Ursula Privacy Policy

Last updated: December 2023.

Ursula ("Ursula" or "Platform") cares about ensuring privacy and protecting your Personal Data and your children's. Therefore, we have prepared this Privacy Policy ("Policy") to show you which Personal Data we process, how we use it, with whom we can share it, and the measures we take to protect it and keep it safe, in accordance with what the General Data Protection Law ("LGPD") provides.

The information highlighted here applies to the services provided through our app, named "Ursula - Virtual Friends", available for use and access on electronic devices (cell phone, tablet, computer) by Ursula Educational LTDA, a company registered under CNPJ/MF [Brazilian National Register of Legal Entities/Ministry of Finance] no. 52.617.135/0001-40, headquartered at Rua Cardeal Arcoverde 2365, cj. 33, Pinheiros - São Paulo, São Paulo, Brazil.

To better understand how our Platform works, the protection of your Personal Data and the guarantee of your privacy, as well as that of your children, we recommend reading together our Terms and Conditions of Use.

  1. What terms do you need to know before proceeding?

Before continuing with the guidelines of this Policy, the following terms are defined for your better understanding:

  • National Data Protection Authority (ANPD): The ANPD is a special nature authority responsible for ensuring the protection of personal data and for regulating, implementing, and supervising the compliance with the LGPD in Brazil.

  • Cookies: Data files that temporarily store what you are visiting on a certain website or app;

  • Personal Data: Data that identifies or makes an individual person identifiable, such as name, home address, ID number, Social Security number, etc.;

  • Sensitive Personal Data: Personal Data about racial or ethnic origin, religious belief, political opinion, union membership, or organization of a philosophical, political, or religious nature, data concerning health or sex life, genetic or biometric data (such as facial features), when linked to a natural person, like sexual orientation, biometric data collected for entry/exit of environments, health data extracted from tests;

  • Artificial Intelligence or "AI": Refers to computer systems or software programs that have the ability to analyze data, identify patterns and make automated decisions based on these patterns, through the use of algorithms and techniques of analysis;

  • LGPD or General Data Protection Law (Federal Law No. 13.709/2018): Legislation that regulates the Processing of Personal Data including any other laws and regulations regarding the treatment, protection, and privacy of personal data, including data from users, which are applicable and, if applicable, all guidelines, standards, rules, ordinances, regulations, and codes of practice of the National Data Protection Authority ("ANPD") or other supervisory or protection authority of Personal Data relevant;

  • Third Party: Clients, partners, suppliers, or any entity that is external to Ursula and has your Personal Data processed;

  • Holder: The natural person to whom the Personal Data being processed refers;

  • Processing: Operations refer to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation, modification, communication, transfer, dissemination or extraction of Personal Data; and

  • User or You: Any person who registers or logs in on the Ursula Platform to enjoy its features under the conditions provided in our Terms of Use and Privacy Policy.

  1. How is your personal data collected?

Your Personal Data and that of your child/children are collected from various sources. These Personal Data can be obtained in different ways, being:

  • Provided directly by You, the holder of the Personal Data and responsible for the Personal Data of the minor, through sharing via inclusion on the Platform. Among the data received are name, email, date of birth, degree of kinship, residential address, physical characteristics, preferences. We emphasize that You must guarantee the veracity/update of the Personal Data provided to Us;

  • Sent by Third Parties, through the registration process via third-party platforms (Apple and Google). We offer the option for You to register using your Apple or Google accounts. Registration through these Third-Party platforms is done automatically, facilitating the process for You. The Platform is not responsible for the information provided by these external platforms. The responsibility for the treatment and protection of these data is exclusive to Apple and Google, according to their respective privacy policies. We recommend that you review and be aware of the privacy policies of these platforms before using registration through them;

  • Automatically collected by Us, from the collection of information from the device used to access the Platform, such as geolocation data, access records, usage patterns of the Platform, information from cookies or similar technologies, statistics, and aggregated data.

