Privacy

Who looks after your data

Controller: TumTum Labs Ltda., CNPJ (Brazilian company registration) 69.860.712/0001-87, São Paulo, Brazil.

Data protection officer (encarregado): write to privacidade@tumtum.cc. It is the channel for every request on this page.

Heart rate is health data

Under Brazil’s General Data Protection Law (LGPD), heart rate is sensitive personal data, concerning health. So TumTum only processes your heartbeat with your specific and highlighted consent (LGPD art. 11, I): a separate yes for each use, which you give, see and withdraw whenever you like.

Your account data (email, name, date of birth) is processed to perform the contract you accept when you create the account. Access logs, because the law requires keeping them (Marco Civil da Internet, art. 15).

TumTum is not a medical device and does not interpret health. It shows when your heart rose, never what that means: nothing here is a diagnosis, an alert or an assessment.

What TumTum keeps

Only what the experience needs:

• Your account: email, name and date of birth (to confirm you are 18 or older).
• Your password, stored only as a hash: in a way nobody can read, us included.
• Your profile photo: stays on your phone, in the app. It is not uploaded.
• While the account is being created: the email, name, date of birth and password (hashed) wait for the 6-digit code we send to your email. If the code never comes back, they are deleted within 24 hours.
• Your heart-rate readings: those the app reads from Health Connect (from your watch), from a Bluetooth sensor (a chest strap), and from a file you import (Polar, Apple Health, Samsung Health, CSV or JSON). Each reading is a time and a number.
• R-R intervals (the time between two beats) and the phone’s motion: kept only on the device, to tell whether the sensor is really on the body, and deleted when the night is saved. They are not uploaded.
• Your moments: the stretches of the night when your heart rose, which TumTum finds.
• Your cards, and whether each one is public.
• In an event feed: your posts, your reactions, and the reports and blocks you make.
• When you share a card, which network it went to.
• Your consents: every yes and every no, with the date and the version of the text you read.
• Your requests to the data protection officer, and the answers.
• Access logs: IP address, date and time, and the path requested from the server.
• On the site waitlist: the email and, if you filled them in, your first and last name.

What TumTum uses it for, and with which yes

Each use has its own consent, asked on the consent screen, at sign-up or in the app. The optional ones start off, and nothing essential depends on them.

Access logs do not depend on consent: they keep the service running, help investigate abuse and meet the law.

• Terms and Policy (required for an account): you accept by ticking the box at sign-up.
• Reading your heartbeat (required to record a night): TumTum reads only in the window of the events you activate, from 30 minutes before the start to 30 minutes after the end, and finds your moments.
• Keeping your nights (optional): the night is uploaded to TumTum’s servers and kept in your collection. Without this yes, the night stays on your phone.
• Crowd statistics (optional): your night joins, without your name, the event’s collective count.
• Comparing with an artist or athlete (optional): does not exist yet. Your choice is kept for when it does.
• Improving the moment detector (optional): your night, without your name, helps TumTum find moments better.
• News by email (optional). Without this yes, you only get account emails: codes, passwords, answers to your requests.

How to change or withdraw a consent

On the site, under Profile → Privacidade or at tumtum.cc/consentimento. In the app, under Configurações → Privacidade.

Turning off "Keep the night": no new night is uploaded to TumTum, and the ones already uploaded are deleted from the server within 24 hours; they stay only on your phone. To delete a single night, use "Tirar da TumTum" on the night; to delete everything, delete the account.

On Android, you can also withdraw the Health Connect permission in its settings. TumTum stops reading at once.

Withdrawing acceptance of the Terms is the same as closing the account.

Your watch, your strap and your files

On Android, the TumTum app asks for a single Health Connect permission: to read the heart rate your watch already recorded. No steps, sleep, weight or any other data.

It reads only the window of the event you activated, and only after you allow it. To find out which watch you use, during setup, the app looks once at the last 60 minutes, on the phone itself, and sends nothing.

With a chest strap, the capture happens on your phone, over Bluetooth. The night only reaches TumTum with "Keep the night" on: then it goes up on its own when it ends. With the switch off it stays on the phone, and a tap on "Guardar minha noite" turns the switch on and uploads that night.

On the site, when you import a file, you choose the event first, and only the readings in its window (30 minutes before the start to 30 minutes after the end) leave your browser. The rest of the file stays on your computer.

A galera: the crowd statistics

With your yes, your night counts, without your name, in the event’s statistics: how many people felt each moment.

They only appear once the event passes 100 measured nights, and are published in bands ("10+", "25+", "50+", "100+", "250+"), never the exact number. A moment felt by fewer than 10 people does not appear.

