Privacy Policy

Introduction

This Privacy Policy describes how Grupo D2C (“we”, “us”, “our”) collects, uses, and shares information when you use the FACT mobile application (“FACT” or the “App”) and related services. We are committed to protecting your privacy. Please read this policy together with any in-app notices; your counsel should review it before publication.

Data controller

For the purposes of applicable data protection laws, the data controller is Grupo D2C. Contact: suporte@grupod2c.com.br. Website: fact.grupod2c.com.br

Information we collect

Depending on how you use FACT, we may process:

• Account and profile data: name, username, email address, password (stored securely), role (mentor or mentee), bio, interests, education or institution details, profile photo, and other fields you choose to provide.
• Connections and activity: match requests, connections, messages, and related metadata (e.g. timestamps) needed to operate messaging and matching features.
• Device and technical data: device type, operating system, app version, language preference, and diagnostic or crash data to keep the App reliable and secure.
• Communications with us: information you send when you contact support.

How we use your information

We use the information above to:

• Provide, maintain, and improve FACT (accounts, profiles, matching, messaging).
• Communicate with you about the service, security, and support requests.
• Protect users and the service, enforce our terms, and detect abuse or fraud.
• Comply with legal obligations.

Where required, we rely on appropriate legal bases such as performance of a contract, legitimate interests (e.g. securing the service), and consent where applicable.

Sharing of information

We do not sell your personal information. We may share information with:

• Service providers who assist us with hosting, infrastructure, analytics, or email, bound by contractual obligations.
• Other users as needed for the App to work (for example, profile information visible to matches and message content between connected users).
• Authorities when required by law or to protect rights and safety.

International transfers

If data is processed in countries other than your own, we take steps designed to ensure appropriate safeguards in line with applicable law. Update this section to reflect where your servers and subprocessors are located.

Retention

We keep information for as long as your account is active and as needed to provide the service, comply with law, resolve disputes, and enforce agreements. Retention periods may be adjusted and should be aligned with your backend practices.

Security

We implement technical and organizational measures designed to protect personal data. No method of transmission over the internet is completely secure; we encourage strong passwords and device security.

Your rights

Depending on where you live, you may have rights to access, correct, delete, or export your personal data, object to or restrict certain processing, withdraw consent where processing is consent-based, and lodge a complaint with a supervisory authority. To exercise these rights, contact us at the email above.

Children

FACT is not directed at children under the age required by your jurisdiction (often 13 or 16). We do not knowingly collect personal information from children below that age. If you believe we have, contact us and we will take appropriate steps.

Changes to this policy

We may update this Privacy Policy from time to time. We will post the new version on this page and update the “Last updated” date. Material changes may require additional notice under applicable law or in the App.

Contact

For privacy-related questions: suporte@grupod2c.com.br

Note for your team: Have qualified legal counsel review this policy, align it with your actual data flows (Laravel/API, hosting, analytics, push notifications, etc.), and with Apple’s App Privacy details in App Store Connect.