Legal document

Privacy Policy

This Policy describes how Thor collects, uses, stores, and protects your personal data — globally.

🇪🇺 GDPR 🇺🇸 CCPA 🇧🇷 LGPD 🌍 Worldwide
Version 2.4 · Last updated: October 13, 2026 · Effective immediately
Quick summary: We collect only what's needed for you to organize your finances. A few optional profile and feedback questions (Sections 2.7 and 2.8) help us improve Thor. We use OpenAI for AI processing, Supabase for storage, RevenueCat/Apple/Google for subscriptions and distribution, and Hubla for Pix purchases. A sample of chat messages is also checked by TypeSafe (Section 5.12). We don't sell your data — ever. You have full rights under GDPR, CCPA, and LGPD. Contact us at privacy@meuthor.com.br for any request.

1. Data Controller

The Data Controller responsible for your personal data is:

The Data Protection Officer (DPO) — also serving as our point of contact under GDPR (Art. 37) and LGPD (Art. 41) — is Bruno Osorio Gonçalves, reachable at the privacy email above.

2. Personal Data We Collect

2.1. Registration data (provided by you)

  • Name (optional);
  • Email address (authentication and service communications);
  • Preferences (language, currency, region).

2.2. Content you submit

  • Audio recordings for expense logging;
  • Images (receipt photos, invoice screenshots, chat screenshots);
  • PDF and CSV documents you choose: the original file remains on your device and only sanitized derived text is transmitted for financial extraction;
  • Free-text input describing your transactions;
  • Personal financial data extracted from the above: amounts, dates, categories, descriptions, counterparties (e.g., "Uber Eats", "Whole Foods").
  • Your plan and goals data: what you enter when setting up your plan (for example, income, balance, and fixed bills), the goals you create and, when you use these features, each goal's pace plan (how much to set aside and on which day), debt payoff goals, and the payments you mark as done ("I paid"), with the history of those actions.

2.3. Payment data (Premium subscribers only)

  • App Store or Google Play subscriptions: billing is handled by Apple or Google. We never see or store your card number, CVV, or bank credentials — we receive only your subscription status (active/expired) via RevenueCat, our subscription manager.
  • One-time access via Pix (Brazil): processed by Hubla outside the app stores. We receive only the purchase email and a redemption code, never your Pix key, bank account, or card. This is distinct from the referral program (Section 2.6), where you optionally provide your Pix key so we can pay you a reward.

2.4. Automatically generated data

  • Technical logs (date/time of access, device type, app version, OS);
  • Device identifiers and push token (for analytics and, only after your consent, notifications);
  • Internal account identifier (UUID);
  • App interaction events and selected categorical properties and counts. Financial amounts, free-form content, email, and name are filtered out before product analytics are sent;
  • Record of your acceptance: when you create your account, the app shows a notice that, by continuing, you confirm you are 18 or older and accept the Terms and this Policy, with links to both documents. We keep the date and time of that acceptance, the document versions and, where the app records it, how you accepted (for example, tapping the sign-in button), as proof of what was accepted;
  • Setup answers in analytics: for the multiple-choice questions in the initial setup, product analytics receives the option you chose at the moment you answer or, where Section 2.7 says so, only whether the question was answered. For amounts you enter (for example, income, balance, or fixed bills), it receives only the range, never the number. This may happen before you create your account; once you create it, these records become linked to it;
  • Your choice about offers and news notifications: whether the option is on or off, when you turned it on or off, and the version of the text shown, as proof of your choice. Product analytics receives only whether the option is on or off.

2.5. Data we do NOT collect

  • Bank account numbers, credit card numbers, or financial institution passwords;
  • Open Banking / Open Finance connections to your bank;
  • Biometric data;
  • Precise GPS location;
  • Contacts, calendar, photos library, or device files (beyond what you explicitly send).

2.6. Referral program data ("Earn with Thor")

If you choose to join the referral program, we collect:

  • Your Pix key (of type CPF, phone, email, or random), entered by you on the program screen in your profile. We collect this key only if and when you register it, for the sole purpose of paying program rewards.
  • Referral records: your referral code, the status of each referral (joined, subscribed, paid), and the reward amount.

The Pix key is payment data. It is stored on a restricted basis, accessible only to our backend under a service credential (service-role) to generate the payout list, is never exposed to other users or to parts of the app running on your device, and is not shared with third parties beyond the financial institution needed to execute the Pix payment. You may change or remove your key at any time on the program screen, or request deletion at privacy@meuthor.com.br.

