Version 2.0 — October 2026

Transparency First: We know that terms of use and privacy policies are often long and exhausting. That's why we wrote this document in a direct, clear, and transparent way, explaining exactly what the app does, how your information is protected, and what your global rights are. If you have any questions, our official contact channel is open at: oi.jeffmonteiro@gmail.com.

General Table of Contents

Part 1: Terms of Use

1. Data Controller Identification and Acceptance of Conditions

2. What Consigo Offers and Offline-First Architecture

3. Eligibility and Minimum Age

4. Account Registration, Credentials, and Security

5. The AI Coach Agent (Health Disclaimer and Crisis Hotlines)

6. Subscription Plans, Billing, and Cancellation (PRO v2)

7. User Content, Photos, and Shared Routines

8. Rules of Conduct and Acceptable Use

9. Intellectual Property and Limited License

10. Disclaimer of Warranties and Limitation of Liability

11. Suspension, Termination, and Self-Service Account Deletion

12. Governing Law, International Arbitration, and Dispute Resolution

13. Modifications to These Terms

Part 2: Global Privacy Policy

1. Data Controller, Data Protection Officer (DPO), and Contact

2. Core Principle: Minimization and Offline-First Operation

3. Personal Data Collected by Plan and Feature

4. Sensitive Personal Data and Emotional Signals

5. Purposes of Processing and Legal Bases (LGPD, GDPR, and Global Laws)

6. Access to Camera, Photo Library, and Image Synchronization

7. Artificial Intelligence, LLM Providers, and No-Training Clause

8. Data Sharing with Authorized Sub-processors

9. Integration with Routine Creators (Lead Machine)

10. International Data Transfers and Safeguards

11. Information Security and Encryption at Rest (Double Envelope)

12. Retention Periods, Data Purging, and Post-Cancellation Grace Period

13. Data Subject Rights and How to Exercise Them

14. Specific Provisions for the European Union and the United Kingdom (GDPR / UK GDPR)

15. Specific Provisions for the United States (CCPA / CPRA / State Laws)

16. Privacy and Protection of Minors

17. Security Incident Management

18. Changes to this Privacy Policy

Part 1 — Terms of Use

1. Data Controller Identification and Acceptance of Conditions

1.1. The Consigo application (also commercially referred to as "Hoje Eu Consigo" or "Consigo — Today I Can") is owned and individually operated by Jeff Monteiro, registered under Brazilian Individual Taxpayer Registry (CPF/ME) No. 214.402.918-02, domiciled in the City of São Paulo, State of São Paulo, Federative Republic of Brazil, hereinafter simply referred to as "Consigo", "we", "us", "our", or "Controller".

1.2. This agreement applies to any successors, assignees, or legal entities that may be formed or come to assume the operation, distribution, and ownership of Consigo's intellectual and operational assets in Brazil or internationally.

1.3. By downloading, installing, registering, or in any way using Consigo, you ("user" or "you") acknowledge that you have read, understood, and fully accepted these Terms of Use and the associated Privacy Policy. If you do not agree with any provision herein, you must not install or use the application.

2. What Consigo Offers and Offline-First Architecture

2.1. Consigo is a personal productivity and self-development platform focused on creating, maintaining, and tracking daily routines and habits. The ecosystem allows users to:

Create, manage, and complete predefined or personalized daily goals and habits;

Record progress through photos and generate celebration achievement cards with statistics and timestamps ("registration cards");

Track a timeline of evolution, consistency, and streaks;

Interact with the AI Coach Agent, receiving conversational support dedicated to routine discipline, organization, and motivation;

Import routines created by other users or publish your own routines for community sharing.

2.2. Offline-First Architecture: The application was built on the premise of on-device data sovereignty. By default, all routines, checklists, and records are created and processed locally on your device. Internet connectivity is utilized only for authentication, subscription verification, AI Coach Agent conversation processing, advertisements (in the free tier), and, for paid plan subscribers, cloud backup mirroring and multi-device synchronization.

