Privacy Policy · Flutue

Honest summary. Flutue is a financial organization tool. We process data necessary to operate the service, optional data for advanced features, and analytics data for security and improvement. We do not sell your data. Part of the processing and storage occurs outside Brazil (see section 11). AI features may send content you provide to third-party operators for processing (see section 7). You control your data and can export or delete it through the app.

1. Controller, scope and contact

The data controller is Flutue, individual responsible for operating Flutue. This Policy applies to individuals who access the website, use the Flutue app, interact with support, receive communications or use features connected to the product.

Flutue is intended for persons aged 18 or older (section 16). Contact for privacy and exercise of rights: contato@flutueapp.com.br. General support: suporte@flutueapp.com.br.

2. Principles and processing commitment

We process data with legitimate purpose, adequacy, necessity, transparency, security, prevention, non-discrimination, accountability and rendering of accounts (LGPD, art. 6). We seek to limit processing to what is necessary to operate, protect, improve and prove compliance of Flutue.

We do not sell personal data.
We do not use your personal data to train our own or third-party AI models for their own purposes without adequate legal basis, transparency and consent when required.
Financial values of entries and recurrences are encrypted (AES-256-GCM) before being stored.

3. Categories of data processed

3.1 Data necessary to operate the service

Account and identification: internal identifier (UID), email, name, profile photo provided by the provider and linked login provider (e.g., Google).
Financial data entered by you: income, expenses, transfers, categories, accounts and banks, credit cards (nickname and, when provided, last digits — Flutue does not collect the full number or card password), reported balances, recurrences, goals and budgets. Monetary values of transactions and recurrences are stored encrypted.
Settings and account: currency, language, theme, functional preferences, subscription plan, Couple Account group identifier and account deletion status.
Device, session and security data: device identifier, platform, app version, language, notification token (FCM), login events, crashes, technical logs and anti-fraud signals.

3.2 Profile and onboarding data (optional)

Date of birth, gender, occupation, interests, monthly income range and main financial goal.
Address and phone number, when you provide them.

3.3 Content and advanced features (optional)

Attachments: receipt images, audio (voice notes) and profile photo you send.
Location: coordinates associated with a transaction (when authorized) and merchant addresses extracted from receipts, used in the spending map.
Free text: descriptions, notes and entry titles.

3.4 Biometrics and local authentication

Biometrics (Face ID, Touch ID or fingerprint) and PIN, when enabled, are processed and stored only on your device (Keychain/Keystore). Flutue does not collect, receive or store your biometric data.

3.5 Analytics and usage

Usage events, accessed screens, interactions, performance, stability and diagnosis, including through behavioral analytics tools (section 9).
Aggregated or pseudonymized data for metrics, improvement and security.

3.6 Sensitive and third-party data

Flutue was not designed to collect sensitive data. As you may enter free text, attachments, receipts and audio, these materials may contain sensitive or third-party data. Avoid sending unnecessary data, especially health information, religion, political opinion, children's data and third-party data without authorization.

4. Bank and benefit notification capture (Android)

On Android, Flutue offers, in an optional and user-activated manner, a feature that automatically organizes entries from movement notifications of bank apps and benefit cards that you select.

The feature depends on specific permission granted by you in system settings and can be disabled at any time.
Information such as the source app, movement notification content, amount and, when available, the merchant, is processed only to suggest an entry to your account.
Processing of this feature occurs on your device and the resulting entry is restricted to your Flutue account, pending your confirmation.
Flutue does not access credentials, passwords or login data of financial institutions.
This feature is not available on iOS due to platform limitations.

5. Data sources

Data provided directly by you in the app, website, onboarding, support or consent flows.
Data generated by use, such as technical events, logs, metadata and preferences.
Data received from authentication providers, app stores, payment platforms, infrastructure, analytics and technical partners, according to your interaction and permissions.
Data inferred or calculated by Flutue, such as suggested categories, recurrences, spending patterns and insights.
In the case of the Couple Account, data entered by the other group member (section 8).

