LEGAL REVIEW DRAFT — This document is incomplete, is not an effective notice or agreement, and must not be relied on until the responsible party and Mexican counsel approve and complete the marked items.
Review draft · 7 November 2026 · No effective date
Privacy notice
This draft describes the service as it is currently built. It is not ready to take effect: the legal controller, contact address, privacy contact, hosting region, operational retention periods, and rights-request channel still need owner and lawyer review.
1. Who is responsible
Responsible party: [INSERT the operator's full legal name and legal form]. Domicile: [INSERT complete notice address]. Privacy contact and rights-request channel: [INSERT a monitored email or postal channel]. These are required completion items, not optional examples.
Bitákura is a shared account platform for Finance, Nutrition, Fitness, and Life. This draft covers the website, account, sign-in, assistant connections, and those products when used. The final notice must identify which legal entity determines each purpose and how users can contact it.
2. Information the service handles
Account and security information includes your email address, account identifier, time zone, email-code verification records, hashed credentials and tokens, authorized assistant connections, and browser-session identifiers, user-agent details, creation and last-seen times, expiry, and revocation state. A browser session currently lasts up to 30 days; email codes are valid for 10 minutes and one use.
When you use a product, Bitákura stores structured records you ask it to keep. Finance can include accounts, balances, income, expenses, transfers, budgets, goals, plans, holdings, user-entered prices, exchange-rate snapshots, notes, and contact or participant labels. Nutrition can include foods, meals, weight, and nutrition goals. Fitness can include workouts, routines, progress, and body measurements. Life can include journal entries, reflections, and verbatim voice transcripts. Notes and journals may contain information you did not intend to disclose.
Nutrition, fitness, body-measurement, and journal records may reveal sensitive personal information. The owner and Mexican counsel must determine the additional notice, express consent, and data-minimization controls required before those products are offered to affected users. This draft does not create or record that consent.
The service also processes request metadata and security events. Application logs can include request method, route, status, duration, and error details. Web-server, tunnel, email-delivery, and operating-system log contents and retention are not confirmed and must be verified before this notice is approved.
3. How information reaches Bitákura
You provide account details and structured records directly or through an assistant that you connect. Bitákura's backend does not call a model provider and does not store raw conversations, prompts, uploaded attachments, or model responses. The assistant provider may receive and retain your prompts, files, and generated responses under its own terms and privacy settings before it sends a structured tool request to Bitákura.
Finance may request a historical exchange-rate quote from Frankfurter using only currency codes and a date. The request does not include your account identifier, financial amount, or transaction record. Values you enter or import remain your responsibility to review.
4. Purposes and legal basis
The service uses account information to create and secure your account, authenticate you, maintain your settings, authorize or revoke assistant access, provide the requested product functions, prepare your Finance export, prevent abuse, troubleshoot failures, and respond to legal obligations. Product records are used to provide the summaries and history you request.
The final notice must map every data category and purpose to the applicable legal basis and distinguish purposes that are necessary to provide the service from optional purposes. No advertising or analytics purpose is described here because none is established in the reviewed website source; verify production tags and infrastructure before approval.
5. Service providers and other recipients
Bitákura uses a Yoga-hosted application and public traffic currently passes through Cloudflare Tunnel. The physical hosting provider and country, Cloudflare account configuration, and access to edge and origin logs must be confirmed. Resend is configured to deliver sign-in emails through its API; the sending domain is in North Virginia (us-east-1). Confirm the provider's data processing and retention details before publication.
An optional Yoga backup job retains the three newest successful encrypted database snapshots when enabled. The production enablement state, snapshot schedule, key custody, and physical locations must be verified. Three snapshots describe a count, not a retention period, and an older account record may reappear after a database restore unless the approved deletion process is reapplied.
The service does not currently have a configured payment provider; account billing reports unavailable. Do not add a payment processor or billing recipient to the final notice until one is selected and its roles, data, locations, and contracts are reviewed.
Connected assistant providers receive information you send to them and process it under their own terms. Bitákura does not control their independent retention or use. Review the provider's current privacy settings and connected-app controls before sending personal, financial, health, or journal information.
- Cloudflare: public traffic and related network/security metadata; confirm the deployed products and settings.
- Frankfurter: currency codes and historical dates for a Finance quote, not personal transaction details.
- Resend: email addresses and sign-in messages sent through its API; confirm data processing and retention details for the configured North Virginia (us-east-1) sending region.
