Privacy Policy

What stays on your iPhone, what reaches us and the rights you have wherever you live.

Last updated: October 6, 2026

Draft for legal review. This Policy describes what Pulogo does today, checked against the App's code on October 6, 2026, and has not yet been reviewed by a lawyer. Pulogo is not on the App Store yet; the final text may change before launch.

This Privacy Policy explains how HayatoLab Tecnologia LTDA (CNPJ 48.551.929/0001-35), a company registered in Brazil (“Pulogo”, “we”), processes personal data when you use the Pulogo app for iPhone (the “App”) and the pulogo.app website (the “Site”). We are the controller of the data we process.

Pulogo was built to work on your iPhone. Today the App has no account, no login and no Pulogo server: what you save is stored on the device, and we have no way to see it.

In short

What you save (links, screenshots, text and your decisions) is stored on your iPhone. The App has no account and no Pulogo server, so we don't see any of it.
Your screenshots are read right here on your iPhone: text, category and Catch-up are all handled on the device. The App only reads Screenshots, and only after you give access.
To show a link preview, your iPhone opens that link, just like Safari would. The link's site sees that request; Pulogo doesn't.
The Instagram and TikTok import reads, on your iPhone, the official file you downloaded from those platforms. No login and no password.
No ads. What you save is never used for advertising, and we never sell or rent data.
On the Site, analytics only run with your consent (Google Analytics), and the email you leave on the waitlist is stored in HubSpot.

1. What stays on your iPhone

The App stores everything on the device itself, in a local database inside the App's space on the iPhone (shared only between the App and Pulogo's share extension). None of it is sent to Pulogo servers, because the App has no server:

What you save. Links, text and images you send through the Share menu or paste into the App's field, with the title, category, preview and processing stage of each one.
Your decisions. Do, Keep or Let go, what's in To do, what became Done, your lists and collections, Catch-up and the recap.
Screenshot text. The text in each screenshot is read by Apple's text recognition (Vision), which runs on the device. The category is chosen by rules that run inside the App.
Light copies of screenshots. The App keeps a light copy of each screenshot that comes into Pulogo, so the save stays readable even if the original leaves your camera roll.
Onboarding answers and preferences, such as what you usually save, the reminder time and the daily Catch-up dose.
Reminders. These are local notifications, scheduled by the iPhone itself.

Because this data never reaches us, we cannot access, export or delete it for you. You control everything in the App (section 10), and deleting the App removes from the iPhone what it stored.

If iCloud backup or computer backup is turned on, iOS may include this data in the device backup. That backup is made and stored by Apple (or on your computer), under Apple's rules, and we have no access to it.

2. What the App accesses on your iPhone

Photos, Screenshots only. If you allow access to Photos, the App reads only screenshots, never camera photos or videos. It counts the screenshots, reads their text on the device and, every day, looks for new screenshots, including in a background refresh that iOS schedules when it chooses. With limited access, the App only sees the screenshots you picked.
Clear roll. The App only removes screenshots from your camera roll when you ask, and only those you've already decided on and that already have a light copy in Pulogo. iOS itself asks for your confirmation before deleting. Removing a screenshot from your camera roll does not delete the save in Pulogo.
Notifications. If you allow them, the App schedules on the iPhone the daily triage reminder and the heads-up for when the export file should be ready.
Share menu. Pulogo's extension receives only what you choose to share with it (a link, a text or an image) and writes it to the App's space on the device.

You can revoke access to Photos and notifications in iOS Settings whenever you want. The rest of the App keeps working.

3. When the App uses the internet

Link previews. When you save a link (a Reel, a TikTok, a recipe on a website), the iPhone uses LinkPresentation, an Apple feature, to open that address and read the title and preview image, just like Safari would. The request goes from your iPhone straight to the link's site (Instagram, TikTok or another), which receives what any visit sends, such as your IP address and the requested address, and handles it under its own privacy policy. The request does not go through any Pulogo server.
Instagram and TikTok import. The App does not log into your account and never asks for a login or password. You request the official export file from Instagram or TikTok and open that file in Pulogo. On the iPhone, the App reads only the saved posts (Instagram) and favorites (TikTok); likes and history are left out. The file is not sent anywhere. Afterwards, previews of the imported posts are fetched like those of any link, as described above.
App Store. Downloads, updates and purchases go through Apple, under Apple's privacy policy.

