Privacy Policy
Last updated: October 20, 2026 · Version: 2.19
YOLKI is a longevity and well-being app for dogs and cats, operated by Coflint OÜ, headquartered in Tallinn, Estonia. Coflint OÜ ("Coflint", "we") is the controller of Yolki Pet and processes your personal data in compliance with the General Data Protection Regulation of the European Union (GDPR), with the Brazilian General Data Protection Law (LGPD, Law 13.709/2018) and other applicable laws. This Policy applies both to the yolki.pet website (waitlist, newsletter, quiz, and corporate forms) and to the Yolki Pet app.
We collect account data, data about your pet, the content you send us, your location (with your permission) and usage data, in order to deliver veterinary teleguidance, the AI assistant, the quiz and gamification.
AI-personalised content is optional: you authorise it (or not) through a specific checkbox at sign-up, separate from your acceptance of this Policy, and you may change your mind at any time. To generate guidance and content, we send the AI provider data from your profile and from your pet, together with the text you write — we do not send photos of your pet to the AI; only the vaccination card page, when you ask us to read it. Your content is not used to train third-party models.
YOLKI has a free plan and paid features, and displays no advertising.
You may delete your account and your data inside the app at any time, and exercise all of your rights under the LGPD — including objecting to processing we carry out on the basis of legitimate interest.
1. Who is responsible for your data
The controller of your data is Coflint OÜ. It is Coflint OÜ that decides how and why your data is processed in YOLKI.
- Legal name: Coflint OÜ (a company incorporated in Estonia)
- Registry code (registrikood): 17294431
- Registered office: Sepapaja tn 6, 15551 Tallinn, Harju maakond, Estonia
- Website: https://yolki.pet
- Contact/support: [email protected]
Coflint OÜ is an Estonian company (European Union) and is the technology platform behind YOLKI. We have no company, branch or Brazilian tax registration (CNPJ) in Brazil — we simply make the app available to the Brazilian public. Because we process data of people located in Brazil, Coflint OÜ is, for the purposes of Brazilian law, the controller of your personal data, and we comply with the LGPD as well as with the applicable European rules.
Even though we are based in Estonia, we maintain a Portuguese-language contact channel for you and for the Brazilian Data Protection Authority (ANPD): our Data Protection Officer (section 19). That is the channel through which you exercise your rights, without having to contact Estonia.
Some services — such as teleguidance — are provided by independent partners, as explained in section 8.
2. About this document
This Policy took effect on the effective date set out below and applies as worded in the version indicated at the top. Whenever there is a relevant change, we publish a new version and update the last-updated date. The effective date marks when this Policy first became binding; the last-updated date indicates when this wording was published.
- Effective date (first version): July 21, 2026
- Last updated: October 20, 2026
- Version: 2.19
3. Who and what this applies to
This Policy applies to the YOLKI app made available to the public in Brazil, and to the yolki.pet website (waitlist, newsletter, quiz, and corporate forms).
Although the company has no establishment in Brazil, the LGPD applies because we offer the service to people located in Brazil. We process your data in accordance with:
- the GDPR — the General Data Protection Regulation of the European Union (Regulation (EU) 2016/679), which applies to us as a controller established in the European Union;
- the LGPD — the Brazilian General Data Protection Law (Law 13.709/2018); and
- the CDC — the Brazilian Consumer Protection Code, in our consumer relationship with you.
Quick definitions. Personal data — information that identifies you or can identify you. Data subject — you. Processing — any operation carried out with your data. Controller — the party that decides on the processing (Coflint OÜ). Processor/sub-processor — the party that processes data on behalf of the controller (our service providers).
Information about your pet, on its own, is not personal data — an animal holds no rights under the LGPD. However, because that information is linked to your account, we treat it with the same care we give to your personal data.
4. You must be 18 or older
YOLKI is only for people aged 18 or over. It is not a service for children or adolescents.
At sign-up, you confirm your age by ticking a self-declaration checkbox ("I am 18 years of age or older...").
If we identify that a user is under 18, we may suspend or close the account and delete the data.
5. How you accept this Policy
At the end of the sign-up flow, we present two separate checkboxes. Neither of them is pre-ticked — the choice is yours.
- Acceptance (mandatory): by ticking it, you declare that you are 18 or older and that you have read and accept the Terms of Use and this Privacy Policy (a "clickwrap" model: the informed click counts as acceptance). Without it, YOLKI cannot be used.
