O PepPro é um diário pessoal de acompanhamento. Ele não é um dispositivo médico e não substitui orientação profissional de saúde.
Plain Language Summary
PepPro is an app for tracking, organizing, and educating about information related to peptides, GLP-1, nutrition, and fitness.
PepPro is not a medical device and does not provide medical advice, diagnosis, treatment recommendations, or dosing instructions.
We collect personal, account, subscription, device, and health-related tracking information when you use PepPro.
We use this information to operate the App, sync your data, provide tracking tools, personalize your experience, manage subscriptions, improve the App, maintain security, and respond to support requests.
We currently do not sell your personal information or your health data.
We currently do not share your personal information or health data for targeted advertising.
We currently do not use your personal health data to train AI models owned by PepPro.
Some features use third-party service providers, including our backend and infrastructure provider, Adapty, the AI provider, Apple, Google Play, and PostHog. We try to limit the information shared with each provider to what is necessary for that feature.
Apple Health and Google Fit data are read with your permission and are not stored on PepPro's servers.
If Upside Company is involved in a merger, acquisition, financing, asset sale, bankruptcy, reorganization, or similar transaction, user information may be transferred to the acquiring or successor entity as part of the transaction. Any future use remains subject to applicable law, required notices, and your rights.
You can access, correct, export, or delete your data, and you may have additional rights depending on where you live.
This summary is for convenience only. The full Privacy Policy below prevails.
1. Overview
PepPro is developed and operated by Upside Company ("PepPro," "we," "us," or "our"), based in Porto Alegre, Rio Grande do Sul, Brazil.
This Privacy Policy and Health Data Notice explains how we collect, use, store, disclose, transfer, and protect information when you use PepPro, our website, and related services.
By creating an account, using the App, or using our services, you agree to this Privacy Policy. This Policy is incorporated into our Terms of Use.
Data Controller: Upside Company is the controller responsible for the personal information processed under this Policy, in accordance with the General Data Protection Law (Law No. 13,709/2018).
2. Medical Notice
PepPro provides only tracking, organization, education, and information features.
PepPro is not a healthcare professional, medical device, pharmacy, telemedicine service, emergency service, or substitute for professional medical advice.
PepPro does not provide medical advice, diagnosis, treatment recommendations, prescriptions, or dosing instructions.
Any information provided by the App, including AI-generated responses, educational summaries, scan results, calculations, estimates, reminders, or tracking insights, is for informational and organizational purposes only.
Always consult a qualified healthcare professional before making health-related decisions.
3. Key Terms
Personal information means information that identifies, relates to, describes, or can reasonably be linked to a person.
Health data means information about your health, well-being, body, peptide use, medication use, dose records, injection sites, side effects, weight, lab results, nutrition, hydration, sleep, progress photos, notes, and similar information that you enter, submit, scan, import, or generate in PepPro.
Sensitive personal data means information treated as sensitive under applicable privacy law, including health data, account credentials, body-related photos, and other protected information. Under the LGPD, health-related data is sensitive personal data.
De-identified (anonymized) data means data processed to remove or obscure personal identifiers, so that it cannot reasonably be linked to a specific person.
Aggregated data means data combined from multiple users into summary statistics or trends.
4. Where This Policy Applies
This Privacy Policy applies to:
iOS App — users can create an account, track information, manage subscriptions, use AI features, and optionally connect Apple Health. Android App — users can create an account, track information, manage subscriptions, use supported features, and optionally connect Google Fit. Website — provides marketing information, links, legal pages, and support contact. Support communications — if you contact us, we process the information you choose to send.
5. Information We Collect
Account Information
We may collect: name, if provided; email address; phone, if provided; authentication provider (such as Apple or Google); account ID; profile photo URL, if provided; and basic account settings.
We use this information to create and manage your account, authenticate you, sync your data, provide support, and protect the App.
Onboarding Information
We may collect information you provide during onboarding, such as: goals, starting weight, primary objective, peptide experience, peptides or GLP-1s used (if provided), age, height, and preferences and settings.
We use this information to personalize your experience and provide relevant tracking tools.
User-Entered Tracking Data
PepPro may collect health-related tracking data that you choose to enter, including: peptide or GLP-1 names; inventory and vial information; dose records and history; injection sites; side effects; hydration; nutrition and calories; weight; sleep; lab results; progress photos; daily check-ins; notes; reminders; and custom entries.
This information is used to provide PepPro's core tracking, organization, reminder, history, and personalization features.
