1. Who we are
EITA Mentor (called EITA Mentora Virtual in Brazil) is a mental health guidance and information service run by an AI agent that talks with you on WhatsApp. Its content is informational and educational, does not replace professional advice, and is not an emergency service.
Data controller: EITA Mentor (EITA Mentora Virtual)
Contact email and privacy questions: suporte@mentoravirtual.com.br
Data Protection Officer (DPO): same contact as above
2. Scope
This Policy describes how we collect, use, share, and protect personal data when you use the Service on WhatsApp, our subscription channels, and our support channels. By using the Service, you agree to this Policy.
3. Legal bases and principles
We process personal data in accordance with Brazil's General Data Protection Law (LGPD), following the principles of purpose, adequacy, necessity, security, prevention, transparency, and non-discrimination. The legal bases we rely on most are performance of a contract, compliance with a legal obligation, legitimate interest, and consent where required. To measure website audience and campaign results and to personalize ads, we rely on legitimate interest, always with the option to turn it off. Details are in section 20.
4. What data we process
Registration and subscription
Name, phone number, email, subscribed plan, payment history, and records of acceptance and consent.
Use of the Service
The full content of the messages you exchange with the virtual mentor, including any attachments you send, plus interaction metadata, preferences, and feedback.
Support and communication
Support records, requests, complaints, and proof of identity when necessary.
Technical data
Access logs, device and app information, date and time, approximate IP address, and session identifiers.
Data you choose to share
Any information you share in your conversations. EITA recommends that you avoid sending sensitive information. If you do share it, we handle it with reinforced safeguards.
5. Purposes of use
- Providing the Service and personalizing responses
- Technical support and customer service
- Compliance with legal obligations, fraud prevention, and security
- Ongoing improvement of the Service, including adjustments to prompts, models, and flows
- Metrics and analytics
- Research and development using anonymized and aggregated data
- Communications and offers: sending notices and offers of EITA products and services by email, phone, and WhatsApp, based on your consent or on legitimate interest, with the option to unsubscribe from offers at any time
6. Processing of sensitive data
When you share sensitive data in a conversation, we use it only to provide the automated service and for your safety. We apply data minimization, restricted access, audit trails, and short retention. Sensitive data is never used for advertising or commercial profiling.
7. Anonymization and use for improvement
We may use excerpts of conversations and usage events, in anonymized and aggregated form, to train, calibrate, and evaluate our systems. Anonymization includes removing or generalizing direct and indirect identifiers, applying minimization rules, and controls against re-identification. We do not publish individual content and we do not sell personal data.
8. Third-party sources and integrations
Messages travel through WhatsApp. If you use WhatsApp Business, Meta Platforms and any connection providers may process data under their own policies.
Cloud, processing, and payment providers
We use providers for hosting, AI processing, secure media, analytics without direct identification, and payment processing. We choose partners with robust security and compliance standards.
Authorized distributors
If you subscribe through a distributor, we share only the minimum needed to activate the service, issue invoices, and provide support.
9. Children and teenagers
The Service is intended for people 18 and older. We do not knowingly collect data from minors. If we identify use by a minor, we will take steps to end access and delete the data, except where we are legally required to keep it.
10. Information security
We apply technical and organizational controls suited to the sensitivity of the Service. Examples:
- encryption in transit and at rest where applicable
- separated environments and role-based access control
- logging and monitoring of security events
- testing and review of code and sensitive prompts
- incident response policies, with notification to data subjects and to the ANPD (Brazil's National Data Protection Authority) when required
No measure is absolute. If an incident poses a relevant risk, we will notify those affected and the competent authorities within the applicable deadlines.
11. Retention and disposal
We keep personal data for as long as needed to fulfill the purposes of this Policy and our legal obligations. General guidelines:
- conversations and operational metadata: retained for an indefinite period, which may be adjusted by legal requirements or for the defense of rights
- consent and contract records: for the term of the contract and up to 5 years after it ends
- technical logs: 24 to 36 months
- sensitive data: minimization and shorter periods whenever possible
When these periods end, we securely dispose of the data or irreversibly anonymize it.
12. Automated decision-making and profiling
The virtual mentor generates responses using language models. We do not make automated decisions that produce legal effects or similarly significant effects on you without a legal basis or your consent. Any profile we use is functional and limited to delivering content and improving the Service.
13. Your rights as a data subject
You may request:
- confirmation that we process your data, and access to it
- correction of incomplete, inaccurate, or outdated data
- anonymization, blocking, or deletion of unnecessary or excessive data, or data processed in violation of the law
- portability, where applicable
- information about who we share your data with
- withdrawal of consent and objection to processing based on legitimate interest
- review of automated decisions, where applicable
To exercise these rights, contact suporte@mentoravirtual.com.br. We may ask for information to verify your identity.
