Privacy Policy

Last updated: June 29, 2026

This document is pending legal review. It is a faithful translation of Calen's Portuguese-language Privacy Policy, produced ahead of the U.S. pilot so the App Store review and early users have an English reference. It has not yet been reviewed by a lawyer qualified in U.S. law, and several sections below are written around the Brazilian LGPD (data-protection bases, retention rules, international-transfer framing, the ANPD as regulator) that will need to be revisited for international users — each is marked [LEGAL REVIEW] inline. Nothing below has been rewritten to invent a U.S.-law equivalent (e.g. no CCPA/CPRA language has been added); that decision is left to counsel.

1. Who we are

Calen is a personal finance organization platform operated by VINICIUS FREIRE BISPO SERVIÇOS ADMINISTRATIVOS LTDA ("Calen", "we"), controller of the personal data processed under this policy and the General Data Protection Law (LGPD, Law No. 13,709/2018). This policy describes how we collect, use, share, store, and protect your data in the mobile apps, the web app, and the usecalen.com.br website.

2. Data we collect

3. What we don't do

• We don't store your bank passwords. Open Finance authorization is processed by Pluggy and confirmed through your own bank's channels — your banking credentials never pass through Calen's servers.
• We don't sell your data and don't disclose it to third parties for marketing.
• We don't use your financial data for advertising.
• We don't move money. Access to bank data is strictly read-only.
• We don't use in-app behavioral analytics — no tool records your screens, taps, or usage habits inside the app.
• We don't collect biometric data.
• We don't receive your credit card data for the subscription — payment is processed entirely by Apple or Google, depending on the platform used.

4. Legal bases (LGPD)

• Contract performance (Art. 7, V): processing registration, financial, and subscription data to provide Calen's features, including automated processing (categorization, projections) and the AI assistant.
• Legal obligation (Art. 7, II): retention of tax and accounting records.
• Legitimate interest (Art. 7, IX): security, fraud prevention, error diagnostics, and service improvement — always respecting your expectations and your right to object.

5. Sharing with third parties

We only share data with vendors that make the product possible, under processing and confidentiality agreements:

• Supabase — database and authentication. Servers in the São Paulo (Brazil) region. Receives the data described in Section 2.
• Pluggy — Open Finance connectivity, regulated by Central Bank rules. Processes your banking credentials and delivers us the financial data of connected accounts.
• RevenueCat (USA) — subscription management. Receives a user identifier, an App Store or Google Play transaction identifier, and plan status/period. Does not receive bank or card data.
• Apple (App Store) and Google (Google Play) — process subscription payments. Your card data stays exclusively with the Store used, under its own privacy policy.
• Anthropic (USA) — provider of the language models behind the Calen Assistant. When you use the assistant, your question and the financial data needed to answer it (transactions, balances, categories, goals) are sent for processing. Your national ID, email, passwords, and account or card numbers are never sent. Anthropic does not use data sent via API to train its models.
• Railway (USA) — hosting for Calen's application server, with encryption in transit.
• Resend — transactional email delivery (receives your name and email).
• Sentry (USA) — server error monitoring. Receives technical failure-diagnostic data; does not receive your financial data as a stated purpose.
• PostHog (European Union) — visit metrics on the website only, usecalen.com.br (the landing page), with forms masked. The app does not use PostHog.
• Logo CDNs (e.g., public favicon and market-data services) — to show your bank's or an asset's logo, the app queries these services only with the institution's or ticker's public identifier. No personal data is sent.

In the event of a merger, acquisition, or sale of assets, data may be transferred to the successor entity, with the protections of this policy preserved.

6. International transfers

Some vendors (RevenueCat, Anthropic, Railway, Sentry, Resend, Apple, and Google) process data outside Brazil, mainly in the United States. These transfers follow LGPD Article 33, backed by data processing agreements (DPAs) with protective clauses and technical measures such as encryption in transit and at rest. You can request information about the safeguards for each transfer through our contact channel.

7. Security

• Connections are always encrypted (HTTPS/TLS).
• Data at rest is encrypted (AES-256) in the database, hosted in Brazil (São Paulo).
• Per-user isolation with Row Level Security in the database.
• Restricted and logged internal access.

Incidents: we maintain an incident-response plan under LGPD Article 48 and ANPD Resolution CD/ANPD No. 15/2024. Incidents with material risk will be reported to the ANPD and affected data subjects within 3 business days, with a description of what happened, the data affected, risks, and mitigation measures.

8. Data retention

• We keep your data while your account is active.
• After account closure, data is deleted within 90 days.
• Tax and billing records may be retained for up to 5 years, under legal obligation (Art. 16, I, LGPD).
• Anonymized data, which does not identify you, may be kept for statistics (Art. 12, LGPD).
• You can also use "Delete all data" in the app (Profile) to reset transactions, accounts, goals, and investments while keeping the account.

9. Your rights (LGPD)

As a data subject, you can, at any time and free of charge:

• Confirm that processing exists and access your data;
• Correct incomplete, inaccurate, or outdated data;
• Request anonymization, blocking, or deletion of unnecessary or excessive data;
• Request the portability of your data;
• Revoke consent and object to processing based on legitimate interest;
• Request review of automated decisions (Art. 20) — for example, manually recategorize any transaction that was categorized automatically;
• Be informed about who we share your data with.

To exercise any right, write to contato@usecalen.com.br — we respond within 15 business days. You can also delete your account directly through the app.

10. AI and automated processing

Calen uses deterministic algorithms for automatic transaction categorization, recurrence detection, and cash-flow projections — you can review and correct any result manually in the app. The Calen Assistant uses Anthropic's language models (see Sections 5 and 6): your financial data is sent only when you use the assistant, and only to the extent necessary to answer your question; conversation history stays in Calen and can be deleted by you. All automated results are informational and do not constitute financial advice.

11. Cookies

The app does not use cookies. On the website and the web app, we use only essential authentication cookies (to keep your session) and, on the website, the visit measurement described in Section 5. We do not use marketing tracking cookies.

12. Children and teenagers

Calen is intended for people 18 and older. We do not intentionally collect data from minors; if we identify a minor's account, it will be closed and the data deleted.

13. Changes to this policy

Material changes will be communicated by email or notice on the Platform at least 15 days in advance.

14. Data Protection Officer (DPO)

Calen's Data Protection Officer is Vinicius Freire, who can be reached at contato@usecalen.com.br. If you believe your rights have been violated, you can also file a complaint with Brazil's National Data Protection Authority (ANPD).