Meal Analysis Data (Photo and Text)
If you use photo or text calorie analysis, photos or meal-related information may be processed by the AI provider to generate nutritional estimates.
Meal photos are used to return the requested result and, depending on your responses, stored locally on your device after processing. We do not intentionally send meal photos to analytics or attribution platforms.
Progress Photos and Uploaded Images
If you save progress photos, vial photos, body photos, or other images in the App, these images may be stored with your account and treated as sensitive information where required by law. You should not upload images containing unnecessary personal, medical, or identifying information.
AI Assistant and Messages
If you use the AI assistant or other AI features, your messages and limited session context may be sent to the AI provider to generate a response.
The AI assistant is for educational and informational purposes only. It does not provide medical advice, diagnosis, treatment, or dosing instructions. We currently do not use AI assistant messages or personal health data to train AI models owned by PepPro.
Apple Health Data
With your permission, PepPro may read certain Apple Health data, such as: steps, workouts, active energy, and other activity metrics you authorize.
Apple Health data is read locally and is not stored on PepPro's servers.
PepPro will not sell Apple Health data, will not use it for advertising or marketing, and will not share it except as permitted by Apple HealthKit rules and applicable law.
Google Fit Data
With your permission, PepPro may read activity and fitness data from Google Fit that you authorize. This data is used only for the features you request and handled in accordance with Google's policies and applicable law.
Subscription Information
Subscriptions are processed by the Apple App Store, Google Play Store, and Adapty.
We may receive: subscription status, entitlement status, product identifier, renewal status, and purchase metadata. We do not receive your full payment card information.
Analytics Data
We use analytics tools to understand App performance, onboarding, and feature usage. We may use providers such as PostHog, Apple, and Google.
We do not intentionally send health entries, dose records, side effects, lab results, notes, injection sites, or peptide and GLP-1 tracking details to PostHog.
Device and Technical Information
We may collect: device type, operating system, App version, error reports, performance logs, basic diagnostics, and network and request metadata (such as IP address, when processed by service providers for routing, security, and fraud prevention).
Support Communications
If you contact PepPro for support, we may collect the information you choose to include in your message. Please avoid sending unnecessary health information. If you include health-related information, screenshots, logs, photos, or account details, we treat this information as sensitive where required and use it only to respond to your request, troubleshoot, maintain support records, prevent fraud or misuse, and comply with legal obligations.
6. Health Data Notice
This section explains how PepPro handles health data.
PepPro may collect health data that you choose to enter, submit, scan, import, or generate through the App. This may include peptide information, dose records, injection sites, side effects, inventory, weight, nutrition, hydration, sleep, progress photos, and notes. Under the LGPD, this data is sensitive personal data and receives enhanced protection.
We use health data to: provide core tracking features; help you organize records, history, inventory, and reminders; sync your data across devices; provide AI features you request; personalize your experience; improve App functionality and reliability; maintain security and prevent misuse; respond to support requests; and comply with legal obligations.
We currently do not sell health data. We currently do not share health data for targeted advertising. We currently do not use personal health data to train AI models owned by PepPro.
If we materially expand how we use, disclose, license, sell, or otherwise process health data, we will update this Policy and provide the notices, consents, authorizations, opt-out options, or other mechanisms required by applicable law.
7. How We Use Information
We use information to: provide, operate, and maintain PepPro; create and authenticate accounts; sync data across devices; provide tracking, logging, reminder, and history features; provide AI features you request; process meal analyses and uploaded photos; personalize your experience; manage subscriptions and entitlements; send reminders and notifications you enable; respond to support requests; improve functionality and reliability; debug issues and fix errors; understand general usage patterns; prevent fraud, abuse, and unauthorized access; enforce our Terms of Use; comply with legal obligations; and protect the rights, safety, and security of users, PepPro, and third parties.
Legal Bases (LGPD)
We process personal data based on: performance of a contract (to provide the App and requested services); consent (for optional features such as Apple Health and Google Fit access, certain AI features and notifications, and for the processing of sensitive personal health data); legitimate interest (for security, abuse prevention, performance improvement, and understanding general usage, where your rights and freedoms do not prevail); and compliance with a legal or regulatory obligation.
8. Future Uses We May Consider
PepPro may consider additional uses in the future, including: research partnerships; de-identified or aggregated trend analysis; product improvement using de-identified or aggregated data; AI model improvement using de-identified, aggregated, or consented data; data licensing or commercial partnerships involving de-identified or aggregated information; and business- or acquisition-related transfers.
