Privacy Policy

Garbo (“Garbo,” “we,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your information when you visit our website [garbocare.com] (the “Site”) and use our services, in accordance with the Brazilian General Data Protection Law (LGPD, Law No. 13,709/2018). Please read this Privacy Policy carefully.

Garbo is a service of Octantis Apps LTDA, registered under Brazilian company number (CNPJ) 68.132.214/0001-55, which is the controller of your personal data under the LGPD.

We may collect information about you in several ways. The information we may collect on the Site includes:

Personal data: information that identifies you, such as your name and email, and demographic data, such as age, gender, and interests, that you voluntarily give us when you register on the Site or when you answer the questionnaire.

Derived data: information our servers automatically collect when you access the Site, such as your IP address, browser type, operating system, access times, and the pages viewed before and after the Site. With your consent in the cookie notice, we use Google Tag Manager and the Meta Pixel on the site to measure the performance of Garbo's own ads and to show Garbo ads to people who visited the site, on Meta's services such as Facebook and Instagram, and only then are Meta's cookies stored in your browser. To do this, the Pixel tells Meta which pages of the site you visited and, when it identifies an email or name field on one of them, may send what you typed there, turned into code (SHA-256), so Meta can recognize the same person. The Pixel runs only on garbocare.com, never in the dashboard questionnaire or on the login screen, and it does not receive color or race or health data. People who visited the site stay on these ad lists for at most 180 days. Declining or clearing cookies stops new collection in that browser, but does not remove you from a list that has already been built; for that, use the channel described in “Contact us,” with the subject “LGPD Rights.” In addition, whether or not you accept the cookie notice, Garbo's servers tell Meta, through the Conversions API, about your purchase (the products and the amount) and the quiz steps leading up to it (signing up in the quiz, opening the preview, and tapping to pay), so we can measure and improve our ads. Along with this, we send your email, your name, and your phone number turned into a code (SHA-256) that cannot be read, but that Meta can compare with the data it already has to recognize the same person; an internal Garbo code linked to your account or, before you have an account, to your quiz session; your IP address; your browser data (the name, the version, and the device's operating system); the approximate location derived from your IP (country, state, city, and ZIP code) and, for a purchase, also the country and ZIP code you entered at payment (the payment ZIP code takes precedence over the one derived from your IP); the Meta ad click code, if you arrived through one, which Garbo itself keeps in two ways, separate from Meta's cookies: in a Garbo cookie that expires after 7 days, and in a copy in your browser's storage that is only used for up to 7 days but is only deleted when you return to the site after that period; and, if you accepted the cookies, Meta's attribution cookies. Declining cookies does not stop this transmission. The browser data, the IP address, the phone number, and the location are kept only for this transmission and are deleted from Garbo's systems within 24 hours. We do not send Meta photos, your face, your measurements, your scores, the result of the analysis, your quiz answers, health data, your CPF (Brazilian taxpayer ID), or your card details. With the same consent, we use PostHog to understand how the site and the dashboard are used. It records your session, that is, how you navigate, scroll, and click on the pages and in the dashboard, and logs clicks, heatmaps (the most-clicked spots on the screen), time of use, and five steps of the journey (starting the quiz, submitting your email in the quiz, viewing the preview, starting the purchase, with the plan and the amount, and entering the dashboard). It also logs when the site has an error, with the type of error, the part of the code where it happened, and the page address (without access codes), and the text of the error message is replaced with fixed text. In the recording, everything you type, the photos of your face, and your health answers (medications, conditions, and treatments) are hidden, and nothing on the login screen is recorded. When you enter the dashboard, these visits are linked to your account's internal code, never to your email. PostHog discards your IP address. This data is stored in the United States, in an international transfer that follows the LGPD rules, for up to 1 year. To withdraw this consent, clear this site's data in your browser settings and choose “Decline” in the cookie notice, which will appear again. What Meta and PostHog have already received before that is governed by each one's privacy policy. Regardless of the cookie notice, we also use Sentry so the team knows when the site has an error, such as a screen that breaks or a payment that fails, and can fix it. It serves to keep the site working and secure, and it does not use cookies. When an error happens, it receives the type of error, the part of the code where it happened, the page address (without access codes), the browser, and the device. Errors go through Garbo's servers, which remove cookies and your IP address before sending them to Sentry. If Sentry adds a location based on that connection, it is the location of Garbo's servers, not yours. Sentry does not store your IP address and does not receive your name, your email, your photos, your answers, what you type, cookies, or the text of the error message, which is replaced with fixed text. This data is stored in the United States, in an international transfer that follows the LGPD rules, for up to 90 days. In the quiz, with or without acceptance of the cookie notice, Garbo logs in its own database how the quiz is used: each screen viewed and the time it was viewed, the options chosen in the multiple-choice questions (except the color or race one), going back to a previous screen, whether the photo was accepted or rejected, whether the photo measurement failed, and the plan chosen, with the type of device (phone or computer). Each visit receives a random code, which goes along with these records and is stored with them. These records have no direct identification: they do not carry your name, your email, your photos, or your facial measurements. But the code and the times make it possible to group the screens of a single visit, and only the Garbo team accesses these records. They are kept for up to 13 months, and a daily cleanup deletes the oldest ones. Without acceptance, this logging does not use cookies, the visit code is not saved in the browser's storage, and the source of the visit is recorded only as a category from a closed list, for example Instagram or Google (anything not on the list becomes “other”), without the page address and without the site you came from. With acceptance, the visit code is kept in the browser tab, so the pages after the quiz count as part of the same visit, and the record includes the five campaign parameters from the link (utm_source, utm_medium, utm_campaign, utm_content, and utm_term) and the domain of the site you came from. Before storing them, the site checks each parameter: it trims spaces at the start and end and discards any that are invalid or too long. A parameter that passes can still carry a name or an email if the link was written that way, and that is stored too. In addition, for everyone, Garbo adds up per day how many times each quiz screen was viewed, counting once per browser tab (so the total counts visits, not people: the same person in another tab counts again), and the time since the last screen counted in that tab, up to 10 minutes. This total has no visit code, source, or answers. So the same screen is not counted twice, the browser tab keeps the list of screens already counted and the time of the last one. Neither the quiz records nor this total store your IP address.

