legal · version 2026-07-23-v1-minuta
Privacy Policy
DRAFT UNDER LEGAL REVIEW. This policy describes the real product and the real data flows, and is being reviewed by a qualified lawyer before the final version.
Which law this document is built on. Pínax is operated from Brazil, and this policy is written against the Brazilian data protection act (LGPD, Law 13.709/2018) — the legal bases, the supervisory authority (ANPD) and the deadlines below are the ones that law defines. This is an English translation of the Portuguese original, offered so you can read what governs you. It is not a GDPR or CCPA statement. If you are outside Brazil and need provisions under your own law, talk to us before signing up.
Legal bases, by purpose
· Account, authentication and billing — performance of a contract. · Invoicing and accounting records — legal obligation. · Fraud prevention, security and logs — legitimate interest, with a right to object. · Strictly necessary cookies (session, CSRF, authentication) — legitimate interest. · Product news by email and optional cookies — consent, specific and revocable. · Use of your own AI key or agent (BYOK) — performance of a contract, with the reinforced transparency described below. · Suggestions based on your usage (PPI) — legitimate interest, with an easy opt-out under Settings → Privacy.
Consent is reserved for what is genuinely optional: withdrawing it never affects the existence of your account.
BYOK and international transfer
When you connect your own key or agent (Anthropic, OpenAI, Google), the content sent for generation travels to the servers of the provider you chose, mostly outside Brazil. Pínax orchestrates that flow, it does not hide it: each provider keeps its own compliance mechanisms (DPA and contractual clauses), and the AI relationship is yours with that provider. Your key is encrypted, non-extractable, and deleted immediately on disconnection or account deletion — zero retention.
Third-party data in your uploads
If you attach documents containing personal data of third parties — your own clients, for instance — you are the controller of that data and Pínax acts as processor, handling it under your instruction. The matching declaration of responsibility is in the Terms of Use.
Suggestions based on your usage
To suggest themes, styles, narratives and brands aligned with what your workspace already uses, we compute a count over the themes, styles, narratives and brands your own decks already use — we never read the text or the content of your decks for this. It is not a new, separate record: it is a computed view over data you already have and already control, and it disappears on its own if you delete the decks. It is always a dismissable suggestion: we never apply a theme or a brand without your confirmation, in the editor or through your AI agent.
You can switch it off any time under Settings → Privacy, without affecting your decks. The same counts also feed, in aggregate and anonymously — never per individual workspace — the decision of which themes and features to build next; that aggregate view is internal and never identifies your workspace.
Cookies
Today the platform uses strictly necessary cookies only: session, security, language preference. We do not use analytics or marketing cookies. If we ever do, they will only run with your prior consent, category by category, through the preferences panel in the footer.
Retention
· Account data and content: until you delete the account, with a 30-day grace window before definitive erasure. · Tax and payment records: 5 years, a legal obligation, even after deletion. · Consent records: kept as documentary proof, with the IP reduced to a hash — minimisation even in the proof. · BYOK keys: zero retention on disconnection. · Suggestion profile: not a new retention — it is computed over what your own decks already use, switches off any time, and goes away with the decks.
Security incidents
Security incidents posing relevant risk to the data subject are reported to the Brazilian authority (ANPD) within 3 business days, and to those affected, through a documented process.
Your rights
Confirmation of processing, access, correction, anonymisation or erasure, portability, information about sharing, and withdrawal of consent. All of it is exercisable under Settings → Privacy inside the platform: see what we keep, export your data, review consents, and request account deletion. The .pnx package and the exports — PDF, PPTX, DOCX — already deliver portability of your content in an open format.
Who to write to
The data protection officer is the founder, Joel Ferreira, at privacidade@pinax.space — a monitored channel, answered within 15 days. Requests received and answered are logged for audit.
Age
Pínax is a professional tool and requires you to be 18 or older, or legally emancipated, to create an account — the declaration is part of sign-up.
Changes
Material changes to this policy require a new acceptance before use continues. Your history of accepted versions lives under Settings → Privacy.