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Privacy Policy

Last updated:

Last updated: October 29, 2026

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Application refers to Mingo, the software program provided by the Company.
  • ANPD refers to the Autoridade Nacional de Proteção de Dados, the Brazilian data protection authority.
  • Business, for the purpose of CCPA/CPRA, refers to the Company as the legal entity that collects Consumers’ personal information and determines the purposes and means of the processing of Consumers’ personal information, or on behalf of which such information is collected and that alone, or jointly with others, determines the purposes and means of the processing of consumers’ personal information, that does business in the State of California.
  • CCPA and/or CPRA refers to the California Consumer Privacy Act (the “CCPA”) as amended by the California Privacy Rights Act of 2020 (the “CPRA”).
  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Agora Labs Tecnologia e Marketing Ltda., CNPJ 58.310.168/0001-83, R. Costa Rica 727, Apt. 602, Andar 6, Curitiba, Paraná, Brazil. For the purpose of the GDPR, the Company is the Data Controller. For the purpose of the LGPD, the Company is the Controlador.
  • Consumer, for the purpose of the CCPA/CPRA, means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
  • Country refers to: Brazil.
  • Data Controller, for the purposes of the GDPR (General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • GDPR refers to EU General Data Protection Regulation.
  • LGPD refers to the Brazilian Lei Geral de Proteção de Dados Pessoais (Law No. 13.709/2018).
  • Personal Data is any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA/CPRA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
  • Service refers to the Application.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used. For the purpose of the GDPR, Service Providers are considered Data Processors.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to Mingo, accessible from https://mingo.fit.
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable. Under GDPR, You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Local-First Architecture

Mingo is designed with a local-first, privacy-centric architecture. All personal health data — including medication dose logs, weight entries, water and fiber intake, and progress photos — is stored exclusively on Your device. We do not transmit, upload, or store Your personal health data on any external server or cloud database.

Any analytics or diagnostic data collected to improve the Service is tied to an anonymous identifier and contains no personal health information.

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • – Email address, where You contact Us for support
  • – Name, email address, phone number (optional) and message, where You write to Us through the contact form on the Website (mingo.fit/contact). We use them only to reply to You.
  • – Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, unique device identifiers and other diagnostic data.

Health and Medication Data

Mingo exists to help You log GLP-1 medication doses, body weight, progress photos, water intake and fiber consumption. This information constitutes data concerning health under the GDPR and sensitive personal data under the LGPD.

This data is stored exclusively on Your device. We do not transmit, upload, or store it on any external server. We process it on the basis of Your explicit consent (GDPR Art. 9(2)(a); LGPD Art. 11, I), given when You choose to record it.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

  • Pictures from Your Device’s camera and photo library. Progress photos are stored locally on Your device only, and are never uploaded to, transmitted to, or stored on any external server.
  • Apple Health data, where You grant permission. This data is used solely within the Application for display and tracking purposes and is governed by Apple’s Health Data policies. We do not access, store, or transmit Apple Health data to any external server, and We never use it for advertising or marketing, disclose it to third parties for advertising or data-mining purposes, or sell it.

You can enable or disable access to this information at any time through Your Device settings.

Food Photo Processing

If You use features involving food photo analysis, such photos are processed in real time for nutritional estimation and are immediately discarded after processing. No food photos are retained or stored beyond the momentary processing required to deliver the feature. The resulting nutritional data is saved locally on Your device only.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: by email or push notification regarding updates or informative communications related to the functionalities, products or contracted services, including security updates, when necessary or reasonable for their implementation.
  • To manage Your requests: to attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Service.

We may share Your personal information in the following situations:

  • With Service Providers: to monitor and analyze the use of our Service, for payment processing, and to contact You.
  • For business transfers: in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: in which case we will require those affiliates to honor this Privacy Policy.
  • With Your consent: for any other purpose with Your consent.

**We do not sell Your personal health data, and We do not share it with data brokers, advertisers, insurers, or employers.

**

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy, and to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

Health and medication data stored on Your device is retained until You delete it or remove the Application. Subscription records are retained for the life of the subscription plus five (5) years to meet Brazilian tax and accounting obligations. Usage Data is generally retained for a shorter period.