- AI-personalised content (optional): a checkbox of its own — "I want personalised content created with artificial intelligence" — through which you authorise us to send your data and your pet's data to an AI provider in order to personalise content and to use the assistant (section 9). Accepting this Policy does not mean authorising the AI: these are separate choices, and you can use YOLKI without ticking the second one.
You may sign in using Google or Apple social login. In that case, we receive the basic data those services share (such as name and email), according to the permissions you authorise.
6. What data we collect
We collect only what is necessary for the app to work and to give you good guidance.
- Sign-up and account data: name, email, phone number (when you provide it), the data from social login (Google/Apple) and your profile photo, when you upload one. The veterinarian who handles your consultation sees this photo while the consultation is booked or in progress. Your Google account photo is shown only to you, in the app.
- Profile — optional fields: gender and date of birth. You may choose "Prefer not to say" and use the app normally; if provided, this data helps personalise content.
- Your pet's data: for example, species, breed, age, weight, whether the pet is neutered, whether it is vaccinated, and the health and routine information you provide.
- Content you send: the text sent to the AI assistant, the pet photos you share during teleguidance with the veterinarian, the photos you attach to the reason for the consultation (up to 3 per consultation) and the documents you keep in your pet's Documents — photos of the vaccination card and photos or PDFs of tests and reports. Photos attached to the reason for the consultation go to the veterinarian who handles that consultation and are also kept in your pet's Documents. Documents are visible to the tutors linked to the pet and are not shared with the veterinarian: they only see the photos attached to the consultation they handle. Pet photos and documents are not sent to the AI assistant; the vaccination card page is only sent to the AI provider when you ask us to read it (section 9). The text you write when requesting a consultation — the reason, the symptoms and how long it has been going on — is saved even before you finish the request, so you can pick up where you left off, including on another device, and so we can improve the service.
- Voice and audio: when you use voice dictation to describe the reason for the consultation, and during video teleguidance, whose audio may be transcribed to support the consultation. See section 9-A.
- Location: with your permission, we collect your device's location, including precise location, to personalise content and recommendations for you and your pet. From it, we may derive your approximate address (country, state, city and neighbourhood). You grant and revoke this permission in your device settings, whenever you wish. If you grant the "Always" permission, location may also be collected while the app is in the background; that permission is optional, and refusing it does not prevent you from using YOLKI.
- Usage, device and diagnostic data: device identifiers, device type, operating system, logs, in-app interactions, performance data and error and crash records. To understand how the app is used and to fix failures, we use an analytics tool that may record your navigation across the app's screens — see section 18.
- Data generated by the features: PetMatch quiz results, gamification progress, history of teleguidance sessions and of conversations with the assistant.
We do not collect your credit card data. See section 12.
7. Why we use your data (purposes and legal bases)
Each use of your data has a clear purpose and a legal basis under the LGPD (article 7).
- Creating and maintaining your account and enabling login — performance of a contract.
- Offering veterinary teleguidance with independent partner veterinarians and clinics — performance of a contract.
- Generating personalised content and educational guidance with AI (the assistant and in-app content) — consent, given through the specific checkbox at sign-up and revocable at any time (section 9).
- Transcribing your speech and the audio of the teleguidance session, in order to make the consultation possible — performance of a contract.
- Running the PetMatch quiz and gamified education, and personalising app features — performance of a contract and, as regards recommendations and improvements, legitimate interest.
- Using your location to personalise content and recommendations — consent, given by you through the operating system permission, and revocable at any time.
- Measuring app usage, fixing errors and improving the experience, including by recording navigation across screens — legitimate interest; measurement is on by default, and you can turn it off in the app (section 18).
- Recording some usage sessions, with the screen masked — consent, requested in the app and revocable at any time (section 18).
- Ensuring security and preventing fraud and abuse — legitimate interest.
- Complying with legal and regulatory obligations — compliance with a legal obligation.
When we process your data on the basis of legitimate interest, you may object to that processing at any time through our Data Protection Officer (section 19). We will review your request in accordance with the LGPD (article 18, paragraph 2).
8. Veterinary teleguidance: how it works
Video teleguidance is provided by independent partner veterinarians and clinics, registered with the CRMV (the Brazilian regional veterinary council), and not by Coflint. Coflint provides the technology platform; the video call runs on the infrastructure of a third-party provider.
