Vullto

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If this English text differs from the Portuguese (Brazil) version, Portuguese (Brazil) governs except where mandatory local law in your country requires otherwise.

Privacy Policy — Vullto

Service: Vullto, gamified social network at vullto.app and in the official mobile applications.
Version: 1.2
Effective from 05/09/2026. Whoever accepts this Policy and the Terms of Use also accepts renewals published at vullto.app/privacy and vullto.app/terms. If a renewal no longer suits them, they may request removal or closure of the Account (Terms, clause 13.9). It is up to the data subject to open these documents whenever they want to review them.

Languages: this Policy exists in Portuguese (Brazil) and English (and in other languages if published). In case of divergence between translations, Portuguese (Brazil) prevails, except for mandatory law of the data subject’s country of residence.

This Policy explains, in clear language, which personal data we process in the global Service, for what purposes, on what legal basis, and what your rights are. Also read the Terms of Use.

Controller

Controller: ARISTECH TECNOLOGIA ME, registered under CNPJ no. 37.156.939/0001-50, with registered office in Suzano/SP, Brazil. The full street address and other company-registry details are not reproduced here; they can be looked up in the public CNPJ query of the Brazilian Federal Revenue (Receita Federal) on gov.br, using the number above.

Single channel (data subjects, authorities, reports): [email protected]
(use to exercise rights, request correction, removal of Followed Profile, or complain.)

LGPD (Brazil): for data subjects in Brazil, the General Personal Data Protection Law (Law no. 13.709/2018) and other Brazilian rules apply when applicable. Data protection officer/contact: [email protected].

In brief

We process what is necessary for Account, game, and security in the global Service. Beta version. Users (Account): 18+ in any country. The catalog lists public figures with public information; minors do not enter, including famous ones (Terms §5.15, §10.4 below). A person without public information is not a discovery target: the way in is to create an Account. Single channel: [email protected]. Coins are not money. Data subjects outside Brazil: section 12.

Summary (read this first)

1. What data we process in the current version

1.1. Data you provide to us

We do not ask for CPF, ID document, residential address, or card at this time. There is no payment in Brazilian reais at this time.

Login: Google acts as login to create or access the Account. Google is an independent controller of that login. Our basis: performance of contract (LGPD, art. 7, V). Policy: Google Privacy.

Post-registration linking (Instagram / YouTube) is separate from Google login — see 1.2.3.

1.2. Data the Service generates

1.2.1. Aggregated data from public sources (news and context)

When we display news excerpts or other information on Profiles, we process only what comes from public sources on the internet — for example, via search feeds or publishers — such as: title, excerpt (snippet), article URL, thumbnail URL, publisher name and URL, and publication date when available.

Vullto acts as an aggregator: we are not author nor holder of that information. The original source remains responsible for full content. We do not reproduce the full article in the Service.

In the discovery game, a Profile may increase visibility of a name or brand within Vullto, with headlines/snippets attributed and linked to the source — product purpose described in Terms, §5.14, not consent or license from the holder and no reach guarantee; correction/removal: [email protected] (Terms §5.11).

In brief: public sources about public figures feed the game; visibility on Vullto does not waive image, name, or publisher rights; users 18+; minors out of the catalog, including famous ones (§10.4).

1.2.2. Public data, search engines, AI assistants, and player interest

Besides 1.2.1, we may process publicly available information (search engines, open sites, news excerpts) and what third-party AI assistants already expose from public sources, to build Profiles and game context.

We also process player interest signals — searches, follows, purchases, sales, and catalog use within Vullto — to order discovery and rankings, without publishing algorithm weights.

To build or enrich Profiles and discovery, we may use Vullto AI features through contracted processors, when they are active. The categories are: search and retrieval of public web references; and a language model for bio synthesis, discovery, and catalog enrichment. We do not publish each processor’s brand here. The current list can be requested at [email protected].

These operators process data under our instructions (processors), generally on public text and metadata or aggregated game signals — not for private chat with you.

AI feature limits. Output may be wrong (incorrect or outdated information, homonyms, mistaken cross-referencing). Display is informational, not verified fact or professional advice. You may report via the button on the Profile page or [email protected] (Terms, §5.16, §6.8). A bio or ranking can change how a person is seen, even without an Account. That is not a decision that grants or denies a right, credit, or a contract (LGPD art. 20). If it becomes one, human review is available at [email protected].

In brief: public sources + in-game community + contracted search and language-model processors (when active); AI may err — report and we correct when appropriate. A bio or ranking can change how a person is seen and is not a decision about a right, credit, or a contract.