Financial data: Garbo does not store your card details. Payment goes entirely through Mercado Pago, in Brazil, or through Stripe, outside Brazil, and each has its own privacy and security policy. We keep the purchase record: the plan or product, the offer, the amount, the dates, the transaction code, and the status of the payment, the delivery, and any refund. If delivery of the purchase fails, we also use the email provided at payment to resolve the problem. To know where purchases come from (which ads, social networks, and partners bring in sales), Garbo stores two of its own cookies in your browser, lasting up to 400 days, for every visitor, whether or not you accept the cookie notice: one keeps your first visit and the other keeps your most recent visit that came from a link with campaign parameters or from another site. They store only the link's five campaign parameters (utm_source, utm_medium, utm_campaign, utm_content, and utm_term) and the domain of the site you came from, never your IP address. Before storing them, the site checks each parameter: it trims spaces at the start and end and discards any that are invalid or too long. A parameter that passes can still carry a name or an email if the link was written that way, and that is stored too. Coming to the site directly or moving between its pages changes nothing. When you make a purchase, this origin is linked to the purchase and to your account. When you start a payment, we keep a temporary copy of it, which is deleted once it moves to the purchase or within 7 days if no purchase is made. On the purchase, it is kept for as long as the purchase record exists. If you delete your account, the origin is deleted, and both cookies are deleted in the browser where you asked for the deletion. On other devices, you can delete them by clearing this site's data in your browser settings.