3. Eligibility and Minimum Age

3.1. The application is intended for users who are at least 13 (thirteen) years of age.

3.2. If you are between 13 and 17 years of age (or the age of legal majority in your jurisdiction of residence), you represent and warrant that you are using the application with the prior assistance, supervision, and express consent of your parents or legal guardians, who agree to be bound by these Terms of Use.

3.3. Prohibition of Children Under 13: Creating an account or using Consigo by individuals under 13 years of age is strictly prohibited. Consigo does not knowingly collect personal data from children under this age. If an account belonging to a user under 13 is detected, the account and all associated data will be immediately and permanently purged from our systems.

4. Account Registration, Credentials, and Security

4.1. Basic offline usage of Consigo may occur without providing prior registration data. However, access to paid subscription tiers, multi-device purchase restoration, routine publishing, or cloud synchronization requires account registration via mobile phone number (authenticated via SMS one-time passcode - OTP) and/or email address.

4.2. You are solely responsible for the truthfulness, accuracy, and timeliness of the information provided, as well as for safeguarding your credentials and keeping your physical device protected against unauthorized access.

4.3. Any activity conducted under your authenticated account will be presumed to be your sole responsibility. In the event of suspected security compromise, credential theft, or unauthorized access, you must notify us immediately through our official support channels.

5. The AI Coach Agent (Health Disclaimer and Crisis Hotlines)

5.1. Consigo provides eligible subscribers with an intelligent conversational assistant known as the AI Coach Agent, powered by state-of-the-art artificial intelligence large language models. The AI Coach Agent is strictly intended as a supportive tool for self-discipline, daily routine organization, habit consistency tracking, and behavioral encouragement.

5.2. CRITICAL MEDICAL AND PSYCHOLOGICAL DISCLAIMER:

CONSIGO AND THE AI COACH AGENT DO NOT CONSTITUTE A MEDICAL DEVICE, HEALTHCARE SERVICE, TELEMEDICINE PLATFORM, THERAPEUTIC PRACTICE, OR PSYCHOLOGICAL/PSYCHIATRIC CLINICAL CARE.

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All interactions, responses, suggestions, and reflections generated by the AI Coach Agent are for motivational and informational habit-building purposes only. The AI Coach Agent DOES NOT DIAGNOSE, DOES NOT TREAT, DOES NOT PREVENT, AND DOES NOT CURE ANY CLINICAL CONDITION, MENTAL DISORDER, OR PHYSICAL ILLNESS.

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The application IS NEVER A SUBSTITUTE for clinical advice, consultation, diagnosis, or treatment by certified physicians, psychiatrists, psychologists, or other licensed healthcare providers. Never disregard, delay, or alter professional medical treatment on account of any interaction with or advice from the AI Coach Agent.

5.3. CRISIS PROTOCOL AND LIFE SUPPORT HOTLINES:

Consigo IS NOT AN EMERGENCY SERVICE and does not provide human-monitored real-time support for psychological emergencies, acute distress, or self-harm ideation.

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If you or someone you know is experiencing acute emotional crisis, severe depression, or thoughts of suicide or self-harm, PLEASE SEEK IMMEDIATE HELP through dedicated crisis hotlines:

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In the United States and Canada: Call or text 988 (Suicide & Crisis Lifeline, available 24/7, free and confidential) or visit 988lifeline.org.

In Brazil: Call 188 for the Centro de Valorização da Vida (CVV) (toll-free, confidential, 24/7) or visit www.cvv.org.br. In medical emergencies, call 192 (SAMU).

In the European Union and the United Kingdom: Call the European emergency number 112 or contact your local national mental health helpline.

All Other Countries: Immediately contact your local hospital emergency room or national suicide prevention crisis center.

