How we collect, use, and protect your personal data under Brazil's General Data Protection Law (LGPD – Law 13.709/2018).
1. Controller and contact
PATRYK MATEUSZ GRABOWSKI LTDA (CNPJ 61.434.746/0001-06), Rua Joaquina de Jesus 127 Lote 16, Vila Isolina Mazzei, São Paulo SP, 02079-070. For any data-protection request write to contact@falando.app.
2. Data we collect
We process the following categories of personal data:
Account data - e-mail address, display name, avatar (optional), and authentication tokens.
Study data - vocabulary progress, grammar scores, review schedules, daily-quest streaks, belt ranks, badges, and content-generation logs.
Payment data - web purchases are processed entirely by Paddle (merchant of record); in-app purchases are processed by Google Play Billing (Android) or the Apple App Store (iOS). We never see or store full card numbers; we keep only a subscription identifier and current status.
Google Analytics data (if you accept) - pages visited, approximate session duration, referrer and campaign tags processed by Google Analytics with first-party _ga / _gid / _gat cookies.
Optional usage and crash telemetry (if you opt in) - device class, operating system, browser, screen size, preferred language, timezone, manual add-to-reviews actions, mark-as-mastered actions, grammar point page opens, verb conjugation table searches, search terms and scopes, and client crash/error reports.
User-generated content - text you paste or type in exercises, voice recordings submitted in the oral-exam and bate-papo modes, and imported BYOC articles/video URLs.
Cookies & local storage - authentication tokens, UI-preference flags (theme, TTS voice, language), and the cookie-consent record itself.
Advertising data (Android app, free accounts only) - your device's Google advertising ID, IP address, coarse device and app information, and ad interactions, collected by the Google AdMob SDK when an ad is requested. Premium accounts are never served ads and none of this is collected for them.
3. Purposes and legal bases
Each processing activity relies on a specific LGPD legal basis:
Contract performance (Art. 7 V) - providing the learning platform and paid-plan features.
Legitimate interest (Art. 7 IX) - improving content, preventing fraud, and generating anonymised analytics from non-optional operational data.
Consent (Art. 7 I) - promotional e-mails, optional notifications, Google Analytics, and optional usage/crash telemetry (each may be withdrawn at any time from Settings > Privacy or the cookie banner).
Legal obligation (Art. 7 II) - keeping tax and billing records as required by Brazilian law.
Exercise of rights (Art. 7 VI) - defending claims in administrative or judicial proceedings.
Protection of credit (Art. 7 X) - processing payment data through Paddle (web), Google Play Billing (Android), and the Apple App Store (iOS) to prevent chargebacks.
Legitimate interest (Art. 7 IX) - showing AdMob ads to free accounts in the Android app to fund the free tier; where consent applies (EEA/UK and US state privacy laws) we rely on your consent instead, collected through Google's consent form and withdrawable at any time from Settings > Privacy.
4. Sharing and international transfers
We share data only with processors that need it to run the service:
OpenAI / Anthropic (AI providers, US) - exercise text sent for evaluation; no personal identifiers are included.
Paddle (merchant of record, web payments, US/EU) - billing details and subscription data for web purchases.
Google Play Billing (in-app payments, Android) - billing and subscription data for Android purchases. Google's own terms apply.
Apple App Store (in-app payments, iOS) - billing and subscription data for iOS purchases. Apple's own terms apply.
Google Analytics (usage analytics, US/EU) - page-view and session events, only after you accept the analytics cookie.
Vercel (hosting & CDN, US/EU) - serves the application; standard HTTP access logs only.
Google AdMob (advertising, Android app, US/EU) - advertising ID, IP address and ad-request data, for free accounts only, used to select and measure ads. Google acts as an independent controller for this data.
International transfers rely on Standard Contractual Clauses or equivalent safeguards (LGPD Art. 33). We do not sell or rent personal data to third parties.