2.7. Profile information you choose to share

During the initial setup, before you create your account, Thor may ask a few profile questions:

  • How you identify (Woman, Man, Other, or Prefer not to say). Answering is optional: you can skip or choose "Prefer not to say". We use this answer to understand who uses Thor, always in aggregate, that is, added to other people's answers (for example, the share of women and men among people who use the app), to guide product and growth decisions. We do not use your answer to decide what to show, send, or offer to you individually. It is not used in any financial calculation, is not sent to the AI provider, and is not used for advertising. Product analytics receives only whether the question was answered, skipped, or marked "Prefer not to say", never the answer. Legal basis: your consent (LGPD 7(I) / GDPR 6(1)(a)), given when you answer. You can delete the answer in Settings at any time, without affecting your use of Thor.
  • How you heard about Thor (TikTok, Instagram, YouTube, someone's recommendation, App Store search, Google, or other). You can skip this question. We use the answer to understand which channels bring people to Thor. It doesn't change your plan.
  • How you organize your money today (not organizing yet, bank app, spreadsheet or notebook, another app). We use the answer to adapt the app's initial explanation and to understand who uses Thor.

Your answers about how you heard about Thor and how you organize your money stay on your device until you create your account; when you create it, they are saved with it. At the moment you answer, product analytics receives the option you chose (never amounts or free text), and that record becomes linked to your account once you create it. They are not used in any financial calculation and are not sent to the AI provider (Section 5.1).

You can view, change, or delete these two answers at any time in Settings, under "Your answers".

2.8. Cancellation feedback and 30-day courtesy access

When you turn off renewal of your subscription, the app may ask why. Answering is optional. If you answer, we collect:

  • The reason you pick from a list (for example, price, low usage, something missing, a technical issue, difficulty of use, privacy, or other) and, if you choose to write one, a comment of up to 1,000 characters. Please don't include passwords, bank details, or financial amounts in that text.
  • Subscription data tied to your answer: a reference to the product you subscribed to and to the end of the period you already paid for; in the courtesy form, also the identifier of your original Apple subscription and the record of the cancellation. We also keep the date of the answer and, in some cases, the app version and the screen that opened the question.
  • If you accept the invitation for 30 days of courtesy Thor Premium (offered in some cancellations of weekly or monthly subscriptions purchased through the App Store): your acceptance of the courtesy terms and their version, and the dates and status of the courtesy access (reserved, granted, or ended).

To decide whether to show the courtesy invitation, the app checks your subscription status and records the invitation, even if you don't answer. Unused invitations are deleted automatically after they expire, in a daily cleanup.

We use this data to understand why people cancel and to improve Thor and, for courtesy access, to check whether the invitation applies to your subscription, grant the 30 days, and make sure courtesy access is granted only once per person. What you answer, including criticism or "I'd rather not share details", does not change the benefit. The courtesy rules are in the terms shown in the app and in the Terms of Service (Section 9.1).

The comment you write is kept in our database under restricted access: it is not sent to product analytics or to the AI provider (Section 5.1). Analytics receives only the reason picked from the list and the progress of the form (for example, that it was opened or sent). Courtesy access is granted through RevenueCat (Section 5.5), which already manages your Premium access, using your internal account identifier.

The invitation screen may show an optional "Talk to me on WhatsApp" button. Tapping it only opens a WhatsApp chat with Thor's founder; the app sends no account data when doing so. From there the conversation takes place on WhatsApp, outside the app: what you write, your phone number, and your profile name reach us through WhatsApp and are also subject to WhatsApp's own terms and privacy policy.

3. Purposes of Processing

We process your personal data to:

  • Enable account creation, authentication, and access to the Service;
  • Process inputs (audio, images, text, and sanitized text derived from PDF/CSV) via AI to generate extraction suggestions;
  • Store your financial records so you can view and consult them;
  • Generate dashboards, insights, and goal tracking;
  • Operate the chat assistant feature;
  • Process subscription payments (Premium tier);
  • Operate the referral program, attribute referrals, and pay rewards due;
  • Send Thor offers and news by notification only if you turn on the "Thor offers and news" option in Settings. This option is off by default, is separate from service notifications, and can be turned off in the same place at any time. Allowing notifications in the system prompt does not turn this option on;
  • Understand which channels bring people to Thor and how they organize their money, and adapt the app's initial explanation (Section 2.7);
  • Understand why people cancel, improve Thor, and grant 30-day courtesy access to those who accept the invitation (Section 2.8);
  • Check, on a sample of chat messages and without changing the result for you, whether Thor correctly understood what was written (Section 5.12);
  • Send essential service notifications (and optional ones with your consent);
  • Detect, prevent, and investigate fraud, abuse, and security incidents;
  • Comply with applicable legal and regulatory obligations;
  • Improve the Service through aggregated, anonymized analytics (when applicable).