  1. What personal data is processed by Ursula - Virtual Friends?

We are responsible for the Processing of Personal Data from various categories as you access, register, and use our Platform, as shown in the table below:

Category of Personal Data

Data Subject

How Personal Data is Collected

Which Personal Data are Processed

Where the Data is Processed

Registration Data


Data provided by the Data Subject* for account creation on the Platform.

*This data may be obtained from Apple and Google if you opt to register through these platforms.

Email and password for access.

Registration Data

You and your child

Data provided by the Data Subject to set up the character and personalize interactions with characters within the platform.

Name, date of birth, degree of kinship, residential address.

Personal Data of Children and Adolescents

Your child (Data Subject)

Data provided by the Data Subject to configure the character and personalize interactions with characters within the platform.

Physical characteristics and data related to personality, interests and preferences of your child (become personal data when combined with Registration Data).

Access Records


Automatic collection of all Users who access the "Ursula - Virtual Friends" application.

IP address, date and time of access, geolocation data precise or approximate, GPS data, log of access, type of browser, type of device, hardware model, network data, operating system and browser used.

Data collected through Cookies and similar technologies


Collected automatically by Us as part of the use of the Platform by the User.

We may use Cookies and electronic device identifiers when the User uses the Platform.

3.1. Processing of personal data of minors

We process the Personal Data of your child(ren) so that he/she/they can use it in the most personalized way possible to interact positively with the characters on the platform. Thus, we highlight the awareness of the Processing of Personal Data of minors, a category of data considered special.

For this reason, in accordance with the guidelines of the ANPD, we process the Personal Data of your child always looking for the best interest of the child/adolescent. Depending on the purpose of the activity carried out, if the collection of Consent is necessary, we will only process your child's Personal Data after such Consent has been provided by You or some legal guardian in a free, unequivocal and informed manner.

3.2. The processing of personal data across different domains

Due to the technical necessity for the availability of services across multiple locations, with low response time and redundancy, the use of multiple servers is required to meet all the demands of the Platform. For this reason, the personal data of users may be linked to the following domains:


Processed Data


Registration Data


Data provided by the Data Subject* for the creation of the account on the Platform.

*These data may be obtained by Apple and Google if you opt for registration through these platforms.

Registration Data

You and your child

Data provided by the Data Subject to set up the character and personalize interactions with characters within the platform.

In compliance with the LGPD and according to the guidelines of the ANPD, the request for exclusion of personal data ensures the complete removal of the same from all the above-mentioned domains, as well as any other new service or domain that is created by Ursula in the future.

  1. For what purposes are personal data used?

We will use the Personal Data described above for the following purposes and in accordance with the applicable legal basis:



Identification or creation of access to the Platform

We will use your Personal Data to identify, authenticate, and individualize you on the Platform to gain access.

Enhancement and personalization of the User experience

We will use your Personal Data and that of your child/children to offer an exclusive enhancement of the services provided by Ursula, mainly in personalizing interactions with the characters on the platform.

Protection and security of the Platform

We may use Access Records to detect possible frauds and security incidents on the Platform. We may also use browser navigation data to enhance your experience, as well as log data to detect errors on the platform.

Resolution of technical problems or attendance to requests

In case of technical problems during your navigation on our Platform, we may use your data to identify, treat and correct the problem or to respond to other requests, including those from complaints.

Sharing with artificial intelligence ("AI") systems to provide our service

We share your Personal Data and that of your child/children with the AI system to the extent necessary to generate the most personalized experience possible during conversations with our characters. This means that we share data with the type of system & necessary for a proper association and compatibility of content.

Compliance with Ursula's legal or regulatory obligations

We will process User Personal Data to comply with our legal and/or regulatory obligations as necessary. These obligations may include, by example, tax obligations, obligations related to the maintenance of technical records, service documentation, accountability, among others.

Exercise of rights related to judicial and administrative processes

We may process your Personal Data to exercise your own rights and/or to defend your rights and interests. This procedure may include extrajudicial measures among others, processes related to our assistance, including administrative actions, and others.

