DRAFT FOR LEGAL REVIEW (rascunho para revisão jurídica). Do not publish before a lawyer reviews it. Items in brackets, such as [RAZÃO SOCIAL], still need to be filled in. Items marked [CONFERIR] depend on technical or legal confirmation.
Version [VERSÃO], effective [DATA DE VIGÊNCIA].
This policy explains what data Pollyfriends uses, why, who it is shared with, how long it is kept and how you control it. It applies to users in Brazil (General Data Protection Law, LGPD), in the European Union (General Data Protection Regulation, GDPR) and in other countries.
1. Who looks after your data
The data controller is [RAZÃO SOCIAL], CNPJ (Brazilian company number) [CNPJ], located at [ENDEREÇO].
Data protection officer (DPO): [NOME DO ENCARREGADO], at [E-MAIL DO ENCARREGADO].
Representative in the European Union (GDPR, art. 27): [REPRESENTANTE NA UE].
2. First of all: who you are talking to
Your friends on Pollyfriends are characters created with artificial intelligence, and their voices are also generated by artificial intelligence. Nobody on our team reads your conversations in order to reply. Messages are processed by automated systems to generate the replies. A team member only looks at a conversation in specific cases, explained in section 5.
3. Data we collect
| Type | What it is |
|---|---|
| Account | Name, email, phone number and password (stored only as a hash). The account is shared with other [RAZÃO SOCIAL] products. |
| Purchase | Platform (OnProfit or Hotmart), order number, product, subscription status and renewal date. We do not receive your card number. |
| Profile | Date of birth, country and city (never your address), time zone, languages you speak, language you are learning, goal, profession, interests and chosen hours. |
| Conversations | Text messages you exchange with the characters and in group chats, reactions and photos you send. |
| Audio | Voice messages you record and send. During calls, your voice passes through the system in real time, but call audio is not stored. |
| Transcripts | Text of what you said in voice messages and calls, generated automatically. |
| Progress recordings | If you agree, your reading of the same text on day one and every 30 days, to compare your pronunciation. |
| Character memory | Facts you shared in conversations (for example, "has a dog named Bob"), so the characters remember you. |
| Progress | Words learned, common mistakes, pronunciation assessments you requested and minutes of conversation. |
| Usage and safety | Access logs (date, time and IP address), app events, AI usage and cost per account, safety filter alerts and technical errors. |
| Device | Device and browser type, and your notification subscription if you allow it. |
We do not ask for ID documents, your address, bank details or photos of you. If you send an ID number, card number or password in a conversation, the system tries to mask it before storing. [CONFERIR: masking is automatic and may fail.]
Sensitive data. In a conversation you may mention something about health, religion, sex life, ethnic origin or political opinion. We do not ask for this kind of information. If you share it, it is processed only so the conversation keeps making sense, based on your consent, and you can delete it at any time.
Your voice is not used to identify you. We do not perform voice recognition or create voiceprints.
4. Why we use it and the legal basis
| Purpose | Data used | Legal basis under LGPD | Legal basis under GDPR |
|---|---|---|---|
| Create the account, grant access and manage the subscription | Account, purchase | Performance of contract (art. 7, V) | Performance of contract (art. 6(1)(b)) |
| Generate the characters' replies, audio and calls | Conversations, audio, transcripts, profile, memory | Performance of contract (art. 7, V) | Performance of contract (art. 6(1)(b)) |
| Remember what you shared and personalize your learning | Memory, progress, profile | Performance of contract (art. 7, V) | Performance of contract (art. 6(1)(b)) |
| Process something sensitive you chose to share | Part of the conversation | Specific consent (art. 11, I) | Explicit consent (art. 9(2)(a)) |
| Keep your progress recordings | Progress recordings | Specific consent (art. 7, I) | Consent (art. 6(1)(a)) |
| Assess your pronunciation when you ask | The chosen audio and transcript | Performance of contract (art. 7, V) | Performance of contract (art. 6(1)(b)) |
| Check age and protect minors | Date of birth, signals in the conversation | Legal obligation (art. 7, II; Law 15,211/2025) | Legitimate interest (art. 6(1)(f)) [CONFERIR] |
| Detect a crisis and show help contacts | Conversations, transcripts | Protection of life (art. 7, VII; art. 11, II, e) | Vital interests and legitimate interest (art. 6(1)(d) and (f)) |
| Moderation, abuse prevention and usage limits | Conversations, usage and safety | Legitimate interest (art. 7, IX) | Legitimate interest (art. 6(1)(f)) |
| Fix bugs and keep the app running | Usage and safety, device | Legitimate interest (art. 7, IX) | Legitimate interest (art. 6(1)(f)) |
| Send notifications | Notification subscription | Consent (art. 7, I) | Consent (art. 6(1)(a)) |
| Keep access logs | IP address, date and time | Legal obligation (Brazilian Internet Civil Framework, art. 15) | Legal obligation (art. 6(1)(c)) [CONFERIR] |
| Send your access details after purchase | Name, email, phone number | Performance of contract (art. 7, V) | Performance of contract (art. 6(1)(b)) |
We do not sell your data. We do not use your conversations for advertising. We do not use your conversations to train our own or third-party artificial intelligence models. [CONFERIR against the OpenAI contract.]
Where the basis is consent, you can withdraw it at any time in settings, free of charge. Withdrawal does not affect what was done before it.
