In short
This is a summary for quick reading, written in plain language. The full text below is what governs.
This Policy explains what personal data CoinPilot2U collects, why it collects it, who it shares it with, how long it keeps it and what you can demand in that regard. It is part of the Terms of Use and Software License and uses the same terms defined there.
We write in plain language on purpose. Where the law requires a technical term, it appears with an explanation alongside it.
The data controller — the party that decides what is collected and for what purpose — is
CoinPilot2U, which is responsible for the website coinpilot2u.com and for the software
covered by the Terms of Use.
Channel for privacy matters, including exercising the rights in Section 9: nao-responda@coinpilot2u.com. Despite its name (Portuguese for “do not reply”), this mailbox, which is used to send automated system messages, is read for privacy requests.
General product support is provided through Discord, as indicated on the website.
We respond to data subject requests within 15 days of receipt, the deadline set by art. 19 of the LGPD. If a request is complex or requires additional identity verification, we will let you know within that period and give you the new date.
We collect only what the service needs to work. Each row below has a concrete purpose — we don't keep data "just in case."
| Data | Purpose | Legal basis (LGPD) |
|---|---|---|
| Name and email | Create and identify your account, send system messages, recover your password | Performance of a contract — art. 7º, V |
| Password | Authenticate access. It is stored as a hash — an irreversible digest. We have no way to read your password, not even to help you | Performance of a contract — art. 7º, V |
| Chosen language | Send emails in the language you selected when signing up or in your profile | Performance of a contract — art. 7º, V |
| Acceptance record for the Terms: date, time, document version and IP address | Prove what was accepted, when and by whom. It is the evidence that protects both sides | Legitimate interest (legítimo interesse) — art. 7º, IX |
| API key from your exchange | Execute the operations you contracted for. See Section 4, which deals only with this | Performance of a contract — art. 7º, V |
| Billing data: plan, amount, currency, payment status and the provider's transaction identifier | Manage the subscription, grant and block access, issue a tax document (documento fiscal) | Performance of a contract and legal obligation — art. 7º, V and II |
| Wallet address, when payment is made in crypto-assets | Identify which payment is yours and reconcile the charge | Performance of a contract — art. 7º, V |
| Access logs: IP, date and time of connections to the application | Security, fraud investigation and compliance with the Brazilian Civil Rights Framework for the Internet (Marco Civil da Internet) | Legal obligation — art. 7º, II in conjunction with Law 12.965/2014, art. 15 |
| Operation logs from the software: starts and stops, errors and technical events | Diagnose problems, prove what the system did and when | Legitimate interest — art. 7º, IX |
It is worth spelling out what does not come in:
We do not sell, rent or give away personal data to third parties for their own use. Sharing is limited to what is described in Section 5: vendors that perform part of the service under our instructions, and authorities when the law requires it.
It is the most delicate piece of data you give us, so it has its own section.
The key is encrypted before it is stored. The website's server encrypts it using a public key and does not have the corresponding private key — in other words, it can lock but cannot unlock. Only the server that runs your bot decrypts it, at the moment of use.
Practical consequence: if the website and the database are fully compromised, the attacker gets scrambled text that cannot be opened.
The key is used exclusively to perform the functions you contracted for. No other use, no other purpose.
Create the key without withdrawal permission. This is the strongest protection there is, and it is entirely in your hands: a key without withdrawal permission cannot take funds out of your account, whether by us or by anyone who might happen to steal it.
You can revoke the key on the exchange at any time, without contacting us. Execution stops immediately. When you cancel your subscription or delete your account, the encrypted key is deleted — it is not subject to the retention period for the other data.
We work with vendors that perform part of the service. Under the LGPD, they are processors: they process the data on our behalf and following our instructions, not for their own purposes.
| Who | Purpose | What they receive |
|---|---|---|
| Hostinger | Hosting of the website, the database and email | Registration data, acceptance record, subscription data and the API key, already encrypted |
| Amazon Web Services | Server that runs the software | API key and operation logs |
| Payment providers | Process billing | Name, email and the data you enter on their screen |
| The exchange you choose | Execute orders. The relationship with it is yours, and direct | The orders sent with your key |
| Discord | Support and community channel | Only what you yourself write there. Joining is optional |
| Google Fonts | Load the fonts used in the website's design | Your IP address, through your own browser, when it fetches the font file |
We also disclose data when the law requires it: a court order, a request from a competent authority or a legal duty. In that case, we notify you whenever the order itself does not prohibit such notice.
