ZuckPay

Privacy Policy

Version updated on February 18, 2026

Hello! If you want to understand how ZuckPay and the other companies in its group collect, store, use, share, and delete your personal data, you are in the right place. Depending on your role on the Platform, some special rules may apply to you. Therefore, please read the information below carefully.

Summary

ZuckPay, and all companies in its group, care about your privacy and are committed to preserving it. The processing of personal data related to your use of services provided by ZuckPay is described in this Privacy Policy, which should be read in conjunction with the ZuckPay Terms of Use and, where applicable, in conjunction with the Terms of Use of the respective group company with which you may interact.

This Policy may be modified at any time, so it is important that you constantly review its terms. When substantial changes are made to this Policy, you will be informed by email if you are a registered User on the ZuckPay Platform or services provided by ZuckPay companies. This Policy and its respective updates prevail over any proposals, contracts, previous understandings, and agreements, verbal or written, that may exist between you and any of the ZuckPay companies, especially regarding privacy or personal data.

Overview

A. This Privacy Policy establishes the rules regarding (a) how and for what purposes your personal data may be processed by ZuckPay companies, (b) with whom this data may be shared, and (c) how Users can manage their personal data. It applies to the use or access to the Platform or other services offered by ZuckPay companies through any of their websites (including, but not limited to, zuckpay.com.br and its subdomains, as well as through other sites, interfaces, or applications where ZuckPay companies make their resources available, including their mobile, tablet, or other electronic device applications).

B. To facilitate the reading of this Policy, we offer a Glossary, which lists the meaning of expressions starting with capital letters in the ZuckPay Terms, as well as in this or other Policies of ZuckPay companies. In addition, it is important for you to understand the specific meaning of the following expressions, used in the context of privacy protection and capitalized in the Terms, in this Policy, or in other Policies of ZuckPay companies without initial capital letters:

“Personal data”, in singular or plural, means any information that identifies the User or makes their identification possible. Therefore, however generic this may seem, personal data can be any information that identifies you directly or any information that works as a piece in the puzzle that leads to your identification.

“Processing”, as well as the verb “to process”, means any operation performed with personal data, such as those referring to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation, control, modification, communication, transfer, dissemination, or extraction.

“ZuckPay Services”, ZuckPay may allow its partners (such as financial institutions, payment institutions responsible for issuing cards under brand licenses, brands, and banking correspondents) to offer their services in an aggregated manner, such as, for example, making the Card available to Users. For more information about ZuckPay Services, access the ZuckPay General Payment Policy.

“User Account Data”: means data related to the User that is necessary for the provision of services offered by ZuckPay companies.

“Creator Account Data”: means personal data that is processed by ZuckPay on behalf of the Creator, when personal data is transferred to the Creator and/or extracted, collected, and/or generated directly by the Creator. The rules for the processing of personal data between ZuckPay and Creator are established in the Personal Data Processing Agreement.

1. PERSONAL DATA PROCESSED BY ZUCKPAY COMPANIES

Personal Data. The personal data processed by ZuckPay companies (“User Account Data” and “Creator Account Data”) may vary according to each of the respective companies and their personal data processing practices, as well as depending on the type of interaction of the User with the Platform or with each of the ZuckPay companies.

This personal data may be collected directly from the User, obtained through third parties, or collected automatically.

Personal data may involve, for example: (a) registration information, such as email, full name, address, phone, mobile, identification documents, profile photo, and passport; and (b) banking information, such as the name of the financial institution where the User has a bank account, account number, account type, branch, the first six and last four digits of the credit card, including the holder's name.

Listed below are the personal data collected by ZuckPay companies, presented in distinct categories and collection forms to facilitate your understanding.

1.1. Personal Data collected directly from the User. ZuckPay companies may collect personal data directly from you when you, for example, create an account, start a purchase process directly via checkout, and/or interact with ZuckPay companies by any means, including our chatbot.

1.2. “Offline” Interaction. ZuckPay companies may collect personal data when you interact with them by means other than accessing the Platform, such as, for example, your registration data or your image when you participate in an event organized by ZuckPay companies or an event organized by a third party whose activity is contractually linked to ZuckPay companies.

1.3. Optional Fields. The Platform provides certain optional fields. These fields are highlighted as optional and are intended to improve the personalization of the content made available to the User.