5.4. Nature of AI-Generated Content: You acknowledge that generative artificial intelligence systems are probabilistic and may occasionally produce inaccurate, misleading, or unexpected output (hallucinations). Consigo does not warrant the absolute accuracy of the AI Coach Agent's responses and disclaims all liability for decisions made based on such conversations.

6. Subscription Plans, Billing, and Cancellation (PRO v2)

6.1. Consigo operates under a freemium subscription model with tiered features (Plan Matrix):

Free Plan: Access to core local habit tracking and challenge recording, supported by third-party in-app advertisements. Does not include cloud backup, cross-device sync, or the AI Coach Agent.

PRO Plan: Complete removal of advertisements, encrypted cloud backup and mirroring of habit data and history with continuous multi-device sync, plus access to the AI Coach Agent with daily AI processing credits and streak protection shields as defined in the app.

ULTRA Plan: All PRO features with significantly expanded capacities: higher daily AI credits, increased monthly streak shields, and an extended 90-day history sync window.

CREATOR Plan: All ULTRA features plus professional routine editing, official community publishing tools, and access to the "Lead Machine" integration feature via secure webhooks, subject to the Creator Terms of Service.

6.2. Billing and Store Purchases: Paid subscriptions are sold exclusively via in-app purchases processed by Apple Inc. (App Store) or Google LLC (Google Play Store). Applicable prices, billing periods (monthly or annual), and any free trials are displayed within the app prior to purchase confirmation.

6.3. Auto-Renewal and Cancellation: Subscriptions renew automatically for the same duration unless canceled at least 24 hours prior to the end of the current billing cycle. Cancellations must be managed directly in your Apple ID or Google Play account subscription settings. Merely uninstalling the app does not cancel your subscription or stop recurring charges.

6.4. Refunds: Refund policies are exclusively governed by the policies of the respective app stores (Apple App Store or Google Play Store). Applicable statutory cancellation rights (such as the 7-day withdrawal period under Article 49 of the Brazilian Consumer Defense Code for Brazilian transactions) must be exercised directly through the respective platform store.

7. User Content, Photos, and Shared Routines

7.1. Photos and Records: Habit registration photos belong to you and are stored primarily on your device. For paid plan subscribers, images are synchronized to our cloud storage strictly to enable your private history restoration and backup.

7.2. External Sharing: Sharing achievement cards to third-party social media or messaging platforms (Instagram, WhatsApp, TikTok, etc.) is done solely on your own initiative outside of Consigo. Consigo assumes no liability for content shared externally.

7.3. Public Routine Publishing: When publishing a routine to Consigo for public or follower sharing, you grant Consigo a worldwide, perpetual, non-exclusive, royalty-free, sublicensable license to host, display, transmit, and allow other users to import such routine within the platform.

7.4. You represent and warrant that you hold all necessary intellectual property and personality rights to content included in your published routines, assuming full liability for any third-party copyright or trademark infringement.

8. Rules of Conduct and Acceptable Use

8.1. When using Consigo, you agree that you will not:

Reverse engineer, decompile, disassemble, or attempt to extract the source code of the app;

Interfere with or disrupt the integrity or performance of Consigo's servers, databases, or infrastructure;

Use automated bots, spiders, or scrapers to extract data from the platform or bypass rate limits;

Upload, transmit, or share content containing nudity, pornography, child sexual abuse material, hate speech, defamation, promotion of illegal acts, or encouragement of self-harm;

Submit malicious prompts (jailbreaks or injection attacks) to the AI Coach Agent attempting to extract underlying models, prompt instructions, or third-party data;

Resell, sublicense, lease, or commercially exploit the app without prior written authorization.

9. Intellectual Property and Limited License

9.1. Consigo grants you a personal, revocable, non-exclusive, non-transferable, limited license to use the app on compatible mobile devices in accordance with these Terms.

9.2. All intellectual property rights in and to Consigo — including trademarks, logos, slogans ("Consigo", "Hoje eu consigo", "Today I Can"), UI designs, illustrations, source code, and software architecture — are the exclusive property of Jeff Monteiro or its licensors, protected by Brazilian laws and international intellectual property treaties.