6. Purposes and legal bases

Contract execution (LGPD, art. 7, V): create and authenticate account, sync data, process entries, provide features, manage plans, support and essential preferences.
Consent (art. 7, I): non-essential cookies, optional location, notification capture on Android, optional AI/OCR/audio features, promotional communications when required and experimental features dependent on authorization.
Legal or regulatory obligation compliance (art. 7, II): compliance with valid orders, mandatory records and applicable legal duties.
Regular exercise of rights (art. 7, VI): prevention and defense in proceedings, billing disputes, fraud, incidents and audits.
Legitimate interest (art. 7, IX): security, fraud prevention, product improvement, operational metrics, abuse prevention, error correction and transactional communications compatible with your expectations.

7. AI, OCR, audio, automation and human review

To recognize receipts, transcribe audio, suggest and categorize entries, extract statements and generate insights, Flutue uses on-device OCR and third-party artificial intelligence operators, which may be located outside Brazil (section 11).

Initial OCR may occur on the device. When you use advanced processing, the receipt image, audio or corresponding text may be sent to AI operators to generate the entry suggestion.
Voice audio sent for transcription is deleted after processing; the result used is the structured entry derived from it.
Insights and categorizations may use transaction data and minimized or pseudonymized data whenever technically feasible.
Automated results are auxiliary and may contain errors; you must review them before saving, declaring, sharing or making any decision.
We do not authorize operators to use your content for their own purposes; however, AI providers have their own policies — therefore, avoid sending sensitive or unnecessary data.
When automated decisions affect your interests, you may request review.

8. Couple Account and sharing between users

The Couple Account allows two users to organize finances together. By creating the group and inviting another person, you declare having authorization and consent from that person to share the group's financial data.

The invitation is sent by email, with a link and token of limited validity, and only takes effect after acceptance by the invited person.
Members can view group entries, accounts, cards, categories, goals, budgets and recurrences, according to the assigned role (editor, who creates and edits, or viewer, who only reads).
Group values are protected by a specific encryption key, made available in encrypted form to each member.
Each member is responsible for the data they enter and the use they make of the information they access. Flutue does not mediate conflicts between members.
Upon closing the Couple Account, new entries become individual again, but already created entries are not automatically deleted.

9. Cookies, analytics and advertising

On the website, cookies and similar technologies may be used for functionality, security, analytics and measurement. In the app and website, we use analytics and usage behavior tools (including session analysis and diagnostics) to understand and improve the experience, prevent abuse and correct errors.

Strictly necessary cookies may operate independently of consent; non-essential analytics and advertising depend on positive expression when required by law.
We currently do not display ads from third-party advertising networks nor perform cross-app advertising tracking. If this changes, we will update this Policy and request consent when required.
You may accept, refuse or change preferences; consent withdrawal has future effects.

10. Sharing and processors (subprocessors)

We share data only when necessary to operate, protect, provide, improve or fulfill obligations related to Flutue. Main operators and recipient categories include:

Google / Firebase — authentication, database, file storage, backend functions, messaging/push, analytics and abuse protection;
AI providers — OCR processing, audio transcription, categorization, statement extraction and insights (including models accessed through intermediaries, such as OpenRouter, and Google models);
Google Maps / Places / Geocoding — location search and address-to-coordinate conversion for the spending map;
Behavioral analytics tool (e.g., Microsoft Clarity) — usage metrics and diagnostics;
App stores and payment processors — Google Play and Apple, for contracting, billing and subscription management;
Public and judicial authorities — upon legal obligation, valid order or regular exercise of rights;
consultants, accountants and lawyers subject to confidentiality, when necessary.

11. International data transfer

To enable the service, part of the data is stored and processed outside Brazil. The main database operates in infrastructure located in the United States; file storage and backend processing features operate in a Brazilian region; and AI, maps, analytics and messaging operators may process data in the United States and other countries.

In these transfers, we adopt measures compatible with LGPD arts. 33–36, such as contractual clauses, technical safeguards, access control, minimization and necessity assessment.

