Legal
Privacy Policy
1. Who we are and how to reach us
Karven ("we") is the controller of personal data processed through the Karven app and website (the "Service"), under Brazil's General Data Protection Law (Law No. 13,709/2018, "LGPD"). The complete identification of the controller is provided to the data subject upon request and to the competent authorities when required by law.
- General privacy contact: [email protected].
- Data Protection Officer (DPO) channel: [email protected].
If you are located outside Brazil, the rights described in this policy are guaranteed to you in the same way, regardless of the country you live in (see §12).
2. Quick summary
- We collect the data you provide to build your profile, log workouts and meals, and let the AI Coach generate personalized plans.
- Workout, diet, and health data are treated as sensitive personal data and are never used for advertising or sold.
- Part of this data, without your name, email, or account identifier, is sent to artificial intelligence providers to generate your plans. Details in §6.
- You can delete your account and your data at any time in the app.
- We use PostHog to understand app usage (without reading the content of your workouts, diet, or photos) and Sentry to monitor errors.
3. What data we collect
| Category | Examples | Source |
|---|---|---|
| Account data | Name, email, authentication identifiers (email/password, Google, Apple) | Provided by you at sign-up |
| Health and physical activity data (sensitive personal data) | Workouts, exercises, sets/reps/loads, meals, macros/calories, body measurements, progress photos | Provided by you as you use the app |
| Profile data | Goal, training experience, physical limitations, available equipment, dietary preferences and restrictions, allergies, date of birth, sex, height | Provided by you during onboarding |
| Subscription data | Subscription status, plan, renewal date | Received from RevenueCat / Apple / Google |
| Technical data | Device identifiers, app version, error logs, IP address, language, time zone | Collected automatically |
| Usage/analytics data | Screens viewed, features used, in-app events | Collected automatically via PostHog (see §11) |
| AI generation records | Context sent to the model and the response received, for each workout or diet generation | Generated when you use the AI Coach (see §6) |
| Verification codes | Temporary code for password reset | Generated when you request a password reset |
| Communications | Support requests, messages sent to us | Provided by you |
We do not sell your personal data.
4. How we collect it
The app is offline-first: the data you enter is stored on your device and synced with our servers when there is a connection. The data listed above is collected both directly (what you type or submit) and indirectly (through automatic sync and technical/analytics signals).
5. Purposes and legal bases
| Purpose | Data used | Legal basis (LGPD) |
|---|---|---|
| Create and manage your account, provide the basic app | Account data, profile data | Contract performance (Art. 7, V) |
| Generate workout/diet suggestions and the AI Coach | Health/physical activity data, profile data | Contract performance; specific and highlighted consent for processing sensitive data (Art. 11, I) |
| Process subscriptions | Subscription data | Contract performance |
| Product analytics: understand feature usage, fix bugs, improve the app | Usage/analytics data (via PostHog) | Legitimate interest (Art. 7, IX; see §11) |
| Error and stability monitoring | Technical data (via Sentry) | Legitimate interest (Art. 7, IX) |
| Security, fraud prevention, legal compliance | Technical data, account data | Legitimate interest / legal obligation (Art. 7, II, IX) |
| Respond to support requests | Communications | Contract performance / legitimate interest |
Because workout and diet data reveal information about your health, we treat it as sensitive personal data under Article 11 of the LGPD and use it only to operate the features you actively use, never for advertising purposes.
6. Artificial intelligence
The AI Coach generates workout and diet plans, and analyzes meal and nutrition label photos, using third-party language models. This section explains exactly what that involves.
What is sent. Depending on the feature you use, the model receives: goal, experience level, available days and minutes, equipment, physical limitations you describe freely (for example, an injury or movement restriction), recent load and repetition history; or dietary restrictions and allergies, preferences, meal routine, calorie and macro targets; or the meal/label image, when you use photo analysis.
What is not sent. Your name, email, and account identifier do not accompany these requests: the model receives only the context necessary to generate the response, without elements that directly identify you.
Who it is sent to. We use OpenRouter, a service that routes requests to third-party language model providers, including companies based outside Brazil. An up-to-date list of the model providers in use is available upon request at [email protected].
