Privacy Policy

FollowUp Pal is operated by AVFA LLC, EIN 32-0841742, registered in the state of Wyoming, United States. It decides the purposes and means of processing the personal data described here.

Any privacy matter, including access or deletion requests, should be sent to the contact address at the bottom of this page, from the email registered on the account.

We process only the categories the product actually uses:

• Account. Name, email, hashed password (never stored in readable form) and the interface language you chose.
• WhatsApp connection. The connected number, the session credentials for that connection, and the names and numbers in the subscriber's own address book, which the product reads to identify who belongs in the pending list.
• Gmail connection (optional). The address of the connected Gmail account, the access credentials (tokens, encrypted) and the email data described in section 5.
• Conversation metadata. Message direction (sent or received), date and time, contact identifier, and whether a reply came back.
• Message content. The text of the messages exchanged in the connected number's conversations — sent and received — stored encrypted for up to 90 days. It is used to build the pending list and, when the subscriber asks for a draft, to give the AI model context (section 6). The product does not store media: photos, audio, video and documents are never kept.
• Subscription. Plan, billing status and transaction identifier. Card data never reaches our servers: it is collected and stored directly by the payment processor.
• Technical. IP address, browser user agent, and access logs for the dashboard and our APIs.

Each purpose maps to a legal basis under Brazil's Lei Geral de Proteção de Dados (LGPD) and the European General Data Protection Regulation (GDPR):

• Providing and billing the service — performance of the contract. Creating and maintaining the account, keeping the WhatsApp connection alive, building the pending list, issuing and reconciling subscription charges, and providing support.
• Security and fraud prevention — legitimate interests. Logging access, detecting misuse, protecting accounts from takeover, and investigating incidents.
• Product improvement — legitimate interests. Understanding in aggregate which features are used and where the product fails, without reading conversation content.
• Tax and accounting records — compliance with a legal obligation. Keeping billing and invoicing records for the periods the applicable law requires.
• Following up on Gmail email — consent. Given by the subscriber on Google's authorization screen when connecting the account, and revocable at any time (section 5).

This is the most sensitive point of the product, so we make it explicit: for the data of the contacts shown in the pending list — name, number and the history of that conversation — the subscriber is the controller and FollowUp Pal is the processor.

That means we process this data only to provide the contracted service and following the subscriber's instructions. We do not use those contacts for any other purpose, do not cross them between accounts, and do not use them for our own prospecting.

It is the subscriber's responsibility to have a lawful basis for processing their contacts' data and to handle the requests those contacts make. The same position is stated in section 8 of the Terms of Service.

If the subscriber connects a Gmail account to FollowUp Pal (the “Connect Gmail” button in the dashboard, with authorization on Google's screen), the product also follows the email conversations of that account, for the same purpose as WhatsApp conversations: identifying emails the subscriber sent that never got a reply and helping them draft and send the follow-up. Connecting Gmail is optional and is not required to use the product.

FollowUp Pal's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. The policy is available at https://developers.google.com/terms/api-services-user-data-policy.

• What we read. Message headers (sender, recipients, subject, date), message and thread identifiers and a short snippet of the text, only from conversations the subscriber takes part in. The full body of a message is fetched on demand, only when the subscriber asks for a draft, to give context to the AI model.
• What we store. Headers, identifiers and the short snippet, encrypted, for up to 90 days. Full message bodies are not stored; attachments are neither read nor stored. Access credentials (tokens) are kept encrypted and deleted on disconnection.
• What we write and send. The follow-up draft is generated inside FollowUp Pal and is only sent — as a reply in the same thread, from the subscriber's own Gmail account — when the subscriber clicks Send. We do not send emails automatically, do not create rules or filters, and do not modify or delete messages in the mailbox.
• Artificial intelligence. The snippet and, when requested, the message body are sent to the Google AI model described in section 6, exclusively to draft the subscriber's own follow-up, on the paid tier under which Google does not use this content to train or improve models. Gmail data is not used for advertising, is not sold and is not used for profiling.
• Human access. Nobody on our team reads email content. Human access only happens with the subscriber's explicit authorization for a support request, for security purposes (investigating abuse or an incident) or when required by law.
• How to disconnect. At any time, through the “Disconnect” button in the dashboard, or by revoking FollowUp Pal's access at https://myaccount.google.com/permissions. On disconnection the tokens are deleted immediately; email data already stored follows the 90-day limit or is deleted earlier on request.