10. Disclaimer of Warranties and Limitation of Liability

10.1. "AS IS" and "AS AVAILABLE": Consigo is provided on an "as is" and "as available" basis without warranties of any kind, whether express, implied, or statutory, including warranties of merchantability, fitness for a particular purpose, or uninterrupted availability.

10.2. Limitation of Liability: To the maximum extent permitted by applicable law, Consigo and its operators shall not be liable for:

Local data loss resulting from device hardware failure, loss, theft, factory resets, or accidental deletion by the user;

Personal wellness, physical fitness, mental health, or productivity results;

Temporary downtime of third-party infrastructure (Google Cloud/Firebase, OpenAI, app stores, or internet providers);

Indirect, incidental, special, punitive, or consequential damages.

10.3. Aggregate Liability Cap: Where liability cannot be fully disclaimed under applicable law, Consigo's total aggregate liability for all claims arising out of or related to these Terms or the app shall be strictly capped at the total amount actually paid by you to Consigo in the twelve (12) months preceding the event giving rise to the claim.

11. Suspension, Termination, and Self-Service Account Deletion

11.1. Consigo reserves the right to suspend or terminate your account access without prior notice or refund in the event of actual or suspected violation of these Terms or applicable laws.

11.2. Self-Service Account Deletion (Apple Guideline 5.1.1(v) & Google Play):

You have the full right to delete your account and all associated data at any time directly within the app under Account > Delete Account.

The process requires two-factor security confirmation via OTP to prevent accidental deletion;

Confirmation triggers the immediate and irreversible deletion of your profile, habit history, cloud sync records, hosted backup photos, and published routines.

12. Governing Law, International Arbitration, and Dispute Resolution

12.1. Users Resident in Brazil:

For users residing in Brazil, these Terms are governed by the laws of the Federative Republic of Brazil, specifically the Consumer Defense Code (Law No. 8,078/1990) and the Civil Rights Framework for the Internet (Law No. 12,965/2014). The courts of the Judicial District of São Paulo, State of São Paulo, Brazil, shall have exclusive jurisdiction.

12.2. Users Resident in the United States of America (Binding Arbitration and Class Action Waiver):

If you reside in the United States, you and Consigo agree that any dispute, claim, or controversy arising out of or relating to these Terms or the app shall be resolved exclusively through BINDING INDIVIDUAL ARBITRATION administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules, and you waive any right to a trial by jury.

CLASS ACTION WAIVER: YOU AGREE THAT ANY CLAIMS SHALL BE BROUGHT IN AN INDIVIDUAL CAPACITY ONLY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, CONSOLIDATED, OR REPRESENTATIVE PROCEEDING.

12.3. Users Resident in the European Union, the United Kingdom, and Other Countries:

If you reside in the European Union or the United Kingdom, nothing in these Terms will deprive you of the statutory consumer protections afforded by the mandatory laws of your country of habitual residence, and you may bring legal proceedings in your local competent courts.

13. Modifications to These Terms

13.1. We may update these Terms from time to time to reflect product enhancements, security updates, or regulatory changes.

13.2. When material changes occur, you will be notified via prominent in-app notices or a terms re-acceptance prompt. Continued use of Consigo following the effective date of updated Terms constitutes your full acceptance.

Part 2 — Global Privacy Policy

This Privacy Policy complies with the Brazilian General Data Protection Law (LGPD — Law No. 13,709/2018), the European Union General Data Protection Regulation (GDPR — Regulation (EU) 2016/679), the UK GDPR, U.S. state privacy laws (including the California Consumer Privacy Act — CCPA/CPRA), and Apple App Store and Google Play Store policies.

