MenoProPrivacy Policy
This is a draft (minuta) of the MenoPro Privacy Policy, pending legal review. It explains in plain language how we process your personal data under Brazil's General Data Protection Law (LGPD, Law 13,709/2018). Last updated: [PREENCHER: effective date].
1. Who we are and data controller
MenoPro is a menopause companion app and website operated by Virex Tech. Data controller: [PREENCHER: legal company name], CNPJ [PREENCHER: CNPJ], headquartered at [PREENCHER: full address].
2. Data we collect
We collect only what is needed to run the service: - Account: name, email and sign-in credentials. - Health data (sensitive personal data): menstrual cycle, symptoms, journal entries, medications and quiz answers. - Usage and device: device type, operating system, language, technical identifiers and in-app interactions. - Community: nickname and the content you post. - AI assistant: messages sent to the assistant. If you use dictation, speech recognition is done by your device's own feature and only the text is sent.
3. Legal basis
We process your health data based on your specific and prominent consent, under art. 11, I, of the LGPD. For other data we rely on performance of a contract (providing the service you requested), legitimate interest (security, fraud prevention and product improvement, always respecting your rights) and compliance with legal or regulatory obligations. You may withdraw your consent at any time, easily and free of charge. Withdrawal does not affect processing already carried out, but may limit features that depend on that data.
4. Purposes
We use your data to: - Create and maintain your account and authenticate your access. - Record and display your tracking of symptoms, cycle, journal and medications. - Personalize wellness content and recommendations. - Operate the AI assistant, the community and notifications. - Process subscriptions and payments. - Ensure security, prevent abuse and fix errors. - Measure and improve product performance. - Comply with legal obligations.
5. Sharing and processors
We share data only with processors needed to provide the service: - Anthropic: processor for the assistant's artificial intelligence. Some processors are located outside Brazil. In those cases, international transfers take place with the safeguards set out in art. 33 and following of the LGPD.
6. AI assistant
The AI assistant provides information and wellness support. It is not a doctor, does not diagnose, and does not replace a consultation with a healthcare professional. We do not use the content of your conversations to train AI models [PREENCHER: confirm contract with the AI provider]. Safety events (for example, messages about risk situations) are logged only as a count per category, without the conversation content.
7. Community
In the community you appear under a nickname, without needing to use your real name. What you post is visible to the group, so avoid sharing information that could identify you. We may moderate, hide or remove content that violates our rules, and record reports to protect participants.
8. Retention
We keep data only as long as needed for the purposes described or as required by law. Retention periods by category: [PREENCHER: retention periods by data category]. When you delete your account, we delete or anonymize your data, except what we must keep to meet a legal obligation.
9. Security
We apply technical and organizational measures to protect your data, such as encryption in transit, access control and monitoring. No system is completely invulnerable; in case of an incident posing relevant risk, we will notify you and the ANPD as required by the LGPD.
10. Your rights
Under art. 18 of the LGPD, you may request: - Confirmation that we process your data. - Access to your data. - Correction of incomplete, inaccurate or outdated data. - Anonymization, blocking or deletion of unnecessary data or data processed in violation of the law. - Data portability. - Deletion of data processed with consent. - Information about who we share your data with. - Withdrawal of consent. - Review of decisions made solely by automated processing. To exercise these rights, write to the Data Protection Officer contact below. We will respond within the legal deadlines.
11. Account and data deletion
You can delete your account and data at any time, in the app or on the account deletion page of our website. Deletion is permanent once confirmed. Subscriptions purchased through the Apple or Google stores must be cancelled directly in the respective store.
12. Data Protection Officer (DPO) and contact
Data Protection Officer: [PREENCHER: DPO name]. Contact: [PREENCHER: DPO email].
13. Minors
MenoPro is not intended for anyone under 18 and we do not knowingly collect data from minors. If we identify such a case, we will delete the data.
14. Changes to this policy
We may update this policy to reflect changes in the service or the law. For material changes we will notify you in the app or by email, and ask for new consent when required.
15. Jurisdiction and ANPD
You have the right to file a complaint with the Brazilian National Data Protection Authority (ANPD) if you believe your rights were not respected. This policy is governed by the laws of Brazil, and jurisdiction is as set out in the Terms of Use.