1. Introduction
ParentLevel ("we", "us", or "our") is a digital platform for personal and family development, with gamification features, aimed at adults including parents, legal guardians, and caregivers. Our goal is to support the building of habits, routines, and family bonds in a structured and intentional way.
This Privacy Policy describes how we collect, use, store, share, and protect personal data in the context of using our services, including the app, website, and related features ("Services").
By creating an account, accessing, or using the Services, you declare that you have read, understood, and agree to this Privacy Policy. If you do not agree with any part of this Policy, you should not use the Services.
This Policy applies to users in different jurisdictions and was developed considering applicable data protection laws, including the Brazilian General Data Protection Law (Lei nº 13.709/2018 - LGPD), the European Union General Data Protection Regulation (GDPR), and, where applicable, the Children's Online Privacy Protection Act (COPPA) in the United States.
If you use the Services on behalf of third parties, including children or other family members, you represent that you have the legal authority to do so and assume responsibility for the information provided, as detailed in this Policy and the Terms of Service.
2. Definitions
For the purposes of this Privacy Policy, the terms below shall have the following meanings:
- "Personal Data": any information that identifies or may identify a natural person, directly or indirectly.
- "Data Subject": the natural person to whom the Personal Data relates.
- "User": the person who accesses or uses the Services, including the account holder and any individuals authorized by them.
- "Legal Guardian": the person with legal authority to act on behalf of another, including parents or guardians of children and adolescents.
- "Child": a minor as defined by applicable law in your jurisdiction.
- "Family Account": an account structure maintained by a primary User that may include other authorized users and related profiles, including children, under their responsibility.
- "Services": all products, features, applications, websites, and services offered by ParentLevel.
- "Data Processing": any operation performed on Personal Data, including collection, use, storage, sharing, deletion, or any other form of processing.
- "Controller": the entity responsible for decisions regarding the Processing of Personal Data, as defined by applicable law.
- "Processor": the entity that carries out the Processing of Personal Data on behalf of the Controller.
3. Information We Collect
We collect and process different categories of personal data as necessary to provide, operate, improve, and protect the Services.
- Account information: Data provided directly by you when creating or managing your account, including name, email address, and user identifiers, as well as other information you choose to provide.
- Data related to children: Information voluntarily entered by you about children in your care, such as name, age or date of birth, routines, tasks, and progress. This data is provided exclusively by the Legal Guardian and remains linked to your Family Account. We do not collect data directly from children.
- Usage and activity data: Information about how you use the Services, including completed challenges, scores (XP), achievements, streaks, check-in logs, interactions, and other activities performed within the app.
- Social connections: Information related to connections with other users, such as account identifiers and relationship status (e.g., partners or friends), used to enable collaborative features such as co-parenting and shared experiences.
- Reproductive health and wellness data (optional): When you choose to use features related to menstrual cycle tracking or the pregnancy journey, we collect data you provide, such as menstruation dates, cycle length, estimated due date, gestational week, and associated emotional logs. This data is treated as a special category of personal data, processed exclusively based on your explicit consent, and never shared with third parties without your authorization, except as described in this Policy.
- Usage and analytics data: Information about browsing and use of the Services, such as pages accessed, features used, session duration, and interactions. This data may be collected based on consent or our legitimate interest in improving the user experience, as applicable.
- Technical and device data: Technical information automatically collected, such as IP address, device type, operating system, browser, technical identifiers, access logs, and error data, used for security, stability, and Service improvement.
- Payment information: If you subscribe to a paid plan, payment processing is handled by third-party providers. We do not store full credit card data or sensitive financial information in our systems.
- Data from third parties: We may receive data from service providers involved in operating the Services, such as authentication and payment providers, strictly to enable features such as secure login and subscription processing.
The use of reproductive health features is entirely voluntary. We do not collect other special category personal data unrelated to the above purposes, such as racial or ethnic origin, religious beliefs, biometric data, or political opinions, unless with your explicit consent and for a specific purpose.
We limit data collection to the minimum necessary to fulfill the purposes described in this Policy, and may update the categories of data collected as the Services evolve, always in compliance with applicable law.