1. Data Controller, Data Protection Officer (DPO), and Contact

1.1. The Data Controller responsible for processing your personal data within Consigo is:

Data Controller: Jeff Monteiro (Individual Taxpayer Registry CPF No. 214.402.918-02)

Location: São Paulo, SP, Brazil

Data Protection Officer (DPO) and Privacy Contact Email: `oi.jeffmonteiro@gmail.com`

1.2. To exercise your privacy rights or submit any inquiry regarding this Policy, please email our DPO at the address above. Requests are handled within applicable statutory timeframes.

2. Core Principle: Minimization and Offline-First Operation

2.1. Consigo is engineered according to Privacy by Design and Privacy by Default standards.

Users without cloud backup (Free Plan): All habit data, completion history, notes, and photos remain saved exclusively in your device's local memory and encrypted database. This data is never sent to, read by, or mirrored on our cloud servers.

Users with active sync (Paid Plans PRO, ULTRA, CREATOR): Data uploaded to our Firebase (Google Cloud) infrastructure acts strictly as an encrypted backup mirror to enable multi-device continuity, history recovery, and account safety.

3. Personal Data Collected by Plan and Feature

Data collection is strictly limited to the features you subscribe to and use:

3.1. Technical and Usage Data Collected Across All Plans

Pseudonymous Installation Identifier: A locally generated identifier (`anonymousCid`) used to track usage metrics without linking to your real-world identity;

Product Telemetry and Performance Diagnostics: App version, device model, OS version (iOS/Android), system language, and aggregated feature metrics (e.g., number of habits completed, streak milestones, navigation flows). Handled via Mixpanel in a de-identified format (never containing message text or photos).

3.2. Additional Data Processed in the Free Plan

Advertising Identifiers: Mobile advertising ID (IDFA on Apple or GAID on Android), IP address, and ad interaction metrics, processed by Google AdMob subject to user consent and operating system privacy controls (such as App Tracking Transparency on iOS).

3.3. Additional Data Processed in Paid Plans (PRO, ULTRA, CREATOR)

Profile Information: Display name, username, verified mobile phone number (via SMS OTP), verified email address (via email OTP), and profile avatar picture;

Habit Data: Habit titles, scheduling frequencies, custom templates, completion history logs, and streak defense shields;

Photo Records: Photos taken during habit completions that the user chooses to store, synced to private cloud storage;

AI Coach Agent Interactions: Chat messages exchanged with the assistant, contextual habit signals, lifestyle onboarding quiz answers, conversational memory items, and feedback ratings.

4. Sensitive Personal Data and Emotional Signals

4.1. Recognition of Sensitive Data: In conversational interactions with the AI Coach Agent, users may voluntarily share reflections regarding emotional states, mood fluctuations, anxiety, personal stress, and lifestyle hurdles. Consigo treats such information with heightened security safeguards as SENSITIVE PERSONAL DATA (under Article 11 of LGPD and Article 9 of GDPR).

4.2. Strict Purpose: This information is processed exclusively to provide personalized, supportive, and context-aware conversational feedback to assist in daily habit discipline.

4.3. In-Chat Fact Erasure: Users may instruct the AI Coach Agent directly within the chat to erase specific recorded memories or facts (via the `forgetUserFact` command), triggering immediate deletion of that memory.

5. Purposes of Processing and Legal Bases (LGPD, GDPR, and Global Laws)

In accordance with Article 9 of LGPD and Article 13 of GDPR, the table below maps our processing activities to their respective legal bases:

6. Access to Camera, Photo Library, and Image Synchronization

6.1. Consigo requests camera and photo library access solely to allow voluntary capture and attachment of photos to habit completion cards.

6.2. Access is requested via operating system dialogs and can be adjusted or revoked at any time in device privacy settings.

6.3. Photo Policies:

Captured photos are never scanned for facial recognition or used to train computer vision models;

In paid plans with backup enabled, photos are synced to Google Cloud Storage under dedicated user directories (`{uid}/history`) protected by owner-only access rules;

In the free plan, photos never leave the local storage of the device.

