LGPD / Compliance
Who we are
ClubeSecretto operates in compliance with the Brazilian General Data Protection Law (LGPD, Law 13.709/2018). We process your personal data solely to provide the verified adult platform.
DPO (Data Protection Officer)
Raiane Florêncio · dpo@clubesecretto.com
Your LGPD rights
- Access: Export all your data (JSON)
- Correction: through your dashboard
- Deletion: request from the dashboard — immediate soft-delete + permanent deletion within 30 days
- Portability: exported JSON dump
- Withdraw consent: via the dashboard
Legal basis for processing
Consent (art. 7, I) for profiles, analytics cookies, marketing. Performance of a contract (art. 7, V) for payments and KYC. Legal obligation (art. 7, II) for retention of identity documents (5 years after account closure).
Data sharing
We do not sell data. Authorised processors:
- Resend (transactional email delivery)
- Cloudflare (DNS, CDN, Turnstile CAPTCHA)
- Sentry (error monitoring — no PII)
- PostHog self-hosted (LGPD-friendly analytics)
- Pagar.me / CCBill (Phase 1 only — payment processing)
Cookies
We use a granular consent banner — you choose which cookies to accept: necessary, analytics, marketing.
Retention
- KYC documents: 5 years after deletion (legal obligation)
- Audit logs: 12 months
- Other data: deleted within 30 days of a deletion request
Incidents
If we identify a data breach, we will notify the ANPD within 72h and the affected data subjects within 7 days.