1.4. Public Data. ZuckPay companies consider some personal data as public because it can be seen by anyone, inside and outside the Platform, even if that person does not have an account on the Platform. Information you enter in fields highlighted with the “public data” notice is considered public data. You, other people using the Platform, and ZuckPay companies themselves can provide access to or send public data to anyone inside and outside the Platform. It is also possible to view, access, reshare, or download public data through third-party tools, such as search engines, APIs, and offline media, or through applications, websites, and other Third-Party Services.

1.5. Personal data obtained from third parties. ZuckPay companies may have access to certain personal data through third parties, whether registration or banking information. This happens, for example, when, due to compliance with a legal or regulatory obligation, a ZuckPay company needs to consult databases maintained by third parties that enable credit restriction analysis, anti-fraud analysis, and other risk management analyses integrated into the Platform. ZuckPay companies also collect registration information through third parties when you link, connect, or log in to the Platform through a Third-Party Service (e.g., Facebook). ZuckPay companies may also have access to registration information through third parties for registration in events, surveys, advertising campaigns, and other activities organized by these third parties, whose activity is contractually linked to ZuckPay companies.

1.6. Personal Data collected automatically when accessing the Platform. Personal data is collected automatically when you access the Platform, even if you do not have an account on the Platform. This information may include the examples below.

1.7. Creator Payment Information. We use third-party payment gateways to process payments made through the Platform. For payments processed by native payment gateways of any ZuckPay company, third parties provide us with information related to the payment status of your account, requiring you to link your payment account to the Platform to receive your payments. By linking your account, we will receive certain information related to your payments, including your payment card type and its last 4 digits, your postal code, country of origin, expiration date, and your email address associated with the payment type. Additionally, we will collect certain personal information for tax purposes, which may include your full name, address, and registration number. Our third-party payment gateways are independent and have their own privacy policies. For additional information on how your payment data is processed and stored, we recommend that you review the privacy policies of the payment gateways.

1.8. Participation in Creator Content. When you enroll in a course, use or access other Creator content, we collect personal data related to your participation in Creator Content, such as the courses you enrolled in, test results, your progress, and certifications.

2. WHAT ARE THE PURPOSES OF PROCESSING PERSONAL DATA

2.1. Purposes of Processing User Personal Data. ZuckPay companies may use personal data for the following purposes:

2.1.1. Provide and develop the Platform:

2.1.2. Provide and optimize advertising and marketing activities

2.1.3. Enable ZuckPay Services

2.1.4. Maintain a secure environment

2.1.5. Purposes of Processing Visitor Personal Data. We may collect personal data from Platform visitors for the following purposes:

3. LEGAL BASES FOR PROCESSING

3.1. Legal Bases. The processing of personal data performed by ZuckPay companies is always based on a legal basis provided for in applicable laws. The legal bases used by ZuckPay companies may vary depending on the context of processing, and include the following:

4. PERSONAL DATA PROCESSED BY ZUCKPAY COMPANIES ON BEHALF OF THIRD PARTIES

4.1. Processing of Personal Data at the Request of Third Parties. There are personal data that are processed by ZuckPay companies at the request of third parties. ZuckPay companies process this personal data following rules formalized with these third parties through written contracts. For example, the Creator may request, through the Platform, additional personal data from the Buyer (“Creator Data”). The types of Creator Data may vary depending on the specific guidance of the Creator.

4.2. Processing of Personal Data related to ZuckPay Services. ZuckPay companies may also process certain personal data on behalf of third parties when you choose to use ZuckPay Services. For more information about ZuckPay Services, access the ZuckPay General Payment Policy.

4.3. Responsibility for Processing of Personal Data by Third Parties. The third parties referred to in the previous items are also processing agents responsible for personal data in the context of offering their products and services. Specifically, third parties may be Creators whose responsibilities and attributions are established in the Personal Data Processing Agreement.

4.3.1. Specifically, the User who chooses the ZuckPay Card, despite not having direct contact with the credit card brand or the payment institution partner of ZuckPay, has a contractual relationship with these third parties and, therefore, is also bound by the terms of use and privacy policies applicable to these third parties.