What TumTum does not do

• Does not sell your personal data.
• Your individual heart-rate data is not shared with commercial partners, clubs, artists or advertisers. Contracted providers (Railway, Vercel, Resend, Sentry) process data strictly on our behalf, under instructions and data-protection obligations, to operate and protect the service.
• Does not show ads.
• Does not read anything from your watch outside the window of the event you activated.
• Does not publish anything unless you press the button.
• Does not make decisions about you. The detector finds moments in a curve, and that is all.

When you share a card

A card becomes public only when you share it. Its page shows what the image shows: your name, the number, the moment, the time and the event. Not your whole curve, not your account, and it asks search engines not to index it.

Once you post the card on Instagram, WhatsApp or any network, TumTum has no control over it there: whoever saw it can save it, and deleting it there is up to you, under that network’s rules.

To undo it on TumTum’s side: "Despublicar" (unpublish) takes the page and the image down at once. Deleting the card does too.

An event feed

A moment appears in the feed only when you press "show", and only to people who also have a measured night at that event — on a tour, to anyone at any date, if you choose. It shows your name, the number, the time and the moment’s name; never your curve or your email. You can take it down whenever you like.

What someone posts is the responsibility of whoever posted it. If something bothers you, report the post or block the person: you stop seeing each other, and a person at TumTum reads every report.

Who else processes your data

TumTum uses these services (processors), contracted to handle data strictly on its behalf, under its instructions and with data-protection obligations, to operate and protect the service:

• Railway: servers and database.
• Vercel: hosts the site.
• Resend: sends the emails (sign-up code, password and email changes).
• Sentry, only when it is switched on (today it is not): it would receive technical errors when something breaks, without request bodies — that is, without your heartbeats.

Data outside Brazil

Your data may sit on servers outside Brazil, with the processors named above. When that happens, the transfer relies on the standard international-transfer clauses those processors publish in their data processing agreements.

The TumTum team looks at individual data only to solve a problem you reported, check a technical error or moderate a report. Every access to heart-rate data made through the app or the site is logged, with who accessed it and when. Direct queries to the database, which only whoever runs the server can make, do not go through that log.

For how long

Each kind of data has its own window. Delete the account and all of it leaves the app and the server at once, and the backups when they expire. Three things stay: a record that an account was deleted, with only the date; the access logs (IP address, date and account), which the law requires us to keep for up to 180 days; and an encoded mark of the email and the account id, which nobody can read, kept for 400 days only to stop a restored backup from bringing the account back.

• Heart-rate readings (the night’s raw series): deleted 7 days after the night’s moments are found.
• Moments, the night’s summary and cards: while your account exists and "Keep the night" is on.
• Card image kept to load quickly: up to 7 days. An unpublished or deleted card stops being shown at once.
• Access logs: 180 days.
• Unconfirmed sign-up: 24 hours.
• Waitlist: until you ask to leave.
• Consents and requests to the data protection officer: while the account exists, to prove what you chose and what you asked.
• Database backups expire on their own, within our retention policy, and are never used to bring back what you deleted.

Your rights, and how to use them

Every request can be made on your Profile (Pedidos ao encarregado), in the app, or by email to privacidade@tumtum.cc. The answer comes within 15 days. If we do not resolve it, you can complain to Brazil’s data protection authority (ANPD), through its channel for data subjects: https://www.gov.br/anpd/pt-br/canais_atendimento/cidadao-titular-de-dados

• Access and confirmation: Profile → Privacidade → Baixar meus dados shows everything TumTum holds about you.
• Portability: the same place gives you a complete JSON file and a CSV of your readings, to take wherever you like.
• Correction: name and email on your Profile. Any other data, by request to the data protection officer.
• Deletion: "Apagar esta noite" on each night (in Suas sessões, or in the app), unpublish or delete each card, and "Apagar minha conta" on your Profile or in the app, with your password.
• Withdrawal: turn off any consent under Profile → Privacidade, at /consentimento or in the app.
• Information about sharing: this page lists every processor. Under Profile → Privacidade → Com quem seus dados estão, you can see who holds your data, your public cards, your feed posts and the shares recorded. To know more, ask the data protection officer.
• Review: the moment detector is automatic, but it decides nothing about you. If you want a person to look, ask the data protection officer.

18 and over only

TumTum is only for people aged 18 or over. Sign-up asks for your date of birth, and the server refuses anyone younger.

If we find that an account belongs to someone under 18, the account and everything in it are deleted. If you know of a case, write to privacidade@tumtum.cc.

When this page changes

If something here changes in a way that matters, we will tell you in the app or by email before it takes effect. If a use changes, TumTum asks for your yes again.