14. Sharing
We share personal data only with:
- processors that provide us with processing, cloud, support, payment, and analytics services
- advertising platforms (Meta, Google, TikTok, and Pinterest), in pseudonymized form, to measure campaigns and personalize ads, unless you turn this off (section 20)
- authorized distributors involved in your subscription and support
- public authorities, upon a valid legal request
We require contracts, confidentiality, and security measures from our processors.
15. International transfers
If data is transferred internationally, we adopt appropriate safeguards, such as standard contractual clauses, risk assessment, and additional security measures, ensuring a level of protection equivalent to that required in Brazil.
16. Payments and billing
Payment data is handled by the payment methods made available at the time of purchase. We receive the transaction identifiers and statuses needed for activation, tax invoicing, reconciliation, and fraud prevention. We do not store full card data.
17. Communications and notices
We use WhatsApp, email, phone, or other channels to send operational notices, contract changes, security communications, and information about your subscription, as well as offers of EITA products and services. You can stop receiving offers at any time through the link or instructions in the message itself, or by contacting support. Essential communications about your account, billing, and security will continue.
18. How we handle content removal
We may review and, when necessary, remove parts of conversations that violate the Terms of Use, our security policies, or the law. We keep minimal records to prevent abuse and comply with the law.
19. Accuracy of AI-generated content
Content may contain errors or bias. We recommend that you verify information and seek qualified professionals when needed. The Service is not suitable for emergencies. If your life or safety is at risk, contact your local emergency services.
20. Cookies and measurement technologies
On the mentoravirtual.com.br and eitamentor.com websites, we use cookies and similar identifiers in four categories:
- Essential: needed for the website to work, such as security, language, and session. Always on.
- Measurement and performance: page usage statistics (Google Analytics, processed on our own server) and, on the sales page and at checkout, heatmaps and session recordings with data masked (Microsoft Clarity, described below). Legal basis: legitimate interest (Article 7, IX, of the LGPD).
- Campaign measurement: identifying which ads brought you here and measuring results. We share pseudonymized data (browsing identifiers and, when you provide them, hashed email and phone number) with Meta, Google, TikTok, and Pinterest. Legal basis: legitimate interest.
- Personalized advertising: more relevant ads and content based on your browsing, including remarketing. Legal basis: legitimate interest, with the right to object. On by default; turn it off whenever you like.
Microsoft Clarity. On the sales page and at checkout, we use Microsoft Clarity, a Microsoft service, to understand how people navigate and to improve our pages. It creates heatmaps and session recordings from taps, clicks, and scrolling and from the content shown on the page. Form fields, conversations with EITA's Secretary, and screens that show your data are masked, and what you type is never collected. Recordings are kept for up to 30 days. Clarity uses the cookies _clck (1 year) and _clsk (1 day) and only runs when the Measurement and performance category is on. To opt out, open "Manage" in the cookie notice (or use the button below) and turn off Measurement and performance. The data is processed by Microsoft, including outside Brazil, with the safeguards described in section 15. Learn more in the Microsoft Privacy Statement.
All categories are on when you first arrive at the website; essential cookies cannot be turned off. You can turn the others off at any time in the cookie notice, using "Reject non-essential" or "Manage," or through the link below. When you turn a category off, we delete its cookies from your browser. Your choice is stored in your browser and remains in effect until you change it or clear your browsing data.
We do not use cookies to process sensitive data or the content of your conversations with the virtual mentor. To turn off personalized ads directly on the platforms, use Google Ad Settings, your Facebook and Instagram ad preferences, and the aboutads.info portal.
21. Changes to this Policy
We may change this Policy at any time. If we make relevant changes, we will notify you via WhatsApp, email, or another appropriate channel before they take effect. Continuing to use the Service after the update means you agree to it.
22. Contact
Questions, data subject requests, and security matters
suporte@mentoravirtual.com.br
Appendix A. Additional transparency for WhatsApp
When you interact with EITA on WhatsApp, your phone number and message metadata are processed by WhatsApp. Please also see Meta's policies related to WhatsApp.
Appendix B. Summary of safeguards for sensitive data
- collected only on the user's initiative
- minimal capture and storage
- logical isolation and reinforced access control
- access logs with audit trails
- reduced retention and secure disposal
- used only to operate the Service and for safety
- never used for advertising
Appendix C. Internal standards for improvement with anonymized data
- removal of direct and indirect identifiers before analysis
- statistical aggregation for metrics and testing
- human reviews under confidentiality and minimum access, only when strictly necessary
- prohibition of re-identification and periodic audits
- documentation of derived datasets, their purpose, and retention period
Language
This Privacy Policy was originally written in Portuguese. This English version is provided for convenience only. In case of any discrepancy between the versions, the Portuguese version prevails.