Privacy Policy
Version 1.2 — effective from 21 October 2026
This Policy explains what personal data we collect, why we collect it, who we share it with and what you can ask of us. It was written to be understood — each section starts with a plain summary.
This is an English translation of the Portuguese version. If the two differ, the Portuguese version prevails.
1. Who is responsible for your data
In short: a Brazilian company, with a registered address and tax ID, and a privacy officer you can contact.
Data controller:
PAULO CAIRES PENA PESSOA JUNIOR TECNOLOGIA DA INFORMAÇÃO LTDA
CNPJ (Brazilian company ID) 67.944.832/0001-37
Rua Visconde do Rio Branco, 1488, Conj. 909, Centro, Curitiba/PR, CEP 80.420-210, Brazil
Trading name: Trix Travel
Data Protection Officer (DPO):
Paulo Pena — privacidade@trix.travel
This Policy follows Brazil’s General Data Protection Law (LGPD, Law No. 13,709/2018), the Brazilian Civil Rights Framework for the Internet (Marco Civil da Internet, Law No. 12,965/2014) and the Brazilian Consumer Protection Code.
2. What data we collect
In short: what you type (email, travel preferences), what the app records automatically (IP, device) and what the AI learns about your travel style.
2.1. Data you provide
| Category | Data |
|---|---|
| Sign-up | Email, password (stored encrypted, never in readable text) |
| Profile (optional) | First name, phone number, avatar chosen from the app’s own illustrations, date of birth, gender, home city |
| Travel preferences | Travel style, pace, budget range, interests (“vibes”) |
| Itineraries | Destinations, dates, number of travellers, estimated and actual budget, special requests, checklists, activities added or removed |
| Communication | Content of the messages you send us |
| Waiting list | Email given on the website |
2.2. Data collected automatically
| Category | Data |
|---|---|
| Access logs | IP address, date and time of connection, browser or device identification (user agent) |
| Use of the service | Itineraries generated, features accessed, processing used per request |
| Diagnostics | Technical error logs, to find and fix faults |
| Website | Browsing data collected by an analytics tool (see Section 7) |
2.3. Travel DNA — what the AI learns about you
As you accept, replace, remove or favourite activities, the system automatically updates a preference profile: things you tend to like, things you tend to avoid, preferred pace and travel style. We call this Travel DNA, and it exists so that your next itineraries need fewer corrections from you.
Section 4 explains in detail how this profile works and how to turn it off.
2.4. Data we do NOT collect
- Payment data. Purchases are processed entirely by the App Store or Google Play. We never have access to your card, bank account or payment method.
- Real-time location. We do not track where you are. When the itinerary opens an address on a map, that happens in your device’s maps app, outside our reach.
- Contacts, calendar, photos or messages on your device.
- Third-party data. We do not buy lists or enrich your account with external databases.
2.5. Sensitive data
We do not ask for, and have no interest in, sensitive data — racial origin, religious belief, political opinion, membership of a trade union or religious organisation, health data or data about sex life.
Some preference fields could, in theory, reveal information of this kind. So we take a preventive measure: preferences are structured as closed, predefined options, with no free-text field in these categories, and the system does not automatically infer information of this kind from your behaviour.
If you nevertheless volunteer sensitive information in a special request, it will be processed only to generate that itinerary and will be deleted together with it. We ask you to avoid doing so.
3. Why we use your data, and on what legal basis
In short: each use has a legal justification. Marketing only with your permission; the rest is the minimum the service needs to work.
| Purpose | Data used | Legal basis (LGPD) |
|---|---|---|
| Create and maintain your account, authenticate access | Sign-up, access logs | Performance of a contract — art. 7, V |
| Generate, save, edit and share itineraries | Profile, preferences, itineraries | Performance of a contract — art. 7, V |
| Personalise suggestions (Travel DNA) | Preferences, interactions with activities | Legitimate interest — art. 7, IX (with an option to turn it off) |
| Support and customer service | Sign-up, communication, diagnostics | Performance of a contract — art. 7, V |
| Notify you about your account and your itinerary | Email, phone number | Performance of a contract — art. 7, V |
| Link the account to a phone number, as a security factor | Phone number | Legitimate interest — art. 7, IX |
| Prevent fraud, abuse and misuse of promotions | Access logs, usage data | Legitimate interest — art. 7, IX |
| Information security and fixing faults | Access logs, diagnostics | Legitimate interest — art. 7, IX |
| Measure usage and improve the product | Usage data, preferably aggregated | Legitimate interest — art. 7, IX |
| Keep application access logs | IP, date and time | Legal obligation — art. 7, II, together with art. 15 of the Marco Civil da Internet |
| Meet tax and accounting obligations | Transaction records | Legal obligation — art. 7, II |
| Announce the product launch (waiting list) | Legitimate interest — art. 7, IX (the purpose of the waiting list itself) | |
| Send additional travel content and other news | Email, first name | Consent — art. 7, I |
| Exercise rights in legal proceedings | As necessary | Art. 7, VI |
About legitimate interest: in each case we assess whether the benefit is proportionate and whether your legitimate expectations are respected. You can object to any processing based on legitimate interest by writing to privacidade@trix.travel.