12. Retention, deletion and disposal

Account deletion: upon requesting deletion in the app, we apply a 30-day grace period, during which you can cancel the request. After that period, associated data is eliminated or anonymized, with the exception of legal, security and technical retention.
Voice audio sent for transcription: deleted after processing.
Attachments (images, transaction audio): retained while linked to the entry, unless deleted by you, technical limitation or legitimate retention obligation.
Entered financial data: while maintained in the account, until deletion by the user or termination.
Security, acceptance and consent logs: for the period necessary for proof, fraud prevention, legal compliance and defense of rights.
Aggregated or anonymized data: may be retained indefinitely when they do not allow identification.

13. Information security and incidents

We adopt technical and administrative measures compatible with the nature of the data and processing risks, including financial value encryption (AES-256-GCM), transit encryption (TLS), access controls, logical segregation, security rules, monitoring, credential protection and privilege restriction.

No system is completely infallible. In case of a security incident that may cause relevant risk or damage, we will adopt response, mitigation, investigation and communication measures.

14. Data subject rights

You may request: confirmation of processing; access; correction; anonymization, blocking or deletion of unnecessary or improperly processed data; portability; information about sharing; information about the possibility of not consenting; consent withdrawal; opposition; and review of automated decisions.

You may exercise some of these rights directly in the app: export your data (Settings → Data → Export) and request account deletion (Settings → Account). For other requests, write to contato@flutueapp.com.br.

15. Consent and withdrawal

When processing depends on consent, it will be free, informed, unambiguous and highlighted. You may withdraw it with future effect, but withdrawal may limit features that depend on that authorization — such as location, notification capture on Android, optional OCR/audio/AI, analytics cookies and eventual future advertising features.

16. Minors

Flutue is intended exclusively for persons aged 18 or older and is not directed to children or adolescents. We do not seek to collect data from minors. If we identify use by a minor, we may block the account, delete the data, request verification and take corrective measures compatible with the law.

17. User data protection obligations

Do not enter third-party data without authorization or legitimate necessity.
Do not send receipts, audio, images or text with unnecessary sensitive data.
Obtain your partner's consent before sharing data in the Couple Account.
Keep device, OS, email, biometrics, PIN and credentials protected.
Review data extracted by OCR, audio, AI or automation before saving or using.
Report suspicion of improper access, fraud or incident related to the account.

18. Changes to this Policy

We may update this Policy due to legal, regulatory, technical, commercial, product, security or governance changes. The current version will be available on this page, with update date. Material changes will be communicated through reasonable channels, and new consents will be requested when required.

19. DPO, support and authority

Privacy and data subject rights: contato@flutueapp.com.br
General support: suporte@flutueapp.com.br
Controller: Flutue, individual responsible for Flutue

If you believe your request was not adequately addressed, you may contact the ANPD (Brazilian Data Protection Authority), without prejudice to other rights provided by law.

20. Feedback channel and user participation

Flutue provides a Feedback menu within the application for you to voluntarily send suggestions, criticisms and compliments. Content submitted may be used for product and experience improvement.

The Flutue team may respond to feedback messages within up to 15 (fifteen) calendar days. There is no obligation to respond to all messages; the team will select which contributions to respond to based on technical and relevance criteria.
Feedback messages may contain personal data provided voluntarily. This data is processed under the same consent basis and protected by the rules of this Policy.
The feedback channel does not replace official support channels or means for exercising data subject rights under the LGPD.

21. Main regulatory references

Lei 13.709/2018 (LGPD), especially arts. 6, 7, 8, 9, 11, 14, 18, 20, 33–37, 41 and 46–49.
Lei 12.965/2014 (Brazilian Internet Civil Rights Framework), especially arts. 7, 10, 11 and 15.
Decreto 8.771/2016 (regulation of the Internet Civil Rights Framework).
Lei 8.078/1990 (Brazilian Consumer Defense Code), when applicable to the consumer relationship.
Lei 10.406/2002 (Brazilian Civil Code), when applicable.
Lei 8.069/1990 (ECA), regarding the prohibition of use by minors.
Lei 9.609/1998 (Software Law) and Lei 9.610/1998 (Copyright Law), when applicable.