Privacy Policy

Version 2026-10-25 · In effect from October 25, 2026

Courtesy translation. In case of any discrepancy, the Portuguese version prevails.

This policy explains how KORBI CONSULTORIA E TECNOLOGIA LTDA (CNPJ 55.560.651/0001-28) processes your personal data in the LEVAMENTE app and website, in accordance with the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados, Law No. 13,709/2018, “LGPD”).

Your inner world is yours aloneNotes, reflections and conversations are encrypted with a key that belongs to your account. Our team has no screen for reading them.

You decideThe AI guide, memory, conversation history, Encounter based on how you feel and notifications only work with your permission, which you can withdraw at any time.

No selling and no adsWe do not sell your data and do not use what you write or feel for advertising.

Your rights at your fingertipsExport your data or delete your account in the app itself, whenever you want.

1. Who processes your data

The controller of your data is KORBI CONSULTORIA E TECNOLOGIA LTDA, CNPJ 55.560.651/0001-28, with its head office at Rua Rio Grande do Norte, nº 1436, Sala 813, Savassi district, Belo Horizonte/MG, Brazil, postal code (CEP) 30.140-138. The person in charge of processing personal data (Data Protection Officer) is indicated in section 18.

2. What data we process

Account: email address, display name (optional), country (optional), language, password (stored only as an irreversible code), login sessions and, if you turn it on, the two-step verification factor.
Preferences and goals: chosen focuses, preferred format (video, audio or reading), time zone, themes you prefer to avoid and the goal you write down.
What you write and record: notebook notes, reflections, small steps, saved memories (memory notice), messages with the guide, excerpts you share with the guide and the monthly summary.
How you arrive and how you leave (only if you turn on Encounter based on how you feel): the feelings and needs you select from a short list, the day, the moment (arrival or departure) and the encounter they refer to, and a summary of what has helped you, learned only from your answers (how it works).
App usage: encounters and sessions, format used, playback position, favorites, ratings, and the scores from 0 to 10 that you give (check-in and wheel of life).
Subscription: plan, status, expiry date, currency, amounts charged and refunded, and purchase identifiers on the website or in the stores. From your card, we keep only the brand, the last 4 digits and the expiry date, to show which card is in use. We do not store your card number: payment is processed by Stripe or by the store (section 6).
Subscribing on the website: name, billing country and, in Brazil, the CPF (Brazilian individual taxpayer number), stored by Stripe, the payment processor, for billing and tax obligations. LEVAMENTE does not store the CPF or the name: it stores only the country and whether a CPF was provided.
Waitlist (website): if you ask to be notified of the launch, your email address, your language, the dates of your request, confirmation and departure, the version of the text you accepted and a technical record of your IP address stored as an irreversible code (section 14).
Device: platform (iOS or Android), app version, language and, if you turn on reminders or team messages, the notification identifier (stored encrypted).
Technical and security records: access dates, IP address in security records, attempt counters and audit events, always without the content of what you write or select.

3. Sensitive data

What you write may reveal sensitive personal data (art. 5, II and art. 11 of the LGPD), such as information about health, sex life, religion or situations of violence. This data comes from your own initiative: LEVAMENTE does not classify it, does not extract it from your text and does not create profiles from what you write. It is encrypted with a key that belongs to your account and is used only to provide the service to you, within the limits of this policy and of the permissions you give.

What you feel is also sensitive data. In the optional Encounter based on how you feel feature, you yourself select how you are arriving (for example, tired or anxious) and what you need. This is health data and is only processed with your specific and prominent consent, to choose and explain the encounter of the day. The app does not guess what you feel: it uses only what you select and your answers about what helped.