Operational communications — account confirmation, password reset, notice of changes to the Terms, receipts — are not marketing and are sent regardless of consent, because the service needs them.
About your phone number: giving it is optional and the account works without it. We use the number for notices about your account and your itinerary and as a security factor, linking the account to a phone. We do not send marketing by phone, SMS or messaging app without your express permission, and you can delete the number at any time when editing your profile.
4. Artificial intelligence, personalisation and automated decisions
In short: itineraries are made by AI. The system learns your preferences to get better. No automated decision affects your rights, and you can turn the learning off.
4.1. To generate an itinerary, we send a third-party artificial intelligence model a structured set with destination, dates, number of travellers, budget range, pace, interests and any special requests.
4.2. We use the AI service under a paid business plan whose terms prohibit using the content we send to train the provider’s models. Your data feeds the generation of your itinerary, not another company’s product.
4.3. We do not train our own models on user data.
4.4. Travel DNA. The system keeps a preference profile updated automatically from your interactions with the suggested activities. The purpose is to reduce rework: the better Trix understands your style, the less you need to correct.
4.5. Your controls over Travel DNA. At any time, you can:
- see what the system has recorded about your preferences;
- correct or delete specific entries;
- turn off the automatic updating, keeping the service working with the preferences you state manually.
Until these options are available directly in the app, we handle the request at privacidade@trix.travel within 15 days.
4.6. Automated decisions. No automated processing is used to deny access, set individual prices, assess credit, rate you by risk or produce any effect on your rights. Automation exists only to suggest travel content, and every suggestion can be edited, replaced or discarded by you.
4.7. Even so, under art. 20 of the LGPD, you can request a review of any automated processing you believe has affected you, and we will reply with an explanation of the criteria used.
5. Who we share your data with
In short: we do not sell data. We share it only with the providers that make the service work, and each receives the minimum necessary.
We do not sell, rent or hand over your personal data for third parties’ commercial purposes.
We use providers that act as processors, following our instructions and contractually bound to confidentiality:
| Provider | Role | Data it accesses | Location |
|---|---|---|---|
| Supabase | Database, authentication, file storage, transactional email | Sign-up, profile, itineraries, access logs | USA (Oregon) |
| Google Cloud Platform | Processing of generation requests | Data sent to generate the itinerary | USA |
| Google (generative AI API) | Generating itineraries | Preferences and trip parameters | USA |
| Google Maps / Places | Searching and validating places | Search terms for destinations and places | USA |
| Vercel | Hosting of the website and the web app | Technical access logs | USA |
| Google Analytics | Website browsing analytics | Browsing data (see Section 7) | USA |
| Mixpanel | App usage analytics | Usage events and technical identifiers (see Section 7) | European Union |
| Unsplash | Photos of destinations and of places in the itinerary | IP address and technical device data, when the photo loads; no account data | USA |
| Loops | Sending marketing emails | Email and first name, only with consent | USA |
| Apple / Google Play | In-app payment processing | Payment data, which we cannot access | USA |
| Stripe | Payment processing on the web (app.trix.travel) | Email and payment data, which we cannot access | USA |
| RevenueCat | Managing subscriptions and purchases, in the app and on the web | Account identifier, email for web purchases, and purchase history | USA |
| Travelpayouts | Affiliate link network | Itinerary identifier, with no data that identifies you | Outside Brazil |
We may also share data when there is a legal obligation, court order or request from a competent authority, and in the event of a corporate reorganisation, in which case the acquirer will be bound by this Policy and you will be notified.
6. International transfers
In short: our servers are in the United States. This is normal and allowed, with the appropriate safeguards.
Our infrastructure runs on servers located in the United States, except for Mixpanel, whose data is kept in the European Union. All providers listed in Section 5 process data outside Brazil.
These transfers are carried out under arts. 33 to 36 of the LGPD, based on specific data protection contractual clauses signed with each provider, which impose a level of protection compatible with Brazilian law.
You can ask for information about the safeguards adopted at privacidade@trix.travel.
7. Cookies and analytics tools
In short: the website uses Google Analytics and the app uses Mixpanel, both only to measure usage. You can refuse both: on the website, through the cookie notice; in the app, in Profile. Neither is used for advertising.
7.1. On the website (trix.travel). We use cookies strictly necessary for it to work and, with your consent, Google Analytics to understand, in aggregate, how people find and browse the website.
7.2. When you first visit the website, you will see a notice allowing you to accept or decline analytics cookies. Declining does not affect your use of the website. You can change your choice at any time in the footer.
7.3. In the app. We do not use advertising SDKs, social media pixels or any tracking for advertising purposes. We use Mixpanel to understand, in aggregate, how people move through the app: which steps they complete and where they give up.