4. How We Use Your Information
We use your personal data to operate, provide, maintain, improve, and protect the Services, including for the following purposes:
- Create, authenticate, and manage your account, and enable your secure access to the Services;
- Provide personalized features, including challenges, progress tracking, and recommendations based on information you provide, including data related to children in your care;
- Enable social and collaborative features, such as partner or friend connections, shared experiences, and co-parenting features;
- Process subscriptions, manage billing, and facilitate financial transactions through payment providers;
- Send service-related communications, including operational notifications, confirmations, security alerts, and other messages necessary for the functioning of the Services;
- Analyze use of the Services for the purpose of improving features, performance, and user experience, using aggregated data or, where applicable, based on consent;
- Monitor, detect, and prevent fraudulent activity, unauthorized access, abuse, or violations of the Terms of Service;
- Ensure the security, integrity, and stability of the Services, including fault diagnosis, error analysis, and infrastructure maintenance;
- Comply with legal and regulatory obligations and exercise rights in administrative, judicial, or arbitral proceedings, when necessary.
We do not use your personal data for automated decisions that produce legal or significantly impactful effects on you, under applicable law.
5. Legal Bases for Processing
We process personal data in accordance with the legal bases provided by applicable law, including the Brazilian General Data Protection Law (LGPD) and the General Data Protection Regulation (GDPR). The legal bases we use include:
- Performance of a contract: Processing necessary to create, maintain, and administer your account, as well as to provide and operate the contracted Services, including essential features, experience personalization, and user support.
- Legitimate interests: Processing necessary to pursue ParentLevel's legitimate interests, including continuous improvement of the Services, usage analysis, new feature development, information security, fraud prevention, abuse prevention, and prevention of unauthorized access. We always assess the impact of such processing on your rights and freedoms, ensuring they do not override your fundamental interests. Additional information about this assessment may be requested through our contact channels.
- Consent: Where required by law, we process data based on your consent, including the use of non-essential cookies, tracking technologies, and certain analytics activities. You may revoke your consent at any time without affecting the lawfulness of processing carried out prior to revocation.
- Explicit consent for health data: The processing of reproductive health data — including menstrual cycle data, pregnancy information, and emotional check-ins linked to these features — is carried out exclusively based on the user's explicit consent, pursuant to Article 11(I) of the LGPD and Article 9(2)(a) of the GDPR. You may revoke this consent at any time through the app settings, which will result in deactivation of these features, without affecting overall use of the Services or the lawfulness of processing already carried out.
- Legal or regulatory obligation: Processing necessary to comply with applicable legal or regulatory obligations, including tax, accounting, audit requirements, and responses to competent authorities.
6. Children's Data and Parental Responsibility
The Services are intended exclusively for adults, including parents, legal guardians, and caregivers. We do not allow children to create accounts directly on our platform.
ParentLevel may allow Users to enter information related to children in their care, such as name, age, routines, tasks, and progress, exclusively for the purpose of using the Service's features. This data is voluntarily provided by the Legal Guardian and remains linked to their Family Account.
We do not intentionally collect personal data directly from children. All processing of data related to children is based on information provided by the Legal Guardian.
By entering a child's data, you represent and warrant that you have the legal authority to do so and are authorized to provide such information and to consent to the processing of that data, where applicable.
The User is fully responsible for the accuracy, legality, and appropriateness of data provided about third parties, including children. ParentLevel does not independently verify the User's authority to provide such data, except as required by law.
Legal Guardians may at any time access, correct, or request deletion of data related to children in their care, as described in the "Your Rights" section of this Policy.
If we become aware that a child's data has been collected or entered in violation of this Policy or applicable law, we may take steps to remove such data and restrict or terminate the associated account as necessary.
7. Sharing Your Information
We do not sell, rent, or trade your personal data. We may share your information only as necessary for the purposes described in this Policy and in the following circumstances:
- Service providers (processors): We may share personal data with service providers acting on our behalf to enable the operation of the Services, including, for example: user authentication, payment processing, cloud storage and infrastructure, usage analytics, communications delivery, and error monitoring. These providers have access only to the data necessary to perform their functions and are subject to contractual obligations of confidentiality, security, and data protection, and may not use the information for their own purposes.