We currently do not sell personal information or health data. Before starting any future practice that requires notice, consent, authorization, or a right to object, we will update this Policy and implement the mechanisms required by applicable law.
Nothing in this section changes our Apple HealthKit commitments. Apple Health data is excluded from any sale, advertising use, unrelated third-party disclosure, or AI training use that violates Apple's rules or applicable law.
9. How We Share Information
We share information only as described in this Policy.
Service Providers
We share information with vendors and service providers that help us operate PepPro. These providers may process information only to provide services to us, subject to contractual obligations and applicable law.
| Provider | Purpose | Data Involved |
|---|---|---|
| OpenRouter | AI assistant, photo and text calorie analysis, AI Insights | Message text, photos, limited session context |
| Adapty | Subscription management | Subscription status, purchase metadata |
| Apple App Store | iOS billing and subscriptions | Subscription status and purchase data |
| Google Play Store | Android billing and subscriptions | Subscription status and purchase data |
| Apple HealthKit | Optional activity sync | Authorized HealthKit data, read locally |
| Google Fit | Optional activity sync | Authorized activity data |
| PostHog | Product analytics | Non-health usage data |
| Support / email tools | Customer support | Information you choose to send |
Legal and Security Disclosures
We may disclose information if required by law, subpoena, court order, legal process, or request from an authority or regulator. We may also disclose information if we believe it is necessary to protect the rights, safety, property, or security of PepPro, users, or third parties.
With Your Consent
We may share information with third parties when you give explicit consent or instruct us to do so.
Business Transfers
If Upside Company or substantially all of our assets are involved in a merger, acquisition, financing, reorganization, bankruptcy, asset sale, assignment, change of control, or similar transaction, your information may be transferred to the acquiring or successor entity as part of the transaction.
The acquiring or successor entity may continue to use, process, store, and disclose your information in connection with operating, maintaining, improving, marketing, and developing PepPro or related products and services, subject to applicable law, this Policy, required notices, and any consent, authorization, objection, or deletion rights available to you.
If the acquiring or successor entity intends to materially change how personal data or sensitive personal data is used, shared, sold, licensed, or processed, it will provide notice and obtain any consent or authorization required by applicable law before those new practices begin.
Apple HealthKit data is excluded from any business-transfer use that violates Apple HealthKit rules or applicable law.
10. What We Currently Do Not Do
PepPro currently does not: sell personal information; sell health data; share personal information for cross-context behavioral advertising; share health data for targeted advertising; use health data for advertising; use Apple Health data for advertising, marketing, data mining, or sale; use your personal health data to train AI models owned by PepPro; provide medical advice, diagnosis, or treatment recommendations; provide dosing instructions; store Apple Health data on PepPro servers; or intentionally send health entries to PostHog.
If any of these practices change, we will update this Policy and provide notice, consent, authorization, or objection rights where required by law.
11. Apple HealthKit Commitments
If you connect Apple Health, PepPro will comply with Apple HealthKit rules.
Apple Health data: will not be sold; will not be used for advertising; will not be used for marketing; will not be used for use-based data mining; will not be shared with third parties except as permitted by Apple and applicable law; will only be accessed with your permission; will only be requested for data types relevant to the App's functionality; and will not be stored on PepPro servers, unless a future feature clearly states otherwise and receives the required permissions.
These commitments prevail over any broader future-use or business-transfer language in this Policy.
12. Where and How We Store Data
| Data Type | Storage | Notes |
|---|---|---|
| Account data | Backend / cloud | Login, account management, and sync |
| Tracking data | Backend / cloud | App features and account sync |
| Uploaded photos | Cloud or AI provider during processing | Stored if saved by user or required for the feature |
| Meal analysis | AI provider during processing; locally afterward | Used to return requested results |
| Apple Health data | Local device only | Read locally, not stored on PepPro servers |
| Google Fit data | As permitted | Used only for requested features |
| Subscription status | Adapty, Apple, Google | No full payment card data |
| Analytics | PostHog | Non-health usage data |
| Support messages | Email / support tools | Only information you choose to send |
We use reasonable administrative, technical, and organizational safeguards to protect information, including encryption in transit and encryption at rest where supported by our service providers. No system can guarantee absolute security. If a security incident requires notification under applicable law, we will notify affected users and the National Data Protection Authority (ANPD) as required.
