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PRIVACY AND DATA PROTECTION POLICY

DANIEL FREIRE SOUZA DE GOIS LTDA. (PULSE FITNESS TECNOLOGIAS DIGITAIS)

Last updated: November 14, 2026

This Privacy Policy describes how Daniel Freire Souza de Gois Ltda., operating under the trade name Pulse Fitness Tecnologias Digitais ("Pulse Nutrition," "we," "us," "our," or "platform"), collects, uses, stores, shares, and protects the personal information and sensitive health data of its users ("User" or "you") in connection with the use of the Pulse Nutrition mobile application and its related services, including the pulsenutri.com.br website.

This Policy has been drafted in strict compliance with the Brazilian General Personal Data Protection Law (Federal Law No. 13.709/2018 – LGPD), the European Union’s General Data Protection Regulation (GDPR – Regulation EU 2016/679), and other applicable legislation.

1. IDENTIFICATION OF THE DATA CONTROLLER AND CONTACT CHANNEL

The entity responsible for the processing of your personal data is Daniel Freire Souza de Gois Ltda., operating under the trade name Pulse Fitness Tecnologias Digitais, registered with the Brazilian Corporate Taxpayer Registry (CNPJ) under No. 55.315.486/0001-49, with its headquarters in Curitiba/PR, Brazil.

For questions, requests regarding your rights, or matters related to privacy and data protection, you may contact our Data Protection Officer (DPO):

2. FUNDAMENTAL DEFINITIONS

For the purposes of reading and interpreting this document, the following definitions apply:

  • Personal Data: Information relating to an identified or identifiable natural person.
  • Sensitive Personal Data: Personal data concerning racial or ethnic origin, religious belief, political opinion, membership in a trade union or an organization of a religious, philosophical, or political nature; data concerning health or sex life; or genetic or biometric data, when linked to a natural person.
  • Processing: Any operation performed on personal data, such as those relating to the collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control, modification, communication, transfer, dissemination, or extraction of information.

3. PERSONAL DATA COLLECTED AND PURPOSES OF PROCESSING

Pulse Nutrition collects and processes different categories of personal data in order to provide and improve its nutrition and physical training services. The table below specifies the types of data collected and the purposes for which they are processed. When the User is followed by a nutritionist or physical education instructor, meal and training plans are created by these professionals. Some features work through automated means, always based on the data provided by the User or the professionals and producing estimates only: the calculation of BMI, basal metabolic rate, daily energy expenditure and daily calorie and water goals (which the User or the nutritionist can adjust manually), progress toward the target weight and, for Users without a nutritionist, the generation of the meal plan from their objective and goals.

Data Category Types of Data Collected Purpose of Processing
Registration Data Full name, email address, CPF (mandatory in Brazil), country, language, encrypted password, and—optionally—phone number and profile photo. Account creation, user identification, access authentication, and operational communication (emails and in-app notifications).
Financial Data Contracted plan, subscription status, and billing history. Card details are provided directly to the payment partner (Stripe) and are not stored on our servers. Processing of subscription payments and billing management.
Profile Data and Goals Date of birth (and the age calculated from it), objective, gender, height, target weight, and daily goals for water intake, calories, protein, carbohydrates, and workouts. Confirmation of the minimum age of 18; personalization of tracking and reminders within the application; automated calculation of BMI, basal metabolic rate, daily energy expenditure, and calorie and water goals (based on age, gender, height, most recent weight, objective, and weekly workouts); tracking of progress toward the target weight; and generation of the meal plan by Users without a nutritionist.
Sensitive Health Data Answers to the health questionnaire (anamnesis) completed by the User (medical conditions, medications and supplements, allergies and intolerances, surgeries, pain and injuries, habits, sleep, and family history) and its previous versions; weight, body fat percentage, muscle mass, body measurements and the BMI calculated from them, training restrictions and injuries, physical assessment and progress photos, water consumption logs, as well as comments and pain levels reported upon completing a workout. Health questionnaire, physical and nutritional assessment, creation and adjustment of meal and workout plans, automated calculation of daily goals, and monitoring of the User’s progress (including progress charts).
Workout and Nutrition Usage Data Sets, loads, and repetitions performed, completed workouts, meals from the plan, and shopping lists. Recording the execution of plans and monitoring by the professional in charge.
Website Browsing Data Only if the visitor accepts cookies on the pulsenutri.com.br website: pages and sections visited, buttons clicked, questions opened, language, device and browser type, approximate city, and a random identifier stored in a cookie. Measuring the website's reach and which paths lead to sign-up and subscription, using Google Analytics, in aggregate figures.

