Privacy and cookie policy
Version Sep 18, 2026
How Aondeir handles personal data of visitors and account holders. Written to meet Brazil's LGPD, the EU GDPR (including Portugal) and Canadian law (PIPEDA and Québec's Law 25).
Technical draft prepared for review by a lawyer. It is not legal advice. The Portuguese version prevails over translations.
Controller details not yet filled in: Data protection officer. This policy must not be published in production like this.
1. Who the controller is
- Controller
- Claudio Freitas Golgo Sociedade Individual de Advocacia
- Company/tax ID
- CNPJ 35.655.457/0001-19
- Address
- to be defined before publication
- Privacy contact
- contato@aondeir.app
- Data protection officer
- to be defined before publication
- DPO email
- contato@aondeir.app
- Database region
- sa-east-1 (São Paulo)
- Website hosting
- VPS Hostinger (São Paulo, Brasil)
- Email delivery
- Resend (smtp.resend.com)
2. Who this applies to
It applies to visitors of public pages and to people who create an account. The service is intended for adults (18+); we do not knowingly collect data from minors as users.
For dependants we only ask for an age range, entered by the parent or guardian, to calculate household size in comparisons and checklists. We never ask for a child's name, document or other details.
3. Data, purposes and legal bases
We process only what is needed for each purpose below.
| Data | Purpose | Legal basis (LGPD · GDPR) |
|---|---|---|
| Email, password (kept by the authentication provider only as a hash), creation and sign-in dates | Create and maintain your account; sign-in; access recovery; transactional emails | Performance of a contract (art. 7, V · art. 6(1)(b)) |
| Optional profile answers: age ranges, nationalities, residence, household, languages, profession, education, work arrangement, goals, incomes and whether they continue after moving, savings, budget, preferences, weights and must-have conditions | Produce, at your request, comparisons, a personal ranking and an informational visa checklist | Performance of a contract (art. 7, V · art. 6(1)(b)). All answers are optional |
| Priorities such as proximity to hospitals, health services or accessibility (only a weight from 1 to 10, no reason) | Only the calculation of your ranking | Performance of a contract. We do not collect health data and infer no condition from these choices |
| Saved rankings, favourites and comparison scenarios | Store and show your results | Performance of a contract |
| Policy version read at sign-up and date | Evidence of the information provided | Exercise of rights / legitimate interest (art. 7, VI and IX · art. 6(1)(f)) |
| Minimal usage events (public page view, sign-up, profile completed, ranking generated, comparison, favourite) with a random analytics identifier not linked to the account, no IP and no profile answers | Measure audience and improve the product | Consent (art. 7, I · art. 6(1)(a); Portuguese Law 41/2004, art. 5). Can be withdrawn at any time |
| Server-side count of public page views, with no cookie, no identifier and no IP | Aggregated operational traffic statistics | Legitimate interest (art. 7, IX · art. 6(1)(f)). Stored records do not identify people |
| IP address, date and time of sign-up, sign-in and password reset | Retention of application access logs required by Brazil's Internet Civil Framework (Marco Civil, art. 15) and account security | Legal obligation (art. 7, II) · legitimate interest (art. 6(1)(f)) |
| Technical connection data in hosting and authentication provider logs; IP used in memory, hashed, to limit sign-in attempts | Security, abuse and fraud prevention | Legitimate interest (art. 7, IX · art. 6(1)(f)) |
| Google advertising cookies and identifiers, only on public pages and only after your consent | Show Google AdSense ads | Consent. Google acts as an independent controller of the data it collects |
4. What we never do
We do not sell, rent, export or pass profiles to advertisers or third parties for commercial purposes, not even with future consent.
Health or accessibility preferences never feed advertising, targeting, campaign emails, logs or metrics.
There are no ads or advertising pixels on sign-up, sign-in, profile, ranking, favourites or account pages.
The ranking is a calculation tool used at your request, with a public methodology. It is not a decision about you and does not indicate a chance of immigration approval. You may ask for an explanation of the criteria (LGPD, art. 20).
7. International transfers
Some vendors are based or run infrastructure outside your country (for example, in the United States). The database region is shown in section 1.
In Brazil, transfers follow LGPD art. 33 using the standard contractual clauses approved by the ANPD (Resolution CD/ANPD No. 19/2024) or another valid mechanism. In the European Economic Area, they follow GDPR chapter V (adequacy decision, such as the EU-US Data Privacy Framework when the vendor is certified, or standard contractual clauses). For Québec, we carry out a privacy impact assessment before communicating data outside the province.
8. How long we keep data
| Data | Period |
|---|---|
| Account, profile, incomes, criteria, rankings, favourites, scenarios and acceptance record | Until you delete the account. Deletion removes this data from the database immediately |
| Access logs (IP, date and time) | 6 months, as required by the Marco Civil. Kept for the legal period even after account deletion, unlinked from it, and only disclosed to authorities under a court order |
| Raw usage events | 30 days |
| Daily usage aggregates (no identifier) | Kept for statistics |
| Provider technical logs | According to each provider's cycle and applicable law |
| Backups | Expire within the retention cycle set for backups (at most 30 days). Deleted data is not restored for use |
9. Security and incidents
Measures in place: encrypted traffic (HTTPS); per-account data isolation enforced by the database itself (row level security); administrative keys only on the server; data minimisation; passwords never stored in plain text; logs without profile data.
If a security incident may cause significant risk or harm, we will notify the ANPD and affected people within 3 business days (Resolution CD/ANPD No. 15/2024), the competent European authority within 72 hours where the GDPR applies, and Canadian authorities where there is a real risk of significant harm.
10. Your rights and how to exercise them
You can: confirm whether we process your data and access it; correct it; request anonymisation, blocking or erasure; portability; information about sharing; withdraw consent; object to processing based on legitimate interest; and request review of automated decisions (LGPD, arts. 18 and 20; GDPR, arts. 15–22; equivalent rights in Canada and Québec).
In your account you can already export all your data as JSON, edit your profile and delete your account. For other requests, write to the privacy contact in section 1. We reply within 15 days (LGPD) or one month (GDPR), which may be extended where the law allows.
You may also complain to an authority: ANPD (Brazil), CNPD (Portugal) or another EU data protection authority, the Office of the Privacy Commissioner of Canada and the Commission d'accès à l'information du Québec.
11. Communications
We only send emails needed for the account (confirmation and recovery). Any other future communication will require specific opt-in, easy unsubscribe and no disclosure of the email list.
12. Changes to this policy
The version date appears at the top. Material changes will be announced in the account before they take effect. We keep the version read at sign-up.