In relation to other activities involving the Processing of Personal Data, the applicable legal bases will be used, such as the execution of a contract or preliminary provisions; compliance with legal or regulatory obligations; exercise and defense of our rights and interests; all with the legitimate interest of our part, always considering and respecting your fundamental rights and guarantees and those of your children, including the collection of Consent when necessary, by the Platform.

  1. With whom do we share your personal data?

First, we inform you that we use an Artificial Intelligence system in our tool to generate plots, scenarios, and provide the best personalized experience to you and your child. If you have any doubts about the use of the AI system, consult our Terms and Conditions of Use.

The sharing of Personal Data involves sending and receiving information from a Third Party, which may be located in Brazil or in foreign territory.

In our case, we will share your Personal Data and that of your children with:

  • The "GPT-4" AI system: with the objective of achieving the Platform's purposes, we use Artificial Intelligence for automated image analysis and natural language processing. To provide this solution, we count on the intelligence of the GPT-4 language, provided by OpenAI. As part of this process, your Personal Data will be shared with these third parties. We emphasize that the responsibility for the processing and protection of this data is exclusive to OpenAI, according to their privacy policies. It is recommended that you review and be aware of the privacy policies of this technology before using the Platform.

  • Digital Platforms: The Personal Data used to log into "Ursula - Virtual Friends" through Apple and Google ends up being shared with us so that the access verification is carried out and your profile accessed.

Besides the situations mentioned in this Privacy Policy, Personal Data may be shared with third parties in the following cases:

  • Regular exercise of rights through administrative, judicial or extrajudicial means: we can share Personal Data with third parties, such as law firms, consulting firms, collection companies, accounting offices and the like, with the objective of exercising their own rights or ensuring compliance with this Privacy Policy and the Terms and Conditions of Use;

  • Judicial or Administrative Request: we may share Personal Data in response to a judicial or administrative request;

  • Compliance with legal or regulatory obligation: we may share Personal Data with government entities, as well as with natural or legal persons of a private nature, to comply with legal or regulatory obligations.

  1. International data transfer

In case your Personal Data is transferred to another country in order to be processed and stored according to the terms and purposes established in this Privacy Policy, as well as for the provision of services, we guarantee compliance with the LGPD and the requirements set forth in article 33 of the Law.

We also emphasize that privacy and data protection laws vary from country to country, and protection standards for Personal Data in other countries may differ from those existing in Brazil. Therefore, we will follow the maximum standard of compliance and guarantee the protection of your Personal Data and, eventually, that of your children, should they also be transferred.

  1. How long do we store your personal data?

Personal Data will be maintained for the time necessary for the purposes described in this Privacy Policy. We adopt controls to ensure that data are kept only as long as they are really necessary, being excluded when the Processing is concluded or when no legal retention basis applies. Besides, in some situations, data can be maintained for a longer period, such as to:

  • Comply with legal or regulatory obligations, like in cases of audit and fraud control;

  • Regularly exercise rights in administrative, judicial, or arbitral processes;

  • Fulfill the duration of a contract.

In the hypothesis of exclusion of Personal Data, these will be deleted when there is no longer a specific purpose for the Processing of personal data, being removed from our systems and records or anonymized, so that identification of individuals is no longer possible.

  1. How do we ensure the security of personal data?

For the Personal Data processed by us and about the purposes highlighted in item 4, we adopt technical and administrative measures for security and protection adequate to the nature of the data collected, used, stored, or otherwise processed by us, in conformity with market practices.

However, no method of transmission or electronic storage of data is completely secure and is not liable to eventual external attacks. For this reason, Ursula cannot guarantee absolute security against measures adopted or the absence of interference by third parties (like hackers). Due to its nature, despite our best efforts, any security measure can fail, resulting in a possible security incident involving Personal Data. These measures extend to Third Parties with whom Ursula shares Personal Data, considering our absence of liability in case of incidents, but we take care in guaranteeing partnerships that have at least good practices in information security.