- At the time of the consultation, you are told which professional or clinic you will be speaking to, and their respective professional registration.
- Teleguidance is not emergency care and does not replace an in-person veterinary consultation. In an emergency or where there is immediate risk to your pet's life, seek in-person veterinary care immediately.
- The teleguidance conversation does not carry the professional secrecy that applies to the human doctor-patient relationship.
Who processes which data. As a matter of data protection, the clinical data you share during the consultation — what you report about your pet's health, and the professional's assessment and guidance — is processed by the veterinarian or the clinic as an independent controller, because the clinical decision is theirs, in the exercise of their profession. Requests concerning that clinical data may be addressed to the professional; requests concerning the remaining app data, to Coflint (section 19).
This does not affect your consumer rights. Towards you, Coflint is answerable for the service it offers on its platform, under the Brazilian Consumer Protection Code. The division set out above concerns who processes each piece of data, and is not a disclaimer of liability.
In short: the veterinarian decides and is answerable for the clinical guidance and for the clinical data; Coflint is answerable for the platform. Your consumer rights remain intact.
9. Artificial intelligence: what it does with your data
You authorise it beforehand — and you may change your mind. Your data is used by the assistant and by AI-personalised content only with your explicit authorisation, given through the specific, optional checkbox at sign-up ("I want personalised content created with artificial intelligence"), separate from your acceptance of this Policy. Before your first conversation with the assistant, we repeat that notice in the chat itself. You may refuse or revoke the authorisation at any time in the app settings. Without authorisation, none of your data is sent to the AI provider for these purposes: the assistant is unavailable, educational content is displayed in a generic version (without personalisation) and YOLKI's other features continue to work normally. The teleguidance summary, described below, is part of the veterinary service and follows its own rule.
What we send. With your authorisation, we send the AI provider: data from your profile — an internal account identifier, your name and, where you provide them, age, gender and approximate location (such as city and neighbourhood) —, structured data about your pet (for example, species, breed, age, weight, whether it is neutered, whether it is vaccinated) and the text you write. We do not send photos of your pet or your documents to the AI assistant. We apply the principle of minimisation. If this changes, we will update this Policy and ask for your authorisation beforehand.
What the AI does: it generates the app's educational content — part of what you see in YOLKI, such as the Discoveries, is created with artificial intelligence, personalised where you authorise it —, replies in the assistant, helps organise your pet's information and supports customer service.
Ancillary services. To suggest relevant content and places, the system queries external services, which receive only what is necessary for each query. Discoveries draw on open-access scientific articles from Europe PMC (a public database run by EMBL-EBI): the query carries only the species, the topic and, where available, the life stage — never your name, your pet's name or your location —, and each Discovery shows the source it used. For nearby places, Google Maps and OpenStreetMap/Nominatim (converting coordinates into an approximate address) receive only your city or region.
What the AI does not do: it does not diagnose your animal, does not prescribe treatment or medication, does not replace a veterinarian and does not take decisions affecting your interests. AI-generated content may contain inaccuracies — confirm important information with a veterinarian. You can report an inappropriate reply or piece of content directly in the app.
Teleguidance summary. When you have a video teleguidance consultation, the consultation transcript (section 9-A) is sent to the AI provider to generate the consultation summary — the one you receive in the app and the record kept by the veterinarian. This is part of the teleguidance service and happens for every completed consultation, regardless of the sign-up authorisation described above. The summary supports the record of the guidance given; the assessment and the guidance remain the veterinarian's (section 8).
Reading the vaccination card. When you use “Scan booklet” with your device online, each photographed page is sent to the AI provider to identify the vaccines, dates, weight and neutering recorded on it — and you check and correct everything before saving. We send only the page image, reduced to the size needed for reading, and your pet's species: not your name, e-mail or account identifier. Of the result, only what you confirm is saved. This transfer is part of the scanning feature you trigger, regardless of the sign-up authorisation described above. Without a connection, the reading is done on the device itself and no image leaves it; and you can always enter the data by hand, without scanning.
How we contract the provider. Processing uses OpenAI's AI models offered by Microsoft through the Azure OpenAI service, running in the Sweden region (European Union) — see section 13. We contract the provider on terms that do not allow your content to be used to train third-party models. To detect and prevent abuse, Microsoft may retain requests and responses for up to 30 days, also within the European Union.