- Other users and social features: Certain Service features allow limited viewing of profile information by other users you connect with, such as name, level, or progress. Rankings and shared experiences may display similar data as configured by you. You can manage connections and visibility preferences directly in your account settings.
- Compliance with legal obligations: We may disclose personal data when required by law, regulation, court order, or valid request from a competent authority, as well as to protect the rights, safety, and integrity of ParentLevel, our users, or third parties.
- Corporate transactions: In the event of a merger, acquisition, corporate reorganization, or sale of assets, your personal data may be transferred as part of the transaction. In such cases, we will take steps to ensure continued data protection and will notify you as required by applicable law, including regarding any material changes to this Policy.
Whenever we share personal data, we limit access to the minimum necessary for the intended purpose and take steps to ensure that recipients meet appropriate data security and protection standards.
Some of the service providers we use may be located outside your country of residence. In such cases, we adopt appropriate safeguards for international data transfers, as described in this Policy.
8. Cookies and Analytics
We use cookies and similar technologies, such as device identifiers, local storage, and analytics tools, to operate, protect, and improve the Services.
- Essential cookies and technologies: Necessary for the basic functioning of the Services, including authentication, session management, security, and performance. These cannot be disabled as they are indispensable for the app to operate.
- Analytics cookies and technologies (optional): Used to understand how users interact with the Services, identify usage patterns, and improve features. This data may be collected in aggregated and/or pseudonymized form, and its use is subject to your consent where required by applicable law.
Where necessary, we will request your consent before using non-essential cookies or technologies. You may manage, grant, or revoke your consent at any time through the settings available in the app or on your device.
Disabling essential cookies may impact the functioning of the Services. For more information on how we use data for analytics and improvement, please consult the other sections of this Policy.
9. International Data Transfers
Your personal data may be transferred, stored, and processed in countries other than the one in which you reside, including countries where ParentLevel or its service providers operate. These countries may have different levels of data protection than those provided in your home jurisdiction.
When we carry out international transfers of personal data, we adopt appropriate measures to ensure an adequate level of protection, in compliance with applicable law, including the Brazilian General Data Protection Law (LGPD) and the General Data Protection Regulation (GDPR). These measures may include the use of Standard Contractual Clauses approved by competent authorities, as well as other recognized legal mechanisms.
We also adopt practices to ensure that our service providers are subject to data protection obligations compatible with this Policy, including security, confidentiality, and limited use requirements.
By using the Services, you acknowledge that your personal data may be transferred and processed as described in this section.
10. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes described in this Policy, as well as to meet legal, regulatory, and contractual obligations and to protect our legitimate interests.
- Active accounts: We retain your personal data while your account is active and as necessary to provide the Services.
- Deleted accounts: When you request deletion of your account, your personal data is removed or anonymized within a reasonable time, unless retention is necessary to comply with legal or regulatory obligations, resolve disputes, prevent fraud, or exercise rights. In some cases, residual copies may temporarily remain in backups and recovery systems before being eliminated according to our retention cycles.
- Legal and regulatory obligations: Certain information may be retained for additional periods when required by law, such as financial and accounting records, which may be kept for the applicable legal period.
- Analytics and improvement data: We may retain data used for analytics and Service improvement in aggregated and/or pseudonymized form, as long as it does not allow direct identification of users, as applicable.
The criteria used to determine retention periods include the nature of the data, processing purposes, applicable legal requirements, and the need to protect ParentLevel's legitimate interests.
11. Your Rights
Under applicable law, including the Brazilian General Data Protection Law (LGPD) and the General Data Protection Regulation (GDPR), you have rights regarding your personal data, which may include:
- Confirmation of processing: Request confirmation of the existence of processing of your personal data.
- Access: Request access to the personal data we hold about you.
- Rectification: Request correction of incomplete, inaccurate, or outdated data.
- Erasure ("right to be forgotten"): Request deletion of your personal data, where applicable, subject to legal and regulatory obligations that may require its retention.
- Portability: Request portability of your data to another service provider, in accordance with applicable regulation.
- Restriction of processing: Request limitation of the processing of your data in certain circumstances provided for by law.
- Objection: Object to processing of data carried out on the basis of legitimate interests, where applicable.
- Withdrawal of consent: Revoke previously granted consent for data processing, where that is the applicable legal basis, without affecting the lawfulness of processing carried out prior to revocation.