13. Data Retention and Deletion
We retain information only for as long as reasonably necessary for the purposes described in this Policy, unless a longer period is required or permitted by law.
| Data Type | Retention |
|---|---|
| Account data | While your account is active |
| Tracking data | While your account is active, unless deleted by you |
| Saved uploaded photos | Until deleted by you or account deletion |
| Subscription records | As needed for billing, support, fraud prevention, and legal compliance |
| Support records | For as long as reasonably necessary for support, records, and legal obligations |
| Error / performance logs | Limited period for debugging, then deleted or aggregated |
| Anonymous, aggregated, or de-identified data | May be retained indefinitely |
Upon an account deletion request: active system data is deleted or deactivated within a reasonable time, generally within 30 days; backup copies may persist for a limited period before being overwritten; some information may be retained for legal, security, fraud prevention, dispute resolution, tax, accounting, or compliance purposes; and data already processed by third-party service providers may remain subject to their retention schedules.
Apple Health data does not require deletion from PepPro servers, because we do not store it on our servers.
14. Your Privacy Rights (LGPD)
Under the General Data Protection Law, you have the right to:
Confirmation that your data is being processed; Access to your data; Correction of incomplete, inaccurate, or outdated data; Anonymization, blocking, or deletion of unnecessary, excessive, or non-compliantly processed data; Portability of your data to another service provider, upon express request; Deletion of personal data processed based on your consent; Information about the public and private entities with which we share your data; Information about the possibility of not providing consent and the consequences of refusal; Withdrawal of consent at any time; Review of decisions made solely on the basis of automated processing.
You can manage several choices in the App, including deleting or editing tracking data, disabling AI features, revoking Apple Health and Google Fit access, and managing notifications.
For account deletion or privacy requests, contact: contato@upsidecompany.com.br.
Data Protection Officer (DPO)
Our Data Protection Officer (Encarregado) can be contacted at: contato@upsidecompany.com.br. You may also file a complaint with the National Data Protection Authority (ANPD).
15. International Users and Legal Bases
PepPro is operated from Brazil. If you use PepPro from outside Brazil, your information may be transferred to and processed in Brazil and in other locations where our service providers operate.
If you are in the European Economic Area, the United Kingdom, or another region that requires a legal basis for processing (for example, under the GDPR), we process information under the following bases: performance of a contract (to provide the App, account features, tracking tools, subscriptions, and requested services); consent (for optional features such as Apple Health and Google Fit access, certain AI features, and notifications); legitimate interest (to protect the App, prevent abuse, improve performance, debug issues, and understand general usage); and legal obligations.
Where required, we use appropriate safeguards for international transfers, such as contractual clauses with service providers. Where local law grants you rights beyond those provided by the LGPD, we will seek to honor them as applicable.
16. Cookies and Tracking Technologies
The App does not use traditional website cookies. Our website may use essential cookies and basic analytics to understand and improve traffic. We currently do not use website cookies for cross-site behavioral advertising. You can control cookies through your browser settings. If we add technologies that require consent, we will update this Policy and provide the required consent mechanisms.
17. Age Requirement
PepPro is intended only for users aged 18 or older. We do not knowingly collect personal information from individuals under 18. If we learn that we have collected information from someone under 18, we will delete it as required by law.
18. Third-Party Links and Services
PepPro may contain links to third-party websites, products, services, or content. This Policy does not apply to third-party services. We are not responsible for the privacy practices, content, or policies of third parties.
19. Automated Decisions
Some features, such as AI calorie analysis and AI Insights, involve automated data processing to generate estimates and patterns. These outputs are informational and do not make decisions with legal effects on you. Under the LGPD, you may request review of decisions made solely on the basis of automated processing that affect your interests.
20. Changes to This Policy
We may update this Policy from time to time. The current version will be published at https://pepproapp.com/privacy. If we make material changes, we will provide notice where required by law, by email, in-app notice, or website notice. Continued use of PepPro after the effective date of an updated Policy means you accept it, except where additional consent or authorization is required by law.
21. Contact Us
Upside Company, operator of PepPro, Porto Alegre, Rio Grande do Sul, Brazil. CNPJ: 57.129.114/0001-53. Email: contato@upsidecompany.com.br. Data Protection Officer (DPO): contato@upsidecompany.com.br.
Privacy Policy: https://pepproapp.com/privacy Terms of Use: https://pepproapp.com/terms
© 2026 Upside Company. PepPro™. All rights reserved.