Privacy Policy

1. Who is responsible for your data

The data controller is TeamInova Soluções em Sistemas Ltda., CNPJ 63.809.245/0001-84, based in Santa Cruz do Sul/RS, Brazil, which operates Come Ricordo.

For anything about personal data, including as the channel to our data protection officer (art. 41 of the LGPD), write to info@teaminova.com.

2. What data we handle

• Account: name, email, password (stored only as a hash, never as text), preferred language and theme, the confirmation of your email, and the record that you accepted these terms.
• What you write and upload: Bios, Memories, sections, dates, places, photos, videos, captions and earlier versions of your texts (so you can go back). This content may include information about other people, including people who have passed away and children. When you upload a photo or a video, we remove from the file the place where it was taken (GPS location) and the details that identify the device, such as its make, model and serial number. We keep the date it was taken, to help organise your photos.
• Voice recordings: if you use Dictate, the recording and the words written from it, kept with the Bio section or the Memory where they were made. Readers only hear a recording if you choose to show it. You can remove a recording at any time; the words stay.
• Writing together: the email of the people you invite, the drafts they write for your page (with their photos and recordings, while they wait for you to read them), the notices on the site and by email about those drafts, and the optional message you write when you discard a draft.
• Comments and replies: the comments you send on other people’s pages, or receive on yours, and the page author’s replies.
• Reports and suggested corrections: the reason and the words written; for a report, the email, if the person chose to give one; the account, if they were logged in (a suggested correction always needs one); and, for the hourly limit, the network (reports) or the account (suggestions), only as a scrambled form (hash), deleted after one hour.
• Access logs: IP address, date and time of each visit and the page requested, which the Brazilian Internet Civil Framework (Marco Civil da Internet, Lei 12.965/2014, art. 15) requires us to keep.

We do not use analytics, advertising or tracking tools, and we do not buy data from third parties. The site’s fonts are served by us, without calling outside services.

3. What we use it for, and on what legal basis

• Providing the service (art. 7, V, performance of a contract): creating and maintaining your account, storing and showing your content according to the visibility you choose, and sending account emails (email confirmation, password change, deletion notice).
• Security and abuse prevention (art. 7, IX, legitimate interest): protecting accounts, investigating misuse, keeping backups.
• Legal obligations (art. 7, II): keeping access logs and complying with court or authority orders.
• Voice dictation (art. 7, I, consent): only after you agree, before your first recording. To withdraw your consent, write to info@teaminova.com.

We do not sell or rent personal data, and we do not use it for advertising.

4. Who can see what you write

Each Bio and Memory has a visibility, which you choose and can change at any time:

• Private: only you can see it, and the people you invite to write with you.
• Anyone with the link: only people who receive the link. These pages ask search engines not to index them.
• Public: anyone, including search engines such as Google.

A page only becomes visible once you publish it. Photos and videos follow the page they appear on: they are only open while they appear on a page that is published and public; a recording, only when you choose to show it.

People who write with you read the page and its photos and write drafts beside it; they never change the page. The Come Ricordo team, to give support, sees account details (name, email, plan, dates) and usage counts (how many pages, photos and minutes of dictation, last login), never the content of your private pages.

5. Who we share it with

Only with those who need the data for the service to work, and only what is necessary:

• Hosting: Contabo, which provides the server Come Ricordo runs on (in the United States; see section 6).
• Sending emails: Titan, TeamInova’s email provider, which sends the account emails.
• Writing down dictation: a provider specialised in transcription, in the United States, which receives a recording only to turn it into text, when you use Dictate, and does not use it to train models.
• Backups: also kept on servers belonging to the team itself, in Brazil.
• Authorities: when the law or a court order requires it.

6. International transfer

Come Ricordo’s main server is in the United States, so your data is transferred outside Brazil (art. 33 of the LGPD). This transfer is made to perform the contract with you, with the safeguards set by the National Data Protection Authority (ANPD) (standard contractual clauses, Resolution CD/ANPD No. 19/2024). We plan to move the server to Brazil; this policy will be updated when that happens.

7. Cookies and data stored on your device

• Session: a cookie that keeps you signed in. Without it you cannot sign in to your account.
• Shared links: when you open a page you received by link, we keep that link’s key in a cookie for 90 days, so the page keeps opening without the full link.
• Preferences and drafts: your theme, language and texts not yet sent are kept in your browser, so nothing is lost if the connection drops. Drafts are deleted when you sign out. A recording that hasn’t been sent yet stays in your browser until it is sent, and is deleted when you log out.
• Installed app: if you install Come Ricordo on your phone, it stores only the app’s own files, never your pages or data.

We do not use advertising or third-party cookies.

8. How long we keep it

• Account and content: for as long as your account exists.
• Bios and Memories you delete: they stay in "Recently deleted" for 30 days, so you can recover them, and are then erased.
• Deleted account: everything goes offline immediately and is erased 30 days later, unless you sign in and choose "Keep my account" before then.
• Backups: what was erased may still exist in backups for up to 12 months, until they are replaced. They are used only to restore the service after a failure.
• Access logs: 6 months, as the Marco Civil da Internet requires.
• Drafts from people writing with you: what you take into your page becomes yours; photos and recordings you don't take are deleted when you finish with the draft. Drafts not yet sent are deleted if the person stops writing with you.
• Attempt counters: to limit logins, password-reset requests, sign-ups, uploads and books, we keep a scrambled form (hash) of the email, network or account, for one hour.
• Reports and suggested corrections: deleted 12 months after they are closed (once our team has decided, or the author has answered). A report about a page or comment we hid is kept for as long as it stays hidden.
• If the person who reported or suggested a correction deletes their account, the report or suggestion is no longer linked to the account: we keep only the reason, what was written and the outcome, for the same time.

9. Your rights

Under the LGPD (art. 18) you can ask for: confirmation that we handle your data, and access to it; correction; anonymisation, blocking or erasure of unnecessary data; portability; information about who we share it with; and erasure of data handled on the basis of your consent.

• In your account: you can correct your name and preferences on the Account page, edit or delete any Bio or Memory, download a copy of everything in your account under Account → Download my data, and delete your whole account under Account → Delete my account.
• If your account is suspended, ask by email at info@teaminova.com and we will send a download link to the account’s email address.
• By email: for any other request, write to info@teaminova.com. We reply within 15 days.

You can also complain to the National Data Protection Authority (ANPD), at gov.br/anpd.

10. Children and teenagers

Only people aged 18 or over can create an account.

A Memory may tell the life of a child, written by someone who raises them or is responsible for them. In that case, the writer is responsible for that content and must act in the child’s best interest (art. 14 of the LGPD). A page about a child is never Public: only Private or Anyone with the link. In a Bio this applies by itself while the date of birth says under 18, and stays until the writer unticks it, after the 18th birthday; in any Bio or Memory, the writer can mark the page as being about a child.

11. Other people in your content

Bios and Memories talk about other people. If you appear on someone else’s page and want to ask for a correction or removal, write to info@teaminova.com with the link to the page, or use Report under the page’s comments. A report is used only to look at that content, by our team; the author is not told who sent it.

When a page that is not public is reported, or a suggested correction reaches our team, we see only what was reported — the reported page, or only the comment or passage in question — and only to assess it.

12. Security

All traffic uses HTTPS. Passwords are stored only as a hash. Photos and videos from non-public pages are delivered only to people allowed to see them. Access to the servers is restricted to the team. We make backups every hour, kept in more than one place, and we test restoring them. If a security incident happens that could put you at risk, we will tell you and the ANPD.

13. Changes to this policy

When we change something important, we will let you know by email before the change takes effect. The date at the top shows the last update.