Privacy Policy

1. Introduction and Commitment to Privacy

This Privacy Policy describes how the Moderatio Platform ("We", "Us", or "Operator"), operated by Moderatio Finance, collects, stores, uses, discloses, and protects your personal information ("User" or "You") in accordance with applicable data protection laws, including the General Data Protection Law (Lei Geral de Proteção de Dados - LGPD) and the general principles of GDPR.

The privacy and security of your financial and profile data is a core pillar of our philosophy. We do not sell your personal data to third parties, nor do we use it for targeted advertising. Our business model is solely based on voluntary paid subscriptions for premium features.

2. Data Collected and Purposes of Processing

To provide our financial management tools, we collect data directly or indirectly as detailed below:

• Registration Data: Full name, email address, encrypted password (or Google sign-in, including profile photo when provided), preferred language, and a timestamp of your acceptance of the Terms of Use and this Privacy Policy.
  Purpose: Account creation, service communications, secure authentication, and proof of legal consent (Performance of a Contract and Consent).
• Financial and Collaboration Data: Account names, balances, categories, transactions (amounts, dates, descriptions, and splits), installment debts, settlements between members, shared financial workspaces, invitations (invitee email and role), and workspace preferences.
  Purpose: Individual and shared financial management, dashboards, and permission control (Performance of a Contract).
• Subscription and Payment Data: Active plan details, subscription identifiers, payment status, and billing webhook events (sanitized payloads without card data). Sensitive payment data for web checkout is processed by Stripe; mobile subscriptions are processed by Google Play Billing and mobile subscription infrastructure. Card data is not stored on our servers.
  Purpose: Billing, premium plan limits, subscription reconciliation, and fraud prevention (Performance of a Contract and Legitimate Interest).
• Technical and Diagnostic Data: IP address, browser/OS, access logs, session/device identifiers, and error reports (e.g., via Sentry), excluding auth tokens and raw financial payloads from transmitted events.
  Purpose: Failure diagnosis, security, and performance (Legal Obligation and Legitimate Interest). We do not use marketing analytics tools in the current product version.

3. Legal Bases for Processing

We process personal data only when supported by explicit legal grounds:

1. Performance of a Contract: To manage your account, provide financial tools, and process payments.
2. Legitimate Interest: To improve our technical services, send product update communications, and protect our platform against security threats.
3. Compliance with a Legal Obligation: To maintain system access logs in accordance with applicable laws (such as the Brazilian Internet Act - Law No. 12,965/2014).
4. Consent: Explicitly collected for specific actions when not covered by the legal bases above.

4. Data Sharing with Third Parties

Moderatio does not sell your personal data. We share information strictly with third-party processors and service providers necessary for operating our platform:

• Stripe Inc.: To process payments, manage billing for Premium plans, and generate invoices on the web.
• Google Inc.: For OAuth sign-in (when selected) and, on the Android app distributed via Google Play, for subscription billing.
• Resend Inc.: For transactional email (welcome, invitations, password reset, and account confirmations).
• Functional Software Inc. (Sentry): For production error monitoring with minimized data and no auth credentials or full financial payloads.
• Hosting and Infrastructure Providers: Cloud database and compute services that store and process platform data.
• Public Authorities: Strictly when required by law or a valid, enforceable court order.

5. Storage, Retention, and Deletion of Data

Your data is stored on secure cloud servers, utilizing encryption in transit and at rest (SSL/TLS and database-level encryption).

Your financial and profile data will be retained as long as your user account is active on the Platform.

• Account Deletion: You may delete your account at any time in Settings (web and mobile app). Deletion removes personal data and financial records from primary databases irreversibly, with anonymization in shared workspaces where applicable.
• Retention Exceptions: We may retain access logs for the minimum legal period (e.g., 6 months under Brazilian law), billing records for tax obligations, and sanitized billing webhook events for the configured operational retention window before automatic purge.

6. Your Rights as a Data Subject

Under applicable regulations (such as Article 18 of the Brazilian LGPD), you have the right to request at any time:

• Confirmation of the processing of your personal data;
• Access to your stored personal data;
• Correction of incomplete, inaccurate, or outdated data;
• Deletion of data processed based on your consent;
• Revocation of consent previously granted;
• Information about public and private entities with which we have shared your data.

These rights can be exercised directly through the user settings panel or by emailing our support team at the address listed below.

7. Information Security

We employ appropriate technical and administrative measures to protect your data — including encryption in transit, password hashing, workspace-based access control, and infrastructure review. No online system is fully infallible; we recommend strong passwords and securing your devices.

8. Cookies and Local Storage

We use browser local storage (localStorage) for the following purposes:

• Essential: Authentication session (access token in memory) and interface preferences (language, active workspace). These are required for the app to function and cannot be disabled.
• Analytics and Diagnostics (Optional): When you consent, we initialize error-monitoring tools (Sentry) and, in future, usage analytics (PostHog) to understand how the app is used and detect issues. No financial data is sent to these tools.

When you first access the web app, a consent banner will ask you to accept or decline optional cookies. You can review or change your choice at any time through the app's privacy settings.

On the backend and server-side web rendering (SSR), error-monitoring remains active regardless of your consent, as it is required for platform security and stability.

9. Changes to this Policy

We may update this Privacy Policy from time to time. Significant changes will be notified via notices in the platform interface or sent directly to your registered email address. We encourage you to review this policy periodically to stay informed about our data practices.

10. Contact for Privacy Inquiries

If you have any questions about this Privacy Policy, our data practices, or wish to exercise your data subject rights, please email us at: contact@moderatiofinance.com.