ThinkE Privacy Policy
Effective [EFFECTIVE DATE]
ThinkE keeps your work on your computer. This policy says exactly what the app and the website send to us, why, how long we keep it, and what you can ask of us.
At a glance
what leaves your computer when why
───────────────────────────────────────────────────────── ───────────────────── ──────────────────────────
nothing of your work: notes, documents, files, chats, never —
summaries, drawings, searches
a one-way code of this computer, app version, system first start one trial per computer
your Google name, email and Google user ID when you sign in your licence
the order (product, price, country) from Paddle or Eduzz when you buy your licence, invoices
your licence and computer codes at least every 90 days confirm the licence
app version and system at start and every check for updates
6 hours, if updates and read our news
are on
a crash report: what failed, never your files when the app fails, find and fix crashes
if reports are on
your IP address, and the approximate location it gives with each of the above security, statistics
(the country)1. What we collect, and why
| Data | When | Purpose | Legal basis (GDPR · LGPD) | Kept for |
|---|---|---|---|---|
| Computer code: a one-way code (HMAC-SHA256) derived from your computer's hardware identifier. We never receive the identifier itself, and the code cannot be turned back into it or matched with other apps | first start; licence activation; licence checks | one trial per computer; up to 3 computers per licence | contract (art. 6(1)(b) · art. 7 V); legitimate interest in preventing abuse (art. 6(1)(f) · art. 7 IX) | trial: 24 months after the trial ends · licence: while the computer is active, then 12 months |
| App and system: ThinkE version, operating system, processor type | first start; update checks; licence checks | deliver the right updates; count installs by version and system | contract; legitimate interest | 30 days in server logs; counts without identifiers indefinitely |
| IP address | every request the app or the website makes to us | security and abuse prevention; derive approximate location | legitimate interest | 90 days |
| Approximate location: the country derived from the IP address. Never a region, a city, GPS or a precise location | trial start; sign-in; purchase; licence checks; downloads from thinke.ai | statistics about where our customers are; tax country checks; abuse prevention | legitimate interest | with the record it belongs to |
| Account: name, email and Google user ID, from Google Sign-In | when you sign in to buy or activate | own and recover your licence; contact you about it | contract | while your account exists |
| Licence: licence ID, status, purchase and renewal dates, the date your updates end, active computers, the date of the last check | purchase; renewal; checks | deliver the licence | contract | while your account exists |
| Order: order ID, product, price, currency, tax, country, payment method type, coupon and campaign tags. Never card numbers or bank details: Paddle and Eduzz keep those | when you buy | deliver the licence; refunds; accounting | contract; legal obligation (art. 6(1)(c) · art. 7 II) | as long as tax law requires (in Brazil, at least 5 years) |
| Marketing preference: whether you want news and offers by email, with the date | when you buy; when you change it | send ThinkE news and offers | legitimate interest in writing to our customers about ThinkE, with the right to object at any time (art. 6(1)(f) · art. 7 IX) | until you object, then only a record that you objected |
| Survey answers, such as how you heard about ThinkE | only if you answer | understand how people find and use ThinkE | consent (art. 6(1)(a) · art. 7 I) | while your account exists |
| Support messages | when you write to us | answer you | contract; legitimate interest | 3 years |
Crash reports: the kind of error, where in ThinkE's code it happened, the app version, system, processor and AI tier, and which part failed (window, background, AI server). Paths are cut to <vault>/… and ~/…. Never the memory snapshot of the app, never your files or what was on screen | when the app fails, if Send crash reports is on (it is on until you turn it off, on the first screen or in Settings → Privacy) | find and fix crashes | legitimate interest in a working product (art. 6(1)(f) · art. 7 IX), with the right to turn it off at any time | 30 days |
| Download counts on thinke.ai: platform, campaign tag in the link, approximate location from the IP | when you download the app | know which channels bring people | legitimate interest | counts only; the IP is not stored |
What we never collect: the content of your vault, the names of your files, what you search, what you ask the AI, or anything the AI writes. The full memory snapshot the system writes when the app fails stays on your computer, in a folder the app shows you; it reaches us only if you choose to email it to us.
