Privacy Notice — VDE 1ª Fase App

1. Who the controller is

The controller of the data processed in the App is Vício De uma Estudante Curso Preparatório para Concursos Ltda. (CNPJ 32.584.678/0001-55), located at Av. Washington Soares, nº 3663, Salas 1003 a 1006 — Torre 2, Bairro Edson Queiroz, Fortaleza-CE, Brazil.

2. Required vs. optional data

2.1 To create and maintain your account in the App, only two pieces of data are required: name and email.

2.2 During onboarding (first use), the App may request additional information to personalize your study experience. All of this information is optional and can be skipped — the App works normally without it. You can fill it in, leave it blank, or edit it later in your profile settings.

2.3 The optional data collected during onboarding is listed in Section 3.2.

4. Device permissions

The App requests the following permissions, always with your authorization and manageable in your device settings:

• Camera: used solely when you choose to take a photo for your profile.
• Photo library: used solely when you choose to select an existing photo for your profile. The App does not access your photos for any other purpose and does not collect images without your direct action.
• Notifications (push): to send study reminders and alerts about your course. Optional (opt-in) and can be disabled at any time.

Declining any permission only limits the corresponding feature, without preventing use of the App’s study functions.

5. In-app purchases and payment data

5.1 On iOS, course purchases made within the App are processed through Apple’s In-App Purchase system. Payment and the related financial data are handled directly by Apple, under Apple’s privacy policy. VDE does not collect or store your card or payment method data used in these purchases — we receive from Apple only the purchase confirmation needed to unlock your access.

5.2 For purchases made on the web (outside the App), payment is processed by Hotmart, as described in the VDE Platform Privacy Notice.

6. Tracking and advertising (ATT)

6.1 On iOS, before using advertising identifiers for cross-app and cross-site tracking with third parties, the App will request your authorization through Apple’s App Tracking Transparency (ATT) framework. You may grant or deny this authorization and change it at any time in your device settings.

6.2 If you do not authorize tracking, the App will continue to work normally, and your data will not be used for targeted-advertising measurement.

6.3 On Android, you can reset or limit the advertising identifier (AAID) in your device settings.

8. International data transfers

Some of the third-party services listed are based abroad, primarily in the United States. As a result, part of your data may be transferred to and stored outside Brazil, always based on the grounds in article 33 of the LGPD (performance of a contract and contractual clauses ensuring a level of protection compatible with the LGPD).

9. Account deletion and data retention

9.1 Account deletion in the App: You may delete your account at any time directly in the App, in the settings/profile area. Deletion may also be requested by emailing suporte@metodovde.com.br.

9.2 When you delete your account, your associated personal data is removed or anonymized, except for information VDE must retain by legal obligation:

• Transaction and tax data: for the periods required by law (minimum of 5 years);
• Application access logs: for the period required by the Internet Civil Framework (minimum of 6 months);
• Data needed to defend legal claims: for the applicable limitation period.

9.3 Once these periods end, data is deleted or anonymized, except in the cases provided in article 16 of the LGPD.

9.4 Deleting your account does not, in itself, entitle you to a refund of courses already purchased. Refunds for purchases made in the App (iOS) follow Apple’s policy; purchases made on the web follow the VDE Platform Terms of Use.

10. Your rights as a data subject

You may, at any time, request: confirmation that processing exists; access to your data; correction; anonymization, blocking, or deletion of unnecessary data; portability; information about data sharing; withdrawal of consent; and review of automated decisions, where applicable. To exercise these rights, use the App settings (including account deletion) or email suporte@metodovde.com.br with the subject “Proteção de Dados / LGPD” (Data Protection / LGPD).

You can also manage directly on your device: permissions, notifications, and tracking authorization (ATT).

11. Security

We adopt technical and organizational measures to protect your data, including encryption in transit and at rest, access controls, and monitoring. No system is 100% secure, so keep your login and password confidential and let us know of any suspected unauthorized access.

12. Data Protection Officer (DPO)

In accordance with article 41 of the LGPD, VDE has a Data Protection Officer. To contact them, email suporte@metodovde.com.br with the subject “Proteção de Dados / LGPD” (Data Protection / LGPD).

13. Changes to this Notice

This Notice may be updated to reflect changes in the App, third-party services, or legislation. Material changes will be communicated through the App and/or by email, and the current version will always be available on the App’s store page and within the App.

14. Contact

VDE 1ª Fase — always one step ahead.