties’ direct marketing purposes. To obtain this information from us, please send an email to [email protected] with the subject line “Request for California Shine the Light Privacy Information” and include your state of residence and email address in the body of your message. Please be aware that not all information sharing is covered by the Shine the Light requirements and only information on covered sharing will be included in our response.
We will retain personal data for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
Please note that we have a variety of obligations to retain the data that you provide to us, including to ensure that transactions can be appropriately processed, settled, refunded, or charged back, to help identify fraud, and to comply with anti-money laundering and other laws and rules that apply to us and to our financial service providers. Accordingly, even if you close or delete your account, we will retain certain data to meet our obligations.
We share information with third parties that help us operate, provide, improve, integrate, customise, support, and market our Service. We may share some sets of personal data, in particular for purposes indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include:
We share personal data with third parties that we engage to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:
All service providers are contractually required to keep your data confidential and to use it only for the purposes we specify.
We may use and disclose personal data to enforce the Terms, to protect our rights, privacy, safety, or property, and/or that of our affiliates or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
As we develop our business, we may buy or sell assets or business offerings. Customer information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service as set forth in the Terms and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.
In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission, or (ii) the European Commission adequacy decisions about certain countries.
We may modify this Privacy Policy at any time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.
We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at [email protected] .
To be in control of your personal data, you have the following rights:
Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided to us by contacting us at [email protected] . You may also request a copy of your personal data collected during your use of the Service.
Deleting your personal data. You can request erasure of your personal data by sending us an email at [email protected] . When you request deletion of your personal data, we will use reasonable efforts to honour your request. In some cases, we may be legally required to keep some of the data for a certain time; in such event, we will fulfil your request after we have complied with our obligations.
Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request to [email protected] .
The right to lodge a complaint with a supervisory authority. We would love you to contact us directly so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work, or where the alleged infringement has taken place.
The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send a respective request to [email protected] .
You may submit requests through an authorised agent, in which case we will need to verify the agent’s identity, your identity, and their authority to act on your behalf before we can process the request.
Except as otherwise stipulated in this Privacy Policy, the Service does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.
If you have any questions or concerns about this Privacy Policy or our collection, use, or storage of your data, please do not hesitate to contact us at:
Email: [email protected]
Balanced Answers Unipessoal Lda
Last updated: April 2026