- Yoga backup: encrypted database snapshots if the optional job is enabled; enablement and schedule remain to be confirmed.
6. International processing
The service is intended to be accessible internationally, but the database's physical country and the locations of hosting, email, tunnel, and backup providers have not been confirmed. The responsible party must document those locations, recipient roles, transfer safeguards, and the notice or consent required for each destination before launch.
A website being reachable worldwide does not by itself establish that every foreign law applies. GDPR and UK GDPR applicability can depend on offering services to people in those regions or monitoring their behavior; US state privacy laws can depend on statutory thresholds and activities. Bitákura's targeting, user counts, revenue, data activities, and representative obligations have not been assessed. Do not describe this draft as global compliance.
7. Retention, account closure, and deletion
Bitákura currently has no complete, approved retention schedule for active-account data, security records, application or infrastructure logs, email-delivery records, or backups. Product data is kept while an account is active according to the current system behavior, but the final notice needs specific durations and the legal or operational reason for each. Expired login codes and revoked sessions are not evidence that the corresponding database rows have been erased.
Self-service account deletion is available from the signed-in website. A verified request suspends ordinary account access and revokes assistant and browser credentials. You may cancel it during the first 48 hours; if you do not, active account records are scheduled for erasure within seven days of the request. These are service timings, not statutory retention periods. Encrypted backups and the deletion journal follow separate retention and recovery rules and may last longer.
Under Mexico's private-party data law, a cancellation request can require blocking before suppression, and blocking may continue for the limitation period of actions arising from the relationship, subject to statutory exceptions. The applicable period depends on Bitákura's legal identity, service, claims, and records and has not been determined. The current deletion flow does not implement record-level legal holds or a separate blocking and suppression path. This draft remains subject to legal review; the seven-day service timing is not a legal determination or a statement of compliance.
8. Privacy rights and requests
For Mexico, users may have rights to access, rectify, cancel, or oppose processing of their personal data (ARCO), along with withdrawal of consent and other rights established by applicable law. Requests should identify the account and requested right, and include only the information needed to verify identity. Do not send passwords, bearer tokens, or one-time codes in a privacy request.
You can revoke an assistant's access in the account Connections page. For another request to limit use or disclosure, withdraw consent, or exercise a right, use: [INSERT a monitored address or secure request form before publication]. The responsible party's identity, domicile, identity-verification method, authorized representative process, and escalation route must also be completed. The current product has no implemented privacy-request workflow.
Mexico's law generally sets 20 days to communicate a determination and, when a request is granted, 15 days to make it effective; statutory extensions and exceptions may apply. The final notice and operating procedure must be confirmed by Mexican counsel. People elsewhere may have additional rights under laws that apply to them.
9. Security
The service uses email verification, hashed login codes and bearer tokens, scoped authorization for user records, HTTPS in production, and encrypted database snapshots when the optional backup is enabled. No security measure can promise absolute security. The service operator can technically access hosted database contents; the product is not end-to-end encrypted from the operator.
The owner must verify production access controls, encryption and key management, backup restore procedures, incident response, provider contracts, and log retention before approving this description. Never send credentials or secrets to support.
11. Children and age limits
The product's minimum age, treatment of minors, and any parental-consent process have not been confirmed. The owner and counsel must choose and implement an age policy before launch; this draft makes no claim that the service is suitable for children or that age is verified.
12. Changes and contact
The final notice must state how material changes will be communicated and when they take effect. Current draft: 7 November 2026. Effective date: [SET only after approval]. Privacy contact: [INSERT verified contact details]. Do not present this draft as the operative notice.
Official sources for review
These primary sources informed this working draft. They do not replace advice about Bitákura's facts, launch markets, and obligations.
- Mexico Federal Law on Protection of Personal Data Held by Private PartiesOfficial consolidated law; counsel should confirm the current text and its application.
- Mexico Federal Consumer Protection LawOfficial consolidated law for electronic commerce and consumer rights.
- EU General Data Protection RegulationOfficial text; assess territorial scope and transfer obligations for actual users and targeting.
- European Commission: when the GDPR appliesOfficial guidance on targeting, monitoring, and territorial scope.
- California Privacy Protection Agency: FAQOfficial agency guidance; coverage depends on the law's current thresholds and facts.
- OpenAI Privacy PolicyExample of a separate assistant provider's privacy terms; each provider has its own policy.
- OpenAI Help: connected apps in ChatGPTProvider-side controls for connected-app context and retention.