Transfer of Your Personal Data

The Company operates from Brazil. Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. This information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.

There is no European Commission adequacy decision covering Brazil, so transfers from the EEA or the UK rely on the Standard Contractual Clauses, with the UK International Data Transfer Addendum where applicable. Transfers out of Brazil rely on the safeguards permitted under LGPD Chapter V.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data We have collected about You.

Because Mingo stores Your health data locally, You can delete it yourself at any time from within the Application, or by removing the Application from Your device. You may also contact Us to request access to, correction of, or deletion of any personal information You have provided to Us.

Please note that We may need to retain certain information where We have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law Enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of the Company, prevent or investigate possible wrongdoing in connection with the Service, protect the personal safety of Users of the Service or the public, or protect against legal liability.

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

The strongest protection We offer is architectural: Your health data does not leave Your device, so there is no central database of it to breach.

If a data breach occurs that is likely to result in a risk to Your rights and freedoms, We will notify the competent supervisory authority within 72 hours of becoming aware of it, and the ANPD within the period Brazilian law requires. Where the risk to You is high, We will notify You directly.

Detailed Information on the Processing of Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third-party vendors collect, store, use, process and transfer information about Your activity on Our Service in accordance with their Privacy Policies.

Analytics

  • Google Analytics — a web analytics service offered by Google that tracks and reports website traffic on mingo.fit. Google uses the data collected to track and monitor use of our Website. Privacy policy: https://policies.google.com/privacy
  • AppsFlyer — a mobile attribution service that tells us which marketing campaign brought a user to the Application. Privacy policy: https://www.appsflyer.com/legal/privacy-policy/
  • RevenueCat — subscription management. RevenueCat assigns Your installation an anonymous identifier and receives Your purchase receipts, the product purchased, Your country, and basic device information. Privacy policy: https://www.revenuecat.com/privacy/

**
Payments**

We may provide paid products and/or services within the Service. In that case, we may use third-party services for payment processing.

We will not store or collect Your payment card details. That information is provided directly to Our third-party payment processors, whose use of Your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council.

Contact Form

Messages sent through the contact form on the Website reach Us through these Service Providers:

Cookies and the Website

Our Website at mingo.fit uses Google Tag Manager and Google Analytics, which set cookies on Your browser. You can control cookies through Your browser settings. Where required by law, We will ask for Your consent before setting non-essential cookies.

This section applies to the Website only. The Application does not use cookies.

GDPR Privacy

We may process Personal Data under the following conditions:

  • Consent: You have given Your consent for processing Personal Data for one or more specific purposes. This is the basis on which We process Your health and medication data (Art. 9(2)(a)).
  • Performance of a contract: provision of Personal Data is necessary for the performance of an agreement with You, such as providing access to a paid subscription.
  • Legal obligations: processing is necessary for compliance with a legal obligation to which the Company is subject.
  • Legitimate interests: processing is necessary for the purposes of the legitimate interests pursued by the Company, such as diagnosing errors and improving the Service.

Your Rights under the GDPR

You have the right to:

  • Request access to Your Personal Data, and to receive a copy of the Personal Data We hold about You.
  • Request correction of incomplete or inaccurate information We hold about You.
  • Object to processing of Your Personal Data where We rely on legitimate interests, and at any time where We process it for direct marketing.
  • Request erasure of Your Personal Data where there is no good reason for Us to continue processing it.
  • Request restriction of processing in certain circumstances.
  • Request the transfer of Your Personal Data in a structured, commonly used, machine-readable format.
  • Withdraw Your consent at any time, without affecting the lawfulness of processing carried out before withdrawal.

Exercising Your GDPR Data Protection Rights

You may exercise these rights by contacting Us at contact@mingo.fit. We will respond within one month, extendable by two further months for complex requests, in which case We will tell You within the first month and explain why.

You have the right to complain to a Data Protection Authority about Our collection and use of Your Personal Data. If You are in the European Economic Area, please contact Your local data protection authority.

