The controller is Douglas Stoneman, an individual resident in Brazil, CPF [DOUG_CPF], [DOUG_ENDEREÇO]. For data requests write to suporte@proequipai.com. This policy is written to meet the LGPD (Lei Geral de Proteção de Dados, Lei 13.709/2018).
This is the part people ask about, so it comes first.
We hold no card details, because there are no cards: payment is by Pix only.
About Google in particular. To score your answer we send Google's Gemini API a text transcript — never the audio. We use Gemini on a paid plan, and Google's terms for paid use state that Google does not use prompts or responses to improve its products or train its models. Google logs prompts and responses for up to 55 days solely to detect misuse of its service; that data is not used for training, and human review is limited to authorised Google staff investigating flagged content. We have also switched off the optional request logging Google offers developers, so no further copy is kept in our Google account. This processing runs under Google's Data Processing Addendum for products where Google is a data processor, which carries specific terms for the LGPD and Brazilian standard contractual clauses. Google may process this data in any country where it maintains facilities.
Asaas operates in Brazil. The other providers listed above operate outside Brazil, so that data is transferred internationally under article 33 of the LGPD. Each is engaged under terms requiring it to process data only on our instructions.
To provide the service you bought (performance of a contract), to meet legal and tax obligations — which is why the CPF given at checkout is kept — and, for the transcripts that make progress tracking work, because they are necessary to deliver what the product does.
Audio: not kept at all. Transcripts, scores and account details: kept while your account exists, including after access expires, so that your record is intact if you return. Payment records, including your CPF, are kept for as long as tax and accounting law requires. Ask us to delete your account and we delete the rest.
Under the LGPD you may ask us to confirm what we hold, correct it, anonymise or delete it, tell you who we have shared it with, or withdraw consent. Write to suporte@proequipai.com. We answer within fifteen days and there is no charge. Write in Portuguese or English — whichever you prefer.
Access to your data is restricted at the database level so that one account cannot read another's. Provider keys are held server-side and never exposed to the browser.
The version and date are shown above. If we change how your data is used, we will say so in the app rather than quietly amend this page.