Sensitive data: images, photos, and detailed information about you and your history are collected to prepare your analysis accurately. In the Complete Transformation dashboard questionnaire, you also provide the medications you take and your health conditions, which are sensitive personal data under the LGPD and serve to tailor your analysis and your protocol. The photo of your face is biometric data, sensitive personal data under the LGPD, and Garbo uses it only to generate your analysis and, if you authorize it separately, to calibrate the measurements, as explained below (what each provider does with it is in “Disclosure of your information”). The same applies to the 3D model of your face, built from your photos only to show the analysis in the dashboard: we do not use it to identify you. Color or race is also sensitive personal data under the LGPD. In the quiz, the question about it is required, and the sentence above the options says what the answer is used for: choosing an option counts as your authorization for that use. The answer is used only to look, at that moment, for the most similar celebrity among those in the same group, when there are enough celebrities in that group; if there are not, the celebrity is chosen without taking color or race into account. The quiz answer is not stored in Garbo's systems or in your browser and is not sent to advertising or usage analytics partners. We keep only proof of the authorization: the date and the version of the text, without the color or race. In the dashboard questionnaire, color or race is also required and is kept with your account. With the health data authorization, it is used to compare your measurements with those of people in the same group and to look for the celebrities most similar to you among those in the same group. To delete it, write to contato@garbocare.com with the subject “LGPD Rights” or delete your account in the dashboard Settings.

Data kept for the Surgical Report: the Surgical Report can be purchased after the analysis is ready, with no deadline for that purchase. To build it without asking for new photos, we keep, together with the analysis, the facial measurements the report uses, your first name, your age, your sex, the comparison group chosen from your answer about color or race, and the description used in the text of the analysis. Since the purchase has no deadline, this data is kept for as long as your account exists. It is deleted immediately if you withdraw the photo authorization or the health data authorization, and it is deleted along with the account, if you delete it. Automatic database backups may contain this data for up to 7 days after that.

Measurement calibration (optional): when uploading the photos for the paid analysis, people aged 18 or over see a separate box, unchecked by default, asking whether they authorize Garbo to keep a copy of the photos and measurements from that analysis to calibrate Garbo's measurements. This authorization is separate, serves only this purpose, applies only to the analysis in which you checked the box (a new analysis asks again), and is recorded with the date and the version of the text. Declining, or unchecking it later, changes nothing in your analysis, the price, or the delivery time.

• What for: to check against real faces how Garbo calculates face shape and proportions, and to suggest adjustments to that calculation. No adjustment goes in on its own: the team reviews it first. In addition, the measurements of the jaw profile go into the group average, the outline that other customers of the same sex see next to their own on the jaw page: only the measurements, never the photos, and the average only appears with measurements from at least 2 people, not counting the person viewing it.
• Which data: the photos from the analysis, the facial measurements calculated from them and, when available, the face shape marked by hand by a member of the team. Your health information, your color or race, and your age are not included. The calibration material does not carry your name or your email; even so, the face is still data that identifies you, and the copy is treated as sensitive personal data.
• Who sees it and where it is kept: the photos and the copy, only the members of the Garbo team in charge of calibration; other customers see only the group average described above. The copy is stored separately, in a private location on Supabase, the service that already stores Garbo's database. In each calibration round, the measurements are recalculated on Garbo's own systems, and the round's material is deleted at the end of it.
• For how long: up to 2 years, counted from the day each copy is made, without restarting; sooner, if you uncheck the box or if calibration is no longer needed. Automatic database backups may contain the measurements, without the photos, for up to 7 days, and are not used in calibration.
• How to uncheck: in the dashboard Settings, whenever you want, or through contato@garbocare.com, free of charge. When you uncheck it in the dashboard, the photos and measurements stop being used immediately, and the copies are deleted within 7 days: the one in the storage location and any that a team member has already downloaded. For about one minute after you uncheck it, a team member who had already downloaded the copy can still download it again, and that file is also deleted within the same 7 days. Withdrawing the photo authorization or deleting the account also deletes the copy.
• What we never do with it: publish it, sell it, use it in ads, identify people by their face, send it to Face++, Anthropic, OpenAI, Google, or any other artificial intelligence service, or use it for any other purpose without asking for a new authorization.