In short: apart from the teleguidance summary and the vaccination card reading, which happen when you use those features, the AI only receives your data if you authorise it. It is educational and guidance support — never a substitute for a professional — and you can switch it off whenever you want.
9-A. Voice, audio and transcription
YOLKI uses your voice in two situations, and neither of them serves to identify you by your voice.
- Voice dictation. When you describe the reason for the consultation by speaking, we use your device's native speech recognition service. In that operation, the audio may be processed on servers of Apple Inc. (iOS) or Google LLC (Android), which act as processors exclusively to convert your speech into text, subject to those companies' privacy policies.
- Video teleguidance. The audio of the consultation may be transcribed, to support the consultation and to record the guidance given. The transcript is used to generate, with AI, the consultation summary (section 9).
We do not perform speaker recognition. We do not extract features of your voice to identify or authenticate you. For that reason, this processing does not, in itself, constitute sensitive biometric data under article 5, II, of the LGPD. Even so, we apply enhanced security measures to this content.
10. Who we share your data with
We share your data only with those who are necessary for the service to work.
- Partner veterinarians and clinics (independent) — they receive the data necessary for the consultation and act as independent controllers of the clinical data generated in the teleguidance session.
- Processors and sub-processors — technology providers that process data on our behalf and under our instructions (section 11).
- App stores — Apple and Google, if and when there is a purchase inside the app (section 12).
- Authorities — where required by law, court order or regulation.
We do not sell your personal data.
11. Processors and sub-processors we use
We rely on technology providers to operate YOLKI:
- Authentication, notifications and remote configuration: Google, through Firebase (Firebase Auth, Cloud Messaging, Remote Config). These are global Google services, operated from the United States.
- File storage: Amazon Web Services (AWS S3), with storage in Brazil — including your pet's documents and the photos attached to the reason for the consultation (section 6).
- App backend and database: Railway, the application infrastructure provider on which the YOLKI backend runs, together with the database that holds your account details, your pet's profile and your usage history.
- Database backups: Railway, through its object storage service (Railway Buckets), which runs on Tigris Data's infrastructure. It holds the continuous backups of the app database — with the same content: your account details, your pet's profile and your usage history — so that we can restore it in case of failure. Storage is in the Amsterdam region, Netherlands (European Union).
- Third-party AI models: Microsoft, through the Azure OpenAI service, with processing in Sweden (European Union) — including the teleguidance transcript, to generate the consultation summary, and the reading of vaccination card pages (section 9).
- Sources and maps in content generation: Europe PMC (EMBL-EBI — open-access scientific articles), queried for Discoveries without any personal data; Google (Google Maps — nearby places) and OpenStreetMap/Nominatim (reverse geocoding), used when you authorise AI-personalised content (section 9).
- Address completion: ViaCEP (a public lookup service for Brazilian postcodes, which receives only the postcode you type) and OpenStreetMap/Nominatim (converting your approximate location into a postcode, when you use auto-fill in your profile).
- Video calls and transcription: LiveKit, a real-time video infrastructure provider, which makes teleguidance and the processing of the consultation audio possible.
- Speech recognition: Apple and Google, depending on your device's operating system (section 9-A).
- Usage analytics and diagnostics: PostHog, with servers in the European Union (section 18).
- Error and crash monitoring: Sentry (Functional Software, Inc.), with servers in the European Union (section 18).
- Email delivery: Loops, the platform we use to send waiting-list messages, the newsletter and service emails, and Amazon Web Services (Amazon SES), the infrastructure that delivers those messages from the updates.yolki.pet domain. They receive your email address, your name (when you provide it) and the technical delivery, open and unsubscribe records needed to operate the sending. Every email carries an unsubscribe link; once you use it, you stop receiving those messages.
- Support and internal team communication: ClickUp, our team's work tool, operated from the United States. It receives an automatic notice when you report a bug, rate the app or a consultation, report a piece of content or express interest in a paid plan, so that the team can respond. The notice carries what you wrote and, depending on the case, your email address; for interest in a paid plan, it also carries your name, the name you prefer to be called and your phone number.
- Social login: Google and Apple.
These partners process data in accordance with our instructions and under security and confidentiality obligations. The up-to-date list of sub-processors, with purpose and country of operation, may be requested through our contact channel, and it is reviewed whenever we add, replace or remove a supplier.