5. When a team member sees a conversation
Only in these cases, and only the part needed:
- a safety filter flagged the message (for example, crisis, possible minor or sexual content) and the case needs review;
- you used the button to report that a reply sounded wrong;
- you asked support for help with a conversation;
- an authority required it under the law.
6. Who we share it with
We use providers that process data on our behalf (processors), only to make the app work:
| Provider | Purpose | Location |
|---|---|---|
| OpenAI | Generate the characters' text, voice and calls; transcribe audio; moderate content; assess pronunciation | United States |
| Vercel | App and file hosting | United States [CONFERIR region] |
| Neon | Database | [CONFERIR region] |
| Upstash (QStash) | Scheduled message queue | [CONFERIR region] |
| [VERCEL BLOB OU CLOUDFLARE R2] | Audio and image storage | [CONFERIR region] |
| Sentry | Technical error logging | [CONFERIR region] |
| Resend | Email with access details | United States [CONFERIR] |
| Twilio | SMS with access details | United States [CONFERIR] |
| Meta (WhatsApp), through our support system | Access confirmation message | [CONFERIR] |
OnProfit and Hotmart process payments as independent controllers, under their own privacy policies. They send us the purchase data so we can grant access.
We may also share data when the law or a court order requires it.
7. International transfers
Our main artificial intelligence provider, OpenAI, is in the United States. Your messages, audio and transcripts are therefore sent there to generate replies. Other providers on the list may also be outside your country.
- Brazil (LGPD, art. 33): transfers rely on [CONFERIR: standard clauses approved by the ANPD or another art. 33 mechanism].
- European Union (GDPR, chapter V): transfers rely on [CONFERIR: the EU-US Data Privacy Framework, if the provider is certified, or the European Commission's standard contractual clauses].
We have a data processing agreement with OpenAI [CONFERIR: DPA signed] and request the shortest possible retention on their side [CONFERIR: retention configured in the OpenAI project].
8. How long we keep it
| Data | Period |
|---|---|
| Account and profile | While the account exists. When you delete the account, we delete it within [PRAZO] days. |
| Purchase data | While the account exists and afterwards for the period required by consumer and tax law [CONFERIR PRAZO]. |
| Text messages | [CONFERIR: while the account exists or 90 days]. Conversations older than 90 days become a summary for the characters; you can delete messages whenever you want. |
| Audio generated by the characters | 90 days. After that, the text remains and the audio is generated again if you tap it. |
| Voice messages you send | [PRAZO DO ÁUDIO DO ALUNO] |
| Call audio | Not stored. |
| Call transcripts | 90 days. |
| Audio clip sent for pronunciation assessment | Deleted right after the assessment. |
| Progress recordings | Until you delete them or withdraw consent. |
| Photos you post as a status | 24 hours. |
| Character memory | Until you edit or delete it. Some facts expire and disappear on their own. |
| Access logs (IP address, date and time) | 6 months (Brazilian Internet Civil Framework). |
| Safety filter alerts | [PRAZO DOS ALERTAS]. Yearly crisis alert totals, with no personal data, are kept for the reports required by law. |
| Usage, cost and technical errors | [PRAZO] |
9. Your rights and how to use them
You have the right to:
- know whether we process your data and access it;
- correct incomplete or inaccurate data;
- receive a copy of your data (portability);
- delete your data;
- withdraw consent;
- know who we share it with;
- object to processing based on legitimate interest;
- request review of a decision made solely by automated means that affects your interests;
- complain to a data protection authority: in Brazil, the ANPD; in the European Union, the authority in your country.
In the app, under Settings, you can:
- export your data as a file (conversations, transcripts, memory, profile, recordings and images linked to your account);
- delete your voice recordings;
- delete facts from the characters' memory;
- delete everything, including stored files;
- review and withdraw consents.
For any other request, write to [E-MAIL DO ENCARREGADO]. We reply within 15 days (LGPD) or within 1 month (GDPR). We may ask you to confirm that you own the account before acting on the request.
Deleting your app data does not cancel your subscription. Cancellation is done on the purchase platform (OnProfit or Hotmart). [CONFERIR: what happens to the account shared with the other products when the user deletes everything.]
10. Age verification
Pollyfriends is for adults 18 and over only.
- When you sign up, we ask for your date of birth. If it shows you are under 18, the app will not open. The date cannot be changed later in the app.
- While you use the app, automatic filters look for signs that the user is a minor (for example, talking about their school grade). If so, the app switches to a restricted mode and the account may be blocked and deleted.
- [CONFERIR: Brazilian law (Law 15,211/2025) requires reliable age assurance and says self-declaration is not enough. The final method still needs to be defined.]
11. Cookies and on-device storage
Pollyfriends only uses what it needs to work:
- a session cookie, to keep you securely logged in;
- local storage and app cache, to open faster, work on poor connections and keep messages on your device;
- a notification subscription, if you allow it.
We do not use advertising cookies or cross-site tracking. [CONFERIR: if an analytics tool is added, this section changes and may require consent.]
12. Security
We use encrypted connections, hashed passwords, restricted database access and logging of administrative actions. No system is 100% secure. If an incident could put you at risk, we will notify you and the authorities as the law requires.
13. Changes to this policy
When we change something important, we will tell you in the app before it takes effect and, where the law requires, ask for your consent again.
14. Contact
DPO: [NOME DO ENCARREGADO], [E-MAIL DO ENCARREGADO] [RAZÃO SOCIAL], CNPJ [CNPJ], [ENDEREÇO]