LGPD Privacy (Brazil)

Under Article 18 of the LGPD, You have the right to:

  • Confirm the existence of processing, and access Your data.
  • Correct incomplete, inaccurate or outdated data.
  • Anonymise, block or delete data that is unnecessary, excessive, or processed unlawfully.
  • Port Your data to another provider.
  • Delete data processed on the basis of consent.
  • Be informed of the public and private entities with which We have shared Your data.
  • Be informed of the consequences of refusing to give consent.
  • Withdraw consent at any time.

To exercise these rights, contact contact@mingo.fit. We will provide a simplified response immediately and a complete response within 15 days, as Article 19 requires.

You also have the right to lodge a complaint with the ANPD (gov.br/anpd).

CCPA/CPRA Privacy Notice (California Privacy Rights)

This section supplements the information in Our Privacy Policy and applies solely to visitors, users and others who reside in the State of California.

Categories of Personal Information Collected

The following categories are those defined in the CCPA/CPRA. This does not mean that all examples within a category were in fact collected, but reflects our good faith belief that some information from that category may have been collected in the last twelve (12) months.

  • Category A: Identifiers (e.g. online identifier, IP address, email address). Collected: Yes.
  • Category B: California Customer Records personal information categories (e.g. medical information). Collected: Yes — stored on Your device only.
  • Category C: Protected classification characteristics. Collected: No.
  • Category D: Commercial information (records of products or services purchased). Collected: Yes.
  • Category E: Biometric information. Collected: No.
  • Category F: Internet or other similar network activity. Collected: Yes.
  • Category G: Geolocation data. Collected: No.
  • Category H: Sensory data. Collected: No — photographs are stored on Your device and are not transmitted to Us.
  • Category I: Professional or employment-related information. Collected: No.
  • Category J: Non-public education information. Collected: No.
  • Category K: Inferences drawn from other personal information. Collected: No.
  • Category L: Sensitive personal information (health information). Collected: Yes — stored on Your device only.

Under CCPA/CPRA, personal information does not include publicly available information from government records, deidentified or aggregated consumer information, or information excluded from the CCPA/CPRA’s scope.

Sources of Personal Information

Directly from You, indirectly from You through Your activity on our Service, automatically through Your Device, and from Service Providers.

Sale of Personal Information

We do not sell Your personal information, and We do not share it for cross-context behavioural advertising.

Some Service Providers we work with for analytics and attribution may use technology that could be characterised as a “sale” or “share” under the CCPA/CPRA’s broad definitions. If You wish to opt out, You may do so through the mobile device settings described below, or by contacting Us at contact@mingo.fit.

We honour Global Privacy Control signals as an opt-out of sale or sharing.

Your Rights under the CCPA/CPRA

California residents have the right to notice, the right to know and access, the right to opt out of the sale or sharing of personal data, the right to correct personal data, the right to limit use and disclosure of sensitive personal data, the right to delete personal data, and the right not to be discriminated against for exercising any of these rights.

Exercising Your CCPA/CPRA Rights

Contact Us by email at contact@mingo.fit.

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request. Your request must provide sufficient information to allow Us to reasonably verify You are the person about whom We collected personal information, and describe Your request with sufficient detail for Us to evaluate and respond to it.

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. This period may be extended once by a further 45 days when reasonably necessary, with prior notice.

Mobile Device Opt-Out

Your mobile device gives You the ability to limit the use of information about the apps You use for interest-based advertising:

  • iOS: Settings → Privacy & Security → Tracking
  • Android: Settings → Google → Ads

Children’s Privacy

Our Service is intended for adults. You must be at least 18 years of age to use Mingo, consistent with our Terms of Use. We do not knowingly collect personally identifiable information from anyone under 18.

If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us at contact@mingo.fit and We will take steps to remove that information.

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the “Last updated” date at the top.

We will let You know via a prominent notice on Our Service prior to the change becoming effective. You are advised to review this Privacy Policy periodically. Changes are effective when posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

Agora Labs Tecnologia e Marketing Ltda. CNPJ: 58.310.168/0001-83 R. Costa Rica 727, Apt. 602, Andar 6, Curitiba, Paraná, Brazil Telephone: +55 41 93618-0103

© AGORA LABS TECNOLOGIA E MARKETING LTDA — CNPJ: 58.310.168/0001-83