12. Payments and advertising
YOLKI has a free plan and paid features. The Solo plan is free; the Duo plan is a paid subscription, and the video veterinary consultation is charged per appointment or per package. Every price is shown in the app before you confirm.
We do not process payments and we have no access to your card data. Charges are made through Apple's and Google's In-App Purchase systems. They are the ones who process the payment and receive your card data.
- We use RevenueCat as a processor to administer purchases and verify whether your subscription is active. It receives your account identifier and the transaction data (what was purchased, when, and whether it is in force), never your card data.
- In our own systems we keep only what is needed to unlock what you bought: which plan or package is active, its term, and the history of consultations purchased. No card number, CVV or bank details.
Today YOLKI displays no advertising. We do not use advertising identifiers or ad network SDKs, and we do not track you across apps. If we ever display advertising, it will be contextual — tied to the app's context, with no individual profile of the pet parent and no cross-app tracking — and we will update this Policy before starting that processing.
The commercial terms — plans, automatic renewal, cancellation and the right of withdrawal — are set out in the Terms of Use.
12-A. Partner Programme: the data of those who promote Yolki
This section is for anyone joining the Partner Programme — creators, shows, clinics and organisations that promote Yolki with their own coupon. It does not apply to people who simply use the app: if you are a pet tutor, skip to section 13.
The controller is Coflint OÜ (Estonia, European Union), the same as in section 1. The partnership agreement is what authorises this processing.
What we ask for, and why:
- Name, e-mail, phone and address — to identify you, contact you and issue the invoice. Legal basis: performance of a contract.
- Tax number (CPF or CNPJ) — required by accounting and for issuing the invoice. Legal basis: legal obligation and performance of a contract.
- A photo of an identity document (ID card, driving licence or passport; plus the company registration card for a business) — to check that you are who you say you are, before we activate a coupon that generates payments. The file is kept in private storage, is never public, and is opened only by whoever performs that check. We keep this photo for as long as the partnership lasts and for 5 years after it ends, because it shows who we contracted with and who we paid. Legal basis: performance of the contract and tax and accounting obligations; and, for the check itself, legitimate interest in preventing fraud.
- Payment details (the account you give us to receive the money) — to pay your commission. Legal basis: performance of a contract.
- Proof that you signed the agreement — date and time, IP address, the device used, the e-mail confirmed by the 6-digit code, and the checksum of the signed text. Without this an electronic contract cannot be proven. Legal basis: legitimate interest in proving the contract and defending claims; and legal obligation, for the accounting retention of the contract and the invoice.
- How your coupon performs — how many subscriptions came through it and how much you are owed. Legal basis: performance of a contract.
What we do not do: we never show a partner who the people using their coupon are. They see numbers, never a name, an e-mail or any tutor data. And we do not use partner data for advertising.
Who we share it with: our accountants in Estonia (for the invoice), the service that sends the programme's e-mails, and the bank or transfer service that executes the payment. The e-mail service is the same as in section 11; the accountants in Estonia and the bank or transfer service act only within the Partner Programme and are not in that list.
How long we keep it: the document photo, for as long as the partnership lasts and for 5 years after it ends. The signed agreement, the invoice and the payment records, for as long as Estonian accounting law requires — seven years from the end of the financial year (Raamatupidamise seadus, § 12) — and for as long as needed to exercise legal claims. The rest of the application, for as long as the partnership lasts and for the limitation period afterwards.
Your rights are the same as in section 15, and the channel to exercise them is in section 21.
13. Where your data is processed
Your data is stored and processed by providers located in Brazil, in the European Union and in the United States, depending on the service, in addition to the providers whose region is determined by themselves, indicated below. Today: file storage is in Brazil (AWS, São Paulo); usage analytics, error monitoring and the app's crash reports are in the European Union (PostHog and Sentry), as are the database backups (Railway Buckets, on Tigris Data's infrastructure, in Amsterdam) and AI processing (Microsoft Azure OpenAI, in Sweden); and in the United States are the account and notification services (Firebase, from Google) and the team's internal notices (ClickUp).
The app backend and database (Railway), the real-time video infrastructure (LiveKit) and email delivery (Loops, delivered through Amazon SES) operate in regions determined by those providers, which are not enumerated in this Policy. You may find out the region currently in use for each of them through our contact channel (section 21).