2. What the app reads but does not send
The app reads thinke.ai/news.json, a file that is the same for everyone, to show news and offers. It
decides on your computer which item to show, from what it already knows (your trial day, whether your
updates have ended, your language). Nothing about that choice is sent. You can turn the news off in
Settings.
3. Who receives data
| Recipient | Role | What | Where |
|---|---|---|---|
| Google (Firebase Authentication, Cloud Firestore, Cloud Functions, Hosting) | our processor | everything in section 1 | United States |
| Google (Google Sign-In) | independent controller of your Google account | your sign-in | Google's terms |
| Paddle.com Market Ltd | merchant of record and independent controller for purchases outside Brazil | the order, payment and tax data | United Kingdom and its processors |
| Eduzz | payment intermediary for purchases in Brazil | the order and payment data | Brazil |
| Hugging Face; the hosts of our installers and updates | serve the files the app downloads; they see your IP address like any website | IP address | their own terms |
| Functional Software, Inc. (Sentry) | our processor, receives crash reports | the crash reports in section 1 | United States |
| An email delivery provider | our processor, sends the emails you asked for | name and email | [EMAIL PROVIDER LOCATION] |
| Authorities | only when the law requires it | what the law requires | — |
We do not sell personal data, and we do not use it for advertising profiles. Approximate location is derived on our servers from a local database, IP Geolocation by DB-IP (db-ip.com, licensed CC BY 4.0): no third party receives your IP address for that purpose.
4. International transfers
We are in Brazil and store data with Google in the United States.
- EU and Brazil. The European Commission recognises Brazil as giving adequate protection (Implementing Decision (EU) 2026/179), and Brazil recognises the EU in return. Data moves between them without additional safeguards.
- The United States. Transfers rely on the EU–US Data Privacy Framework, for which Google LLC is certified, and on the Standard Contractual Clauses in Google's data processing terms.
5. Your rights
| Right | GDPR | LGPD (art. 18) |
|---|---|---|
| Know whether we hold data about you, and get a copy | ✔ | ✔ |
| Correct it | ✔ | ✔ |
| Delete it | ✔ | ✔ |
| Restrict or object to its use, including marketing | ✔ | ✔ |
| Receive it in a portable format | ✔ | ✔ |
| Withdraw consent | ✔ | ✔ |
| Complain to a data protection authority | ✔ your country's authority (in Portugal, the CNPD) | ✔ the ANPD |
Write to [email protected]. We answer within one month (GDPR) and within 15 days for a full access report (LGPD). Deleting your account ends the licence it holds, because the licence can no longer be checked; we tell you before we do it. Records the law requires us to keep, such as invoices, are kept for the time the law sets.
6. Automated decisions
Two checks are automatic: whether a computer has already used a trial, and whether a licence is valid and within its computer limit. If you think either got it wrong, write to us and a person will review it.
7. Security
Connections use TLS. The licence and the trial date the app keeps are signed by our server, so they cannot be edited. They are stored in the macOS Keychain or, on Windows, in your user's registry, with a copy in a folder shared by the computer's users. Our database denies direct access from apps and browsers; only our server functions read and write it, and only one administrator account, protected by two-factor authentication, can open our admin tools.
8. Children
ThinkE is not directed to children under 16, and we do not knowingly collect their data.
9. Changes to this policy
We tell you in the app or by email before a change that affects you takes effect. The date at the top shows the version in force.
10. Contact
[email protected] · [COMPANY LEGAL NAME] Ltda, CNPJ [CNPJ], [REGISTERED ADDRESS], Brazil. EU representative: [EU REPRESENTATIVE NAME AND ADDRESS].