Privacy Policy (LGPD)
Version: 2026-07-22.v1 · Last updated: 22 de julho de 2026 · Not yet in effect. Document in draft.
How we collect, use, share, and protect your personal data, under Brazilian Law No. 13,709/2018 (LGPD).
1. Who we are (Controller)
The controller of the personal data processed on the Duoworks platform is [RAZÃO SOCIAL], CNPJ [CNPJ], headquartered at [ENDEREÇO DA SEDE]. Questions and requests regarding personal data: see the Data Protection Officer (DPO) channel in section 7.
2. Data collected and purposes
We collect only what is necessary to operate the marketplace (the minimization principle). No data is collected without a defined purpose.
| Data | Purpose | Legal basis (LGPD, Art. 7) |
|---|---|---|
| Full name, e-mail, password (stored as a hash) | Account creation and authentication; essential communications | Performance of a contract |
| Date of birth | Solely to verify legal age (18+). Never displayed publicly; restricted access | Legal obligation / performance of a contract |
| Professional profile (photo, bio, skills, experience, hourly rate, links) | Public display of the listing and search functionality | Performance of a contract |
| Transaction data (amounts, status, Stripe identifiers) | Escrow, commission and payout processing | Performance of a contract / legal obligation (tax records) |
| Professional's payout details (PIX key or USDC wallet address + network) | Transfer (withdrawal) of the released escrow balance to the professional | Performance of a contract |
| Chat messages and attachments | Communication between the parties; evidence in disputes; detection of attempts to pay off-platform | Performance of a contract / legitimate interest |
| Technical logs (IP, date/time, sensitive actions) | Security, auditing and fraud prevention | Legitimate interest / legal obligation |
| Record of acceptance of the legal documents (version, IP, timestamp) | Proof of consent and of contractual acceptance | Legal obligation / performance of a contract |
| Analytics/marketing cookies | Usage metrics and product improvement (when enabled) | Consent (genuine opt-in, see the Cookie Policy) |
The profile photo undergoes EXIF metadata removal before publication (this eliminates, for example, geolocation data embedded by the camera).
3. Sharing: processors
We do not sell personal data. We share data only with the processors necessary to provide the service, under contract:
| Processor | Role | Data involved |
|---|---|---|
| Stripe | Payment, escrow and payout processing (PCI-DSS) | Transaction and payout data. Card data is handled exclusively by Stripe, and never passes through our servers |
| Mercado Pago | Payment processing (card, PIX, boleto), when the client chooses to pay via Mercado Pago | Transaction data. Card data is handled exclusively by Mercado Pago, and never passes through our servers |
| NOWPayments | Cryptocurrency/stablecoin payment processing (international checkout), when the client chooses to pay in crypto | Transaction data. International processor. See International transfer (§4). [Confirmar DPA e região dos servidores na revisão jurídica] |
| Resend | Sending of transactional e-mails | E-mail, name and content of the notifications |
| Upstash | Rate limiting (security), when enabled | Technical identifiers (e.g., IP, user id) |
| [PROVEDOR DE HOSPEDAGEM: ex.: VPS/datacenter contratado] | Infrastructure where the application and the PostgreSQL database (self-managed by us) run | Account and platform-usage data, stored under our direct administration; technical access logs |
| Sentry | Application error monitoring | Technical error logs (personal data minimized at the source) |
Data may also be shared with authorities pursuant to a legal obligation or a court order.
4. International transfer
The processors above may store data on servers located outside Brazil (for example, the United States and the European Union). These transfers occur with the safeguards of Art. 33 of the LGPD, including contractual clauses and provider certifications [TRANSFERÊNCIA INTERNACIONAL: detalhar mecanismo do art. 33 por operador na revisão jurídica; confirmar região dos servidores da VPS].
5. Retention and deletion
- Data is retained while the account exists and the purpose of the collection remains necessary.
- Account deletion: soft delete for 30 days (cooling-off window), followed by hard delete. Only data whose retention is a legal obligation is preserved, such as tax and transaction records.
- Chat history: retained while the account exists, as it is evidence in escrow disputes. This is disclosed in the chat itself and in this Policy.
- Security audit logs are retained for a minimum period [PERÍODO DE RETENÇÃO DE LOGS: definir, ex.: 6 meses, art. 15 do Marco Civil da Internet].
6. Data subject rights (LGPD, Art. 18)
You may, at any time, request:
- Confirmation of the existence of processing and access to the data;
- Correction of incomplete, inaccurate or outdated data;
- Anonymization, blocking or deletion of unnecessary or excessive data;
- Portability: the My data page lets you export your data in JSON format;
- Deletion of data processed on the basis of consent: account deletion is available in Settings;
- Information about the sharing carried out;
- Withdrawal of consent (e.g., analytics cookies), without affecting the lawfulness of prior processing.
7. Data Protection Officer (DPO) channel
Data Protection Officer (DPO) channel: [email protected]. We will respond to requests within the time limits set by the LGPD. If you are not satisfied, you may appeal to the National Data Protection Authority (ANPD).
8. Security
Security is the project's number-one principle: encryption in transit (HTTPS/HSTS), hashed passwords, server-side authorization checks on every operation, optional two-factor authentication (2FA), temporary account lockout after failed login attempts, httpOnly session cookies, rate limiting, audit logs and the principle of least privilege for internal access. No system is infallible; security incidents that may entail relevant risk or harm will be reported to the affected data subjects and to the ANPD, in accordance with Art. 48 of the LGPD.
9. Changes to this Policy
This Policy is versioned. Material changes will be communicated by e-mail and will require a new acceptance. The current version is always published on this page.
Version: 2026-07-22.v1 · 22 de julho de 2026