7. Artificial Intelligence, LLM Providers, and No-Training Clause

7.1. To deliver the conversational AI Coach Agent experience, messages are securely proxied via backend functions to leading Large Language Model (LLM) providers: OpenAI, LLC and Groq, Inc.

7.2. EXPRESS COMMITMENT: NO TRAINING ON USER DATA:

Our enterprise API agreements with our AI infrastructure providers strictly stipulate that:

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1. Prompts, conversational text, habit reflections, and user inputs ARE NOT USED by OpenAI, Groq, or any third party to train, retrain, fine-tune, or improve general or commercial foundation models;

2. Transmitted data is processed ephemerally solely to generate the immediate text completion returned to the user;

3. Consigo never sells or monetizes user conversation data.

7.3. Internal Product Quality Reviews (Wave 3) and Right to Opt-Out:

To monitor technical accuracy and prevent hallucinations, Consigo's engineering team may perform internal reviews on de-identified AI interactions;

Mandatory De-identification: Texts are permanently separated from user identity and assigned a non-reversible pseudonym (`R-<hash>`), automatically stripping names, emails, and phone numbers. Photos are NEVER included in internal quality reviews;

Every internal review generates an audit log entry;

Instant Revocation in App: You can disable internal AI review sharing at any time in the app under Account > Data Sharing. Toggling this off immediately stops future internal review access on our servers.

8. Data Sharing with Authorized Sub-processors

We never sell or rent your personal information. Data is shared only with technical service providers acting as sub-processors under strict contractual instructions:

9. Integration with Routine Creators (Lead Machine)

9.1. If you choose to import a habit routine published by a CREATOR plan user, the creator may require contact information in exchange for access ("Lead Machine").

9.2. Lead Machine Rules:

Explicit Prior Consent: Any routine requesting data presents an upfront screen specifying the exact data fields (e.g., Name, Phone, Email, progress milestones) and the creator's identity;

Legal Roles: Consigo acts solely as a secure transmission conduit. Once data is transferred to the creator's secure HTTPS webhook, the creator becomes an Independent Data Controller governed by their own privacy policy;

Creators are contractually bound by Consigo's Creator Terms of Service.

10. International Data Transfers and Safeguards

10.1. Because our cloud infrastructure providers are based globally, personal data may be transferred to and stored on servers outside your home country, primarily in the United States.

10.2. Transfer Safeguards:

For transfers from Brazil: We implement safeguards under LGPD Article 33 and ANPD Resolution CD/ANPD No. 19/2024, utilizing Standard Contractual Clauses;

For transfers from the EU/UK: Transfers are governed by the European Commission's Standard Contractual Clauses (SCCs) and the EU-U.S. Data Privacy Framework (where applicable).

11. Information Security and Encryption at Rest (Double Envelope)

Consigo uses robust technical safeguards to protect your personal data:

11.1. On-Device Double Envelope Encryption at Rest:

Sensitive account information (profile, habits, completion logs, AI conversations, memories, and emotional signals) is encrypted on your device using AES-256-GCM with Authenticated Associated Data (AAD). The primary Data Encryption Key (DEK) is protected by device hardware keystores (Apple Keychain / Android Keystore).

11.2. Cloud Mirror Encryption:

For paid tier cloud backups, data rests in Firestore within encrypted envelopes. Server-side administrators cannot read conversations or emotional reflections in plaintext without user keys.

11.3. Encryption in Transit:

All data in transit between your mobile device, our cloud services, and AI providers is encrypted using TLS 1.3 or TLS 1.2.

11.4. Log Hygiene (Wave 1):

Cloud logging policies actively exclude user conversational content. No chat text or intimate reflections are written to persistent technical server logs.