Today the App has no account, login, sync between devices, usage analytics SDK, ads SDK or third-party crash reporting. If that changes, for example to validate the Pro subscription or measure App usage, we will update this Policy first, saying what is sent, to whom and on what legal basis. The content of what you save will remain outside any analytics.

4. What reaches us

Through the App

Nothing you save. Not the links, not the screenshots, not their text, not your decisions.
Purchases. When Pulogo Pro is on sale, Apple sells and bills. Apple gives us transaction data, such as the product, dates, the storefront country and whether there was a refund. We do not receive your name, your email or card details.
Apple diagnostics. If you turned on the option to share analytics with developers in iOS Settings, Apple may pass us crash reports and aggregated usage numbers, without identifying you.

Through the Site

What is described in section 5.

Support

If you write to us, we keep your message, your email and whatever else you decide to include.

We do not collect your contacts, your location, health data or the advertising identifier (IDFA), and we do not ask for permission to track you.

5. The website

Analytics (only with your consent): if you tap “Accept” on the cookie banner, the Site loads Google Analytics 4, which sets cookies (such as _ga) to count visits and see which pages and buttons are used. Google receives your IP address and browser data for this. If you decline or ignore the banner, Google Analytics is not even loaded.
Visit source (only with your consent): with the same consent, the Site stores in your browser's local storage where your first and last visits came from (for example, the campaign or site that brought you), so we know which channels work.
Waitlist: if you leave your email to hear when Pulogo arrives on the App Store or to join the beta, we store the email in HubSpot along with your language, the page and button used, the source information above and a tag marking the request as Pulogo's, to send you what you asked for.
Creator program (when open): if you apply, we store the data you send (name, email, social profiles, audience size and your answers) in HubSpot to review the application.
Free tools: the Site's tools run in your browser. What you type or paste into them is not sent to us.
Hosting: the Site is hosted by Vercel, which processes technical logs (IP address, browser, pages accessed) for security and operation.

Your cookie choice is stored in the browser for 12 months, and you can change it whenever you want in “Cookie preferences”, in the footer of every page; declining deletes the analytics cookies. You can also block or delete cookies and local storage in your browser settings; the Site works the same either way. Every email we send has an unsubscribe link.

6. What we use data for and on what legal basis

Making the App work on your iPhone: this happens on the device and involves no data processing by us.
Sending the emails you requested through the Site (waitlist, beta invite): your consent, which you can withdraw whenever you want.
Analytics and visit-source cookies on the Site: your consent, given on the cookie banner and revocable at any time.
Fulfilling the Pulogo Pro purchase and handling refund requests: performance of the contract with you.
Answering support and understanding failures through Apple's aggregated reports: our legitimate interest in making a product that works, balanced against your rights.
Complying with the law (taxes, accounting, responses to authorities, handling your rights requests): legal obligation.

What you save is never used for advertising, to build advertising profiles or to train AI models, and we do not make decisions about you based solely on automated processing.

8. International transfers

We are based in Brazil and our providers process data mainly in the United States, so Site and support data may be transferred to other countries. We protect these transfers with the safeguards required by the law that applies to you, such as the standard contractual clauses approved by the ANPD (Resolution CD/ANPD No. 19/2024), the European Commission's Standard Contractual Clauses (and the EU-U.S. Data Privacy Framework when the provider is certified) and the UK International Data Transfer Addendum. You can request a copy of these safeguards at privacy@pulogo.app.

9. How long data is kept

What's on your iPhone: until you delete it in the App or delete the App. Pulogo deletes nothing on its own, not by age, not by quota, not when a subscription ends.
Waitlist and creator applications: until you unsubscribe or request deletion, and at most 24 months after our last contact.
Site analytics cookies: your choice lasts 12 months; Google Analytics cookies last up to 2 years, per Google, and are deleted if you decline.
Purchase records received from Apple: for the period required by tax and accounting law (generally 5 years in Brazil).
Support emails: up to 3 years after the conversation ends, in case the same problem comes back.

10. Your choices and controls

Let go archives, it doesn't delete. The save goes to Let go and comes back whenever you want.
Delete permanently: in Settings → Let go, swipe the item and confirm. It's the only way to delete a save inside the App, and it only happens with your confirmation.
Delete everything: deleting the App removes from the iPhone everything it stored.
Revoke permissions: Photos and notifications can be turned off at any time in iOS Settings.
Site: change your choice in “Cookie preferences”, block cookies in your browser and unsubscribe from any email through the link it contains.
Anything else: write to privacy@pulogo.app.