5. Cookies and local storage
We use essential cookies (authentication session) and UI-preference flags stored in localStorage. We also set first-party Google Analytics cookies (_ga, _gid, _gat) — but only after you accept the analytics category in the cookie banner. The website itself uses no advertising cookies. The Android app is different: free accounts are shown AdMob ads, which rely on your device's advertising ID rather than cookies — see "Advertising in the Android app" below. You can change your choice anytime from "Cookie settings" in the footer or from Settings → Privacy.
6. Your LGPD rights
Under the LGPD you may, at any time:
Confirm whether we process your data.
Access a copy of your data.
Correct inaccurate data.
Anonymise, block, or delete unnecessary data.
Request data portability.
Delete your data (request via Settings → Delete Account or e-mail us at contact@falando.app).
Know which entities we share data with.
Be informed about denying consent and its consequences.
Withdraw consent for optional processing.
7. Retention, security and encryption
We keep personal data only while your account is active or as legally required (e.g., tax records for five years). After account deletion we erase or anonymise all personal data within 30 days. Data is encrypted in transit (TLS 1.2+) and at rest (AES-256). Access is restricted to authorised personnel on a need-to-know basis. As an additional safeguard, the most sensitive content you create is also encrypted at the application level (AES-256-GCM): the contents of your journal entries together with their AI feedback, and your Celpe-Bras candidate background (the personal profile you provide for the oral exam). This content is stored only as encrypted text, and the encryption key is held separately in our application environment, never in the database, so it cannot be read directly in our database or in backups. We decrypt it only to show it back to you and to generate your AI feedback or exam interaction, which briefly sends the relevant text to our AI provider (OpenAI). This is encryption at rest to protect against unauthorised database access, not end-to-end encryption. Protecting what you write is central to how we respect your privacy.
8. Children and adolescents
Falando is available to users aged 13 and over. Users between 13 and 18 must have parental or guardian consent. We do not knowingly collect data from children under 13; if we discover such data we will delete it promptly.
9. Optional usage and crash telemetry
If you opt in, Falando collects lightweight product-usage and crash analytics so we can fix bugs and understand which features are working:
Device class - Web (desktop, mobile, tablet) or the Android app.
Operating system and browser, with version.
Screen resolution and viewport size.
Preferred language and timezone from your browser.
Manual add-to-reviews actions and mark-as-mastered actions for vocabulary, listening, and grammar exercises.
Grammar point page opens.
Verb conjugation table searches.
Search terms and search scopes.
Client crash/error reports, including screen path and technical error details.
Why we collect this: to fix platform-specific bugs, measure whether learning features are useful, prioritise engineering work, and detect abusive automation. We do not sell this data or use it for advertising.
How to opt out: leave the signup checkbox unchecked, use the cookie banner, go to Settings > Privacy and turn off "Help improve Falando", or write to contact@falando.app. Opting out deletes telemetry stored for you and stops new collection immediately.
Where it is stored: Supabase (US region). Retention: telemetry is kept while your account is active and is erased on opt-out or account deletion.
10. Advertising in the Android app
Free accounts using the Falando Android app are shown one full-screen ad after a completed practice session, served by Google AdMob. Ads never appear on the website, and never for Premium accounts — for them no ad is requested and no advertising data is collected.
What Google collects - your device's Google advertising ID, IP address, coarse device and app information, and ad interactions (impressions, clicks). This is gathered by Google's SDK inside the app; Falando does not receive your advertising ID.
Why - advertising funds the free tier. Upgrading to Premium removes ads and this data collection entirely.
Who receives it - Google, acting as an independent controller under its own privacy policy, and, where you consent to them, its advertising partners.
Your choices - where consent is required (the EEA, the UK, and US states with applicable privacy laws), Google's consent form appears the first time you open the app, and you can reopen it at any time from Settings → Privacy → "Ads privacy". Android's own settings also let you reset or delete your advertising ID.
Where consent is required, no ad is requested until you have made a choice, and declining means no personalised ads are served. Ads appear only after a practice session you finished — never during an exercise.
11. Changes and contact
We may update this policy to reflect legal or product changes. Material updates will be announced via in-app notification at least 15 days before they take effect. For questions or data-subject requests, contact contact@falando.app.
