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Privacy Policy — Brazil

Draft — not final

This is provisional development content pending legal review; it must not be relied on and does not ship to production unreviewed.

Effective date:
[to be provided — effective date · pending launch/counsel]
Version:
[to be provided — version number · pending counsel sign-off]
Last reviewed:
[to be provided — last legal review date · S-023]

This Privacy Policy describes how Klyka handles your personal data in Brazil, under the General Data Protection Law (LGPD, Law No. 13,709/2018), supervised by the National Data Protection Authority (ANPD).

Controller and contact

The controller of your data is [to be provided — controller legal entity name · S-023 OQ-5], with domicile at [to be provided — controller domicile/address · S-023 OQ-5].

For privacy questions, contact privacy@klyka.app. Data protection officer (encarregado): [to be provided — data protection officer / privacy contact · S-023 OQ-6].

The app and audience

Klyka is a treatment-reminder and food-diary app. Klyka is not a medical device and does not diagnose, treat, cure, or prevent any condition.

Klyka is intended for adults aged 18 and older.

Data we collect

Account identity and email; and the health and nutrition data you record — medication schedule, symptoms, weight and measurements, food and protein. This data is treated as sensitive personal data.

This marketing site does not collect health data; email is collected only when you request account deletion.

Purposes and lawful basis

We process your data to operate the app — reminders, recording your history, and organizing your information for consultations — and to support your account. There is no advertising purpose.

The final lawful basis for each purpose, and which are required or optional, are pending legal determination: [to be provided — final lawful basis per purpose · counsel].

Required and optional choices

Some data is necessary for your account and features to work; declining it prevents use of the corresponding feature. Optional choices can be declined or revoked at any time without losing basic access to the app.

Processors and recipients

We share data with processors that provide services to us — the site is hosted by Vercel. The final list of processors and material vendors is pending: [to be provided — final processor/vendor list · U-19 (Vercel confirmed; analytics TBD; Sentry U-10)].

We do not sell your data or share it for third-party advertising.

International transfers

Some processors may handle data outside Brazil. The destinations and international-transfer mechanism will be stated here: [to be provided — international transfer destinations & mechanism · counsel/U-19].

Retention and deletion

We keep your data while your account exists. On a deletion request, active data is locked immediately and erased within 7 days; immutable encrypted backups expire within 35 days at most; third-party processors are queued immediately and complete within 15 days.

Your rights

You may access, correct, export (portability), object to processing, revoke consent, and request deletion of your data.

To exercise these rights or file a complaint, contact the encarregado at privacy@klyka.app. You may also complain to the National Data Protection Authority (ANPD).

Report sharing and notifications

Any report you share sends information, at your own direction, to a recipient you choose. Notifications exist only to support your use of the app.

Security

We apply technical and organizational measures to protect your data, including encryption of sensitive data. We do not disclose details that could facilitate attacks.

Version and changes

Effective date: [to be provided — effective date · pending launch/counsel]. Version: [to be provided — version number · pending counsel sign-off].

If we make a material change, we will notify you and keep previous versions accessible through a link on this page for the applicable retention period.

No advertising

Klyka shows no advertising and does not use your health data for marketing or profiling.

Subscription and account deletion

A Premium subscription is billed by the App Store or Google Play, separately from your Klyka account. Deleting your account does not cancel a store subscription — manage cancellation in your store account.

Cookies

Essential — no consent required
Locale preference, a CSRF token, and your cookie-consent choice. These are required for the site to work (S-020 §10.2).
Analytics and third-party — consent required
These require your consent and are not set until you opt in. The site currently sets none.

Deleting your account

You can request deletion of your account and data at any time, including after uninstalling the app.

Go to account deletion

Legal review

Legal review (reviewer and date): [to be provided — counsel reviewer & date, Brazil + Mexico · S-023 external gate]