1. About this Policy
This Policy explains how InfoLedger handles personal data relating to people who use the platform or contact us, and how it processes uploaded documents. It applies to the service at infoledger.net.
Our privacy contact is [email protected]. You may use it without an active account. Naming this contact does not appoint a data protection officer; the identity of any appointed officer will be published once defined.
2. Roles in data processing
InfoLedger determines how to handle data needed to administer accounts, protect the service, answer requests and manage the commercial relationship. For these activities, it acts as a personal data controller.
When a customer uploads documents containing other people's data for processing in a professional activity, that customer must determine the purpose and legal basis for using the data. InfoLedger processes the content to perform the requested service, acting as a processor where that relationship applies. Roles depend on the actual operation and do not waive either party's responsibilities.
If your data appears in a document uploaded by a customer, you may contact the party responsible for the document or write to us. We will help identify an appropriate way to handle your request without disclosing another account's files.
3. Data we process
For registration and account management, we handle your name, email, verification status, password protected by hashing, uploaded profile picture and language, theme, time zone and display preferences. Security settings may include a recovery email, two-factor authentication secret and recovery codes protected by the service's controls.
For authentication and security, we handle session identifiers, IP addresses, browser information, access dates, authentication attempts, usage limits and administrative action logs. These records support access control, troubleshooting and abuse prevention.
For documents, we handle original files, names, types, sizes, dates, processing status, extracted text, generated tables and conversations used for AI conversion or editing. The contents may include your personal data or other people's data, depending on what was uploaded. You do not need to include personal data beyond what your purpose requires.
For purchases, we send Stripe your name, email and identifiers needed to associate the purchase with your account. We receive customer, subscription and price references, billing status and cycle dates. Full payment card details are supplied directly to Stripe and are not stored by InfoLedger.
For support, we handle email, messages, account or subscription references and information you supply. Acceptance records retain the account, context, language, date and document revision presented. Withdrawal requests retain a receipt identifier, message, subscription reference, communications and the handling outcome.
4. Purposes and legal grounds
| Activity | Purpose | Legal basis depending on the operation |
|---|---|---|
| Registration, preferences and subscription | Create the account, deliver the service and manage the agreement | Performance of a contract and steps requested by the data subject |
| Document processing | Extract, structure, display and export uploaded content | Legal basis determined by the customer controller; delivery of the service under its instructions |
| Authentication and security | Control access, contain abuse and protect accounts | Performance of a contract, legitimate interests where applicable and legal obligations |
| Support, cancellation and privacy | Handle requests and exercise rights | Performance of a contract, legal obligations and establishment or exercise of rights |
| Financial records and legal requests | Meet legal duties and respond to authorities or disputes | Legal or regulatory obligations and establishment or exercise of rights |
Use of legitimate interests must take account of necessity and the data subject's rights and expectations. Sensitive data is not processed under blanket authorisation: the party uploading it must observe the specific grounds under the LGPD. Acknowledging this Policy does not replace any specific consent required for an operation.
5. Documents and artificial intelligence
Files are sent to the Docling extraction service configured for the platform. To structure tables or edit results with AI, extracted text and messages needed for the operation may be sent to the Google Gemini API. Basic's initial conversion also uses this flow; AI processing is therefore not limited to Professional.
The Gemini API terms, effective since March 2026, distinguish unpaid and paid services. For unpaid services, Google may use inputs and responses to improve products and machine learning technologies, including through human review, and instructs users not to submit personal, sensitive or confidential information. For paid services linked to a project with active billing, Google states that it does not use those inputs and responses to improve its products, but provides for limited logging for safety and legal requirements.
The Gemini API arrangement for production remains to be defined and must be identified here before final publication. This version does not state that the supplier will never use content to improve models. Processing personal or confidential documents must be compatible with the arrangement and agreements actually adopted. We do not use content to train InfoLedger's own models.
6. Sharing data
Access or transmission is limited to service needs: hosting and databases; file storage; document extraction; AI; transactional email delivery; and Stripe payments. Docling is the extraction component configured by the platform operator, not permission to publish uploaded files. The actual hosting, storage and email providers and their regions must be confirmed before final publication.
Authorised administrators may access data for support, security and administration. This access does not make documents public. Authorities and other recipients may receive data where a legal obligation, valid order or the establishment or exercise of rights requires it. We do not sell documents or personal data for advertising.
7. Processing outside Brazil
Providers such as Google and Stripe may process data outside Brazil. Choosing a hosting or storage region does not mean all other processing occurs in that country.
Before final publication, destinations and applicable transfer mechanisms must be confirmed under the LGPD and ANPD regulations, such as an adequacy decision or valid contractual clauses. This draft does not claim that unverified agreements or safeguards are already implemented. You may request information about recipients and transfers through the privacy contact.
8. Cookies and browser storage
InfoLedger uses authentication and security cookies to recognise sessions and protect access. It also uses language and navigation preferences and local storage for theme selection. These resources support operation and interface personalisation.
No third-party advertising or behavioural analytics tool is integrated into the current offer reviewed. External services reached by redirection, such as Stripe Checkout, follow their own policies. Any future optional technology requiring consent must have its own information and controls before activation. Blocking session cookies may prevent sign-in.
9. Retention and deletion
Files and extracted data follow the plan's retention period, measured from upload. Current limits and procedures are in the Commercial Terms. Once a document exceeds its applicable retention period, it is marked for deletion and an additional 7 days are provided for export before removal. Documents still processing are not removed by the automatic procedure while in that state.
Deleting a document removes its file from active storage and its associated data once the operation completes. Permanent deletion does not provide recovery through the platform. Request account deletion through the privacy contact; handling includes verifying identity and confirming effects on files and the subscription. Acceptance records associated with the account are deleted with it.
Cancelling only the subscription does not delete the account. Basic retention applies after the paid period ends, which may schedule older documents for deletion. Export or download a backup before that transition.
Financial records, withdrawal requests and information needed for legal obligations or the establishment or exercise of rights may be retained after account deletion, limited to those purposes. Platform deletion does not automatically erase records that Stripe or other providers must keep under their own obligations. Infrastructure copy and technical log retention periods depend on confirmation of the production environment; we do not promise immediate deletion of every copy.
10. Information security
The service applies authentication, account-level document access controls, email verification, optional two-factor authentication, request limits and administrative action logging. Files are accessed through application routes. Production infrastructure must maintain private storage and HTTPS transport.
No system removes every risk. Protect your devices and credentials and notify support if you identify an incident. Where an incident requires notification to ANPD or data subjects, handling must follow applicable law and deadlines.
11. Your rights and how to exercise them
You may request confirmation and access, correction, information about sharing, anonymisation, blocking or deletion of excessive or unlawfully processed data, portability under applicable regulations, deletion of consent-based data where applicable, information about withholding consent, withdrawal of consent and objection where provided by law. You may also request review of decisions based solely on automated processing that affect your interests, where such a situation occurs.
Write to [email protected], describe your request and supply the account email if you have one. We may ask only for information needed to verify identity and avoid disclosing data to third parties. Confirmation or access will be provided in simplified form immediately where possible, or in a full statement within 15 days under the LGPD. Other requests follow applicable deadlines; any inability to fulfil a request will be explained.
The contact remains available without renewed contractual acceptance. You may also contact ANPD and competent authorities. The platform is not intended for people under 18; report any such use for assessment. Children's data uploaded by customers remains subject to legal protections and controller responsibilities.
12. Updates and language
Material changes will be communicated before taking effect. Where processing relies on consent, changes in purpose must meet the specific requirements for that consent. Portuguese is the official reference for the service in Brazil; this English reference translation does not reduce statutory rights.