  1. What are your rights and how can you exercise them?

We provide means for you to exercise your legal rights over your Personal Data and that of your children. In this item we will describe these rights and how Data Subjects can exercise them:

  • Confirmation of existence of processing: You can confirm if we are processing your Personal Data;

  • Access to Personal Data: You can access your Personal Data, including requesting copies;

  • Correction of incomplete, inaccurate, or outdated Data: You can request alteration or correction of your Personal Data that is incorrect;

  • Anonymization, blocking, or deletion: You can request anonymization, blocking, or deletion of unnecessary, excessive Data or Data processed in noncompliance with the Data Protection Legislation;

  • Review of Automated Decisions: You can request a review of decisions made solely based on automated data processing;

  • Deletion of Personal Data: You can request the exclusion of your Personal Data processed by Ursula when they are no longer necessary or pertinent, through the Platform itself or by request through the channels of service indicated in this Privacy Policy;

  • Revocation of Consent: You may, at any time and at your discretion, revoke the consent previously provided for the processing of Personal Data, with the treatments based on it, until that moment, valid.

The rights mentioned above and others foreseen in the LGPD (such as the right to oppose processing that violates your interests, access to information about public and private entities with which the controller has shared data, and information about the possibility of not giving consent and the consequences of denial) can be exercised by you on our Platform, you will be able to directly exercise certain rights or request rights by means such as email, for example, data access and editing tools through pedro@ursula.ai .

  1. Cookies

Cookies are small text files generated by the sites you visit from the collection of your information. These files enable a more personalized navigation by remembering if you have been there, recalling which pages you opened, identifying which type of device you are accessing, tracing a profile about you based on your preferences and even recommending advertisements targeted to your buying profile. Due to the purposes of use, your Personal Data may also be collected, such as your IP address, your navigation record by time and date, your geographic location, spoken language, your behavioral data related to consumption habits.

Cookies can be divided based on their functionality for the site. The table below illustrates more clearly the category and description of the Cookies used:

Cookie Category




Cookies used so that the site functions correctly and that without them you and other users would not be able to utilize the main service of the application.

Not necessary

Cookies that, if disabled, do not prevent the full use and correct functioning of the application.



Cookies that collect information about the navigation in the application for statistical purposes. Thus, we will understand how you use the Ursula app - Virtual Friends, including the error rate of the application among users, among other information.


Cookies that provide the basic service of the application and allow remembering preferences, such as your user name, when you visited, your location, and your language.


Cookies that construct your profile from the data extracted from your navigation habits, and from this, they can direct advertisements and marketing to you.

Information Storage Period


Cookies used so that the site functions correctly and that without them you and other users would not be able to utilize the main service of the application.


Cookies that, if disabled, do not prevent the full use and correct functioning of the application.

Considering the functionality of each Cookie, when you visit our application "Ursula - Virtual Friends," we only store the necessary cookies for the platform to function and for you to interact with the characters and create stories. On the other hand, Cookies such as those used for (a) personalized marketing purposes, (b) statistics on your navigation profile, and (c) making your experience more personal, are not immediately stored by us.

The Cookie banner that appeared at the moment you entered our application is used for you to actively give us your consent regarding the storage and use of certain categories of Cookies. If you opt for Cookies not to be stored, your information, and eventually, Personal Data, will not be treated by Ursula. Depending on your choice, it may be that your experience is not personalized, that you do not receive targeted advertising, and that we cannot track your navigation profile.

This possibility of refusal to store also applies to the necessary Cookies for the functioning; however, you will not obtain the proper performance and functioning of the Ursula Platform if they are not enabled.

  1. Updates to the privacy policy

Our Privacy Policy may undergo modifications due to constant legislative updates related to the protection of Personal Data and the continuous improvement and development of our services. Therefore, we will notify our Platform when the Policy is updated. If you continue to converse with the characters of Ursula - Virtual Friends, we will understand that you are aware of all updates.

  1. Any doubts?

In case of any doubts about the Processing of your Personal Data, you can contact us by email at pedro@ursula.ai .

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