11. Your rights

Depending on where you live (see your country's section below), you can ask us to: confirm whether we process your data and give you access to it; correct it; delete it; export it in a portable format; restrict or object to certain processing; withdraw consent; and not be discriminated against for exercising these rights.

These requests apply to the data we hold (Site, waitlist, support and purchase records). What's on your iPhone never reached us: you access, correct and delete it directly in the App.

Send requests to privacy@pulogo.app from the email linked to the data (for example, the waitlist one), so we can confirm it's you. We respond within the period your law sets and, whenever possible, within 15 days at most. Exercising your rights is free. If we cannot fully comply, for example because the law requires us to keep a record, we will explain why.

You may also appoint an agent to make the request on your behalf; we may ask for proof of that authorization.

12. Children and teenagers

Pulogo is not directed at children under 13 and we do not knowingly collect their data. If the law of your country requires an older age to consent to data processing on your own, anyone below that age needs the authorization of a parent or guardian. If you believe a child under 13 has left data on the Site, write to privacy@pulogo.app and we will delete it.

13. Security

On the iPhone, the App's data stays in the App's protected space, with iOS data protection and encryption. What reaches us through the Site is encrypted in transit (TLS) and at rest by our providers, and access is restricted to those who need it.

No system is completely secure. If a security incident could pose a risk to your rights, we will notify you and the competent authorities, as the law requires.

14. Changes to this Policy

When we change how we process data, we will update this page and the date at the top. For material changes, such as starting to send any App data to a server, we will notify you in the App before the change takes effect and, where the law requires it, ask for your consent.

15. Contact

HayatoLab Tecnologia LTDA · CNPJ 48.551.929/0001-35 (Pulogo), Brazil. Controller of the personal data described in this Policy.

Registered office: Alameda Rio Negro, 503, Sala 2020, Alphaville Centro Industrial e Empresarial, Barueri, SP, CEP 06454-000, Brazil

Privacy requests and data protection officer: privacy@pulogo.app

General support: hello@pulogo.app

16. Your rights by country

The rights and protections above apply to everyone. The laws below add specific rights, contacts and authorities depending on where you live.

Brazil

Law: General Personal Data Protection Law (Law 13.709/2018, “LGPD”). HayatoLab Tecnologia LTDA is the controller.
Legal bases: consent (art. 7, I), compliance with a legal obligation (art. 7, II), performance of a contract (art. 7, V) and legitimate interest (art. 7, IX), as described in section 6.
Your rights (art. 18): confirmation that processing exists; access; correction of incomplete, inaccurate or outdated data; anonymization, blocking or deletion of unnecessary or excessive data; portability; deletion of data processed with consent; information about the entities we share data with; information about the possibility of not consenting and its consequences; withdrawal of consent; and review of automated decisions (art. 20).
Data protection officer (encarregado): contact at privacy@pulogo.app.
Timeframe: confirmation or access in simplified form immediately, and a full statement within 15 days of your request.
Teenagers: data of people aged 13 to 17 is processed in their best interest, as required by art. 14 of the LGPD.
Security incidents: if an incident could cause you significant risk or harm, we notify the ANPD and the affected data subjects within 3 business days of becoming aware of it, as required by art. 48 of the LGPD and Resolution CD/ANPD No. 15/2024.
Complaints: you can petition the National Data Protection Authority (ANPD) at gov.br/anpd.

European Union, EEA and Switzerland

Law: General Data Protection Regulation (EU) 2016/679 (“GDPR”) and, in Switzerland, the Federal Act on Data Protection (FADP).
Legal bases: consent (art. 6(1)(a)), contract (art. 6(1)(b)), legal obligation (art. 6(1)(c)) and legitimate interests (art. 6(1)(f)), as described in section 6.
Your rights: access (art. 15), rectification (art. 16), erasure (art. 17), restriction (art. 18), portability (art. 20), objection, including to processing based on legitimate interests (art. 21), and withdrawal of consent at any time, without affecting prior processing.
Timeframe: we respond within one month, extendable by two more months for complex requests; we will let you know if that's the case.
Digital age of consent: between 13 and 16, depending on the country; below it, parental consent is required.
Transfers: see section 8 (Standard Contractual Clauses and EU-U.S. Data Privacy Framework).
Complaints: you can complain to the data protection authority of the country where you live or work (list at edpb.europa.eu) or, in Switzerland, to the FDPIC (edoeb.admin.ch).