If CoinPilot2U is sold, merged or has its operations transferred, the data may be transferred along with it — for the same purpose and under this Policy or an equivalent one. You will be notified in advance and may delete your account if you do not agree.
Part of the infrastructure is outside Brazil. The server that runs the software is in Japan; payment and communication providers operate from the United States and the European Union. This means your data crosses borders.
The transfer is made on the basis of art. 33, II, "d" and art. 33, V of the LGPD — contractual clauses with the vendors and necessity for the performance of the contract you entered into. We choose vendors that offer protection clauses equivalent to those required by Brazilian law.
Data kept without a reason is needless risk. Each period below has a reason:
| Data | Period | Why |
|---|---|---|
| Registration data (name, email, language) | As long as the account exists | It is the account. Deleting the account deletes the registration data |
| Encrypted API key | Until turned off or canceled | If it is not in use, it is not kept |
| Application access logs | 6 months | Minimum period under the Brazilian Civil Rights Framework for the Internet, art. 15 |
| Software operation logs | 12 months | Diagnosis and proof of what the system executed |
| Acceptance record for the Terms | 5 years after the end | Period during which a claim for payment or a complaint may still arise |
| Tax data from billing | 5 years | Tax obligation. We cannot delete it sooner |
When you request deletion, we delete whatever depends solely on us. What the law requires us to keep — access logs and tax documents — remains until the period expires, isolated and not used for anything else. This is provided for in art. 16 of the LGPD and applies to any company.
The website uses Google Analytics 4 to measure audience: how many people visit, where they come from and which pages they read. It writes cookies in your browser (_ga and _ga_*) holding a random identifier, and sends Google technical data such as the page viewed, language, device type and a shortened IP address. We never send Analytics anything that identifies you — no e-mail, no tax ID, no API key, no balances from your account. We do not use advertising cookies and we do not sell data. You can refuse this measurement with Google’s official opt-out add-on or by blocking cookies in your browser; the website keeps working either way.
We use local storage in your browser for two simple things, which stay on your device and are not sent to us:
cp2u_idioma_email — the language you chose, so the screen opens in it.cp2u_assinatura — a marker that your subscription is active, so the dashboard
doesn't ask for payment on every visit.Once the service goes live, there will also be a session cookie, which is what keeps you logged in. It is strictly necessary and expires when you log out.
You can clear all of this at any time in your browser settings. The website keeps working — it just goes back to the default language and asks you to log in again.
Art. 18 of the LGPD gives you rights that you can exercise against us, and you don't need to justify your request:
To exercise any of them, write to nao-responda@coinpilot2u.com from the email address registered to your account. This is the fastest way for us to confirm that it is you — we will not hand over your data to someone who merely claims to be you.
Handling your request is free of charge. If a request is manifestly repetitive or abusive, we may refuse it, always explaining the reason in writing.
If you disagree with our response, you may file a complaint with the
National Data Protection Authority (ANPD — Autoridade Nacional de Proteção de Dados) at gov.br/anpd. We prefer to
resolve matters directly with you, but that route exists and it is your right.
We adopt technical measures commensurate with the size of the operation: traffic encrypted with HTTPS, password stored as a hash, API key encrypted with a public key as described in Section 4, restricted administrative access and logging of access.
No system is infallible, and be wary of anyone who says otherwise. We do not promise absolute security — we promise proportionate care and transparency when something fails.
If a security incident occurs that poses a relevant risk to your rights, we notify you and the ANPD within a reasonable time, in accordance with art. 48 of the LGPD, stating what happened, which data was affected and what to do.
On your side, three things matter more than all of ours: a unique password for this website, an API key without withdrawal permission and two-factor authentication enabled on your exchange.
The service is not intended for minors under 18, and we do not knowingly collect data from children and adolescents. If we identify an account in this situation, it is closed and the data is deleted.
This Policy may be updated — due to changes in the law, the service or the vendors. The version in force is always the one published on this page, with its number and date at the top.
When a change reduces your rights or expands the use of your data, we notify you at your registered email address with at least 15 days' notice before it takes effect. If you do not agree, you can cancel and request deletion of your account.
Wording corrections, formatting adjustments and updates to a vendor's name without a change of purpose do not require prior notice.