Santolingo privacy policy

Version 0.1, draft dated 2026-10-01, under review. English translation of the Portuguese policy, which prevails in case of conflict. It supplements the Gracefold privacy policy, which applies to everything not covered here.

Summary. Santolingo does not ask for an account, name, e-mail or phone number. It has no ads, no tracking SDKs and does not sell data. Your progress stays on your device. The app uses the internet to download lesson content and, if you choose, the camera to recognize the physical cards and the microphone for pronunciation practice.

1. Who is responsible

Santolingo is published by GRACEFOLD TECH LTDA, CNPJ 69.276.507/0001-79, SAUS Quadra 4, Bloco A, s/n, Sala 513 Parte 1002, Plano Piloto, Brasília/DF, CEP 70070-938, Brasil, which is the controller of the data described in this policy. Data protection officer: privacy@gracefold.tech.

2. What the app does not do

3. Data that stays only on your device

To work, the app stores locally, in its own space on your device:

This data is not sent to Gracefold. It is deleted when you uninstall the app. Automatic system backups (iCloud, Google) may include it, depending on your device settings and the policies of Apple and Google.

4. Data processed when the app uses the internet

The app connects to the network to download the content catalog, lesson packs, images and audio, and to check for content updates. These requests go to Gracefold servers running on Cloudflare infrastructure. As with any internet access, the server records technical data: IP address, date and time, resource requested, and app and system identification (user agent). The logs are used for security and diagnostics and kept for a short period. They are not linked to a profile of yours, because the app has no profile or user identifier.

Legal basis: performance of the service you requested by using the app (LGPD, art. 7, V) and legitimate interest in the security of the service (art. 7, IX).

5. System permissions

PermissionPurposeWhat happens to the data
CameraRecognize the code on Santolingo physical cards to open the card in the app.Images are processed on the device in real time; they are not recorded or sent anywhere.
Microphone and speech recognitionPronunciation practice and voice search: the app listens to the word you say and checks whether it matches.Audio is processed by the operating system's own speech recognition service (Apple or Google). Depending on the device and language, that service may process audio on Apple's or Google's servers under their privacy policies. Gracefold does not receive or store the audio.
NotificationsStudy reminders you set up.Local notifications scheduled on the device. Gracefold runs no notification server.
InternetDownload content and check for updates.See section 4.

All permissions are optional and can be revoked in the device settings; the corresponding features stop working.

6. Third-party services

7. In-app purchases

If the app offers purchases, they are processed by Apple or Google, who are responsible for payment data. Gracefold has no access to your card or account. Refund requests follow the store's rules; under Brazilian consumer law (CDC, art. 49) you may withdraw from a distance purchase within seven days by contacting support.

8. Children and teenagers

Santolingo may be used by people of any age under the responsibility of their parents or guardians. Because the app requires no account and collects no identifying data, no personal data of children is collected beyond the technical logs in section 4. There are no profiles, behavioural advertising, chat or social features. The app's age rating is the one shown on the store page.

9. How to delete your data

Uninstall the app: this deletes all downloaded content, your progress and your preferences. As there is no account, there is nothing to delete on our servers. For any request about personal data (including technical logs), write to privacy@gracefold.tech.

10. Your rights and contact

Data subject rights (LGPD, art. 18), response times, international transfers, security measures and the incident procedure are described in the Gracefold privacy policy. App support: support@gracefold.tech.

11. Changes

Changes to this policy will have a new version number and date on this page. If a new app version processes data differently, the policy will be updated before that version is released.

Version history