Whenever there is an international transfer of data, we adopt the safeguards required by law — such as the ANPD's standard contractual clauses (Resolution CD/ANPD No. 19/2024), for data subject to the LGPD, and the European Commission's standard contractual clauses, for flows under the European regime.
The specific location of each server may change over time, without altering the level of protection described in this Policy.
In short: part of your data stays in Brazil; part is processed abroad, always with the protections required by the LGPD and by the European rules.
14. How long we keep your data
We keep your data only for as long as necessary for each purpose. After that, we delete or anonymise it.
- Account and pet data: for as long as your account exists.
- Conversations with the AI assistant: for as long as they are necessary to provide and continue the service — for example, so that you can consult your history. When they are no longer necessary, they are deleted or anonymised.
- Audio and transcripts: the voice dictation audio is kept only for as long as necessary to convert it into text. Teleguidance transcripts are kept for the period necessary for the consultation and for legal obligations.
- Teleguidance and pet health data: for the period necessary for the service and for legal obligations.
- Pet documents: for as long as they are in your account. You can delete each document in the app whenever you want. When you delete your account, the files are deleted — except those of a pet that another tutor keeps following in the app, which stay with that tutor.
- Photos attached to the reason for the consultation: a photo attached to a consultation is kept with that consultation's history, for the same period as teleguidance data, and the copy in your pet's Documents follows the documents rule. A photo attached without completing the booking is deleted automatically within 2 days. When you delete your account, the consultation photos are deleted.
- Consultation reason draft: if the request does not become a consultation, we delete the text 90 days after the last edit; once it becomes a consultation, it follows the retention period for telehealth data.
- Profile photo: kept while it is on your profile. When you change or remove the photo, the previous one is deleted, and it is also deleted when you delete your account. If a veterinarian reports the photo, our team reviews it and may remove it; the report record is deleted together with the account.
- Partner Programme document photo: kept for as long as the partnership lasts and for 5 years after it ends. See section 12-A.
- Usage and diagnostic data: for the period necessary for the purpose of analysis and failure correction.
- After account deletion: deleted, except for what the law requires us to keep — for example, records for the regular exercise of rights in legal proceedings, as a rule for the applicable limitation period.
When we use data to improve the service, we do so in aggregated or anonymised form.
15. Your rights as a data subject (LGPD, article 18)
You are in control of your data. The LGPD guarantees you the right, at any time, to:
- Confirm whether we process your data and access it.
- Correct incomplete, inaccurate or outdated data.
- Request the anonymisation, blocking or deletion of unnecessary or excessive data, or data processed in breach of the law.
- Request the portability of your data.
- Obtain information about the sharing of your data.
- Be informed about the possibility of not giving consent and about the consequences of refusing.
- Revoke consent at any time.
- Object to processing we carry out on the basis of legitimate interest (article 18, paragraph 2).
- Request a review of decisions taken solely by automated means that affect your interests (article 20). The AI assistant generates educational content and does not take that kind of decision.
To exercise these rights, contact our Data Protection Officer (section 19) or use the contact channel (section 21).
We respond as quickly as possible. For requests to confirm processing and to access data, we provide the simplified statement immediately and, if you request the complete statement, within 15 days, as required by the LGPD (article 19). Other requests are handled within a reasonable period, depending on their complexity.
16. How to delete your account and your data
You can delete your account and your data directly in the app, whenever you wish.
- In the app: through the account deletion option in the settings.
- Outside the app: by emailing [email protected], without having to reinstall the app.
After deletion, we erase your data, except for data we are required by law to keep.
Having an active subscription does not prevent the deletion of your account — your right to erasure remains fully available. But deleting the account does not cancel the subscription, which was taken out with the app store and must be cancelled by you in the subscription settings of your Apple or Google account. The conditions are set out in section 15 of the Terms of Use.
17. How we protect your data
We adopt technical and administrative measures to keep your data secure: access controls, encryption in transit (TLS) and, where applicable, at rest, and contractual security obligations with our partners.
If a security incident occurs that may give rise to relevant risk or harm to you, we will notify the ANPD and you, within the deadlines and on the conditions set out in the law. Where the European regime applies, we notify the competent authority without undue delay and, wherever possible, within 72 hours of becoming aware of it (GDPR, article 33), and we notify you where the incident may result in a high risk to your rights (GDPR, article 34; LGPD, article 48).
