Privacy Policy

Last updated: October 19, 2026

This Privacy Policy explains how Anderson de Aguiar Pimenta, the independent developer of Elevo ("we", "us"), collects, uses and protects your personal data when you use the Elevo app on iOS and Android and the Elevo website. We collect only what is needed to run and improve the service.

1. WHO IS RESPONSIBLE

Anderson de Aguiar Pimenta is the data controller for the personal data described in this policy. For any privacy matter, contact us at contact@actustech.tech.

2. DATA WE COLLECT

• Account data: e-mail address and password (stored only in encrypted, hashed form by our authentication provider).
• Profile data: what you choose to share during onboarding or in your profile, such as name, age range, education level, goals, obstacles, reading habits, interests, mood and commitment level.
• Sensitive data (optional): personal struggles related to emotional wellbeing, and interests that may reveal religious beliefs or political opinions (such as Christianity or politics). These questions are optional and we only keep the answers with your explicit permission (see section 4).
• Usage and reading data: reading sessions, progress, articles read, streaks, the limits and reading goals you configure, and your app settings.
• Apps you choose to limit: on Android, the list of apps you select and their limits; on iOS, only the names of the categories you select. They are saved in your account so they can be restored on a new device.
• Your documents: files you upload to read in the app. They are converted to text only on our own server in the EU and are never sent to third-party converters.
• Subscription data: your subscription status and related transaction identifiers, received from Apple or Google. We never receive your payment card details.
• Technical data: app version, device type, operating system, language, a random device identifier used to manage your active session, and error and diagnostic logs. Our logs do not record the names of the apps you limit or your e-mail address.
• Support data: messages, suggestions and attachments you send us through the app or by e-mail.
• Newsletter (website): if you subscribe, your e-mail address, the date of your request and of your confirmation, and the consent text shown at the time.

3. WHAT STAYS ON YOUR DEVICE

• iOS: the apps you select are handled by Apple's Screen Time framework as anonymous tokens. We cannot see which apps you selected or how long you use them.
• Android: the Accessibility and Usage Access permissions are used on your device only to detect when a selected app is opened and to apply your limits. We do not read your messages, passwords or screen content, and we do not send your activity in other apps to our servers.
• Your daily usage counters and notifications are produced on your device. We do not use push notification servers.

4. SENSITIVE DATA AND YOUR PERMISSION

Before the optional questions about personal struggles and faith or political interests, the app asks for your explicit permission (GDPR art. 9(2)(a); LGPD art. 11, I). If you skip, those questions and options are not shown. You can withdraw your permission at any time in Settings → Sensitive data: your answers are then deleted from your device and from our servers, and readings stop using them. Accounts that already had these answers were asked for permission once, with the option to delete them.

5. HOW WE USE YOUR DATA AND LEGAL BASES

• To create and manage your account and provide the service (performance of a contract).
• To personalize readings, including AI-generated content, based on your profile and preferences (performance of a contract; for sensitive data, your explicit consent).
• To process and verify subscriptions with Apple or Google (performance of a contract).
• To keep the service secure, prevent abuse, fix errors and improve features (legitimate interests).
• To send the newsletter you subscribed to (consent).
• To send you notifications you have allowed (consent, which you can withdraw in your device settings).
• To respond to your requests and comply with legal obligations (legal obligation).

We do not make automated decisions that produce legal or similarly significant effects on you.

6. ARTIFICIAL INTELLIGENCE

To generate personalized readings, we send the topic you choose and limited preferences (language, reading level, education level, mood, goals and obstacles) to Google's Gemini API. We do not send your name, e-mail address, personal struggles or uploaded documents for this purpose. Google processes this data on our behalf under its terms for paid services and may not use it to train its models or advertise to you.

7. WHO WE SHARE DATA WITH

We do not sell your personal data and do not share it for advertising. We share data only with service providers that help us operate Elevo, acting under our instructions:

• Supabase (database, sign-in, file storage and server functions) — servers in Ireland (EU).
• Hostinger (our document conversion server and the website) — servers in France (EU).
• Google (Gemini API, to generate readings) — may process data outside the EU.
• Resend (USA) — sends our e-mails: password reset codes, account notices and the newsletter.
• Telegram — internal alerts about errors and the messages you send through the in-app feedback form (including your e-mail address and attachments).
• Apple and Google — app distribution, purchases and subscription status.

We may also disclose data where required by law, to protect our rights or users' safety, or as part of a business reorganization, subject to this policy.

8. INTERNATIONAL TRANSFERS

Some providers process data outside the European Economic Area (for example, in the USA). In those cases we rely on appropriate safeguards, such as European Commission adequacy decisions (including the EU-US Data Privacy Framework) or Standard Contractual Clauses.

9. HOW LONG WE KEEP YOUR DATA

• Account, profile, reading data and settings: while your account exists. When you delete your account, they are deleted immediately, including your uploaded documents.
• Inactive accounts: deleted after 24 months without use, with an e-mail notice at least 30 days before.
• Sensitive data: until you withdraw your permission or delete your account.
• Technical logs: 14 days (information), 30 days (warnings) and 90 days (errors). Error reports and AI usage records: 90 days.
• Newsletter: unconfirmed requests are deleted after 7 days; your address is deleted 30 days after you unsubscribe.
• Support messages: up to 1 month in our internal alert channel.
• Backups: deleted data may remain in secure backups for a short period (up to 7 days) before being permanently removed.

10. SECURITY

We use technical and organizational measures to protect your data, including encrypted connections, your session stored in your device's secure storage, strong password rules, access controls and data isolation between accounts. No system is completely secure, but we work continuously to protect your information, and we have a procedure to respond to and, where required, report security incidents.

11. YOUR RIGHTS

Depending on where you live (including under the EU/UK GDPR, Brazil's LGPD and US state privacy laws), you have the right to access, correct, delete and port your data, to restrict or object to certain processing, and to withdraw consent at any time without affecting earlier processing. Directly in the app you can:

• Download your data: Settings → Download my data (PDF to read, or JSON to take to another service).
• Correct your data: Settings → Edit Profile.
• Withdraw permission for sensitive data: Settings → Sensitive data.
• Delete your account and data: Settings → Delete Account.
• Unsubscribe from the newsletter: using the link in any newsletter e-mail.

For anything else, contact us at contact@actustech.tech. We will respond within the time required by law and may need to verify your identity. You can also lodge a complaint with a data protection authority (in Portugal, the CNPD; in Brazil, the ANPD).

12. CHILDREN

Elevo is intended for people aged 18 and over, and we do not knowingly collect data from anyone under 18. If someone indicates an age under 18, the app does not create the account, or offers to delete an existing one. If you believe someone under 18 has given us their data, contact us and we will delete it. We plan to offer a Parental Control mode that will only work with a parent's or guardian's consent.

13. CHANGES TO THIS POLICY

We may update this policy from time to time. We will update the date above and, for significant changes, notify you in the app.

14. CONTACT

If you have questions about this Privacy Policy or your data, please contact:

contact@actustech.tech

Address: Guimarães PT

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