Privacy Policy

1.Who we are — the Controller

The Modo Vitta app (available for Android) is operated by an individual under the trade name Modo Vitta, based in Brazil.

For the purposes of the Brazilian General Data Protection Law (LGPD — Law No. 13,709/2018), the data Controller is the operator of Modo Vitta, reachable through the official channel:

2.Data we collect

We collect only the data strictly necessary to run the app and to provide the services you sign up for. Each category is detailed below:

2.1 Account and identity data

• Full name
• E-mail address
• Gender
• Age range (used to confirm that you are 18 or older)
• CPF (the Brazilian individual taxpayer number) — asked only of people who take part in the referral program: when you type a referral code while signing up, or when you apply a code under MyVitta → Refer & Earn. If you never use a referral code, the field is never shown and no CPF is ever sent. When it is provided, it is stored only as an irreversible cryptographic hash, never in plain text, and it is used for fraud prevention and for the integrity of the referral program
• Password (stored as an irreversible hash — never in plain text)
• Restoration credential — created when you sign in and also, when this device does not have one yet, when you open the app with your session already validated, if your device offers the Android feature that gives your access back when you move to a new handset without asking for your password again. On our server we keep only the public half of that credential, its identifier, the model of the component that generated it, a usage counter, the creation and last-use dates and the revocation flag. On its own, none of that opens your account. The half that actually opens it is held by the Android Credential Manager and never reaches us — see sections 4 and 7

2.2 Usage and productivity data

• Tasks you create, their states (Resolve, Resolving and Resolved — with Completed and Cancelled as the two outcomes within Resolved) and the pillars they belong to
• Weekly goals and the balance of hours across your pillars (VittaBalance™) — how many hours of the week you plan to devote to each area of life, and the balance within the 168 hours
• VittaFocus™ focus sessions (Timer and Cycle)
• Scores, streaks and unlocked achievements
• Método Vitta settings (VittaFlow™, personalized pillars)
• App usage markers: dates only, with no content whatsoever — the day this device first saw your account, the dates on which we already showed you each referral and each app-rating invitation, the day you dismissed a prompt bubble (the VittaCheck™ check-in, the weekly report), the moment you marked the bell notifications as read, and the week each pillar was celebrated. They do not record what you did in the app: they record what the app has already shown you, so we do not repeat invitations and prompts you have already seen
• Free text you write: the notes on each task, your VittaNotes™ notepad, the content of your VittaTarget™ goals (Vision, Intention, Trajectory and Action) and the comments you write when you log progress on a goal. In Google Play Data Safety terms, this is Other user-generated content. This text is yours, it stays tied to your account and it is deleted in full when you delete your account
• VittaPartner™ (Partner Mode) comments: the text of the comments you write — including on your partner’s tasks — and the marker of how far you have read theirs. In Google Play Data Safety terms, this is Other in-app messages

2.3 Technical device data (Device or other IDs)

• Device identifier — a random code generated by the app itself on first launch, with no relation whatsoever to the serial number, the IMEI or any other factory identifier of the handset. It exists so that we can recognize the devices on which you have already confirmed your access code (and therefore not ask for the code every time)
• Operating system and version
• Version of the installed app
• Crash reports: when the app crashes or hits an error, Google Crashlytics records the error type, the screen and the feature in use at that moment or shortly before — including the wellbeing features — and the technical state of the device at that moment, so that we can fix the problem. These reports never carry the content you write — see the details in section 4 and how to switch it off in section 12
• Usage data (Google Analytics for Firebase): the name of the screen opened inside the app, the language, the approximate country and a random identifier generated by the installation. It tells us which screens and features are actually used and where people give up, so we can prioritise improvements. This collection is a navigation count: it does not carry the content you record, nor your wellbeing and health data — see the details in section 4 and how to switch it off in section 12

2.4 Biometric data

2.5 Payment and subscription data (Purchase history)

• Plan status (Free, Premium or VIP)
• Subscription transaction history
• Payment data is processed directly by the app store (Google Play) or by RevenueCat — Modo Vitta does not store card numbers or bank details

2.6 Notification tokens

• FCM token (Firebase Cloud Messaging), used to deliver push notifications to the registered device

2.7 Advertising data

• Device advertising identifier (GAID on Android)
• Ad interaction data (impressions, clicks)

2.8 VittaPartner™ (Partner Mode) data, when enabled

• The link between two Vitta accounts (anonymized internal identifiers)
• The partnership invites you send and receive. If you invite someone who does not have an account yet, we store the e-mail address you typed in order to send the invite and to recognize that person if they later sign up
• While the partnership is active, your task schedule and your goal collection become visible to your partner — the exact scope is detailed below

2.9 Wellbeing and health data (sensitive — Health info)

2.10 Approximate location

• The state and city you enter in your profile, used to personalize your experience. We do not use GPS and we do not track your position. In Google Play Data Safety terms, this is Approximate location — literally “the city the user is in”.