Cookies on the website. The pulsenutri.com.br website uses Google Analytics cookies (_ga and _ga_<identifier>) solely for audience measurement, valid for up to 2 years, and only after the visitor clicks "Accept" on the cookie notice. Without acceptance, none of these cookies are stored and no browsing data is sent to Google. The choice is stored in the browser itself and can be changed at any time through the "Cookie preferences" link in the website footer; upon refusal, the Google Analytics cookies are deleted. We do not use advertising cookies, website data is not used for ads, and it is not combined with the account data in the application. The mobile application does not use Google Analytics.

4. LEGAL BASES FOR PROCESSING

The processing of personal data by Pulse Nutrition is strictly based on the legal grounds authorized by current legislation:

  • Performance of a Contract (Art. 7, V of the LGPD): Processing of registration and financial data essential for the provision of the contracted services.
  • Data Subject Consent (Art. 11, I of the LGPD): For the processing of sensitive health data (health questionnaire, body measurements, physical restrictions and injuries, assessment records, and body photos), consent is provided upon the creation of your account in the application, when you agree to this Policy and the Terms of Use. This consent may be revoked at any time (see section 7).
  • Compliance with a Legal or Regulatory Obligation (Art. 7, II of the LGPD): Retention of application access logs to comply with the Brazilian Internet Civil Rights Framework (Marco Civil da Internet – Law No. 12.965/2014) and tax obligations.
  • Legitimate Interest (Art. 7, IX of the LGPD): For the continuous improvement of the application’s features, anonymized statistical usage analysis, and fraud prevention.
  • Consent (Art. 7, I of the LGPD): For the website's audience measurement cookies, given through the cookie notice and revocable at any time through the "Cookie preferences" link.

5. DATA SHARING WITH THIRD PARTIES

Pulse Nutrition respects the confidentiality of your data. Data is shared only when strictly necessary and for the purposes described below:

  • Accredited Health and Physical Education Professionals: Data regarding physical and nutritional assessments, as well as training restrictions, may be accessed by nutritionists and/or physical education professionals affiliated with the platform who are working with the data subject, for the purpose of developing personalized plans. Health questionnaire answers and body-related records entered into the application (measurements and progress photos), as well as comments and pain levels reported upon completing a workout, are visible—in a read-only format—to the nutritionist and physical education professional currently working with the user; the administrative team does not have access to these photos. All professionals are bound by both contractual and ethical obligations regarding professional confidentiality.
  • Third-Party Service Providers: Data is shared with providers for cloud hosting (Amazon Web Services), payment processing (Stripe), email delivery (Resend), and mobile notifications (Expo, Apple, and Google), and website audience measurement (Google Analytics, only with the visitor's consent). These partners act as data processors under the instructions of Pulse Nutrition and receive only the data necessary to perform their specific services.
  • Judicial Orders or Legal Requirements: Data may be shared if requested by a competent police, judicial, or governmental authority, in strict compliance with the law.

Important: Under no circumstances does Pulse Nutrition sell or rent its users' personal or sensitive data to third parties.