- Review of automated decisions: Request review of decisions made solely based on automated processing of personal data that affect your interests, where applicable.
To exercise your rights, you may contact us through the channels indicated in the "Contact Us" section. We may request additional information to confirm your identity before fulfilling the request, in order to protect your personal data from unauthorized access.
We will respond to requests within the time limits provided by applicable law, which may be extended where permitted by law, depending on complexity and volume of requests received.
In certain situations, we may not be able to fully comply with a request, for example when doing so would violate legal obligations, third-party rights, or compromise the security and integrity of the Services.
If you believe your rights have not been respected, you have the right to lodge a complaint with the competent data protection authority, such as the National Data Protection Authority (ANPD) in Brazil or the corresponding supervisory authority in the European Union.
12. Changes to This Policy
We may update this Privacy Policy periodically to reflect changes in the Services, legal requirements, or improvements in our data processing practices.
When we make material changes, we will take reasonable steps to notify you, such as through the app, email, or other appropriate channels, as required by applicable law.
Where necessary, especially in cases where law requires consent for certain changes, we will request your express acknowledgment before such changes take effect.
In specific situations, such as compliance with a legal obligation or the need to protect the security and integrity of the Services, we may implement changes with immediate effect.
By continuing to use the Services after changes take effect, you agree to the updated version of this Policy, unless applicable law requires a specific indication of consent.
We recommend that you review this Policy periodically. We may retain previous versions for reference, as applicable.
13. Contact Us
ParentLevel acts as the controller of personal data processed in the context of the Services described in this Policy.
For questions, requests, or to exercise rights related to your personal data, you may contact our privacy team through the following channel:
Email: parentlevel@gmail.com
We may request additional information to verify your identity before processing certain requests, in order to protect your personal data from unauthorized access.
We will respond to requests within the time limits provided by applicable law, as described in the "Your Rights" section of this Policy.
For general questions, we will do our best to respond within a reasonable time, taking into account the complexity of the request and the volume of inquiries received.
14. User Responsibilities
By using the Services, you agree to comply with this Privacy Policy and the Terms of Service, and are responsible for appropriate use of your account and the information you provide.
- Account security: You are responsible for maintaining the confidentiality of your access credentials and for all activities carried out in your account. You must notify us immediately of any unauthorized use or suspected security breach.
- Accuracy of information: You commit to providing true, up-to-date, and complete information, and are responsible for correcting or updating data when necessary.
- Third-party and children's data: When entering personal data of third parties, including children, you represent that you have the legal authority to do so and assume full responsibility for the content, legality, and appropriateness of such information.
- Appropriate use of the Services: You agree not to use the Services for illegal, abusive, fraudulent purposes, or in ways that violate third-party rights, including privacy and data protection.
- Family account and linked users: The Family Account holder is responsible for all users, profiles, and data associated with their account, including those linked to partners, family members, or children.
ParentLevel is not responsible for data entered incorrectly, without authorization, or in violation of applicable law, and the User is solely responsible for such information.
15. Limitation of Liability
The Services are provided "as is" and "as available", without warranties of any kind, express or implied, except as required by applicable law.
- User-provided content: ParentLevel is not responsible for the accuracy, legality, or appropriateness of data and content entered by Users, including information related to third parties and children.
- Use of the Services: Use of the Services is your sole responsibility. ParentLevel is not responsible for decisions, actions, or consequences arising from the use of information or features made available.
- Availability and continuity: While we strive to keep the Services available and secure, we do not guarantee that they will be uninterrupted, error-free, or entirely secure.
- Third-party services: ParentLevel is not responsible for third-party services, systems, or platforms used in operating the Services, including any failures, unavailability, or data processing carried out by those providers.
- Information security: Despite measures adopted to protect personal data, no system is completely secure. ParentLevel cannot guarantee absolute security against unauthorized access, data loss, or data alteration.
To the maximum extent permitted by applicable law, ParentLevel shall not be liable for indirect, incidental, special, consequential, or punitive damages, including loss of data, profits, or revenue, arising from or related to the use or inability to use the Services.
Nothing in this Policy limits or excludes liability that cannot be limited or excluded under applicable law.