1.2.3. Data from networks you link (Instagram, YouTube)

In brief: only if you opt in, after registration, to display/verify profile or channel on Vullto.

If you authorize linking:

We do not receive network passwords. We do not publish for you. We may begin to offer other networks with notice in this Policy.

Unlink: we remove tokens and data obtained solely through linking, except legal retention (see section 7). Request also via [email protected].

Provider terms: YouTube — YouTube API Terms of Service, Google Privacy, revocation at Google security permissions. Instagram — Meta platform terms and Meta Privacy Policy. Meta and Google/YouTube are independent controllers in their authorizations. Google login and YouTube linking use distinct flows and purposes.

1.3. Technical data

1.4. What we do not process at this time

Login with Google is not the same as linking Instagram or YouTube (1.2.3).

2. For what purposes and on what legal basis

We are honest about the basis. We do not use “generic consent” for what the contract already covers.

Brazil: the bases below cite LGPD (Law no. 13.709/2018) when you are in Brazil or when LGPD applies. EEA/UK: equivalent legal bases (contract, consent, legitimate interest, legal obligation) under GDPR / UK GDPR — details in section 12. California: categories and opt-out in section 12.3.

| Purpose | Examples | Basis (LGPD art. 7) | |---|---|---| | Create and maintain Account, authenticate, recover access | email, hashed password, session | V — performance of contract | | Google login | email or equivalent id, name, photo URL, stable provider id | V — contract | | Link Instagram or YouTube to Profile (optional, post-registration) | handle, ids, encrypted tokens, authorized public signals | I — consent (revocable when unlinking) | | Create your claimed Profile and display it in the game | username, bio, avatar | V — contract | | Ledger, balance, check-in, buy, sell, portfolio | entries, completed operations, positions | V — contract | | Referral (1 level) | who referred, referral movements | V — contract | | Cheer (game event, not dividend) | Virtual Share position, cheer movements | V — contract | | Follow, friendships, blocks, and discovery | follow relations, friend requests, blocks, searches, catalog | V — contract | | Virtual collection items | catalog, ownership, public showcase | V — contract | | Notifications (in-app and push, when active) | game events, device token | V — contract | | Aggregate news excerpts and public context on Profiles | title, snippet, URL, thumbnail, publisher (public feeds) | V — contract (in-game discovery) and, when applicable, IX — legitimate interest on manifestly public data | | Handle claim request | request data and evidence | V — contract (and, if third-party data, limits of clause 4) | | Transactional emails (confirmation, security, Terms notice) | email | V — contract | | Security, fraud, abuse, multi-account, virtual market manipulation, parameter audit | IP, logs, internal team trail | IX — legitimate interest and, when law requires retention (Internet Civil Framework, access log rules), II — legal obligation | | Exercise rights in proceedings or respond to authority | minimum necessary set | II — legal obligation and/or VI — regular exercise of rights | | Marketing / newsletter | email | We do not do this in the current version. If we ever do: consent or, in product communication to existing users, legitimate interest with easy opt-out. Without opt-in, it does not send. | | Web measurement cookies (Google Analytics) | pages visited, referrer, device, approximate region, cookies _ga / _ga_* | I — consent (web banner; refusal as easy as accept) |

Legitimate interest (security and logs), in plain language. We need to detect cloned Account, bot, coordinated pump, and intrusion. Without IP, time, and technical trail that does not work. The interest is ours and all players’. We do not use those logs for advertising profiling. Impact is that of a common authenticated service. You may object: we will assess and, if processing is truly necessary for security, we may refuse with justification (LGPD art. 18, §2).

Quotes, rankings, limits, and bios are game rules, partly automated, and can change how a person is seen, even without an Account. They are not a decision that grants or denies a right, credit, or a contract (LGPD art. 20). Quotes and limits apply to everyone: they are not “credit” or consumer scoring. If a processing activity becomes that kind of decision, human review is available at [email protected].

3. Followed Profiles — the most sensitive point

3.1. What the current version actually does

Followed Profiles are created and enriched from public sources — public social profiles, open databases, public search, product-permitted imports, and discovery signals — as described in Terms, §9.2. We process names, handles, compiled bios, public avatars, news excerpts, and metadata visible at the source, within the limits of Terms clause 5.

If something incorrect or not authorized by the public source appears in the catalog, the channel in section 11 and [email protected] serve for correction or immediate takedown.

3.2. What the current version does not claim

Displaying a Followed Profile does not mean the person or brand participates, endorses, or speaks for Vullto. We use the label “Followed Profile — not yet claimed” when there is not yet an approved owning Account.