5. PERSONAL DATA RETENTION PERIOD

5.1. Processing Period. Personal data is processed by ZuckPay companies until at least one of the hypotheses described below is reached. They are:

5.2. Conservation of Personal Data. In certain situations, ZuckPay companies may residually conserve personal data even after the hypotheses of termination of personal data processing, due to compliance with legal or regulatory obligation, or in circumstances where there is a legitimate purpose of ZuckPay companies. In these cases, personal data will be stored in a secure location with restricted access and for the time necessary to comply with the legal or regulatory obligation, or the termination of the legitimate purpose of ZuckPay companies.

5.2.1. The conservation periods for personal data differ and depend on the type of information and the objectives for which we use the information. For more details on the retention period of a specific category of personal data, please contact us via this form.

6. SHARING OF PERSONAL DATA

6.1. ZuckPay companies only share personal data with third parties in the circumstances described below. These third parties enter into a written contract with ZuckPay companies and are aware of their responsibilities at each stage of processing, especially the duty to implement security measures that meet the requirements of the contract and applicable laws. ZuckPay companies do not sell personal data.

6.1.1. User Consent. When you give your consent, we share your information as described at the time of consent – such as, for example, authorizing the sending of personal data to third parties to enable participation in events.

6.1.2. Compliance with law, prevention of damage and safety. When there is a need to share personal data with third parties in order to (a) prevent fraud (such as, for example, anti-money laundering risk analysis), which may involve automated decisions; (b) check list of Users with restrictions; (c) authenticate forwarded documentation; (d) enable support service; (e) avoid illegal activities; (f) proceed regarding disputes between Users; (g) proceed regarding internal investigations related to any conduct that may violate the rules of the Terms or Policies of ZuckPay companies.

6.1.2.1. You agree and authorize ZuckPay to perform the processing, storage, and sharing of your personal data, to subsidize procedures intended for controls and fraud prevention, in accordance with the guidelines established by competent authorities.

6.1.3. ZuckPay Services. Personal data is also shared with third parties when the User, in some way, uses ZuckPay Services, especially when the User chooses the ZuckPay Card. Personal data, including card number, will be shared with the credit card brand and the payment institution partner of ZuckPay companies. This sharing aims to process payment, provide card services, prevent, detect, and investigate potential fraud or restriction lists, facilitation in resolving disputes involving refund or chargeback.

6.1.4. Between Companies of its Economic Group. The sharing of personal data may occur between controlling, controlled, affiliated companies or under common control of ZuckPay, or any companies of the Economic Group, to enable the Services of ZuckPay companies, generate administrative efficiencies, and facilitate the use of different services by the same User. ZuckPay companies may also share your personal data in scenarios of transactions of part or all of our business, such as a sale of a business unit, acquisition, merger, consolidation, or in case of bankruptcy or judicial recovery.

6.1.5. Service Providers. Your personal data may be shared with third parties involved in financial, accounting, legal advisory activities, non-profit activities, and potential investors, as well as third parties involved in providing data backup, cloud computing service providers, or to conduct analytical studies.

6.1.6. Sharing of Information between Users. When you participate in Creator Content, ZuckPay companies will share certain information with the Creator to allow the Creator to provide services to you. This information includes: (a) account information, such as your name and email address; (b) payment information, such as the amount paid, your address, and other billing information, but never your full credit card number; (c) your IP address; (d) information about your participation in Creator Content, including your enrollments, progress, test results, and certificates; (e) any message you have exchanged with the Creator through the Platform. Another situation may occur when you use ZuckPay companies' Services to publish Creator Content, information contained in your Creator Content will be visible to Users who have access to Creator Content. For example, when you publish your bio on a sales page, personal data in your bio will be visible to people visiting the sales page.

6.1.7. With Integrated Services. When the User decides to integrate third-party services, their personal data will be shared with these third parties. We recommend that you read the terms of use and privacy policies of these third parties to understand how they collect, use, and share your personal data.

6.1.8. With Business Partners. ZuckPay companies may partner with third parties to offer events, promotions, contests, and other programs. To participate in these offers, you may be requested to provide your email address and other personal data.

6.1.9. With Advertisers and Analytical Data Providers. We may share your Personal Data with advertisers, ad networks, and analytical data providers through cookies or other technologies.

6.1.10. With Government Authorities, Police, or the Judiciary. ZuckPay companies may be required to share your personal data with government authorities, police, or the Judiciary, whenever necessary to comply with a court order or request from the respective authority.