Under the EU/UK General Data Protection Regulation (GDPR Article 6) and the Brazilian General Data Protection Law (LGPD Article 7), we rely on the following legal bases:

  • Contract performance (GDPR 6(1)(b) / LGPD 7(V)): for everything necessary to deliver the Service you signed up for, and to pay any referral reward you become entitled to.
  • Consent (GDPR 6(1)(a) / LGPD 7(I)): for optional push notifications, processing the content you voluntarily submit, and joining the referral program (including the Pix key you optionally register).
  • Legitimate interest (GDPR 6(1)(f) / LGPD 7(IX)): for product improvement, security, fraud prevention, and technical diagnostics. You can object at any time — see Section 8.
  • Legal obligation (GDPR 6(1)(c) / LGPD 7(II)): to comply with court orders, tax law, and other legal duties.

We do not rely on legitimate interest where it is overridden by your fundamental rights.

For Sections 2.7 and 2.8 and for offers and news notifications, we rely on:

  • Consent (GDPR 6(1)(a) / LGPD 7(I)): to send you Thor offers and news by notification, and for the profile answers that Section 2.7 identifies as consent-based.
  • Legitimate interest (GDPR 6(1)(f) / LGPD 7(IX)): for your answers about how you heard about Thor and how you organize your money; to review the cancellation feedback you choose to send; and to prevent the same subscription from receiving courtesy access more than once. You can object at any time through the contacts in Section 15.
  • Contract performance (GDPR 6(1)(b) / LGPD 7(V)): to verify your subscription and grant the 30-day courtesy access when you accept its terms.
  • Legitimate interest (GDPR 6(1)(f) / LGPD 7(IX)): for the sample check described in Section 5.12, which measures and improves the quality of Thor's answers. You can object to this processing through the contacts in Section 15.

Some choices can be made directly in the app, without writing to us: in Settings you can change or delete the profile answers in Section 2.7 and turn offers and news notifications on or off. Deleting an answer or turning offers off does not affect your use of Thor. To have cancellation feedback deleted before the period in Section 7, write to privacy@meuthor.com.br.

5. Recipients (Sub-Processors)

We never sell your data. We share with the following sub-processors strictly to operate the Service:

5.1. OpenAI, L.L.C.

Provides the AI models for audio transcription, image vision, and structured extraction from free text. Submitted content is transmitted to OpenAI exclusively for real-time processing.

5.2. Supabase Inc.

Provides database, file storage, and authentication infrastructure.

5.3. Apple Inc.

App Store distribution, iOS subscription billing, push notifications via APNs, and optional Sign in with Apple.

5.4. Google LLC

Android distribution and subscription billing through Google Play, Google authentication, and Android notifications through Firebase Cloud Messaging (FCM), only after push consent.

5.5. RevenueCat, Inc.

Manages your subscriptions and Premium access status (entitlements) across devices. Receives your internal account identifier and purchase history to validate and sync your subscription.

5.6. Hubla Tecnologia Ltda.

Processes one-time access purchases made via Pix (outside the app stores; Brazilian entity, CNPJ 36.062.381/0001-80). When you buy access via Pix, Hubla processes the payment and sends us a redemption code tied to the purchase email, used solely to unlock your Premium access. We do not receive your Pix key, bank account, or card details.

5.7. PostHog, Inc.

Product analytics and experimentation platform: in the apps, receives a provider-specific pseudonymous account identifier, an SDK-generated identifier, app interaction events, and selected categorical properties and counts. Financial amounts, email, name, record identifiers, and free-form chat text are filtered out before events are sent. On the public landing pages, it receives anonymous pageview and interaction metrics in a cookieless mode without persistent browser storage.

5.8. Sentry

Error monitoring and crash reporting: receives technical failure reports (stack traces and sanitized context) for diagnostics and fixes. The app does not send raw error messages or default PII to Sentry.