United Kingdom

Law: UK GDPR and Data Protection Act 2018. The legal bases and rights are the same as for the European Union above.
Transfers: protected by the UK International Data Transfer Addendum or the UK Extension to the EU-U.S. Data Privacy Framework.
Complaints: Information Commissioner’s Office, ico.org.uk, phone 0303 123 1113.

United States

California (CCPA/CPRA)

Categories collected in the last 12 months: identifiers (waitlist email, cookie identifiers and IP address on the Site); commercial information (purchase records received from Apple); internet activity (Site usage, only with consent); and approximate geolocation from IP address (country or region only). We do not collect the content of what you save in the App. Sources: you, your browser and Apple. Purposes and recipients: as described in sections 6 and 7; disclosed to service providers for business purposes only.
Sensitive personal information: we do not use or disclose sensitive information to infer characteristics about you.
No sale or sharing: we do not sell personal information or share it for cross-context behavioral advertising, and we have not done so in the last 12 months. We have no knowledge of selling or sharing the data of consumers under 16. We honor Global Privacy Control signals as an opt-out request, even if there is nothing to opt out of.
Your rights: to know and access, delete, correct, limit the use of sensitive information, opt out of sale or sharing, and not be discriminated against. Use privacy@pulogo.app; we confirm receipt within 10 business days and respond within 45 days (extendable once by another 45).
Retention: see section 9.

Other states

Residents of Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, Virginia and other states with comprehensive privacy laws have similar rights: to confirm and access, correct, delete, obtain a portable copy, and opt out of targeted advertising, sale and profiling (which we don't do).
Appeals: if we deny your request, you can appeal by replying to our decision at privacy@pulogo.app. We respond to appeals within 45 days (60 days in Colorado). If you disagree with the outcome, you can contact your state's Attorney General.

Children

We comply with the Children’s Online Privacy Protection Act (COPPA): the Service is not directed at children under 13.

Canada

Law: Personal Information Protection and Electronic Documents Act (PIPEDA) and, in Québec, the Act respecting the protection of personal information in the private sector (Loi sur la protection des renseignements personnels dans le secteur privé, as amended by Law 25).
Your rights: access, correction, withdrawal of consent and, in Québec, portability and information about automated decisions.
Person in charge of the protection of personal information: contact at privacy@pulogo.app.
Site and support data may be stored and processed outside Canada (see section 8), where it may be accessible to authorities under local law.
Complaints: Office of the Privacy Commissioner of Canada (priv.gc.ca) or, in Québec, the Commission d’accès à l’information (cai.gouv.qc.ca).

Mexico

Law: Ley Federal de Protección de Datos Personales en Posesión de los Particulares (LFPDPPP, 2025).
ARCO rights: you can access, rectify, cancel or object to the processing of your data and withdraw consent by writing to privacy@pulogo.app with your name, the email linked to the data, a description of the request and any supporting documents. We respond within 20 business days and carry out the request within 15 business days after that.
Transfers: transfers to our service providers (section 7) do not require your consent because they are necessary to provide the Service.
Complaints: you can contact the Mexican data protection authority if you believe your rights have been violated.

Japan

Law: Act on the Protection of Personal Information (個人情報保護法, APPI).
Transfers abroad: Site and support data is processed by providers in the United States (section 7). The United States has no general federal data protection law equivalent to the APPI, but each provider is contractually bound to take measures equivalent to those the APPI requires, and we monitor them.
Security measures: we have data handling rules, restricted access and technical measures such as encryption and access control (section 13).
Your rights: you can request disclosure (including of records of provision to third parties), correction, addition or deletion, and suspension of use or of provision to third parties, by writing to privacy@pulogo.app.
Complaints: Personal Information Protection Commission (ppc.go.jp).

India

Law: Digital Personal Data Protection Act, 2023 (DPDP Act) and its rules, as they come into force.
Your rights: to obtain a summary of your data and its processing, to correct, complete, update and erase it, to nominate another person to exercise your rights in case of death or incapacity, and to have your grievances addressed.
Grievance officer: contact at privacy@pulogo.app. We respond within the period set by the rules and within 30 days at most.
Complaints: after using our grievance channel, you can approach the Data Protection Board of India.

Other countries

If you live elsewhere, you have at least the rights described in section 11 and any additional rights your local law guarantees. Write to privacy@pulogo.app and we'll help you exercise them and point you to the authority you can complain to.