This text is not in force yet. It already describes what these pages do today — only the waiting list, no account and no billing — but it has not been through legal review. Until it is in force, nothing here counts as a commitment, and search engines are asked not to index this page.
In short: the only thing you hand us is an email address for the waiting list. A confirmation link goes to that address, and without confirmation it leaves the list within four days. To leave after confirming, you request an opt-out link yourself and click it, with no sign-in and nobody’s permission. No account, no password, no payment, no tracking before you say yes.
1. Controller and contact
The personal data processed on these pages is controlled by Gustavo Guedes, an individual. Contact: contato@affily.club.
There is no company behind Affily yet. When there is one, this section will carry the company’s razão social and CNPJ, and the change will be announced like any other (§ 13).
There is no formally appointed data protection officer. Resolution CD/ANPD No. 2/2022 waives that requirement for small-scale processing agents, provided a channel is kept open for data subjects. That channel is the address above.
2. What this site collects
- The address you type into the waiting-list form. It is the only piece of data you hand us on purpose.
- Language and origin
- Which of the three languages you were reading, and which page you signed up from — the home page or the product page. They tell us what language to answer in.
- Sign-up date
- The moment the sign-up was requested.
- Confirmation date
- The moment you clicked the confirmation link. Until then, the sign-up is pending. The two dates, the language and the origin are the record of your consent — with no IP address and no browser data.
- Confirmation and opt-out links
- Each link carries a single-use code. The database keeps only a cryptographic digest (hash) of that code, from which the code cannot be rebuilt, and the moment it expires: the confirmation link is valid for 72 hours, and the opt-out link for 24 hours.
- Technical records
- The server logs the IP address, date and time of requests, and the rate limiter counts requests per IP so the forms cannot be abused. On the two forms that send email — the sign-up form and the opt-out link request — it also counts per address: the address you type becomes the key of a counter, held in the server’s memory for up to an hour, even if it is not on the list. That counter goes to neither the log nor the database.
- Audience measurement
- Only after you accept in the banner. Google Analytics then receives what it collects by default: pages viewed, where the visit came from, device type and a browser identifier.
Each row also carries an internal identifier, generated at random, which says nothing about you and exists only so the database can tell one row from another.
We do not ask for your name, phone number, ID number, payment details or any sensitive data. There is no sign-up, no password and no account — please do not send any of it.
3. What we use it for, and on what legal basis
- Checking that whoever controls the address is the one who asked for the sign-up, by keeping the pending sign-up and sending the confirmation email to the address — legitimate interest (LGPD, art. 7, IX). We keep the minimum, for the shortest time that lets you click, and objecting costs nothing: just do not click.
- Telling you when Affily opens, in the language you signed up in — consent (art. 7, I), given by clicking the confirmation link and revocable at any time.
- Gauging interest and deciding what to build first, from the count and the origin of confirmed sign-ups — the same consent, given with the same click. Pending sign-ups are not counted.
- Sending the opt-out link you request, and deleting the address when you click it — compliance with a legal obligation (art. 7, II): it is the withdrawal of consent (art. 8, § 5) and the deletion you ask for (art. 18, VI), and the link is how we check that whoever asks controls the address.
- Keeping the forms standing and containing abuse, through operational logs and rate limits per IP and per address — legitimate interest (art. 7, IX), and the minimum that stops the forms becoming a spam gateway against a person.
- Understanding how the pages perform, through audience measurement — consent (art. 7, I), given in the banner and revocable there.
Until Affily announces its launch, the list receives two kinds of message and no other: the confirmation email, which goes to a pending sign-up, and the opt-out link, which goes to a confirmed sign-up only when it is requested through the form. The launch announcement will go only to confirmed sign-ups, with an opt-out link.
4. Cookies and what stays in your browser
This site sets no cookies of its own. What it does keep in your browser is a single local-storage entry, affily.consent, holding one of two values: granted or denied. It exists so we do not ask twice. It stays on your device and is never sent to the server.
If you accept measurement, Google Analytics then writes its own cookies. If you refuse, none are written — and refusing costs exactly the same single click as accepting.
There are no advertising, remarketing or profiling cookies here, and no social-network pixels.