What we do with the response. The result of each generation is saved on our servers. For workout and diet generation, we also keep a copy of the profile context sent to the model, to investigate quality issues and for auditing, subject to the retention period in §9. Meal and nutrition label photos submitted for analysis are not stored by us: the image is used only during the call to the model and discarded immediately afterward; only the analysis result (for example, the identified foods and macros) is saved.
Automated decisions. The plans generated are suggestions, not automated decisions that produce legal effects or a significant impact on you. Even so, you have the right to request human review of an AI Coach suggestion, under Article 20 of the LGPD, by contacting [email protected].
7. Who we share data with (processors)
We share data only when necessary to operate the Service, with providers bound by data processing agreements:
- Hosting/infrastructure: Cloudflare (website and photo storage), Google Cloud Platform (API), and Neon (database).
- Artificial intelligence: OpenRouter and the model providers it routes to (see §6).
- Subscriptions: RevenueCat, and the Apple App Store / Google Play for payment processing.
- Login: Apple, Google (only if you choose to sign in with these accounts).
- Product analytics: PostHog (see §11).
- Error monitoring: Sentry.
- Transactional email: Resend (for example, password reset emails).
- Legal/compliance: authorities, when required by law or to protect our rights.
We do not share your data with third parties for their own marketing purposes.
8. International data transfers
Some of the providers above process data outside Brazil. In these cases, we adopt the transfer mechanisms required by the LGPD (Art. 33), such as contractual clauses and the selection of providers that offer adequate security and confidentiality safeguards.
9. Data retention
We keep your data while your account is active. If you delete your account, we erase your personal data from our active systems, including progress photos stored in our file infrastructure and AI generation records, within 30 days. Backup copies that still contain this data are overwritten in the normal rotation cycle, within 90 days. We may retain data for longer when necessary to comply with a legal obligation, resolve disputes, or enforce our contracts (for example, tax records).
10. Security
We use technical and organizational measures to protect your data, including encrypted transport (HTTPS), encrypted storage of authentication tokens on the device, and access controls across our infrastructure. No system is 100% secure; if we become aware of a security incident affecting you, we will notify you and the ANPD as required by law.
11. Cookies and analytics
On the website, we use only a strictly functional cookie (KARVEN_LOCALE, valid for one year) to remember your chosen language. The website does not use analytics or advertising cookies.
In the app, we use PostHog to understand how features are used and prioritize improvements. We do not collect the content of your workouts, diet, body measurements, or photos through this channel. We collect only usage events (for example, which screens you open) and a limited set of profile attributes: whether you are a Pro subscriber, your goal, experience level, and activity level. We do not use session replay or automatic screen capture. You can request deletion of your analytics data or ask to stop having new events collected at any time by contacting [email protected].
12. Your rights
Under the LGPD (Art. 18), you have the right to:
- Confirm the existence of processing and access your data;
- Correct incomplete, inaccurate, or outdated data;
- Request anonymization, blocking, or deletion of unnecessary or excessive data;
- Request portability of your data to another provider;
- Request deletion of personal data processed based on consent;
- Obtain information about the entities with which we share your data;
- Withdraw consent at any time (for example, by deleting your account);
- Object to processing carried out on the basis of legitimate interest;
- Request review of automated decisions that significantly affect your interests.
These rights are guaranteed to all data subjects, regardless of the country they live in.
You can exercise most of these rights directly in the app (Profile → My Account → Delete Account) or by contacting [email protected]. We will respond within the timeframe required by the LGPD.
13. Account and data deletion
You can permanently delete your account and associated personal data in Profile → My Account → Delete Account in the app, or by emailing [email protected]. This removes your workouts, diet records, body measurements, progress photos, and profile data from our active systems, within the timeframe in §9, subject to the retention exceptions described there (for example, tax records required by law).
14. Minimum age
The Service is intended for users 18 years of age or older. We do not knowingly collect personal data from users under 18. If you believe a minor has provided us with data, contact [email protected] and we will delete it.
15. Changes to this policy
We may update this Privacy Policy to reflect changes in our practices or legal requirements. Material changes will be communicated in the app or by email before taking effect. The "last updated" date at the top of this page reflects the most recent revision.
16. Contact
Questions or requests about privacy: [email protected]. Data Protection Officer: [email protected].