Privacy Policy

The controller of the personal data described in this policy is DONNU LTDA, CNPJ 65.082.197/0001-09, with its registered office at Rua Lorena, 649, Loja Parte, Padre Eustáquio, Belo Horizonte/MG, CEP 30.730-170, Brazil. DONNU LTDA operates the Free Gelato Balancing App.

• Account. Your email address and password. The password is stored only as a one-way hash (bcrypt), so nobody, including us, can read it. You may also add a username, a display name and a profile photo.
• Your content. The recipes you save, the ingredients you create, your diary and experiment entries, and the settings of your public profile (a profile can be public or protected by a password).
• Purchases on the website. Books, guides and the custom recipe service are sold only on the website, never inside the Android app. Payment is processed by Stripe. We receive your name, email address, the product purchased and the amount; we never receive your card number. If you order the custom recipe service, we also receive the recipe and the details you send in your brief.
• Usage and technical data. A session cookie (sid) keeps you signed in. We keep our own records of which pages are viewed and which buttons and offers are clicked, tied to a random visit identifier. The website uses Google Analytics through Google Tag Manager, and so does the Android app, because it opens the website. Our servers keep short technical logs (IP address, browser and time of each request) for security and troubleshooting.
• What we do not collect. Your location, contacts, camera or microphone. A photo is uploaded only when you choose one for your profile.

We process personal data only for the purposes below, each with its legal basis under article 7 of the LGPD:

• Providing the software and your account: creating your account and signing you in, saving and syncing your recipes, ingredients and diary, showing your public profile when you choose to, delivering what you buy, answering support requests and sending account emails (email confirmation, password reset, purchase receipts and messages about the custom recipe service). Legal basis: performance of a contract (art. 7, V).
• Security and fraud prevention: protecting accounts, detecting abuse and fixing errors. Legal basis: legitimate interest (art. 7, IX).
• Product analytics: understanding which features and pages are used, so we can improve the software. Legal basis: legitimate interest (art. 7, IX).
• Occasional feedback emails from our team asking about your experience. Legal basis: legitimate interest (art. 7, IX). You can ignore them, or ask us to stop.
• Tax and purchase records. Legal basis: compliance with a legal obligation (art. 7, II).

Where we rely on legitimate interest, we weigh it against your rights and expectations, and you can object at any time (section 8). For users in the European Union, the corresponding GDPR legal bases are article 6(1)(b) (contract), 6(1)(f) (legitimate interests) and 6(1)(c) (legal obligation).

We do not sell personal data, there is no advertising in the app and we do not use advertising networks.

We share personal data only with the providers (processors) that help us run the service, and only to the extent each one needs:

• Supabase: database and file storage, hosted in São Paulo, Brazil.
• Railway: hosting of the website and the API.
• Stripe: payment processing on the website.
• Resend: delivery of emails.
• Google: Google Analytics and Google Tag Manager; Google Play, which distributes the Android app.

We may also disclose data to public authorities when required by law or by court order, or to exercise our rights in legal proceedings.

What you make public is visible to others: your public profile and your public recipes can be seen by anyone with the link, and a password-protected profile by anyone who has the password. You can change this at any time in your profile.

Your account data, content and files are stored in Brazil (Supabase, São Paulo). Some of the providers listed in section 4 process data outside Brazil. These transfers are made under the safeguards required by the LGPD and, where applicable, the GDPR, and under the data protection terms of each provider.

• Account data and content: kept while your account is active. When you delete your account, it is closed immediately, and your recipes, ingredients, diary, profile and photos are permanently deleted after 30 days (see how to delete your account).
• Purchase records (including the brief sent for a custom recipe): 5 years, as required by tax law, even if you delete your account.
• Technical server logs: kept for a limited period and for as long as the law requires.
• Statistics: we may keep aggregated statistics that do not identify you.

We use technical and organizational measures suited to the data we hold: HTTPS on every connection; passwords stored only as bcrypt hashes; sessions kept on our servers; and a database that is not exposed to the public API (row-level security denies public access) and that only the application can reach. No system is completely immune to incidents, so we cannot guarantee absolute security. If an incident may cause you relevant risk or damage, we will notify you and the authorities as required by law.

Under article 18 of the LGPD, you can ask us for:

• confirmation that we process your data;
• access to your data;
• correction of incomplete, inaccurate or outdated data;
• anonymization, blocking or deletion of data that is unnecessary, excessive or processed in breach of the LGPD;
• portability of your data to another provider;
• information about the public and private entities with which we share your data.

You can also object to processing based on legitimate interest, ask us to delete your account and data (see how to delete your account) and file a complaint with the Brazilian National Data Protection Authority (ANPD).

If you are in the European Union, the GDPR gives you equivalent rights: access, rectification, erasure, restriction of processing, data portability and objection, and the right to lodge a complaint with the data protection authority of your country.

To exercise any of these rights, write to contact@freegelatobalancing.app from the email address of your account. We reply within 15 days and may ask you to confirm your identity. Much of this you can do yourself at any time: edit your profile, make recipes private and delete your account in the app.

• sid: an essential session cookie that keeps you signed in. Without it you cannot use your account.
• Visit identifier: a random number stored in your browser's local storage, used to avoid counting the same visit twice and to know which page led to a purchase.
• Preferences: your language choice is remembered in your browser's local storage.
• Google Analytics: cookies set through Google Tag Manager to measure how the website is used.

We do not use advertising cookies. You can block or delete cookies and local storage in your browser settings; blocking the session cookie signs you out.

The software is intended for adults (18 or over) and is not directed to children or adolescents. We do not knowingly collect their data. If you believe a minor has created an account, write to us and we will close it.

The Android app, distributed on Google Play, opens this same software in Chrome (a Trusted Web Activity). It:

• asks for no device permission besides internet access;
• shows a local screen when you are offline;
• follows the same data practices described in this policy, including Google Analytics;
• sells nothing: there are no purchases inside the app.

Installing the app from Google Play is also subject to Google's own terms and privacy policy.

We may update this policy. The date at the top always shows the version in force, and material changes are announced by email to account holders.

Our data protection officer (the encarregado required by the LGPD) can be reached at contact@freegelatobalancing.app. Use this address for questions about this policy and to exercise your rights. We reply within 15 days.