PRIVACY POLICY

1. Introduction

CapsHold Corp. ("we", "our", "company") is committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy describes how we collect, use, store, and protect your information when you use our platform.

By using our services, you agree to the collection and use of information in accordance with this policy. This policy complies with the General Data Protection Law (LGPD - Law No. 13.709/2018) and other applicable data protection laws.

2. Information We Collect

2.1. Information Provided by You

We collect the following information when you use our services:

• Account Data: Name, email address, and other information provided during registration
• Payment Information: Credit card data processed through secure third-party providers (Stripe)
• Capsule Content: Texts, images, videos, audio, and documents you choose to store
• Metadata: Creation date, scheduled opening date, file sizes, file types
• Recipient Information: Name and email of the capsule recipient (when applicable)

2.2. Automatically Collected Information

We automatically collect certain information when you use our platform:

• Usage Data: Pages visited, time spent, actions taken
• Technical Information: IP address, browser type, operating system, device used
• Cookies and Similar Technologies: We use cookies to improve your experience and analyze platform usage
• Logs: Activity records, errors, and security events

3. How We Use Your Information

We use your information for the following purposes:

• Service Delivery: Create and manage your account, process payments, store and protect your content
• Security: Detect and prevent fraud, abuse, and suspicious activities
• Communication: Send notifications about your account, service updates, and important information
• Improvements: Analyze platform usage to improve our services and user experience
• Support: Respond to your requests and provide technical support
• Legal Compliance: Comply with legal and regulatory obligations

4. Information Sharing

We do not sell, rent, or trade your personal information. We share information only in the following circumstances:

4.1. Service Providers

We may share information with third-party service providers who help us operate our platform, including:

• Payment providers (Stripe) to process transactions
• Hosting and cloud storage providers (AWS S3)
• Authentication services (Clerk)
• Analytics and monitoring services

These providers are contractually obligated to protect your information and use it only for specified purposes.

4.2. Legal Requirements

We may disclose information if required by law, court order, or legal process, or to protect our rights, property, or safety, or that of our users.

4.3. Capsule Content

Important:: Content stored in your capsules is encrypted and is not accessible by our team or third parties, except in the legal circumstances mentioned above. Not even we have access to the decrypted content of capsules.

5. Data Security

We implement robust technical and organizational security measures to protect your information:

• Encryption: We use end-to-end encryption (AES-256) to protect capsule content
• Secure Storage: Data stored on secure servers with redundancy and regular backups
• Restricted Access: Data access limited only to authorized employees with need-to-know
• Monitoring: Continuous monitoring of suspicious activities and unauthorized access attempts
• Security Updates: Regular system maintenance and application of security patches
• Content Moderation: Automated content analysis to detect prohibited or illegal material

Although we implement rigorous security measures, no system is 100% secure. You are also responsible for maintaining the security of your access credentials and rescue code.

6. Your Rights under LGPD

You have the following rights regarding your personal data:

• Access: Request access to your personal data we hold
• Correction: Request correction of incomplete, inaccurate, or outdated data
• Deletion: Request deletion of unnecessary data or data processed in non-compliance with LGPD
• Portability: Request portability of your data to another service provider
• Revocation of Consent: Revoke your consent at any time
• Objection: Object to data processing under certain circumstances
• Information: Obtain information about public and private entities with which we share data

To exercise these rights, please contact us at: [email protected]

7. Cookies and Similar Technologies

We use cookies and similar technologies to improve your experience, analyze platform usage, and personalize content. The types of cookies we use include:

• Essential Cookies: Necessary for basic platform functionality
• Performance Cookies: Collect information about how you use the platform
• Functionality Cookies: Remember your preferences and settings

You can manage your cookie preferences through your browser settings. Note that disabling cookies may affect platform functionality.

8. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes described in this policy, unless a longer retention period is required or permitted by law:

• Account Data: Retained while your account is active and for up to 2 years after closure
• Capsule Content: Retained until the scheduled opening date and for up to 30 days after opening
• Payment Data: Retained as required by tax and regulatory laws
• Logs and Metadata: Retained for up to 1 year for security and compliance purposes

9. International Data Transfer

Some of our service providers may be located outside Brazil. By using our services, you consent to the transfer of your information to these countries. We ensure that such transfers are made in compliance with LGPD and that adequate protection measures are implemented.

10. Protection of Minors

Our services are intended for users aged 18 or older. We do not intentionally collect personal information from minors. If we become aware that we have collected information from a minor without proper consent, we will take steps to delete such information immediately.

11. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of significant changes through:

• Platform notification
• Email to the address associated with your account
• Update of the "Last updated" date at the top of this page

We recommend that you review this policy periodically to stay informed about how we protect your information.

12. Contact and Data Protection Officer

If you have questions, concerns, or requests related to this Privacy Policy or the processing of your personal data, please contact us:

• Privacy Email: [email protected]
• General Email: [email protected]
• Data Protection Officer (DPO): [email protected]

You also have the right to file a complaint with the National Data Protection Authority (ANPD) if you believe that the processing of your personal data violates applicable legislation.