5.9. Resend

Transactional email provider: receives your email address and the content required to send the message.

5.10. Public authorities

We may disclose data in response to a valid court order, subpoena, or other legal request from a competent authority, after assessing the legitimacy of the request.

5.11. Payment financial institution

To pay referral program rewards, we transmit your Pix key and the amount to the financial institution or payment arrangement through which the Pix is sent, strictly to execute the payment.

5.12. TypeSafe AI, Inc. (Jev)

Provider of a verification model we use in the background to check whether Thor correctly understood what you wrote in the chat (for example, that an installment purchase was not treated as a fixed expense). The check runs after your answer is already built, on a sample of chat text messages, and the result does not change your answers or your records.

We send only the text of the current message (typed, or transcribed from your voice message), limited to 1,000 characters, together with the type of record our AI proposed. Before sending, we replace with markers the amounts and numbers, dates, email addresses, Brazilian tax IDs (CPF/CNPJ), phone numbers, postal codes and street addresses, health and religion terms, and names of people. We do not send your conversation history, your account identifier or email, audio, or images. This replacement is automatic and may not recognize everything: store names, descriptions of the expense, and uncommon names may remain in the text sent.

  • Privacy policy: typesafe.ai/legal/privacy-policy
  • Country: United States
  • Retention at the provider: for as long as necessary to provide the service, under TypeSafe's data processing agreement. The agreement does not set a fixed number of days.
  • Data training: TypeSafe's privacy policy states that it does not train or fine-tune artificial intelligence models on the content sent.

6. International Data Transfers

As noted above, sub-processors are primarily located in the United States. Cross-border transfers are made under the following safeguards:

  • For EU/UK users: Standard Contractual Clauses (SCC) approved by the European Commission, supplemented where needed by additional technical measures (encryption, pseudonymization).
  • For US transfers specifically: Reliance on the EU-US Data Privacy Framework (DPF) when applicable, plus SCC as backup.
  • For Brazilian users (LGPD Art. 33): Transfer based on contract performance (33-II) and adoption of contractual safeguards with operators.
  • Encryption in transit and at rest applies to all transferred data.

7. Data Retention

  • Account data and financial records: retained while your account is active.
  • Original audio and images: retained while needed to provide the Service and support re-audit; removed when the account is deleted or upon an applicable request, subject to legal obligations.
  • Technical logs and analytics events: retained for the period configured with the relevant processors and needed for security, diagnostics, and Service improvement, subject to applicable rights and legal obligations.
  • Payment records: retained as required by tax law (typically 5-7 years).
  • Referral program data (Pix key and records): retained while you take part in the program and for the period needed to meet legal and tax obligations related to payments; the Pix key is removed when you delete it, when you close your account, or on request, subject to the minimum retention required by law.
  • Profile information you choose to share (Section 2.7): retained while your account exists, or until you delete the answer in Settings. Deleted with the account.
  • Cancellation feedback and courtesy access (Section 2.8): the comment written in the courtesy form is erased 90 days after you send it. The reason picked, the dates, the courtesy status, and the subscription data are kept while your account exists and deleted with it, as are the answers (reason and comment) to the simple cancellation question without courtesy access. After the account is deleted, we keep only a code (hash) derived from the identifier of your original Apple subscription, without your account identifier, for as long as the courtesy campaign exists, so that the same subscription cannot receive courtesy access twice.
  • Chat sample check (Section 5.12): Thor does not keep the text sent or the provider's response, only a technical record without text. At the provider, the text is kept for as long as necessary to provide the service, under its agreement, with no fixed number of days.
  • Consent and acceptance records (acceptance of the Terms and this Policy; turning offers and news notifications on or off): retained while your account exists, as proof of what you authorized, and deleted with it.
  • After account deletion: personal data is erased within 30 days, except where retention is required by law or for the establishment, exercise, or defense of legal claims (GDPR Art. 17(3) / LGPD Art. 16).