3.3. Scale, identifiable real people, and RIPD/DPIA

When we process Followed Profiles of identifiable real people or entities, at scale or elevated sensitivity:

Candidate legal basis, to be reassessed case by case: legitimate interest (art. 7, IX) on manifestly public data of a person with notoriety, for social discovery game purposes — not to harass, profile consumption, sell data, or offend.

Public figures with manifestly public data may appear in the catalog. A person of little relevance and without public information is not a discovery target (Terms §9.2). Minors stay out, including famous ones (Terms §5.15, §10.4). Expanding the catalog beyond those rules requires a Data Protection Impact Assessment (RIPD/DPIA) and review of this Policy.

3.4. Third-party portfolio

In the current version the portfolio is private, for the logged-in user. We do not publish anyone’s wallet. If one day there is public wallet, it will be the Account holder’s choice.

4. With whom we share

We do not sell personal data.

We may share, strictly as necessary:

4.1. Processors we use or may use

We describe categories. The brand of a processor that does not appear on screen for you (search, language model, email, hosting) is not published here; the current list can be requested at [email protected]. Categories:

We do not describe a processor we have not contracted.

4.2. App stores, infrastructure, and third-party information

In brief: ARISTECH controls processing described in this Policy; Apple, Google Play, hosting, and cloud providers are not publishers of in-game content; requests go to [email protected].

Echo of Terms, §17.4: data about third parties shown in the catalog comes from public sources, reports, and Vullto AI features (§1.2.2). Apple, Google (Google Play), hosting, cloud, and other technical operators do not review or endorse that content and, to the extent permitted by law, are not responsible for it toward you — without prejudice to mandatory rights you retain against ARISTECH and required store policies. Privacy and data-subject requests: [email protected].

5. International transfer

5.1. Vullto is global, but the controller is in Brazil. Data may be processed in Brazil, the United States, and other countries where processors (hosting, analytics, login, network APIs, search, and language models) maintain infrastructure. Contracted language-model and search processors may process text and metadata in the country where that processor operates, which may be outside Brazil and outside the United States. The safeguards in this section 5 apply.

5.2. Brazil (LGPD): international transfers follow LGPD (Law no. 13.709/2018, art. 33) when applicable — for example, country with adequacy recognized by ANPD, or contractual clauses / equivalent safeguards.

5.3. EEA/UK (GDPR / UK GDPR): when applicable, we use safeguards such as Standard Contractual Clauses (SCCs) approved by the European Commission or mechanisms recognized by the ICO, as the case may be.

5.4. We do not transfer player data to “media partner” — we do not sell personal data nor share for cross-context behavioral advertising (see 12.3 California). Measurement data accepted on the web may be processed by Google Analytics in the US or other countries (section 6.5).

5.5. Instagram/YouTube linking: tokens and Meta and Google APIs may imply processing outside Brazil. Revoking linking on Vullto or in provider permissions stops new access; retention in section 7.

6. Cookies, session, and apps

6.1. On the web, we use storage necessary for session and authentication (for example, secure session cookie). That is strictly necessary cookie/storage. Without it login does not work.

6.2. In native apps, the token stays in device secure storage, as the platform allows.

6.3. There is no advertising cookie, remarketing pixel, or third-party social network cookie. There is, on the web and only with your consent, measurement cookies via Google Analytics (see 6.5).

6.4. On the web, we display a cookie banner while measurement cookies may be used and no choice is yet recorded. Refusing is as easy as accepting. The team’s internal panel does not use that measurement.

6.5. Google Analytics (web). We only load after acceptance in the banner — including for visitors without Account. Purpose: measure aggregate site use and improve the product. Basis: consent. To revoke: refuse again after clearing site data in the browser or write to [email protected]. Complementary disclosure: Terms, clause 20.

7. Retention

We retain:

We do not announce eternal deadline of “everything deleted next day.” We also do not keep “infinitely just in case” what we can already delete.

8. Your rights and conflict with the ledger

You may, through [email protected]:

  1. confirmation that we process your data;
  2. access;
  3. correction of incomplete, inaccurate, or outdated data;
  4. anonymization, blocking, or erasure of unnecessary, excessive, or non-compliant data;
  5. portability, within ANPD regulation limits and what is technically possible (we export what is yours: registration, statement, positions — in structured format, when available);
  6. information about entities with whom we share;
  7. information about possibility of not consenting and consequences — in the current version marketing is already off;
  8. revocation of consent, when that was the basis — including unlink Instagram or YouTube (1.2.3) or request via [email protected];
  9. objection to processing based on legitimate interest;
  10. review of automated decision, if one day exists within art. 20 meaning;
  11. petition to ANPD and, if consumer, consumer protection agencies.