4. What we use it for and on what legal basis

Purpose	Main data	Legal basis (LGPD)
Create and protect your account, allow you to log in	email, password (code), sessions, device	performance of a contract (art. 7, V); fraud prevention and security (art. 11, II, “g”)
Provide the service: daily encounter, content, notebook, steps, wheel, monthly summary	preferences, usage, what you write	performance of a contract (art. 7, V); for sensitive data, your specific and prominent consent (art. 11, I)
Encounter based on how you feel: choose and explain the encounter of the day taking into account how you are arriving and what has already helped you (how it works)	feelings and needs you select, answers to “did this help you today?” and “how are you leaving?”, summary of what helped	specific and prominent consent (art. 11, I), requested separately in the app; you can withdraw it at any time
AI guide, memory and conversation history (memory notice)	messages, context you authorize, memories	consent (art. 7, I and art. 11, I)
Show help resources when there are signs of crisis in the conversation	only the alert category, without the text	protection of life and physical safety (art. 11, II, “e”)
Notification reminders	notification identifier, times, time zone	consent (art. 7, I)
Team messages on your phone (LEVAMENTE news and encouragement)	notification identifier and language; the message is written by the team and does not include data from your account	consent (art. 7, I)
Subscription and payments	plan, status, currency and amounts, purchase identifiers, card brand and last 4 digits; when subscribing on the website, name, billing country and, in Brazil, CPF (stored by Stripe, not by LEVAMENTE)	performance of a contract (art. 7, V); compliance with a legal obligation, including tax obligations (art. 7, II)
Service emails (confirmation, password, account and subscription notices)	email, language	performance of a contract (art. 7, V)
Email announcements about LEVAMENTE (news, changes to the service, content), for accounts with a confirmed email address	email address only	legitimate interest (art. 7, IX); you can unsubscribe at any time through the link at the end of each announcement
Waitlist: notify you about the app launch and send LEVAMENTE news (section 14)	email, language, dates of the request, confirmation and departure, version of the text accepted and technical record of the pseudonymized IP address (irreversible code)	consent (art. 7, I), given by ticking the box on the form and confirmed through the link sent by email; you can withdraw it at any time
Security, abuse prevention and auditing	technical records without intimate content	legitimate interest (art. 7, IX) and fraud prevention (art. 11, II, “g”)
Support when you ask for help	minimum account data (email, status, dates, subscription), never what you write or select	performance of a contract and legitimate interest (art. 7, V and IX)
Service indicators (number of active accounts, encounters by format, etc.)	aggregate counts only; small numbers are hidden	legitimate interest (art. 7, IX)
Fulfill your rights (export, deletion) and comply with the law	account data	compliance with a legal obligation (art. 7, II); regular exercise of rights (art. 7, VI)

We do not make automated decisions that produce legal effects on you. The choice of the encounter of the day follows simple rules and shows the reason for the suggestion, including when it takes into account what you feel.

5. Your permissions (consents)

Some features only work with your permission, requested in the app clearly and separately. You can withdraw each one at any time in the app's privacy settings; the withdrawal applies from then on and, where applicable, deletes what depended on it. If the text of a permission changes, the app may ask for your permission again before using the feature again.

AI guide: processing your messages in order to reply.
Memory: keeping memories that you confirm, for the guide to use in conversations. Turning memory off makes the guide stop using them, but does not delete them: to delete them, use “delete” on each memory or “delete all”. Details in the memory notice.
Conversation history: keeping your conversations; without it, they are deleted within 24 hours.
Sharing notebook excerpts with the guide: per chosen excerpt and for a limited time.
AI-generated monthly summary.
Encounter based on how you feel: using what you select about how you arrive and how you leave, and your answers about what helped, to choose the encounter of the day. It is a specific consent, because it involves health data. Withdrawing it immediately deletes what you selected and what the app learned. Details on the Encounter based on how you feel page.
Notification reminders.
Team messages: receiving notifications from the team on your phone with LEVAMENTE news and encouragement. Withdrawing it cancels any that were still scheduled for you.

6. Who we share data with

We do not sell or rent your data. We share only what is necessary with service providers that process data on our behalf (processors), under contract and with a duty of confidentiality and security. These are the categories:

Infrastructure: hosting, database, file storage and content delivery, so that the app and the website work.
Artificial intelligence: only when you use the guide or the AI-generated monthly summary, and only with the context you authorized.
Communication: sending service emails, announcements and waitlist emails (only your email address, for the mailing list) and phone notifications (the latter only with reminders or team messages turned on).
Payments: Stripe, for credit card payments on the website (see below), or Apple and Google for purchases made through the stores.

We do not send the content of your notes, memories or conversations to advertising or tracking tools. What you select in Encounter based on how you feel stays only in the app's infrastructure: it does not go to Stripe, to email delivery, to analytics tools or to artificial intelligence.

We may also share data when required by law, by court order or by order of a competent authority, or to exercise rights in legal proceedings.

