Privacy policy
Last updated: October 26, 2026
This policy explains what data Vitralis (the iPhone app and the vitralis.app website) processes, why, who we share it with and how you can exercise your rights. It follows Brazil’s General Data Protection Law (Law No. 13,709/2018, “LGPD”) and, where applicable, other data protection laws such as the GDPR and US state privacy laws.
1. Who is responsible
The data controller is P.r.o Tecnologia Consultoria e Desenvolvimento de Software LTDA (trading as P.r.o Tecnologia), Brazilian taxpayer ID (CNPJ) 37.302.421/0001-87, located at Avenida Gabriel de Rezende Passos, 316 - Santa Ines, Betim - MG, ZIP 32.603-100, Brazil (“Vitralis”, “we”). Communication channel for privacy matters and data subject requests: [email protected]. As a small-scale processing agent, the controller is exempt from appointing a data protection officer (article 11 of ANPD Resolution CD/ANPD No. 2/2022); this channel handles communication with data subjects and with the Brazilian data protection authority (ANPD).
2. What we collect
Account and sign-in
- Your email address, when you sign in with email or when Apple or Google share it with us.
- Your account identifier at the sign-in provider (Apple or Google). For Sign in with Apple we also keep the refresh token Apple provides, used only to revoke the authorization when you delete your account.
- Email sign-in codes: stored only as a hash, valid for a short time and deleted after use or expiry.
- Sessions: a hashed session identifier for your device and its expiry date.
Security and abuse prevention
- App Attest (Apple): when you sign in with email, the app proves it is the genuine app running on an Apple device. We keep the attested key identifier and single-use challenges. Keys unused for 180 days are deleted.
- IP address: we use a hashed version of your IP to rate-limit sign-in attempts and email sends. These records are deleted after 24 hours. We also keep a hashed version of your email for 24 hours to count code sends.
App usage
- Your answers to the initial questionnaire (for example: age range, eras, places and topics you like, preferred time of day, daily goal and what usually gets in the way) and the free chapter picked from them.
- Progress: chapters started and finished, the scene you stopped at, quiz scores, daily goal and streak.
- Preferences stored on your device, such as language, narration and the daily reminder. The reminder is a local notification scheduled by your iPhone: we don’t collect a push token.
- Widget: widget quotes are stored on your device.
Purchases
- In-app purchases (App Store) are processed by Apple. Subscription status reaches us through RevenueCat, which receives your Vitralis account identifier and the purchase details. We never receive your card details.
- Website purchases are processed by a partner payment platform, which collects what it needs for payment (such as name, email, ID and payment details) under its own policy. The platform notifies us of each purchase; we keep the purchase email, the invoice, subscription and product identifiers, the plan, the status, the payment and access-expiry dates and the language, to unlock your access in the app and send the confirmation email. We also log the notifications we receive from the platform (type, identifiers and outcome) so the same notification is never processed twice.
The vitralis.app website
- The website has no sign-up. Quiz answers on the website stay in your browser (session storage) and are not sent to us.
- We store a cookie with your chosen language and, during your visit, the campaign parameters in the URL (such as utm_source), which are passed on to the partner platform’s checkout page.
- Analytics tools (Google Analytics 4 and Microsoft Clarity) and marketing tools (Meta Pixel) are only loaded if you accept that category in the site’s cookie notice. See section 6.
3. Why we use data and on what legal basis
| Purpose | Legal basis |
|---|---|
| Create and run your account, sign you in and sync your progress | Performance of a contract |
| Unlock what you bought (App Store or website) and manage subscriptions | Performance of a contract |
| Build your plan and suggest chapters from your answers | Performance of a contract |
| Prevent fraud and abuse (App Attest, IP and email limits) | Legitimate interests |
| Send access emails and sign-in codes | Performance of a contract |
| Meet legal and tax obligations and defend legal claims | Legal obligation and legitimate interests |
| Measure how the website is used (Google Analytics 4 and Microsoft Clarity) to improve it | Consent, only after you accept in the cookie notice |
| Measure our ads and show them to people who visited the website (Meta Pixel) | Consent, only after you accept marketing |
We don’t sell your data. With your marketing consent, the Meta Pixel shares events from your visit to the website with Meta to measure and target ads (“sharing” under US state laws such as the CCPA/CPRA, which you can refuse or withdraw at any time); your answers and progress in the app are never used for advertising.