No system is 100% immune; for that reason, keep your login credentials secret.
18. Identifiers, usage analytics and session recording
We use identifiers and similar technologies for the app to work and to understand how it is used:
- Authentication, security and usage metrics.
- Usage data, with PostHog — measurement is on by default, and you can turn it off. We measure how the app is used: the screens you open, the actions you take and the options you choose in the app's features, when you open the app, and errors and crashes. Along with these go the app version, the device's operating system and language, your plan and the link or coupon through which you came to YOLKI. These records are linked to your account through an internal identifier, without your name and without your e-mail address. They serve to understand how the app is used, to find errors and friction points and to improve the experience. We do not share these records with ad networks, nor do we use them to build a commercial profile. PostHog's servers are located in the European Union. This measurement is carried out on the basis of our legitimate interest.
- How to turn measurement off. In the app, open the "Profile" tab, tap "Security and privacy" and, under "Privacy and data", turn off "Usage data". From then on, the app stops sending usage records, and session recording, if it is on, is turned off with it. The choice is stored on the device: if you use YOLKI on more than one device, or reinstall the app, check the option on each one. You can turn it back on in the same place, whenever you like. Turning it off does not limit your use of YOLKI. The failure reports sent to Sentry, described below, do not depend on this option. Records made before that follow the period in section 14, and you may also object to this measurement through our Data Protection Officer (section 19).
- Records made by our servers. Some service facts are recorded in PostHog by our servers, linked to the same account identifier — for example, a consultation credit granted, used or expired, and a completed consultation. They carry identifiers, categories and numbers, without your name, your e-mail address or the content of the consultation. Turning off "Usage data" stops the measurement made by the app. The measurement made by our servers only stops when the app informs them of that choice, which depends on the version of the app installed. In any version, you can ask for it to stop through our Data Protection Officer (section 19).
- Session recording — only with your consent. It is a separate choice from measurement and is off by default. After you have opened the app a few times, never the first time, we ask whether we may record the screen; once you answer, we do not ask again. If you accept, some sessions may include a screen recording in which nothing is legible: text, images and everything you type are masked on your device, before being sent. If you decline, no recording is made. You can turn the recording on or off whenever you like, on the same "Security and privacy" screen, under "Masked screen recording", without affecting your use of YOLKI (legal basis: consent — LGPD, article 7, I; GDPR, article 6(1)(a)). With "Usage data" turned off, the recording is off as well.
- Error monitoring with Sentry. When the app encounters a failure, a technical report — device model, operating system and app version, and the error trace — is sent to Sentry, whose servers are located in the European Union. We do this on the basis of our legitimate interest in keeping the app stable and secure.
- We do not use advertising tracking SDKs to build a profile or track you across apps.
You can control some of these technologies in your device settings — for example, by resetting or limiting the advertising identifier.
19. Data Protection Officer (DPO) — LGPD, article 41
We have a Data Protection Officer responsible for data processing, who is your point of contact for privacy matters and also the channel through which the ANPD contacts us.
- Name: Franz Kunz
- Email: [email protected]
You may also contact the ANPD if you believe your rights have not been respected.
20. Changes to this Policy
We may update this Policy from time to time.
When that happens, we publish a new version, update the last-updated date at the top and record both dates — effective date and last updated — in section 2, and we will notify you by appropriate means — for example, inside the app.
For relevant changes that broaden the processing or reduce your rights, we will ask for your acceptance again.
21. Contact us
- Support/contact: [email protected]
- Website: https://yolki.pet
- Data Protection Officer (DPO): [email protected]
22. Governing law and jurisdiction
This Policy complies with the Brazilian legislation applicable to our relationship with you — in particular the LGPD and the Consumer Protection Code — and, where applicable, with the European data protection rules.
Because you are a consumer in Brazil, the Brazilian protective rules always prevail where they are more favourable to you. The courts of your domicile apply, in accordance with the Consumer Protection Code. We do not impose a foreign jurisdiction on you.
23. Data protection authorities
If you believe your rights have not been respected, you may lodge a complaint with the competent supervisory authority:
- Brazil — ANPD (Autoridade Nacional de Proteção de Dados): www.gov.br/anpd
- Estonia — AKI (Andmekaitse Inspektsioon): www.aki.ee