7.3.1. What is sent to Mixpanel. Usage events — opening the app, completing a step, requesting an itinerary, reaching sign-up — and technical identifiers: a device identifier generated by us and, after login, your account identifier. The content of your itineraries, the text you write, your name, your email and any account data are not sent. The data is kept on servers in the European Union.
7.3.2. Some metrics are still calculated internally. Itinerary volume, processing cost and feature usage come from our own database, without going through third parties. Mixpanel covers what the database cannot see: the path taken before the itinerary exists.
7.3.3. This measurement relies on legitimate interest (art. 7, IX). The notice about it appears at sign-up, together with the Terms and this Policy, and the measurement can be turned off at any time in Profile → Privacy and account → Measure app usage. Anyone who refuses stops sending any event to Mixpanel from that moment on, with or without an account. To also delete the records already sent, write to privacidade@trix.travel.
7.3.4. When you delete your account, the device identifier used by Mixpanel is replaced with a new one, and later use of the app on that device is no longer associated with the deleted account.
7.4. We do not track you across third-party apps or websites and do not sell data for advertising purposes.
8. How long we keep data
In short: for as long as your account exists. After that, we delete it — with a few exceptions required by law.
| Data | Period |
|---|---|
| Account, profile and preferences | While the account is active |
| Itineraries and associated data, including the parameters used to generate them | While the itinerary exists; deleted when you delete the itinerary or the account |
| Waiting list | Until it becomes an account, until you ask for removal, or after 24 months without interaction |
| Application access logs (IP, date and time) | 6 months, as required by art. 15 of the Marco Civil da Internet |
| Transaction records | 5 years, as required for tax and accounting purposes |
| Support communications | 2 years |
About deletion: when you delete your account or an itinerary, the data is removed from our database immediately, permanently and irreversibly. We keep no copies in a secondary database for recovery, and deleted data cannot be restored — not even at your request.
9. Your rights
In short: you can see, correct, take away and delete your data. Just ask, and we reply within 15 days.
The LGPD gives you the following rights:
| Right | What it means |
|---|---|
| Confirmation | Knowing whether we process your data |
| Access | Getting a copy of your data |
| Correction | Correcting incomplete, inaccurate or outdated data |
| Anonymisation, blocking or deletion | Asking for the removal of unnecessary or excessive data, or data processed in breach of the law |
| Portability | Receiving your data in a structured, machine-readable format |
| Deletion | Erasing data processed on the basis of consent |
| Information about sharing | Knowing who we share data with |
| Information about consent | Knowing that you can refuse consent and what the consequences are |
| Withdrawal | Withdrawing consent at any time |
| Objection | Objecting to processing based on legitimate interest |
| Review | Requesting a review of automated decisions |
How to exercise them:
- Deleting your account and all your data: directly in the app’s settings menu, at any time, without needing to contact us.
- Unsubscribing from marketing: a link in every email we send.
- Refusing app usage measurement: in Profile → Privacy and account → Measure app usage.
- A copy of your data: in Profile → Privacy and account → Request a copy of my data, which opens an email already addressed to us.
- All other rights, including portability: write to privacidade@trix.travel. We reply within 15 days. We may ask you to confirm your identity before acting, to protect your account.
You can also lodge a complaint with Brazil’s National Data Protection Authority (ANPD) — gov.br/anpd.
10. Security
In short: what we actually do to protect your account.
- Encrypted communication in transit (TLS) between the app and our servers;
- Passwords stored with a hashing algorithm, never in readable text;
- Checking against passwords exposed in public breaches at sign-up;
- Email address confirmation;
- Per-user data isolation in the database, so that each account only accesses its own records;
- Two-step authentication available;
- Restricted and logged administrative access.
No system is completely immune. We recommend a unique, strong password, turning on two-step authentication and caution on shared devices.
11. Security incidents
If a security incident occurs that may pose a relevant risk or harm to you, we will notify the ANPD and the affected data subjects within a reasonable time, stating the nature of the data involved, the risks, the measures taken and what you can do.
12. Under-18s
Trix is intended exclusively for people aged 18 or over. We do not knowingly collect data from children or adolescents.
If we become aware of an account belonging to someone under 18, it will be closed and the data deleted. Parents or guardians who identify this situation can contact us at privacidade@trix.travel for immediate deletion.
13. Changes to this Policy
We may update this Policy. Material changes — a new purpose, a new legal basis, a relevant new sharing — will be announced by email and in the app 30 days in advance.
The effective date and version number are at the top of the document. We keep the version history available for consultation.
14. Contact us
Privacy and data protection: privacidade@trix.travel
Data Protection Officer (DPO): Paulo Pena
General enquiries: contato@trix.travel
Address: Rua Visconde do Rio Branco, 1488, Conj. 909, Centro, Curitiba/PR, CEP 80.420-210, Brazil
Document updated on 21 October 2026. Version 1.2.