We share data only with the subprocessors the service needs to run, each with a defined purpose and a data processing agreement:

• Supabase. Database and authentication: stores account data, conversation metadata, encrypted content and subscription records.
• WhatsApp connection infrastructure. Keeps the connected number's session alive and delivers conversation events to the product.
• Google LLC — artificial intelligence model. When the subscriber asks for a follow-up draft (or when the daily batch prepares drafts for their pending items), we send Google's AI model the contact's name, the last message sent and the most recent messages of that conversation, so the suggested text has context. We use the paid tier of the service, under which Google does not use this content to train or improve its models and retains it only for the limited period needed for abuse detection. Nothing is sent unless there is a pending item on an active account; the draft comes back to the subscriber and only reaches the contact if the subscriber approves it.
• Lovable. Application hosting, transactional email (sign-up confirmation, password recovery, billing notices and the pending-items digest) and the bridge for Google sign-in. The infrastructure providers Lovable relies on are bound to it by contract.
• Expo. Delivery of the mobile app's push notifications, when the subscriber installs it. A notification carries the contact's name and a short preview of the received message, which pass through Expo and through Apple's and Google's notification services on the way to the device.
• Paddle (official reseller and Merchant of Record). Processes the order and the subscription charge, issues receipts, collects applicable taxes, and handles payment data as its own controller.
• Google and Apple — sign-in. If the subscriber signs in with a Google or Apple account, the chosen provider confirms their identity and gives us their name and email. Each handles that data under its own policy.

Reminder emails we send to the subscriber may include the first name of their contacts — first name only, with no phone number, full surname or message excerpt — to show which conversations are still waiting for a reply.

We do not sell personal data and do not share it for advertising or third-party profiling. We may also share data with lawyers and accountants under confidentiality duties, and with authorities where the law requires it.

Data is processed and stored in the United States, where AVFA LLC is registered and where our subprocessors' servers are located.

For people in Brazil or the European Economic Area, this is an international transfer. The mechanism we rely on is contractual: we keep a data processing agreement with each subprocessor containing protection clauses equivalent to those required by the LGPD and the GDPR, including confidentiality, security, purpose limitation and assistance with data subject requests.

Each category has its own period:

• Message content: 90 days. Counted from sending, deleted automatically after that, with no request needed.
• Email data (Gmail): 90 days. Headers, identifiers and snippets are deleted 90 days after the message date. Access tokens are deleted the moment the account is disconnected.
• Conversation metadata and account data: for as long as the subscription exists. After cancellation they are kept for a further 90 days in case the subscriber returns, then deleted. Deletion can be requested sooner.
• WhatsApp session credentials: until disconnection. Deleted as soon as the number is disconnected in the dashboard.
• Tax and billing records: for the period the law requires. Kept even after the account is closed, because retention is a legal obligation.

Under article 18 of the LGPD you have the right to confirmation that processing exists, access to your data, correction of incomplete or outdated data, anonymisation, blocking or deletion of unnecessary or unlawfully processed data, portability, deletion of data processed on consent, information about who we share data with, and withdrawal of consent.

If you are in the European Economic Area or the United Kingdom, the GDPR gives you the equivalent rights of access, rectification, erasure, restriction of processing, portability, objection to processing based on legitimate interests, and withdrawal of consent, plus the right to lodge a complaint with your national data protection authority. In Brazil that authority is the ANPD.

To exercise any of these rights, write to the contact address on this page from the email registered on your account — that is how we confirm the request is yours. We reply within 15 days, and never later than 30 calendar days.

Data travels over encrypted connections and is encrypted at rest. Message content and connection credentials get an additional encryption layer before being written.

The database isolates data per subscriber: access rules are enforced in the database itself, so one account cannot reach another account's data. Human access by our team is restricted, logged, and only happens when the subscriber asks for support and explicitly authorises it.

No system is fully immune. We do not promise absolute security — we commit to technical and organisational measures appropriate to the risk, reviewed regularly. If an incident with material risk occurs, we notify affected subscribers and the competent authorities.

Functional cookies, needed for the site to work:

• Session cookie. Keeps the subscriber signed in while using the dashboard.
• fup_lang. Stores the chosen language so the site opens in the same language next time.
• fup_consent. Stores your choice about the measurement tools described below.

Beyond these, our public website uses three third-party tools: Google Analytics, Google Ads and the LinkedIn Insight Tag. They measure site audience, measure the results of our ads (how many visits became sign-ups or subscriptions) and build ad audiences on Google and LinkedIn.

These tools load by default, without asking for prior consent, and set cookies belonging to Google and LinkedIn. If you are in the European Economic Area or the United Kingdom and prefer that they never load, use the control below on your first visit.

How to refuse: in the footer of any page, click "Tracking preferences" and then "Opt out of tracking". It takes effect immediately, without reloading, and your choice is stored in the fup_consent cookie for 12 months. The same control lets you allow them again whenever you want.

FollowUp Pal is a professional product and is not intended for anyone under 18. We do not knowingly collect data from minors. If we identify such an account, it is closed and the data deleted.

This policy may be updated as the product changes. Material changes — a new purpose, a new subprocessor or a new retention period — are announced by email to active subscribers in advance.

The date of the last update is visible at the top of this page. Continuing to use the service after the notice means agreeing to the current version.