2.11 Photos you send us

• Profile picture (avatar): if you choose one, the image is uploaded to our servers and stays tied to your account until you replace it or delete your account. It is optional — the app works without it.
• Contact Us attachment: if you attach an image to a support message, it travels by e-mail to our support inbox together with your report.
• We never access your camera or your gallery on our own: we only receive the image that you select and send.

2.12 Website waiting list (iPhone and iPad)

This is the only collection made outside the app, and it does not require an account. Anyone who fills in the "Coming to iPhone and iPad" form at modovitta.com — opened by the Waiting List button or by the Apple icon on the home page — sends us:

• the e-mail address you typed
• the IP address the submission came from and its date and time
• a cryptographic digest (hash) of the IP, kept for 1 hour, used only to limit repeated submissions from the same point

Filling it in is voluntary: browsing the pages of the website without using that form sends no data at all. Joining the list does not create an account in Modo Vitta™ and has no connection to the app data described above. The purpose and the legal basis are in item 3, the retention period in item 6, and how to leave the list in item 10.2.

2.13 Screen time in social apps (VittaScroll™)

• The list of apps is fixed and defined by us, inside the application. We do not read and do not receive the list of applications installed on your device.
• We do not see what you do inside those apps: no content, no accounts, no messages, no browsing history. The only data point is how long each of them was in the foreground.
• Only time with the app open on screen counts. Music, podcasts and video playing in the background are not included.
• It is optional and reversible. The feature only works after you authorise Modo Vitta™ under "Usage access" in Android’s own settings, and you can switch it off at any time in the same place. Without that authorisation, nothing is read.
• Because the data is neither stored nor transmitted, there is no retention period to observe: switching the authorisation off ends the reading, and nothing is left behind on our side.

3.Purposes and legal bases (LGPD)

Every processing operation carried out by Modo Vitta has a specific, explicit and legitimate purpose, grounded in at least one of the legal bases set out in Arts. 7 and 11 of the LGPD:

4.Sharing with third parties

Modo Vitta does not sell personal data. Apart from Partner Mode — where you are the one who decides to give another person access, as described in item 2.8 — sharing happens only with the essential providers listed below, all of which have their own privacy policies and contractual data protection obligations. There is one exception, and it is declared in the table: the Android Credential Manager. It is not a provider we contracted — the restoration credential is kept in your own Google account, under the terms you already have with Google, so there is no contract of ours to invoke over it. We list it all the same, because the data leaves our reach and you have to know:

We may also share personal data when required by law, by court order or by a competent authority, limited to what is strictly necessary.

5.International data transfers

The main Modo Vitta server is located in Brazil (Hostinger). However, some of the providers listed in the previous section (Google Firebase, Crashlytics, AdMob, Unity Ads, RevenueCat) have global infrastructure and may process data in other countries, including the United States. The restoration credential also leaves Brazil: it is held in your own Google account, whose infrastructure is global.

In those cases, we ensure that the transfer takes place under the mechanisms set out in Art. 33 of the LGPD and under the Data Processing Agreements signed with each provider, which include clauses equivalent to the European Union Standard Contractual Clauses (GDPR Standard Contractual Clauses).

The restoration credential is the exception, for the same reason as in the previous section: it does not go to a provider we hired, but to your own Google account — the transfer is governed by the terms you already have with Google, not by any contract of ours, and we have no way of bringing it back to Brazil. What supports this transfer is Art. 33, IX combined with Art. 7, V of the LGPD: it is necessary in order to perform what you signed up for — getting back into your account.