6. DATA STORAGE AND SECURITY

We implement appropriate technical, administrative, and organizational measures to protect your personal data against unauthorized access, loss, destruction, alteration, or any form of improper or unlawful processing:

  • Encryption of data transmitted between the application, the dashboard, and our servers (using TLS/HTTPS protocols);
  • Assessment and progress photos stored in a private environment, accessible only via the user’s application or the dashboard used by the professionals overseeing their care;
  • Access control based on necessity (the principle of least privilege), ensuring that health data is accessible only to the professionals responsible for the user’s care;
  • Regular updates to system components and the application of security patches;
  • Passwords stored exclusively as cryptographic hashes—never in plain text.

7. DATA SUBJECT RIGHTS

In accordance with the LGPD (General Data Protection Law) and the GDPR (General Data Protection Regulation), you have the following rights regarding your personal data:

  1. Confirmation and Access: To confirm the existence of data processing and to access your registration and health data stored within the application.
  2. Correction: To request the rectification of incomplete, inaccurate, or outdated data.
  3. Anonymization, Blocking, or Deletion: To request appropriate handling of data that is unnecessary, excessive, or processed in violation of the law.
  4. Portability: To request the transfer of your data to another service provider, upon express request and subject to the protection of trade and industrial secrets.
  5. Revocation of Consent and Deletion: To revoke, at any time, the consent granted for the processing of health data, and to request the deletion of your account and any associated sensitive data.
  6. Information Regarding Sharing: To receive clear information about the public and private entities with which Pulse Nutrition has shared your data.
  7. Review of Automated Decisions (Art. 20 of the LGPD): To request a review of results produced solely by automated processing, such as the calculated goals and the generated meal plan. Goals can also be adjusted at any time under Profile → Edit details or by the nutritionist working with the User.

You may delete your account directly within the application by navigating to Profile → Account and Privacy → Delete My Account. All other requests are free of charge and can be made by sending a direct message to our DPO at dpo@pulsenutri.com.br.

8. DATA RETENTION AND DELETION

Personal and sensitive data will be retained for as long as the User maintains an active account or for the period necessary to provide the contracted services.

Following a request by the User to delete their account, or upon the termination of the contractual relationship:

  • Sensitive health data (including all versions of the health questionnaire), as well as assessment and progress photos, are removed from Pulse Nutrition’s active databases at the time of deletion; backup copies may retain this information for a limited period until overwritten during the standard retention cycle (further details can be found on the "Account Deletion" page).
  • Certain personal data and connection logs may be retained for longer periods if required to comply with legal, regulatory, or tax obligations, or for the purpose of defending the company in judicial or administrative proceedings.

Website browsing data, whether or not the visitor has an account in the application, is kept in Google Analytics for up to 14 months and is then automatically deleted.

9. INTERNATIONAL DATA TRANSFER

Pulse Nutrition’s servers, databases, and photos are hosted on Amazon Web Services in the São Paulo (Brazil) region. Some data is processed outside of Brazil by the partners mentioned in Section 5, specifically those involved in payment processing (Stripe), email delivery (Resend), and mobile notifications (Expo, Apple, and Google), and website audience measurement (Google Analytics).

In such cases, we ensure that any international data transfer is made only to countries that provide a level of personal data protection equivalent to that required by the LGPD (Brazilian General Data Protection Law), or through the implementation of equivalent contractual guarantees and safeguards.

10. CHANGES TO THIS PRIVACY POLICY

Pulse Nutrition reserves the right to update or modify this Privacy Policy at any time to reflect improvements to the application, legislative changes, or new operational requirements.

We will notify the User of any significant changes via the application itself or through the email address registered on the account before such changes take effect. We recommend reviewing this document periodically.

11. LEGISLATION AND JURISDICTION

This Policy shall be governed, interpreted, and enforced in accordance with the laws of the Federative Republic of Brazil, regardless of the location from which the User accesses it. The courts of the judicial district where the User resides are designated as the competent forum to resolve any disputes arising from this document.