Privacy Policy

1. Data Controller

The controller of personal data processed through the Service is:

• Lokify
• Contact email: suporte@lokify.app
• Data Protection Officer (DPO): suporte@lokify.app

2. Data We Collect

2.1 Data Provided Directly by You

2.2 Pet Data

2.3 Session and Content Data

2.4 Automatically Collected Data

2.5 Payment Data

We do not store sensitive financial data (such as credit card numbers). This data is processed directly by our payment partners (Stripe, Apple App Store, Google Play Store, RevenueCat). We only collect subscription history, payment status, and plan type for feature management purposes.

2.6 Third-Party Authentication Data

When using login via Google OAuth, we receive your profile name, email, and unique Google identifier for account creation and linking. We do not have access to your Google password.

3. Legal Bases for Processing (LGPD)

4. How We Use Your Data

4.1 Service Operation

• Authentication and account management
• Processing audio recordings and AI-powered transcription
• Generating behavioral analyses and training plans
• AI chat assistant functionality
• Subscription and plan feature management
• Sending transactional emails (account confirmation, password recovery, notifications)
• Achievements and gamification system

4.2 Artificial Intelligence Processing

To provide our AI features, data is sent to third-party providers:

• OpenAI (primary provider) — GPT models for transcription, analysis, and content generation
• Google Gemini (secondary/fallback provider) — used when the primary provider is unavailable

Data sent: audio transcriptions (which may contain names of people and pets), pet information (species, breed, age, gender, name), behavioral context, plan and session details, and chat messages.

AI providers process this data in accordance with their own privacy policies. Lokify strives to use configurations that minimize data retention by these providers.

4.3 Pet Industry Research and Analysis

Lokify may use your data in an anonymized and aggregated form for pet industry research and analysis purposes, including:

• Identifying which species and breeds are most frequently trained
• Mapping the most common behaviors reported by pet owners and trainers
• Analyzing the effectiveness of different training methods and plans
• Generating statistics and trends about the animal training market
• Publishing reports, articles, and studies on animal behavior and training
• Collaborating with universities, research centers, and pet industry organizations

Anonymization guarantee: No data used for research will allow the identification, directly or indirectly, of any specific user, pet owner, trainer, or animal. Data undergoes an irreversible anonymization process before any use for research.

4.4 Marketing and Promotional Communications

With your express consent, Lokify may use your data to send promotional emails, newsletters, personalized feature recommendations, targeted campaigns, and offers from pet industry partners.

You may revoke your consent at any time, without any impact on your use of the Service, through the unsubscribe link, preference settings, or by contacting support.

4.5 Improvement and Development

• Analyzing usage patterns to improve existing features
• Developing new features
• Bug fixes and performance improvements
• Training and improving our own models and algorithms (with anonymized data)

5. Data Sharing

5.1 Service Providers (Operators)

5.2 Research and Partnerships

We may share anonymized and aggregated data with research institutions, universities, organizations, and pet industry partners. This data will never allow the identification of individual users.

5.3 Partner Marketing

Only with your prior and express consent, we may share limited data with pet industry partners for relevant marketing communications.

5.4 Legal Obligation

We may disclose data when required by court order, determination by a competent authority, or to protect the rights of Lokify and its users.

5.5 International Data Transfer

Your data may be transferred to servers outside Brazil, particularly to AI providers (OpenAI and Google, with servers in the USA). These transfers are carried out in compliance with Art. 33 of the LGPD. Lokify's main infrastructure is on AWS in the Sao Paulo, Brazil (sa-east-1) region.

6. Storage and Security

6.1 Security Measures

• Password encryption with bcrypt algorithm and pepper
• Token-based authentication with JWT and refresh tokens
• Secure token storage on device (Secure Store)
• Pre-signed URLs for file uploads
• Encrypted communication via HTTPS/TLS
• Role-based access control (IAM)
• Continuous error and incident monitoring
• Automatic expiration of temporary tokens (TTL)

6.2 Retention Period

7. Cookies and Tracking Technologies

Essential cookies are required for the Service to function. Analytical cookies can be disabled through your browser settings.

8. Your Rights (LGPD)

Under the LGPD, you have the following rights:

• Confirmation and access: confirm whether we process your data and access a copy
• Correction: request the correction of incomplete or inaccurate data
• Anonymization, blocking, or deletion: of unnecessary data or data processed in non-compliance
• Portability: request the portability of your data
• Deletion: of data processed based on consent
• Information about sharing: know which entities your data is shared with
• Consent revocation: at any time
• Opposition: to processing in non-compliance with the LGPD

8.1 How to Exercise Your Rights

Email: suporte@lokify.app
Response time: up to 15 (fifteen) business days, as required by the LGPD.

8.2 Account Deletion

• Your personal data will be deleted within up to 30 days
• Audio recordings and images will be removed from servers
• Previously generated anonymized data will not be deleted, as it does not allow identification
• Data subject to legal obligations will be retained for the legally required period

9. Protection of Minors' Data

Lokify is not intended for individuals under 18 (eighteen) years of age. We do not intentionally collect data from minors. If we become aware that data from a minor has been collected without the consent of a legal guardian, we will take steps to delete such data.

10. Security Incidents

In the event of a security incident that may cause relevant risk or harm, Lokify will notify the Brazilian National Data Protection Authority (ANPD) within the legally required timeframe, notify affected data subjects, and take technical measures to mitigate the effects.

11. Changes to This Policy

Lokify reserves the right to update this Policy at any time. Changes will be communicated through the application or by email. The "Last updated" date at the top will indicate when the most recent version was published.

12. Applicable Law and Jurisdiction

This Policy is governed by the laws of the Federative Republic of Brazil, in particular the LGPD (Law No. 13,709/2018) and the Internet Civil Framework (Law No. 12,965/2014). The court of the jurisdiction where Lokify is domiciled is elected to resolve any disputes.

13. Contact

For questions, requests, or complaints:

• Email: suporte@lokify.app
• Support channel: Through the application

You also have the right to file a complaint with the Brazilian National Data Protection Authority (ANPD) through the website www.gov.br/anpd.