5. Who we share it with
We do not sell personal data and we do not hand it to third-party advertising. Today it reaches:
- the provider that hosts the application and the database, so that the page exists and the list is stored;
- Resend, the transactional email provider, which delivers the list’s two emails — the confirmation and the opt-out link — and receives the address and the content of the message to do so;
- Google, as the audience-measurement provider — and only once you have accepted in the banner;
- authorities, where there is a legal obligation or a court order.
Nobody else. There is no email-marketing tool, no CRM, no support chat and no analytics beyond the one above.
6. International transfer
The hosting, the email-sending provider and the audience measurement may process data outside Brazil. Where they do, the transfer rests on the provider’s own standard contractual clauses and on safeguards equivalent to those required by art. 33 of the LGPD.
7. How long we keep it
A confirmed sign-up stays on the list until you ask to leave, or until Affily opens and the list has done what it promised. If the project is discontinued, the list is deleted.
A sign-up that is not confirmed leaves the list within four days of the last sign-up request: the confirmation link expires after 72 hours, and a daily routine deletes pending sign-ups whose link has expired.
Signing up again with a pending address does not create a second row: the language, the origin and the link become the new ones — the previous link stops working — and the date of the first sign-up is preserved. Signing up again with a confirmed address changes nothing, and no email is sent.
These deadlines apply to the list’s database, not to its backup copies: the backups keep the address until they expire. If one of them is restored, a pending sign-up it brings back leaves again through the same daily routine.
Technical records are kept only for as long as operating and debugging require. The six-month retention that art. 15 of the Brazilian Internet Civil Framework imposes applies to providers organised as legal entities, which is not the case here.
8. How to leave the list
To leave, follow the link in the footer of the pages, type the address and request the opt-out link. It reaches the address, it is valid for 24 hours, and the address is deleted from the list when you confirm on the page it opens — no sign-in, no questions. The link goes only to a confirmed sign-up; if you signed up and did not confirm, there is nothing to do: the pending sign-up leaves on its own within four days (§ 7).
Removal keeps working even while sign-ups are switched off. Closing the way out along with the way in would mean using a privacy safeguard to block the exercise of a right.
The answer to the link request is the same whether the address was on the list or not. That is deliberate: a different answer would turn the page into a way of finding out who signed up.
If someone else entered your address, it receives only the confirmation email, and without the click the address leaves the list within four days. There is nothing to do.
The backup copies of the database keep the address of whoever left until they expire, which is why a restore made from a copy older than the departure undoes it.
9. Security
Traffic between your browser and the platform runs over HTTPS. Access to the database is restricted to whoever operates the service, and the list’s forms are rate-limited per IP — and, on the two that send email, per address as well.
Collecting little is itself part of the security here: what is never collected cannot leak.
No system is immune to incidents. Should one occur with relevant risk to data subjects, we notify the people affected and the ANPD within the applicable deadlines.
10. Your rights
Art. 18 of the LGPD gives you the right to ask for:
- confirmation that processing exists, and access to your data;
- correction of incomplete or outdated data;
- anonymisation, blocking or deletion of unnecessary data;
- portability, and information about who we share it with;
- withdrawal of consent, at any time and without penalty.
Write to contato@affily.club and we answer within 15 days. For deletion, the removal page is faster than the email. Since the only data identifying you is the address itself, we act on requests sent from that address — it is how we confirm identity without asking for documents. You may also complain directly to Brazil’s National Data Protection Authority (ANPD).
11. Minors
Affily is aimed at people over 18 and offers nothing directed at children or adolescents. We do not knowingly collect a minor’s data; if such an address reaches the list, we delete it as soon as we are told — and the removal page settles it too.
12. What this policy does not cover yet
This version describes a platform that has not opened. There is no account, no password, no subscription, no billing and no integration with any third-party service — and therefore no processing of registration data, payment data or connected-account data.
When any of those exists, this policy is rewritten and published first, not afterwards. A policy that describes processing which does not happen is inaccurate in the direction that misleads; here the text follows the code, never the other way round.
13. Changes to this policy
When this text changes, the new version is published on this page and the date and version number at the top change with it.
A change that widens the processing is announced before it takes effect, and where it depends on consent it is asked for again rather than assumed.