Last updated: 4 September 2026 · This version covers Kolo's closed pilot.
Who is responsible for your data
Alexandre Cesar Azinheira is the controller of the personal data described here.
Contact: privacidade@kolo.pt · Rua Quirino da Fonseca 27, 3D, 1000-251 Lisboa
Kolo is currently a closed pilot: a small, invited group of practitioners and their guests in the Lisbon area, testing an app that is not finished. That matters for how you should read this document. Things may break. Some data may be deleted when the pilot ends. If you would rather wait for a finished product, that is an entirely reasonable choice.
What Kolo is
Kolo is a map-based network where people offer and find care (bodywork and related practices) and craft (practical services). You publish what you offer or what you are looking for, and other people can find you. Exchanges happen between the two of you — Kolo does not stand in the middle.
What we collect, and why
Your account. Your email address and a password, stored hashed. Without these there is no account. Legal basis: performance of our contract with you.
Your profile. A name and photo if you choose to add them (both optional), the profile name that forms your public web address, and anything you write about yourself. Contract.
What you offer or seek. The services in your kolos, their categories, and any description you write. Contract.
Credentials. If you claim a protected professional title — psychotherapy, physiotherapy, osteopathy — you submit a credential for confirmation. We keep the confirmation and the fact of the title. Contract, and compliance with rules on protected professional titles.
Your location. See the dedicated section below.
Photos. Your profile photo and up to three photos of your work or workspace. Location data embedded in image files (EXIF) is removed before the image is stored, whether you take the photo in the app or choose one from your library.
Messages. What you write to other people through Kolo, so it can be delivered. Contract.
Ratings and vouches. Reviews you receive, vouches from other members, and the resulting score. Contract. A review's text is only shown on your public page if its author separately and explicitly agrees to that — see below.
Notification tokens. If you allow notifications, an identifier for your device so we can send them. Consent.
Counts, for the future fee. How many times your public page was opened, how many people started a conversation with you, and how many exchanges were confirmed. Page opens are counted as events with no identifier of any kind attached — no cookie, no fingerprint, no stored IP, nothing that could be traced back to a visitor. We can tell you your page was opened fourteen times. We cannot tell you, or ourselves, by whom. Legitimate interest in operating and one day charging for the service.
kolo.pt sets one cookie, and only if you tap PT or EN: it remembers which language you chose. It holds nothing else, identifies no one, and never enters the counting.
Technical and diagnostic data. When the app crashes, a report is sent so we can fix it. Coordinates, email addresses and authentication tokens are stripped before it leaves your device. Our servers keep ordinary access logs for security. Legitimate interest in a working, secure service.
Nothing is sold, ever, to anyone. Kolo has no advertising and no third-party trackers.
Health-related information — read this part
Kolo is a place to find bodywork and related care. What you look for, and who you book, can say something about your health. Under the GDPR that is special category data, and it gets stronger protection.
We handle it on the basis of your explicit consent, which we ask for separately when you first describe what you are seeking. You can withdraw that consent at any time, and doing so removes what you shared and does not affect your account.
Concretely: what you are seeking is never shown on your public page and is visible only to practitioners you are matched with or write to. Your seeking kolos are not public, not indexed, and not shared with anyone else.
Your location — how the dial actually works
Location is the most sensitive thing Kolo holds, particularly for someone who practises alone from home.
Nothing is on the map unless you put it there. Visibility is opt-in and a person who has not set a location does not appear at all.
You control the precision, and the dial is real. Your published position is snapped to a cell whose size you choose. The blurring happens on our servers, not in the app — the precise coordinate is never sent to anyone else's device, so it cannot be recovered from what we publish.
The precise coordinate stays with us, used only to compute the cell you chose.
The lookout ("guardian") feature shares your live position with a person you name, for a house call, for as long as you leave it on. It is off unless you turn it on, and only the person you chose can see it.
Photos carry no location. EXIF is stripped on upload.
Map tiles are served by OpenFreeMap, which receives your device's IP address and the part of the map you are looking at, as any map does.
Legal basis: consent, which you can withdraw by changing your visibility or deleting your location.
What is public
Your public page at kolo.pt/your-name is exactly that — public, visible to anyone with the link, and findable by search engines. It shows what you have published: your name and photo if you added them, what you offer, your photos, your rating, and your recent Atlas post.
Two things worth knowing:
Your rating is always shown on a published page. There is no setting that hides it. You can choose not to publish a page at all.
A review's text appears only with its author's separate, explicit and revocable permission. Agreeing to rate someone is not agreeing to be quoted. Attribution is anonymous unless the author chooses otherwise, and they can withdraw at any time.
Atlas posts expire after seven days and are not archived.
Who else touches your data
We use a small number of service providers, each under a data processing agreement, each acting only on our instructions:
Who · What for · Where
- Hetzner Online GmbH · Servers and file storage · Germany
- Sentry · Crash reports (with personal data stripped) · European Union
- Resend · Verification and notification emails · Ireland (EU sending region); Resend is a US company
- Expo, Apple, Google · Delivering push notifications to your device · See their own policies
- OpenFreeMap · Map imagery · Hungary (EU)
Your data is stored in Germany, inside the European Union. Push notifications necessarily pass through Apple's and Google's systems to reach your phone; we keep the content of them minimal (never a message's text, never a review's words).
We will disclose data to authorities only where the law actually requires it, and we will tell you unless we are legally forbidden from doing so.
How long we keep things
Your account and profile: until you delete them.
Atlas posts: seven days.
Messages: until you or the other person deletes them, or you close your account.
Page-open and exchange counts: 30 days, then aggregated.
Crash reports: 90 days.
Security logs: 90 days.
When the pilot ends, we may delete pilot data entirely. We will tell you before we do.
Deleting your account removes your profile, your page, your offerings and your location. Messages you sent may remain visible to the person who received them, as their copy of a conversation they were part of.
Your rights
You can ask us to show you what we hold, correct it, delete it, restrict what we do with it, or give it to you in a portable form. You can object to processing based on legitimate interest, and you can withdraw any consent at any time without giving a reason — withdrawing does not undo what was lawful before, and does not cost you your account.
Write to privacidade@kolo.pt. We will answer within one month.
If you are unhappy with how we have handled it, you can complain to the Portuguese data protection authority, the Comissão Nacional de Proteção de Dados (CNPD) — www.cnpd.pt.
Security
Passwords are hashed. Traffic is encrypted in transit. Access to our servers is limited to Alexandre Cesar Azinheira alone. We test that one person's data cannot be reached with another person's credentials, and we treat location precision as a security property rather than a display preference.
No system is perfect. If something goes wrong that puts you at risk, we will tell you.
Age
Kolo is for adults. You must be 18 or older to have an account.
Changes
If this policy changes in a way that matters, we will tell you in the app before the change takes effect — not by quietly updating a page.
Contact
privacidade@kolo.pt · Alexandre Cesar Azinheira, Rua Quirino da Fonseca 27, 3D, 1000-251 Lisboa