LGPD — Your Data Protection Rights
Last updated: [DATE]
1. About this page
Phrason is committed to complying with Brazil's General Data Protection Law (LGPD). This page explains, in addition to our Privacy Policy, the specific rights the LGPD guarantees to you as a data subject ("titular dos dados").
2. Legal basis for processing
We process your data based on: your consent when you create an account, the performance of a contract when you purchase a theme or card, and our legitimate interest in improving Phrason's exercises based on how they're used.
3. Your rights under the LGPD
Confirmation & access
Confirm whether we process your data, and access it.
Correction
Correct incomplete, inaccurate or outdated data.
Anonymization or deletion
Request we anonymize, block, or delete unnecessary or excessive data.
Portability
Request a copy of your data in a portable format.
Information on sharing
Know which public or private entities we share your data with.
Revoke consent
Withdraw consent at any time, and request deletion of data processed on that basis.
4. International transfers
Some of the services Phrason relies on (such as our authentication and hosting providers) may process data outside Brazil. Where this happens, we rely on those providers' own LGPD/GDPR-compliant safeguards.
To exercise any of these rights, contact our team directly.
Submit a data request5. Data Protection Officer (Encarregado)
[Name / contact of your designated Encarregado goes here — required under the LGPD for formal compliance.]
6. Contact
Questions about your rights under the LGPD can be sent to privacy@phrason.com.