Having accurate information about you allows us to offer you a smooth, efficient, and personalized experience. Specifically, we may use the information collected through the Site to:

• Create and manage your account.
• Process your transactions and send related information, including purchase confirmations and invoices.
• Administer promotions, surveys, and other features of the Site.
• Improve our site to serve you better.
• Send technical notices, updates, security alerts, and support and administrative messages.
• Respond to your comments, questions, and requests, and provide customer service.
• Monitor and analyze trends, usage, and activities on the Site.
• Offer you a personalized product and service.

The purposes of improving the site, surveys, and usage measurement do not include your photos, your health information, or the content of your analysis. Measurement calibration, explained above, is a separate purpose and only happens with your authorization.

If you answer the quiz and do not buy, we keep your email and your quiz answers (except color or race, which is not stored) to send you Garbo news and offers. They are kept for as long as they are used to send news, until you ask to leave the list. To leave, use the link at the end of each email or write to contato@garbocare.com: your email and your quiz answers are deleted within 15 days, and we keep only the email and the date of the request, so we don't send anything else.

We also send a weekly newsletter with Garbo articles to the email you left with Garbo, on garbocare.com, or on Garbo's previous site; to leave, use the link at the end of each issue, and leaving the newsletter does not remove you from Garbo's other emails.

We may share the information we collect about you in some situations. Your information may be disclosed as follows:

• By law or to protect rights: if we believe that releasing information about you is necessary to respond to legal process, to investigate or remedy possible violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.
• Business transfers: we may share or transfer your information in connection with a merger, sale of company assets, financing, or acquisition of all or part of our business by another company, or during negotiations.
• Service providers: we may share your information with third parties that perform services for us or on our behalf: Mercado Pago (Brazil) in processing payment in Brazilian reais and Stripe (USA) in processing payment in US dollars (the card details stay with them, not with Garbo), Anthropic (USA), with the Claude models, in reading the photos, to prepare the analysis and to decide whether the clothing color images should show you in a plain T-shirt, and in the AI chat replies (to reply, it receives the result of your analysis, the conversation history, and the message you just sent), OpenAI (USA) in generating the images and, if Anthropic fails, in reading the photos (OpenAI does not receive the chat), Google (USA), with Gemini, in the AI chat replies if Anthropic fails, with the same data, in reading the photos if Anthropic and OpenAI fail and, if Anthropic fails, in reading one of your photos to decide whether the clothing color images should show you in a plain T-shirt, Face++ (Megvii, China, with servers outside Brazil) in marking the points of the face, in the skin analysis, and in building the 3D model of the face from the photos, TypeSafe (USA) in classifying the texts of the analysis, the questionnaire answers, and the chat messages and, in the free quiz preview, in choosing the suggestions from the facial measurements in words and categories (without the photo), Supabase (USA) for the database, Vercel (USA) for hosting, Resend (USA) for sending emails, Trigger.dev for processing background tasks, with data processing outside Brazil, Upstash for rate limiting and access protection, for which it receives the IP address, the account identifier, or a cryptographic digest of the email, depending on the operation, PostHog (USA) for analyzing use of the site and the dashboard, without the IP address, Sentry (Functional Software, Inc., USA) for notifying the team of site errors, without the IP address, Google (USA), with Gmail, for receiving operational alerts, which, in access or purchase delivery failures, may contain the account identifier, the email provided at payment, and the transaction details, so the team can resolve the problem, and Google (USA), with Google Tag Manager, and Meta (USA), with the Pixel and the Conversions API, for measuring ads and, with the Pixel, for showing Garbo ads to people who visited the site. The country in parentheses is where each company is headquartered, not necessarily where the data is stored. When a provider processes data outside Brazil, the transfer follows the LGPD rules for international transfers and, in the case of photos, depends on your specific authorization.
• Providers' terms: each provider also processes data under its own terms and its own privacy policy, which Garbo does not control. Anthropic states in its commercial terms that, by default, it does not use what it receives through the API to train its models; that it deletes what it receives and the responses it generates within 30 days, with exceptions, such as content flagged for violating its usage policy, which is kept longer, or when the law requires retention; and that it stores data in the USA and may also process it in other countries. Deleting your account or withdrawing your authorization at Garbo does not immediately delete what a provider has already received: those copies follow each provider's timeline. Face++ (Megvii), in particular, states in its terms that it may keep the images it receives and use them in internal research to improve its own algorithms, and that it deletes them when they are no longer needed, with no maximum period, on servers in China and Canada. By authorizing the use of your photos, you declare that you are aware of this and authorize sending them to Face++, outside Brazil.
• Google's terms for Gemini: Garbo uses Gemini under the paid API tier, under which, according to Google's terms, what is sent and the responses generated are not used to improve Google's products. Google states that it keeps logs of the content sent, the context, and the responses for 55 days for safety, abuse monitoring, and compliance with legal obligations; that its authorized employees may review content flagged in this monitoring; and that these logs do not train its general models, but may train the systems it uses to enforce its own usage rules. These logs are separate from the project's optional logs, which have their own retention periods; saved datasets may be kept with no fixed period. Voluntarily sharing datasets or feedback with Google may allow product improvement, model training, and human review, under the terms of those options. Personal, sensitive, or confidential data should not be shared through those options. The 55-day abuse monitoring period does not guarantee deletion of all copies in those other features. Google may process data in the countries where its facilities and those of its subprocessors are located, and Google's data processing agreement includes LGPD provisions and clauses for international transfer of data from Brazil. Deleting your account or withdrawing your authorization at Garbo does not immediately delete what Google has already received: those copies follow its timelines and rules.
• Affiliates: we may share your information with our affiliates and, in that case, we will require them to comply with this Privacy Policy.
• With your consent: we may disclose your personal information for any other purpose with your consent.