8. Your Rights Under GDPR (EU/UK)

If you are in the European Union, European Economic Area, United Kingdom, or Switzerland, you have the following rights:

  • Right of access (Art. 15): obtain a copy of your data.
  • Right to rectification (Art. 16): correct inaccurate data.
  • Right to erasure / "right to be forgotten" (Art. 17): delete your data.
  • Right to restriction (Art. 18): limit how we process your data.
  • Right to data portability (Art. 20): receive your data in structured, machine-readable format (CSV/JSON).
  • Right to object (Art. 21): especially to processing based on legitimate interest.
  • Right to withdraw consent (Art. 7(3)): at any time, without affecting prior processing.
  • Right not to be subject to automated decision-making (Art. 22): including profiling that produces legal effects (we don't do this — AI suggestions always require your manual confirmation).
  • Right to lodge a complaint with your local data protection authority — list at edpb.europa.eu/members.

To exercise any of these rights, email privacy@meuthor.com.br with subject "GDPR Request — [your request]". To delete your account, use Settings → Delete account in the app or visit meuthor.com.br/deletar-conta. We respond within 30 days (extendable by 60 days for complex requests per Art. 12(3)).

9. Your Rights Under CCPA/CPRA (California)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

  • Right to know: what personal information we collect, use, disclose, and sell.
  • Right to delete: request deletion of personal information.
  • Right to correct: request correction of inaccurate personal information.
  • Right to opt out of sale: not applicable — we do not sell personal information as defined by the CCPA.
  • Right to opt out of sharing for cross-context behavioral advertising: not applicable — we do not engage in such sharing.
  • Right to limit use of sensitive personal information: we don't process sensitive info beyond what's necessary for the Service.
  • Right to non-discrimination: we won't deny service, charge different prices, or provide a different quality of service for exercising your rights.

To exercise CCPA rights, email privacy@meuthor.com.br with subject "CCPA Request — [your request]". We verify your identity before fulfilling requests. Response within 45 days (extendable by 45 days). You may also file a complaint with the California Privacy Protection Agency at cppa.ca.gov.

"Do Not Sell My Personal Information": Since we don't sell, no opt-out mechanism is needed, but you can confirm this status by writing to the email above.

10. Your Rights Under LGPD (Brazil)

If you are in Brazil, you have all rights set out in LGPD Article 18:

  • Confirmation of processing existence;
  • Access to data;
  • Correction of incomplete, inaccurate, or outdated data;
  • Anonymization, blocking, or deletion of unnecessary or non-compliant data;
  • Portability to another service provider;
  • Deletion of data processed with consent;
  • Information about data sharing with public/private entities;
  • Information about the possibility of refusing consent and its consequences;
  • Revocation of consent at any time.

Email privacy@meuthor.com.br with subject "LGPD Request — [your request]". Response within 15 days per LGPD. Complaints to the Brazilian National Data Protection Authority (ANPD): gov.br/anpd.

11. Information Security

We implement technical and administrative measures appropriate to the risk:

  • Encryption in transit: TLS 1.2+ on all client-server communication.
  • Encryption at rest: AES-256 for stored data.
  • Row-Level Security (RLS) in the database for strict account isolation.
  • Least-privilege access control for internal team.
  • Multi-factor authentication required for all administrative access.
  • Audit logging of administrative actions and security events.
  • Periodic backups with limited retention.
  • Vendor security review for all sub-processors.

In the event of a personal data breach involving risk to data subjects, we notify the competent supervisory authority within 72 hours (GDPR Art. 33 / LGPD Art. 48 / state breach notification laws) and affected users without undue delay.

12. Cookies and Local Storage

This website (meuthor.com.br) uses PostHog for anonymous pageview and interaction metrics. The integration honors Do Not Track, disables session replay, and uses in-memory persistence without PostHog cookies or persistent browser storage. We do not use:

  • Advertising or marketing cookies;
  • Cross-site tracking;
  • Third-party analytics that profile individual users.

The iOS and Android apps do not use browser cookies but may use platform-protected and local storage for session data and preferences.

13. Children

Thor is not directed to children under 18. We do not knowingly collect data from minors:

  • Under 13 (US — COPPA);
  • Under 16 (EU — GDPR Art. 8, varying by Member State);
  • Under 18 (Brazil — LGPD Art. 14 plus our internal policy).

If we learn we have collected data from a minor without verified parental consent, we will delete it promptly. Parents or guardians who believe their child has provided personal data may contact privacy@meuthor.com.br.

14. Changes to this Policy

We may update this Policy from time to time. The current version is always available at meuthor.com.br/privacy with the date of last update at the top.

For material changes, we notify users at least 30 days in advance via in-app notice and email. Continued use after the effective date constitutes acceptance.

15. Contact

Privacy questions, requests, or complaints:

Supervisory authorities: