Privacy Notice

Last updated: 9 November 2026 · Version: 2026-11-09

This notice explains what data FLIO processes, why, who we share it with, and what you can do about it. It is written to be read, not to defend us from you.

The Portuguese version of this notice is the authoritative one. FLIO is operated by a Brazilian company under Brazilian law (the LGPD), and this translation is provided for convenience.

In short

• FLIO exists to organise your financial life, which means it has to read your transactions. We do not sell your data and we do not use it for advertising.
• Your bank password never passes through FLIO. The connection is made by a regulated Open Finance provider, inside your bank's own environment, and it is read-only.
• Your database is in Brazil, in the São Paulo region, and that is where your data is stored. The server that runs the application is in the United States, so your data is read and processed there every time you use it. Section 5 explains this properly.
• The AI receives summarised totals to generate your insights. The exception is receipt scanning, where the photo you upload is processed by an AI provider.
• You can download everything we hold about you, or delete your account, at any time, by yourself, inside the app.

1. Who processes your data

The controller of your personal data is:

DASHFY CONSULTORIA EM SISTEMAS DE INFORMACAO LTDA CNPJ 56.098.018/0001-22 Rua Rio de Janeiro, 243, Sala 802, Centro, Belo Horizonte/MG, CEP 30.160-040, Brazil Phone: (27) 99508-3732

Data Protection Officer (Encarregado): privacidade@flio.com.br

That is the channel for any question, request or complaint about your personal data.

2. What data we process

Data you provide

• Sign-up details: name, email and password.
• A profile picture, if you upload one.
• Accounts, cards, goals, budgets and categories you create.
• Statements you upload (OFX files).
• Notes and attachments you add to transactions (images, PDFs, text).
• Receipts you photograph.
• Assets you register: properties and vehicles, with their identifying details.
• People in your household you add as family members: a name, a colour and, if you upload one, a picture. We also keep which accounts, cards and transactions each person is linked to, and how you divide costs and settle up between you.
• An adult in your household you invite to sign in: their email, their date of birth (to confirm they are 18 or over) and the role you choose. A partner sees and manages your household's finances as you do; a restricted member only sees what is linked to them and cannot change anything. We keep these from the moment you send the invitation, before that person has signed in or agreed to anything, and we send them an invitation email on your behalf. The first time they sign in, they accept the terms and this notice themselves, and from then on we also keep their login, their sessions and that acceptance, as for any user. When you revoke their access, their login, sessions and acceptance are erased and they are signed out; the email, date of birth and role stay on the member so you can invite them again, until you remove the member or delete your account, which also erases their login. The invited person can exercise their own rights (section 9) through the contact in section 14.

Data from your bank, with your authorisation

• Identification of connected accounts and cards.
• Balances, limits and bills.
• Transactions: date, amount, description and merchant.

Data FLIO generates

• Categorisation of your transactions.
• Cash-flow and spending projections.
• Insights and reports on your financial behaviour.
• Suggestions for recurring payments, instalments and investments.

Your subscription data

• The plan you are on, the subscription's status and its renewal or end date.
• A customer identifier generated by Stripe, linking your account to their subscription record.
• Your card details never pass through FLIO. Payment happens on a page hosted by Stripe, and we neither receive nor store a card number, expiry date or security code.

Technical data

• IP address, browser and device, recorded on security and consent events.
• Application access logs.
• If you accept analytics cookies: the pages you visit, your browser and device type, and the sign-up and initial set-up steps you complete. Section 11 explains what happens if you decline.

3. What we use it for, and on what legal basis

You can withdraw marketing and analytics consent whenever you like without affecting your use of the product. The contract-based purposes cannot be switched off individually: they are the service. If you do not want them, the route is to close your account, and that is also in your hands.

4. Who we share it with

We do not sell your data and we do not share it for advertising. We share it only with providers that perform part of the service, and only as far as necessary:

We may also share data where legally required, by court order or at the request of a competent authority.

5. International transfers

There is a distinction here that most privacy policies skip: where your data is stored and where it is processed are not the same thing.

Where it is stored: Brazil. The database and the files you upload live in the São Paulo region, and so do the backups. The durable copy of your data does not leave the country.

Where it is processed: the United States. The server that runs the application is in Virginia, because our infrastructure provider has no South American region. In practice, every time you open the app your data is read from the database in Brazil and processed on that server. It is not stored there, but it passes through.

Add to that the AI, notification, error-monitoring, usage-analytics, bot-protection and payment providers, which also operate in the United States, and the email provider, which operates in France. That is the only destination outside Brazil which is not in the United States.

On payment: Stripe receives your email address, an internal identifier for your account, and whatever you type on their payment page. That page is Stripe's, not ours, which is why your card number never reaches us.

On error monitoring: when something breaks in the app we send Sentry the failure report, your account's internal identifier and the address of the screen it happened on. We do not send request contents, your IP address, or any screen recording. The identifier is there so we can tell whether a fault hit one person or everyone.

On bot protection: on the sign-in, sign-up and password forms, Cloudflare Turnstile runs a check in your browser to tell a person from an automated program. For that check Cloudflare receives your connection's IP address and information about your browser and device.

On usage analytics: if you accept analytics cookies, we send PostHog the pages you visit, your browser and device type, the sign-up and initial set-up steps you complete, and the plan you choose. If you are signed in we also send your account's internal identifier, and never your name, email address, balances or transactions. Page addresses have their parameters removed before they are sent, because that is where access codes would sit; only campaign-source parameters and the chosen plan remain. On the public pages of the site we may record your browsing session, with typing fields masked. Inside the app the screen is never recorded. As with any website you visit, PostHog receives your connection's IP address.

All of this is international transfer of personal data under LGPD Art. 33, and it happens on the basis of the standard contractual clauses approved by the ANPD (Resolution CD/ANPD No. 19/2024). The law permits these transfers; what it requires is that contractual safeguards exist and that you know they happen. That is why this section exists instead of a sentence claiming your data never leaves Brazil.

6. Artificial intelligence: what leaves here

This distinction matters, so it gets its own section:

• Insights, projections and reports: the AI provider receives summarised totals (how much went to each category, how the month behaved). Your name and your account numbers are not sent.
• Receipt scanning: this one is different. The photo you take is sent to the AI provider so the line items can be read, and it contains whatever is printed on the receipt, including your CPF if you gave it at the till. Scanning receipts is optional: your transactions arrive through your bank connection or your statements either way.

AI providers process this data only to answer FLIO's request. We do not use your data to train third-party models.

7. Automated decisions

FLIO makes automated decisions about your data. They are:

• Automatic categorisation of transactions.
• Detection of recurring payments and instalment plans.
• Cash-flow and spending projections.
• Automatic distribution of contributions across goals.
• Generation of insights and alerts.

These decisions are based on your history: amounts, dates, descriptions, merchants and how often they repeat. They are suggestions about your own financial life and have no effect on credit, scoring or access to third-party services.

Under LGPD Art. 20 you may request a review of any of them by writing to privacidade@flio.com.br. You can also turn off automatic application of suggestions in Settings, and review each one manually instead.

8. How long we keep it

When you delete your account everything goes, with two exceptions: the access logs the law requires us to keep, and the record that you asked for deletion. That last one contains nothing about you or your finances, and exists so we can demonstrate your request was honoured.

9. Your rights

LGPD Art. 18 gives you:

• Confirmation and access: whether we process your data, and what it is.
• Portability: a machine-readable copy.
• Correction of incomplete or outdated data.
• Deletion of your data.
• Information about who we share it with.
• Withdrawal of consent, and information about the consequences of refusing it.
• Review of automated decisions (Art. 20).

Four of these you exercise yourself, without asking anyone, in Settings → Data:

• Download your data generates a file with everything we hold about you.
• Delete my account blocks access immediately and erases everything after 7 days. You can cancel during that period.
• Disconnect a bank revokes the authorisation at the institution.
• Cookie preferences changes your choice about analytics cookies, at any time. The same link is in the site footer.

For the others, write to privacidade@flio.com.br. We reply immediately in simplified form and in full within 15 days, under LGPD Art. 19.

You may also petition the ANPD, Brazil's National Data Protection Authority, directly.

10. Security

• All traffic is encrypted in transit (HTTPS/TLS), and data is encrypted at rest with AES-256.
• Isolation between accounts is enforced by the database itself, which refuses to return records that are not yours, and not by the application alone.
• Files you upload are held in private storage, reachable only by you and only when signed in.
• Bot protection on sign-in, progressive lockout after repeated attempts, and expiring access links.
• We do not have and do not store your bank password.

No system is immune. In the event of a security incident carrying relevant risk, we will notify you and the ANPD within the deadlines set by Resolution CD/ANPD No. 15/2024.

11. Cookies

We use essential cookies: the ones that keep you signed in and remember preferences such as language. They do not depend on consent, because the service does not work without them.

With your consent we also use PostHog analytics cookies, to understand how the site and the app are used. We ask on your first visit, and declining is as simple as accepting. Until you answer, nothing is recorded.

If you decline, we count your visit without cookies and without storing anything in your browser. PostHog computes a code from your IP address and your browser, combined with a random value that changes and is discarded every day, so the same person is not recognised from one day to the next. In that case your browsing is not recorded and the visit is not linked to your account.

You can change this choice at any time under Cookie preferences, in the site footer or in Settings → Data. We do not use advertising cookies.

12. Children and adolescents

FLIO is not intended for anyone under 18: only adults create an account or sign in, and we do not knowingly collect data from children or adolescents as users. If we identify such an account, it will be removed.

The exception is your family. You can add a child, or anyone else in your household under 18, as a family member, to split the household's spending by person. In that case we keep only what you enter: a name, a colour and, if you upload one, a picture, plus the accounts, transactions and costs you link to that person. A member under 18 never gets their own access to FLIO: the invitation to sign in is refused for them. This data stays in your account and is deleted when you remove the member or delete the account.

13. Changes to this notice

We may update this notice. The date and version at the top show what is in force. If a change is material we will tell you, and where the law requires it, ask you to accept it again.

14. Contact us

Questions, requests or complaints about your data:

privacidade@flio.com.br

DASHFY CONSULTORIA EM SISTEMAS DE INFORMACAO LTDA · CNPJ 56.098.018/0001-22 Rua Rio de Janeiro, 243, Sala 802, Centro, Belo Horizonte/MG, CEP 30.160-040, Brazil