7. INTEGRATIONS AND THIRD-PARTY PARTNERS

7.1. You can allow our Platform to interact with third-party services (such as Facebook, Google, Zoom). The information you allow to be accessed by us depends on each service and may be affected by the privacy settings you and others with whom you are connected establish when using the services. Third-party services are operated, controlled, and maintained by Third Parties, without any relationship with us. We recommend that you read the terms of use and privacy policies of respective Third Parties to understand how your personal data is collected, used, and shared by them with us or with other Third Parties.

7.2. Specifically, ZuckPay companies, in certain cases, may link third-party services to the Platform through application programming interfaces (APIs), such as the YouTube API. These third-party services are not part of the scope of ZuckPay companies' services and do not form part of the Platform, being subject to different terms and conditions, such as YouTube's Terms of Service and Google's Privacy Policy. ZuckPay companies are not responsible for these services and, when you interact with them, you are providing your personal data directly to them.

7.2.1. The ZuckPay application uses and transfers information received from Google APIs to any other application within the requirements of the Google API Services User Data Policy, including limited use requirements.

8. INTERNATIONAL TRANSFERS

8.1. International Transfers. ZuckPay companies may transfer your personal data to countries other than the one where you are located. ZuckPay companies adopt measures required by law, when existing and applicable, to ensure the protection of this personal data. In jurisdictions where current legislation or regulation does not yet provide specific criteria or clear rules for international transfers of personal data, ZuckPay companies adopt good practices to protect your personal data, entering into contracts with recipients of respective information that establish measures consistent with the standards of the locations where personal data was initially collected.

9. RIGHTS REGARDING YOUR PERSONAL DATA

9.1. Rights: Depending on the laws applicable to the processing of your personal data, you may possess certain specific rights regarding your personal information, which can be exercised through this form. Listed below are the applicable rights:

9.2. To speak with our person responsible for personal data protection, contact us through this form.

9.3. Whenever a ZuckPay company is acting on behalf of third parties, and the User decides to seek from a ZuckPay company the fulfillment of one of their rights, we may attend, in certain circumstances, to this request, if applicable.

If you wish to cancel the sending of newsletters, emails, phone calls, or advertising SMS, you can do so through the link provided in the communications themselves.

ZuckPay reserves the right to refuse requests that are manifestly unfounded and/or excessive.

All rights above that are applicable in your jurisdiction can be exercised by you at any time, free of charge, unless charging a fee is permitted according to current legislation or regulation, and ZuckPay companies undertake to make their best efforts to attend to your requests transparently and quickly.

To ensure that rights are being exercised by you or your duly constituted legal representative, ZuckPay companies may request necessary information or proof regarding your identity, in order to avoid fraud and ensure your privacy, so that your personal data is not shared with anyone who is not authorized to do so.

We will respond to your requests within a reasonable time, in accordance with applicable law, remembering that we can only respond to some requests after receiving the confirmations provided above.

In certain cases, such as when your request is particularly complex or when we receive a high volume of requests at the same time, our response may not be as quick as we would like it to be. On these occasions, we will always keep you informed and updated on the progress of your request.

10. SECURITY

10.1. Security Measures. ZuckPay companies employ security, technical, and organizational measures necessary to protect personal data they process. Efforts aim to mitigate risks of destruction, accidental or illegal loss, alteration, disclosure, or unauthorized access or any other form of illegal or unauthorized processing. To this end, ZuckPay companies rely on strict restricted access controls, based on least privilege, to information technology systems to protect personal data against potential security incidents. For more information, access the Cybersecurity and Information Security Policy.

10.2. Although ZuckPay companies implement these measures to minimize risks of security incidents and improper access, it is not possible to guarantee absolute security of your data, especially against attacks perpetrated by malicious persons, which can be highly sophisticated and innovative, with techniques and methods unknown until then, even by the best information security tools.

10.3. The security of your data also depends on the adoption of reasonable measures by you in the use of your devices and software.

11. PROCESSING OF MINORS' PERSONAL DATA

11.1. Minors' Personal Data. ZuckPay companies do not knowingly collect or solicit personal data from minors under 13. If we become aware that personal data of a minor under 13 has been collected, we will cancel the account created on the Platform and delete the personal data, only keeping personal data intended to prevent a new registration attempt.