Privacy Policy
2026-10-19
This document is a draft pending legal review. This Privacy Policy explains what personal data Sibila collects, why, with whom it is shared, how long it is kept and how you can exercise your rights.
1. Who is responsible for your data
The controller of your personal data is [PENDENTE: razão social e endereço], registration number [PENDENTE: CNPJ/NIF].
Contact: [PENDENTE: e-mail de contato]. Data protection officer: [PENDENTE: encarregado/DPO].
2. Account data
If you create an account, we store your email address, your password as a scrypt hash, an optional display name, your language (locale), your market and your time zone.
3. Readings and journal
We store your readings: the question you asked, the cards drawn, the AI-generated text (when applicable) and any journal notes you add.
4. Credits, orders and payments
We keep a credit ledger recording credits added and used in your account.
For each order we store the amount, the currency, the billing country provided by Stripe and the order status.
Payments are processed by Stripe. We never see or store your full card data.
To grant the signup bonus only once per email address, we keep a keyed hash of the email address, even after the account is deleted.
5. Guests
If you use Sibila without an account, we apply the limit of 1 free reading per day using a signed first-party cookie and a keyed hash of your IP address. We do not store your raw IP address.
Retention period for these identifiers: [PENDENTE: prazo de retenção dos identificadores de visitante].
6. AI processing
When AI interpretations are enabled, the question, the cards and any previous follow-ups of that reading are sent to Anthropic (Claude API) to generate a personalized text.
Account holders give consent at signup and can turn this off at any time in account settings. With it off, only the classic interpretation is shown and no reading data is sent to Anthropic. Guests are shown a notice about this processing.
We do not use your readings to train models.
7. Cookies and measurement
Essential cookies are needed for the service to work: session, visitor identifier, language, market and your consent choice.
Optional measurement tools (Google Analytics and Meta Pixel) only load after you give explicit consent. Rejecting them takes one click.
We also record first-party analytics events containing the event name and a keyed visitor hash. Campaign parameters (UTM) are recorded only if you consent to measurement.
8. Purposes and legal bases
Contract: to create and run your account, provide readings, manage credits, process purchases and subscriptions.
Consent: for AI interpretations and for optional measurement (Google Analytics, Meta Pixel and campaign parameters). You can withdraw consent at any time.
Legitimate interest: for fraud prevention, including the daily guest limit and the one-time signup bonus.
Legal obligation: to keep tax records of orders and credits.
9. Who we share data with
We use the following processors: Stripe (payments), Anthropic (AI interpretations), Resend (password-reset emails) and our hosting provider, [PENDENTE: provedor de hospedagem e país].
If you consent to measurement, data is also collected by Google (Google Analytics) and Meta (Meta Pixel).
International data transfers: [PENDENTE: países e mecanismos de transferência internacional].
10. How long we keep data
Account data is kept while your account exists.
Orders and the credit ledger are kept for the period required by tax law: [PENDENTE: prazo fiscal].
Analytics events are kept for 13 months.
11. Your rights and how to exercise them
You can access and correct your data, and withdraw any consent you have given.
Export: on your account page you can download your data as a JSON file.
Deletion: on your account page you can delete your account. This deletes your readings, journal and personal data, anonymizes the account and cancels any active subscription. Order and credit records required for tax and anti-fraud purposes are kept without your email address.
For any other request, contact [PENDENTE: e-mail de contato].
12. Rights by region
Brazil: you have the rights provided by the LGPD (Law 13,709/2018) and may file a complaint with the ANPD (National Data Protection Authority).
Spain and the European Union: you have the rights provided by the GDPR (RGPD), including access, rectification, erasure, portability, objection and restriction, and may file a complaint with the AEPD (Spanish Data Protection Agency).
United States: residents of states with privacy laws, such as California (CCPA/CPRA), have rights that include knowing, accessing, correcting and deleting their personal information. We do not sell or share personal information for cross-context behavioral advertising without consent.
13. Security and minors
Passwords are stored only as scrypt hashes, sessions use httpOnly cookies, IP addresses are kept only as keyed hashes and full card data never reaches our systems.
Sibila is for people aged 18 or older and is not directed at minors.