12. Retention Periods, Data Purging, and Post-Cancellation Grace Period

Data is retained only as long as necessary to serve its legitimate operational purposes:

13. Data Subject Rights and How to Exercise Them

13.1. Regardless of your location, you enjoy comprehensive data privacy rights (LGPD Art. 18 and GDPR Arts. 15–22):

Access and Confirmation: Confirm processing and obtain copies of your data;

Correction: Rectify incomplete, inaccurate, or outdated data;

Erasure and Anonymization: Request deletion or anonymization of unnecessary data;

Withdrawal of Consent: Revoke previously granted consents without affecting prior lawful processing;

Objection: Object to processing based on legitimate interests;

Portability: Request your profile data in a structured, machine-readable format.

13.2. Instant Self-Service in the App:

Account Deletion: Go to Account > Delete Account in the app to instantly delete profile, credentials, history, photos, and cloud data;

Opt-Out of AI Quality Review: Go to Account > Data Sharing to toggle off de-identified internal review;

Profile Editing: Edit name, username, phone, and email anytime in profile settings;

In-Chat Fact Erasure: Instruct the AI Coach Agent directly to forget specific memories.

13.3. Formal Inquiries via DPO:

For requests that cannot be resolved in-app, contact our Data Protection Officer at: oi.jeffmonteiro@gmail.com. Legitimate requests are answered within 15 business days (or applicable statutory deadlines).

14. Specific Provisions for the European Union and the United Kingdom (GDPR / UK GDPR)

If you are located in the European Economic Area (EEA) or the United Kingdom:

14.1. Legal Bases: We process your personal data only under recognized GDPR Article 6 bases (contract performance, consent, legal obligation, or non-overriding legitimate interests) and Article 9 for sensitive data.

14.2. Automated Decisions and Profiling: The AI Coach Agent provides conversational habit guidance. It DOES NOT MAKE AUTOMATED DECISIONS that produce legal effects or significantly affect you under GDPR Article 22.

14.3. Right to Lodge a Complaint: You have the right to lodge a complaint with your local EU Member State Data Protection Authority (DPA) or the UK Information Commissioner's Office (ICO).

15. Specific Provisions for the United States (CCPA / CPRA / State Laws)

For residents of California and states with similar privacy frameworks:

15.1. Notice of No Sale or Sharing:

CONSIGO DOES NOT SELL AND HAS NEVER SOLD YOUR PERSONAL INFORMATION.

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We do not share personal information with third parties for cross-context behavioral advertising without your explicit system-level consent.

15.2. Your Rights under CCPA/CPRA:

California residents have the right to:

Know what categories of personal information are collected and the business purposes;

Request deletion of their personal information (Right to Delete);

Request correction of inaccurate personal information (Right to Correct);

Non-discrimination: You will never receive discriminatory treatment or diminished service quality for exercising your CCPA rights.

15.3. Submit CCPA requests by emailing oi.jeffmonteiro@gmail.com with the subject line "CCPA Request".

16. Privacy and Protection of Minors

16.1. Consigo is intended for individuals aged 13 and older. We do not knowingly collect personal information from children under 13, in compliance with the U.S. Children's Online Privacy Protection Act (COPPA), GDPR Article 8, and LGPD Article 14.

16.2. If a parent or guardian discovers that a child under 13 has provided personal data to Consigo, please notify us immediately at oi.jeffmonteiro@gmail.com so we can delete such data permanently.

17. Security Incident Management

17.1. We maintain technical monitoring to protect user data. In the unlikely event of a security incident presenting significant risk to user rights and freedoms:

We will promptly notify relevant data protection supervisory authorities (such as Brazil's ANPD and applicable international authorities);

Impacted users will be transparently notified with guidance on the nature of the event, affected data, and remedial protective actions taken.

18. Changes to this Privacy Policy

18.1. This Privacy Policy may be updated periodically to reflect service improvements, security enhancements, or regulatory developments.

18.2. Material updates will be communicated prominently within the app. The date of the most recent revision will always appear at the top of this document.

Consigo — Today I can.

Jeff Monteiro © 2026. All rights reserved.