We use administrative, technical, and physical security measures to help protect your personal information. Although we have taken reasonable steps to protect the personal information you give us, please be aware that, despite our efforts, no security measure is perfect or impenetrable, and no method of data transmission is free from interception or other types of misuse.

Garbo is for people aged 16 or over, and Garbo's ads are not directed at minors under 18. The processing of data of people aged 16 or 17 must respect their best interests, as required by Article 14 of the LGPD. The optional authorization to calibrate the measurements is only for people aged 18 or over. After authorization, the photos sent to prepare the paid analysis go to Face++, including those of people aged 16 or 17. Under its terms, Face++ may keep these images for internal research and improvement of its own algorithms, outside Brazil, with no defined maximum period, as explained in “Disclosure of your information.”

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any change by posting the new Privacy Policy on this page and updating the “Last updated” date at the top of this Privacy Policy.

If you have questions or comments about this Privacy Policy, contact us:

GarboOctantis Apps LTDA, controller of your dataCNPJ 68.132.214/0001-55garbocare.comEmail: contato@garbocare.com

To exercise your rights as a data subject under the LGPD (confirm whether we have your data, access it, correct it, delete it, take it to another service, or withdraw your consent), write to contato@garbocare.com with the subject “LGPD Rights.” Account deletion can also be requested in the dashboard Settings, and the account, photos, and analyses are deleted from Garbo's systems within 15 days; what a provider has already received follows its own timeline, as explained in “Disclosure of your information.” The authorization for photos and health data can also be withdrawn in the dashboard Settings: the photos of your face are deleted from your account immediately, and the 3D model of your face within 24 hours; your health information and your demographic group stop being used; the written analysis remains in the dashboard. Here too, what a provider has already received follows its own timeline. Handling these rights is free of charge, done by email, on any plan, and does not depend on the AI chat. If you are not satisfied with our response, you can contact the Brazilian National Data Protection Authority (ANPD) at gov.br/anpd.