Legal
Privacy Policy
This is a template and does not constitute legal advice. Review with a qualified lawyer before publishing, and replace every [bracketed] placeholder with your real company and contact details.
This Privacy Policy explains how [Company legal name], [CNPJ/registration number] ("Karven", "we", "us"), as data controller, collects, uses, shares, and protects personal data when you use the Karven app and website (the "Service"). We process personal data under Brazil's General Data Protection Law (LGPD) and, for users in the European Economic Area/UK, the GDPR.
1. Data controller and contact
- Controller: [Company legal name], [CNPJ/registration number], [address].
- Data Protection Officer (Encarregado/DPO): [name] — [dpo email].
- General privacy contact: [privacy email].
2. What data we collect
| Category | Examples | Source |
|---|---|---|
| Account data | Name, email, authentication identifiers (email/password, Google, Apple) | Provided by you at sign-up |
| Health and fitness data (sensitive personal data) | Workouts, exercise logs, sets/reps/weights, meals, macros/calories, body measurements, progress photos | Provided by you as you use the app |
| Profile data | Goal, training experience, equipment available, dietary preferences, birthdate, sex, height | Provided by you during onboarding |
| Subscription data | Subscription status, plan, renewal date | Received from RevenueCat / Apple / Google |
| Technical data | Device identifiers, app version, crash logs, IP address, locale, timezone | Collected automatically |
| Usage/analytics data | Screens viewed, features used, in-app events (once analytics is enabled — see §4) | Collected automatically via PostHog |
| Communications | Support requests, messages you send us | Provided by you |
We do not sell your personal data.
3. How we collect it
The app is offline-first: data you enter is stored on your device and synced to our servers when you have a connection, so the same data listed above is collected both directly (what you type or upload) and indirectly (through automatic sync and technical/analytics signals).
4. Purposes and legal bases
| Purpose | Data used | Legal basis (LGPD) |
|---|---|---|
| Create and manage your account, provide the core app | Account data, profile data | Contract performance (Art. 7, V) |
| Generate workouts/diet suggestions and the AI Coach | Health/fitness data, profile data | Contract performance; consent for sensitive health data (Art. 11, I) |
| Process subscriptions | Subscription data | Contract performance |
| Product analytics — understand feature usage, fix bugs, improve the app | Usage/analytics data (via PostHog) | Consent (Art. 7, I) — see §9 |
| Security, fraud prevention, legal compliance | Technical data, account data | Legitimate interest / legal obligation (Art. 7, II, VI) |
| Respond to support requests | Communications | Contract performance / legitimate interest |
Because workout and diet data reveals information about your health, we treat it as sensitive personal data under LGPD Art. 11 and only process it to run the features you actively use, never for advertising.
5. Who we share data with (operators/processors)
We share data only as needed to run the Service, with providers bound by data-processing terms:
- Hosting/infrastructure: Vercel (website), [API hosting provider] (backend).
- Subscriptions: RevenueCat, and the Apple App Store / Google Play for payment processing.
- Sign-in: Apple, Google (only if you choose to sign in with them).
- Product analytics: PostHog (see §9).
- Legal/compliance: authorities, when required by law or to protect our rights.
We do not share your data with third parties for their own marketing purposes.
6. International data transfer
Some providers above may process data outside Brazil (e.g., EU or US data centers). Where that happens, we rely on the transfer mechanisms required by LGPD/GDPR (such as standard contractual clauses or an adequacy decision) and choose providers that offer equivalent safeguards.
7. Data retention
We keep your data for as long as your account is active. If you delete your account, we delete or anonymize your personal data within [30/90] days, except where we must retain it longer to comply with a legal obligation, resolve disputes, or enforce our agreements (e.g., billing records).
8. Security
We use technical and organizational measures to protect your data, including encrypted transport (HTTPS), encrypted storage of authentication tokens on your device, and access controls on our infrastructure. No system is 100% secure; if we become aware of a data breach affecting you, we will notify you and the relevant authority (ANPD) as required by law.
9. Cookies and analytics (PostHog)
On the website, we use cookies/local storage for essential site operation and, only after you accept our cookie banner, for analytics via PostHog. You can withdraw consent at any time by changing your choice in the cookie banner/settings.
On the app, analytics via PostHog is off by default and only starts collecting events once you opt in from Settings → Privacy → "Share usage data." You can turn it off again at any time, which stops new data collection going forward.
What PostHog may collect once enabled: pages/screens viewed, features used, in-app events, device/browser type, coarse location (from IP), and a device/anonymous identifier. We do not use PostHog to collect your workout, diet, or body-measurement content. Session replay is not currently enabled; if we enable it in the future, we will update this policy and mask sensitive fields before doing so.
10. Your rights
Under LGPD (Art. 18) and, where applicable, GDPR, you have the right to:
- Confirm whether we process your data, and access it;
- Correct incomplete, inaccurate, or outdated data;
- Request anonymization, blocking, or deletion of unnecessary or excessive data;
- Request portability of your data to another provider;
- Request deletion of personal data processed with your consent;
- Obtain information about entities we've shared your data with;
- Withdraw consent at any time (e.g., turn off analytics, or delete your account);
- Object to processing carried out under legitimate interest;
- Request a review of automated decisions that significantly affect you.
You can exercise most of these directly in the app (Settings → Account → Delete account; Settings → Privacy → Share usage data) or by contacting [privacy email]. We will respond within the timeframe required by LGPD.
11. Account and data deletion
You can permanently delete your account and associated personal data from Settings → Account → Delete account in the app, or by emailing [privacy email]. This removes your workouts, diet logs, body measurements, and profile data from our active systems, subject to the retention exceptions in §7 (e.g., billing records required by tax law).
12. Children's privacy
The Service is not directed at children under [13/16]. We do not knowingly collect personal data from children below that age. If you believe a child has provided us data, contact [privacy email] and we will delete it.
13. Changes to this policy
We may update this Privacy Policy to reflect changes in our practices or legal requirements. Material changes will be notified in the app or by email before they take effect. The "last updated" date at the top of this page reflects the latest revision.
14. Contact
Privacy questions or requests: [privacy email]. Data Protection Officer (Encarregado): [dpo email].