4. Who we share it with
We use service providers that process data on our behalf, only to run the service:
- Cloudflare: hosting for the website, API, database and media files.
- Apple: Sign in with Apple, App Attest, the App Store and local notifications.
- Google: Google Sign-In, if you use it.
- RevenueCat: management of App Store subscriptions.
- Partner payment platform: website payments.
- Resend: delivery of sign-in and access emails.
- Google (Google Analytics 4) and Microsoft (Clarity): website usage analytics, only if you accept analytics cookies.
- Meta (Meta Pixel): measuring and targeting ads on Facebook and Instagram, only if you accept marketing cookies.
These providers may store data outside your country. International transfers rely on the contractual safeguards these providers offer. We may also share data when required by law or by a competent authority.
5. How long we keep it
- Account data, answers and progress: for as long as your account exists. Deleting your account erases them.
- Sign-in codes: until used or expired. Hashed IP and email-send records: 24 hours. App Attest keys: up to 180 days of inactivity. Sessions: until they expire or you sign out.
- Purchase records (including website purchases): for the period required by tax and consumer law, even after the account is deleted.
6. Cookies and similar technologies
When you open the website, we only use what it needs to work. Analytics and marketing cookies stay off until you accept them in the cookie notice (Accept turns both on; Customize lets you choose each one); before that, no Google, Microsoft or Meta script is loaded. If your browser sends a Global Privacy Control signal, we treat it as a refusal, including an opt-out of sharing for advertising.
| Category | What | Why | Legal basis | Duration |
|---|---|---|---|---|
| Necessary | vt_lang cookie | remember your chosen language | legitimate interests (running the site) | 1 year |
| Necessary | vt_params (session storage) | carry campaign parameters (such as utm_source) to the checkout page | performance of a contract | until you close the tab |
| Necessary | vt_consent (local storage) | store your cookie choice, with version and date | legal obligation | until you change it or clear your browser |
| Analytics | Google Analytics 4: _ga and _ga_* cookies | count visits, page views and clicks (for example, viewing the plans, clicking to buy, starting and finishing the quiz) | consent | 13 months; reports are kept up to 14 months in the Google Analytics account |
| Marketing | Meta Pixel: _fbp cookie and, when you arrive from an ad, _fbc | tell Meta about events in your visit (page view, viewing the plans, clicking to buy with plan and price, finishing the quiz) to measure which ads work and show our ads to people who visited the website | consent | 90 days |
| Analytics | Microsoft Clarity: _clck and _clsk cookies | heatmaps and session recordings (movements, clicks and scrolling) to find problems on the page; text typed into fields is masked | consent | _clck 1 year, _clsk 1 day; data kept up to 13 months in Clarity |
International transfers. Google LLC, Microsoft Corporation and Meta Platforms (Meta Platforms Ireland Limited and Meta Platforms, Inc.) process this data in the United States and other countries, relying on standard contractual clauses and the safeguards these providers offer (including certification under the EU-U.S. Data Privacy Framework).
How to change or withdraw consent. Use the Cookie preferences link in the footer of any page. When you refuse or turn a category off, we stop loading its scripts and delete the cookies the website can delete (_ga, _ga_*, _clck, _clsk, _fbp, _fbc). You can also delete cookies in your browser settings and adjust your ad preferences in your Meta account.
7. Your rights
You can ask to access, correct, delete or port your data, restrict or object to processing, withdraw consent and learn who we share data with. Write to [email protected]. You can also complain to your local data protection authority (in Brazil, the ANPD).
Deleting your account: in the app, go to Settings › Delete account. This erases your account, progress and answers and revokes Sign in with Apple. It does not cancel subscriptions: on the App Store, cancel in your iPhone Settings; for website purchases, use the payment platform’s customer area or contact us.
8. Security
We use encrypted connections (HTTPS), store codes and sensitive identifiers only as hashes, rate-limit access attempts and check app integrity with App Attest. No system is 100% secure; if a relevant incident happens, we will notify you and the authorities as the law requires.
9. Children
Vitralis is meant for people aged 18 or older. We don’t knowingly collect data from children. If you believe a child has given us data, write to us and we will delete it.
10. Changes
We may update this policy. The current version always lives on this page, with the date at the top; we will announce relevant changes in the app or by email.