Response time: LGPD time (15 days for access, art. 19, extendable as provided by law; other rights within reasonable time, as a rule 15 days).

8.1. Erasure versus ledger

The game needs an append-only ledger: nobody “edits the past” of the market. Other people bought and sold Virtual Shares of your Profile; those plays of theirs are their data too.

Therefore, when you request Account erasure, what we concretely do:

  1. we terminate login and access;
  2. we remove or replace personal identifiers (email, name, avatar, bio);
  3. the public Profile, if it must continue to exist for market already played, becomes an anonymous/aggregated card (“closed profile” or equivalent — never “ownerless” in the Followed Profile sense);
  4. ledger entries and completed operations remain with internal identifier without email and without name, or aggregated, so third-party totals, quotes, and positions stay consistent;
  5. we do not rewrite other people’s historical price.

This meets erasure right to the extent possible (art. 18, VI) without destroying third parties’ data and game, and without pretending erasure the database would not perform. If ANPD or a court orders a different regime, we will comply.

8.2. Third-party Followed Profile

If you are the depicted person (when that exists) and have no Account, the same correction, objection, and erasure/takedown rights apply, through the same channel. Claim is one path; removal may also be, as the case may be.

8.3. Aggregated information (news and public context)

If you are a subject cited in a news excerpt or other aggregated information displayed in the Service, you may request correction, blocking, or removal through [email protected], indicating Profile URL and, if possible, article link. Vullto is not holder of the content — we act as aggregator — but we will assess the request based on LGPD, this Policy, and the Terms, and may remove or block display of the excerpt in the Service when appropriate.

9. Security

We apply measures proportional to an authenticated service in Beta phase: password hash, secure session, encrypted communication in transit (HTTPS) when the Service is live, team access control, auditable ledger, and parameter change logging.

No system is infallible. If there is an incident with relevant risk, we will notify you and ANPD as LGPD arts. 48 et seq. provide.

10. Minors — users (Account) and catalog

In brief: (A) only 18+ have Accounts; (B) the catalog does not include minors, including famous ones.

10.1. (A) Account holders (users). The Service is for persons 18 years of age or older worldwide. It is not directed at children or adolescents (COPPA, GDPR children in EEA/UK, Digital ECA in Brazil — when applicable).

10.2. (A) Underage user data. We process personal data of users (Accounts) only if they are 18+. If we learn an Account belongs to someone under 18, we terminate and delete registration, with clause 8.1 logic for market already played. Self-declaration at registration; Google login does not waive age.

10.3. Brazil — Digital ECA (Law no. 15.211/2025), when applicable to users, and LGPD art. 14 (best interest). Documentary reinforcement we may begin to require if law or stores require it.

10.4. (B) Minors in the catalog. Rule: the catalog does not include a person under 18, including a child artist, junior singer, youth athlete, or any other minor public figure (Terms §5.15). That person cannot create an Account before 18. No private accounts, no sensitive data, no contact, location, school/family, or direct messages.

Error and review. A system error may import that data. Removal requests: [email protected]. A new Followed Profile goes through periodic review and may be removed without prior notice. On removal, current positions in that Profile are undone (Terms §5.15).

11. Channel, ANPD, and changes

11.1. Single channel: [email protected] (data subjects, authorities, reports).

11.2. Brazil: national authority ANPD. You may petition ANPD without prejudice to contacting us first.

11.3. EEA/UK: if law requires representative (GDPR art. 27), we will publish contact in this Policy when designated. Until then: [email protected].

11.4. Changes to this Policy follow Terms clause 16: the published version counts as a renewal; whoever accepted also accepts renewals; if it no longer suits them, they request Account closure. It is up to the data subject to reread this Policy when they want. When a change is material, we will tell Account holders, by email and in the Service, what changed and from when it applies.

11.5. Current version: vullto.app/privacy.

12. Users outside Brazil — regional rights

In brief: mandatory laws of your country of residence are not waived. This channel works for everyone: [email protected].

12.1. EEA and United Kingdom (GDPR / UK GDPR)

If you are in the European Economic Area or United Kingdom and GDPR or UK GDPR applies, you have, in plain language:

Legal bases used: contract performance, consent, legitimate interest (security/antifraud), and legal obligation, as described in section 2. International transfers: section 5.3.

12.2. Other jurisdictions

If mandatory law of your country of residence grants additional rights (access, correction, deletion, objection, portability, etc.), you may exercise them via [email protected]. We will assess under that law.

12.3. California (CCPA / CPRA)

If you are a California resident and CCPA/CPRA applies:

Vullto · Privacy Policy · Version 1.2 · vullto.app/privacy