6.Data retention and deletion

Erasing only your data, without deleting your account

If you want to get rid of the content you created without losing your account, the app offers a separate path — Erase My Data. You stay signed in, with the same login, and start over from scratch:

1. Open the Modo Vitta™ app with your account signed in
2. Go to MyVitta → MY ACCOUNT → Manage Data → Erase My Data
3. Type “ERASE” to confirm and tap Send confirmation code
4. Enter the 6-digit code sent to your registered e-mail address (valid for 5 minutes) and confirm

How to delete your account and your data

You can delete your account and all of your data at any time, free of charge, by following the steps below:

1. Open the Modo Vitta™ app with your account signed in
2. Go to MyVitta → MY ACCOUNT → Manage Account → Delete account
3. Type “DELETE” to confirm and tap Send confirmation code
4. Enter the 6-digit code sent to your registered e-mail address (valid for 5 minutes) and confirm

The same deletion is also available under MyVitta → MY ACCOUNT → Manage Data, at the bottom of the page.

No access to your account or to your registered e-mail address? Send a request to contato@modovitta.com from the e-mail address associated with your account.

When deletion happens. The moment you confirm, the account is deactivated right away: every session is ended, the data held on the device you asked from is wiped, and nobody can reach the account any more — neither you, nor anyone who shared an agenda with you. The permanent deletion on the server runs 7 days later.

If you used Modo Vitta™ on more than one device, the others lose access as soon as they reconnect and return to the login screen; until then, with no connection, whatever was already downloaded may keep showing up on them. The copy left on those devices is erased when the app is uninstalled, or when someone signs in on them with a different account.

Those 7 days are yours, to change your mind. If you sign back in with the same email and password within that window, the account is restored with everything that was in it and the deletion is cancelled. After the 7 days there is no way back. While the window is open, your email stays reserved for that account and cannot be used to create another one.

Backup copies may retain the data for up to 30 days after the permanent deletion, before the final purge, as stated in the table above.

7.Data security

We apply technical and organizational measures in line with the state of the art to protect personal data against unauthorized access, loss, alteration or destruction:

• Encryption in transit: all communication between the app and the server uses HTTPS with TLS 1.2 or higher
• Encryption at rest: the local database is encrypted with SQLCipher (AES-256)
• Secure storage: credentials and tokens stored in the Android Keystore
• Multi-factor authentication: e-mail OTP available to every user
• Risky environment warning: the app detects whether the device is in developer mode or is an emulator and shows you a warning. It is informational only — it does not block access, it does not check for root/jailbreak and the result never leaves the device
• Password: stored exclusively as an irreversible hash (bcrypt/argon2)
• Leaked password: whenever you set a new password, the server checks whether it has already appeared in public breaches and refuses one that is already circulating on the internet — without your password going anywhere beyond our server (see the box just below)
• CPF: stored exclusively as an irreversible cryptographic hash, with a secret salt kept on the server — never in plain text
• Restoration credential: of the key pair that gives your access back on a new device, our server keeps only the public half. The private half — the one that actually signs and opens the account — is generated and held by the Android Credential Manager, is never transmitted to us and does not exist on any server of ours. It is invalidated when you remove the key under MyVitta → MY ACCOUNT → Trusted Devices (Automatic Sign-In list), when you change your password or use End All Sessions, and fully deleted when you delete your account
• Least privilege: internal staff access personal data only on a need-to-know basis and with an audit record
• Periodic testing: security reviews before every version published to the stores

In the event of a security incident that may create relevant risk or damage to data subjects, Modo Vitta will notify the ANPD and the affected users within the legally prescribed period, under Art. 48 of the LGPD.

8.Minimum age — 18 and over

Modo Vitta is intended exclusively for people aged 18 and over. During sign-up, the user confirms their age range and declares being of legal age; there is no sign-up flow for people under 18.

We do not knowingly collect data from people under 18. If we identify an account belonging to a minor, that account will be removed and the data deleted.

Parents or guardians who identify the use of the app by a minor can request deletion at contato@modovitta.com.

9.Your rights as a data subject

The LGPD (Art. 18) grants data subjects the following rights, which may be exercised at any time through the contact channel given in section 13:

We answer requests within 15 business days, extendable by a further 15 days with justification, as provided for by the ANPD.

10.Cookies and tracking technologies

10.1 Mobile app (Android)

Native apps do not use browser cookies. We use technical identifiers held in the secure storage of the device to keep the user session authenticated.