Payments on the website

Payments on the website are processed by Stripe, which acts as a processor. From us, it receives your email address, name, billing country and, in Brazil, CPF.
Card details do not pass through LEVAMENTE: you type them into a field that belongs to Stripe, within our page, and they go directly to Stripe. From Stripe, we receive only the card brand, the last 4 digits and the expiry date, and we check the card type and the country where it was issued, to apply the payment rules (credit card only; cards issued in Brazil charged in reais).
If you withdraw from the subscription within the withdrawal period (Terms of use, section 7.4), we use your email address and the charge details to issue the refund through Stripe, to the same card. We record the refund (date and amount) together with the receipt and let you know by email.
The currency of the charge follows the billing country you enter, according to the Terms of use (section 7). When the currency of the charge differs from your card's currency, or when your bank treats the purchase as international, your bank may convert the amount and charge fees or taxes, such as IOF (the Brazilian tax on financial transactions). These charges are set by your bank; LEVAMENTE does not receive them.

7. International transfer

Some providers (such as file storage, content delivery, email delivery, notifications, payment processing and app stores) may process data outside Brazil. When you subscribe on the website, Stripe may process your email address, name, billing country, CPF and card details outside Brazil. In these cases, the transfer follows art. 33 of the LGPD, with standard contractual clauses approved by the Brazilian National Data Protection Authority (Autoridade Nacional de Proteção de Dados, ANPD) or another safeguard provided for by law, so that your data has protection equivalent to that of Brazilian law.

8. How long we keep data

This section is our retention policy. We keep each piece of data only for as long as necessary. When a period expires, the data is deleted automatically or is no longer used, as described below. Deleting your account deletes your personal data (section 9).

While your account exists, or until you delete it

What you write and your use of the app (notes, reflections, steps, encounters, scores from 0 to 10, wheel of life, favorites): while your account exists, or until you delete them.
Saved memories: until you delete each one, delete all of them or delete your account. Turning memory off does not delete them; it only makes the guide stop using them. A memory with an expiry date is no longer used after that date, but remains stored until you delete it.
Conversations with history turned on: until you delete the conversation. If you turn history off, they start being deleted within 24 hours.
Summary of what has helped you (Encounter based on how you feel): while the permission is active. Older answers count less and less (their weight is halved every 90 days). You can delete one item or everything whenever you want, and withdrawing the permission deletes everything immediately.
Subscription in LEVAMENTE (plan, status, currency, amounts and card brand, last 4 digits and expiry date): while the account exists.
Your email address on the announcements list: while the account is active. It is removed from the list within 24 hours after the account is deleted or the email address is changed. If you unsubscribe through the link in an announcement, we do not add it back.

Short periods

Conversations without history turned on: up to 24 hours after the last message.
What you select in Encounter based on how you feel (how you arrive and how you leave): deleted automatically after 90 days. After that period, the reason given for the encounters chosen on that basis no longer mentions what you selected and becomes a general sentence.
Memory suggestions you did not confirm: expire after 7 days. Suggestions that have already been answered or have expired are deleted 30 days later (the memory you confirmed remains stored).
Notebook excerpts shared with the guide: valid for a limited time (7 days, unless another period is chosen, and never more than 30 days); once expired or revoked, they are deleted within 7 days.
Safety alert records (without text): 90 days.
Export file of your data: available for 7 days.
Ended sessions: deleted 30 days later.
Waitlist: an unconfirmed request is deleted within 7 days (the confirmation link is valid for 48 hours); a confirmed email address is kept until you leave the list or until the waitlist is closed, and we will notify you by email before closing it; when you leave, you stop receiving the emails within 1 hour, and your entry on the list is deleted within 24 hours (section 14).

Technical records and legal obligations

Payment records and tax documents: for the period required by tax law, kept by Stripe, even after the account is deleted.
Payment notifications received from Stripe (only identifiers, dates and amounts, without name, email, document or card): 90 days after they are processed.
Artificial intelligence usage records (amount of text processed and cost, without the content): up to 400 days, or until the account is deleted.
Security and audit records (without intimate content): for 6 months, as provided by the Brazilian Civil Rights Framework for the Internet (Marco Civil da Internet) for access records, or for longer if they are needed to investigate a security incident or to defend rights in legal proceedings.
Minimum record of deletions and withdrawn permissions (without content): kept, so that deleted data does not come back if a backup copy needs to be restored.

9. Account deletion

You can delete your account in the app, in two steps and with confirmation. Deletion cuts off access immediately, deletes your personal data (including what you selected in Encounter based on how you feel and what the app learned) and removes your email address from the announcements list; encrypted content becomes unreadable when your account's key is destroyed. Backup copies are replaced in regular cycles, and we keep only a minimum record, without content, to ensure that deleted data does not come back in a restoration. If you have a subscription made on the website, deletion ends it immediately, together with the account, and your customer data is deleted at Stripe (the invoices remain with Stripe, for tax obligations). Deleting your account does not cancel subscriptions made through the stores: cancel them with Apple or Google as well.

10. Security

Encryption specific to each account for personal content, and encryption in transit (HTTPS).
Isolation of each person's data in the database.
Team access restricted by role, with two-step verification and auditing; there is no team screen for reading what you write or what you select about how you feel.
Technical records without the content of your notes and conversations and without what you select about how you feel.

No system is completely immune to failures. That is why we work continuously to prevent, detect and respond to incidents.

11. Your rights

The LGPD (art. 18) guarantees you, among others, the rights to:

confirm whether we process your data and access it;
correct incomplete, inaccurate or outdated data;
request the anonymization, blocking or deletion of unnecessary data or of data processed in breach of the law;
data portability;
deletion of data processed with your consent, and information about the possibility of not giving consent;
know who we share your data with;
revoke your consent at any time.

How to exercise them: in the app itself (export data, correct your profile and records, revoke permissions, delete your account) or through the Data Protection Officer's channel in section 18. We will respond within the time limits set by law. You can also file a complaint with the Brazilian National Data Protection Authority (ANPD).

12. Minors

LEVAMENTE is intended for people aged 18 or over. We do not knowingly process data of children and adolescents; if we identify such use, the account will be closed and the data deleted.

13. Website, cookies and analytics

The website currently does not use advertising cookies or third-party tracking tools.
The website's fonts are loaded from Google Fonts, which receives your browser's IP address in order to deliver them.
On the subscription and subscription management pages, the card form belongs to Stripe: it loads its own code and may use cookies and browser information to prevent fraud, in accordance with Stripe's privacy policy.
If we start using audience measurement, it will be optional and will depend on your consent, with a notice on this page.

14. Waitlist

Before the app launches, you can leave your email address on the website to be notified when LEVAMENTE arrives on the App Store and Google Play.

Data: your email address; the language of the page on which you signed up, so that we write to you in that language; the date and time of your request, confirmation and departure; the version of the text you accepted; and a technical record of the IP address of the request, stored as an irreversible code (pseudonymized), used as proof of the request and to prevent abuse. We do not ask for your name and do not create an account.
Purpose: to notify you about the LEVAMENTE launch and send you news about the service.
Legal basis: your consent (art. 7, I, of the LGPD), given by ticking the box on the form and confirmed through the link we send by email. You can withdraw it at any time.
Email confirmation: after your request, we send you an email with a link to confirm that the address is yours. The link is valid for 48 hours. Only confirmed email addresses receive the notices.
How long we keep it: an unconfirmed request is deleted within 7 days. A confirmed email address is kept until you leave the list or until the waitlist is closed; before closing it, we will notify you by email. When you leave, you stop receiving the emails within 1 hour, and your entry on the list is deleted within 24 hours.
How to leave: through the “leave the list” link in the confirmation email, through the unsubscribe link included in every announcement or by writing to contato@levamente.com.br.
Who sends the emails: an email delivery service provider, in the “Communication” category (section 6), which receives only what is necessary to send the messages. It may process data outside Brazil, with the safeguards described in section 7.

The waitlist is not a subscription and does not generate any charge.

15. Team data

For team members who use the administration panel, we process account data, roles, two-step verification and audit records of their actions, for security and for control of the published content.

16. Incidents

If a security incident occurs that may pose a relevant risk or harm to you, we will notify you and the ANPD, under art. 48 of the LGPD, with the relevant information and the measures taken.

17. Changes to this policy

We may update this policy. Significant changes will be announced in the app or by email and, when required by law, we will ask for your consent again. The current version is always available on this page.

18. Data Protection Officer and contact

Person in charge of processing personal data (Data Protection Officer, DPO): privacy team of KORBI CONSULTORIA E TECNOLOGIA LTDA

Email: contato@levamente.com.br (subject: “Privacy”)

Controller: KORBI CONSULTORIA E TECNOLOGIA LTDA · CNPJ 55.560.651/0001-28 · Rua Rio Grande do Norte, nº 1436, Sala 813, Savassi district, Belo Horizonte/MG, Brazil, CEP 30.140-138

General questions: contato@levamente.com.br. See also the Terms of use, the memory notice and the Encounter based on how you feel page.