10.2 This website

The public pages at modovitta.com (overview, Terms, Privacy and account deletion) do not use analytics or advertising cookies: there is no audience-analytics tool, and ads are served only inside the mobile app.

The website makes one single collection, and it is voluntary: the iPhone and iPad waiting list form (item 2.12). What it receives is kept in a file on our server outside the public area of the website, on the same infrastructure already listed in item 4, and in a copy sent by e-mail to the Modo Vitta™ support address. There is no recipient other than us, and this data is not shared with third parties.

How to leave the list: write to contato@modovitta.com asking to be removed. We erase the record — the e-mail, the IP and the date/time go together, because they are the same line — and confirm it to you. You do not have to justify the request.

11.Ads and personalization

Users on the Free plan see ads served by Google AdMob, which may call on mediation partners to fill those slots — today, Unity Ads. Your consent choice is passed on to them and applies just the same. In the regions where regulation requires it (European Economic Area and United Kingdom), the app shows the Google consent form (UMP) on launch, before requesting any ad; in Brazil that form is not shown, and control sits with the Marketing consent inside the app.

What each choice does:

• Marketing consent on — personalized, interest-based ads, using the device advertising ID
• Marketing consent off (the default state on install) — non-personalized ads, including those delivered by the mediation partners: they are still shown on the Free plan, but they are not based on your interests and may be less relevant
• Refusing the Google form, where it is required (European Economic Area and United Kingdom) — the app requests no ads at all

That choice takes effect immediately and can be changed whenever you want under MyVitta → MY ACCOUNT → Manage Data.

To sustain the free plan, ads may be targeted by age range (adult audience, 18 and over), always respecting the consent choice made by the user.

Users on the Premium and VIP plans are not subject to any form of advertising inside the app.

12.Consent and withdrawal

Where processing is based on consent (LGPD Art. 7, I), the user may withdraw it at any time, free of charge and without difficulty, without affecting the lawfulness of the processing carried out before the withdrawal.

Channels for withdrawing specific consents — and, in the case of crash reports and usage metrics, for objecting to processing based on legitimate interest (Art. 18, § 2):

• Push notifications: device settings or MyVitta → PREFERENCES
• Personalized advertising: MyVitta → MY ACCOUNT → Manage Data — Marketing switch
• Crash reports (Crashlytics): collection starts out on, based on our legitimate interest in keeping the app stable (Art. 7, IX), and does not rely on consent — but you can switch it off at any time inside the app, under MyVitta → MY ACCOUNT → Manage Data; once you do, Crashlytics stops collecting and sending crash reports
• Usage metrics (Analytics): collection starts out on, based on our legitimate interest in understanding how the app is used so that we can improve it (Art. 7, IX), and does not rely on consent — but you can switch it off at any time under MyVitta → MY ACCOUNT → Manage Data; once you do, Analytics stops collecting and sending usage metrics
• Wellbeing and health data (Art. 11): MyVitta → MY ACCOUNT → Manage Data — the wellbeing and health data item; withdrawing switches VittaCheck™, VittaSleep™ and VittaHydratta™ off and stops any new recording, without erasing what has already been recorded (see item 2.9)
• E-mail communications: the unsubscribe link present in every e-mail, or contato@modovitta.com
• All consents / account deletion: MyVitta → MY ACCOUNT → Manage Account → Delete Account, or by e-mail — see modovitta.com/excluir-conta-en.html

13.Data Protection Officer (DPO)

The Modo Vitta Data Protection Officer is responsible for receiving communications from data subjects, from the ANPD and from interested parties on privacy matters.

14.Brazilian National Data Protection Authority — ANPD

If you believe that your rights as a data subject have not been properly addressed by Modo Vitta, you have the right to file a complaint directly with the Brazilian National Data Protection Authority (ANPD):

• Website: www.gov.br/anpd
• Electronic filing: through Consumidor.gov.br or the ANPD portal

15.Updates to this Policy

This Privacy Policy may be updated from time to time to reflect changes in the app, in legislation or in our data processing practices. Material changes will be communicated to the user through:

• A notice inside the app (banner or informational modal)
• An e-mail to the registered address (when the change is relevant)

The version in force is always available at modovitta.com/privacy-en.html (English) and at modovitta.com/privacy.html (Portuguese), with the date of the last update shown at the top of the document.

Continued use of the app after the effective date of a new version constitutes acceptance of the changes.