Last updated: 25 September 2026

Kess Company LTDA, operating as Upelia (“Upelia”, “we”, “us” or “our”), is responsible for personal data processed through upelia.com, the Upelia mobile application and related services.

1. Data we collect
   Depending on how you use Upelia, we may collect your name, email address, telephone number, city/country, profile and account information, learning interests, course enrolments, lesson progress, quiz or exercise responses, certificates, waitlist and event responses, community posts or messages, and support requests. We may also process subscription or purchase status and transaction references supplied by app stores or payment providers. Technical data may include IP address, browser, device type, operating system, app version, device or advertising identifiers where permitted, push-notification token, timestamps, cookie identifiers, website activity, diagnostics, performance and crash data.

2. How we use data
   We use personal data to create and manage accounts; provide courses, resources, events and community features; record learning progress; process access to free, paid or sponsored programs; respond to requests; send service and security notices; deliver notifications selected by the user; improve Upelia; prevent fraud and misuse; and comply with legal obligations.

3. Legal bases
   Under Brazil’s LGPD, processing may be based on consent, performance of a contract or steps requested before a contract, compliance with legal obligations, exercise of rights, fraud prevention, or legitimate interests after considering your rights and reasonable expectations. Consent may be withdrawn at any time.

4. Payments and app stores
   Purchases may be processed by Apple, Google, Wix or other authorized payment providers under their own terms and privacy practices. Upelia does not receive full payment-card details. We may receive transaction references, subscription status, product purchased and limited billing information needed to provide access, maintain records and handle support.

5. Sharing and international transfers
   We do not sell personal data. Data may be shared only as necessary with Wix, Apple, Google and providers supporting hosting, video delivery, authentication, analytics, communications, payments, security, customer support and professional services, or with authorities when required by law. Providers may process data outside Brazil using safeguards intended to meet applicable LGPD requirements.

6. Notifications and device permissions
   Where enabled, the application may request permission to send push notifications or access device features required for a function selected by the user. You can change permissions in your device settings. We do not access features such as camera, microphone, photos or location unless the application presents a specific function that requires it and you grant permission.

7. Retention
   We retain data only as long as reasonably necessary to provide services, maintain learning and transaction records, meet legal requirements, resolve disputes and protect the platform. Data is then deleted or anonymized unless continued retention is legally permitted or required.

8. Your rights and account deletion
   Subject to the LGPD, you may request confirmation, access, correction, anonymization, blocking or deletion, portability as regulated, information about sharing, withdrawal of consent, deletion of consent-based data where applicable, and review of qualifying automated decisions. You may also request deletion of your Upelia account and complain to Brazil’s ANPD. Some records may be retained where legally required.

9. Children and adolescents
   Minors should use Upelia only with authorization and supervision from a parent or legal guardian. Where applicable, we will seek consent or another valid legal basis appropriate to the child’s best interests. If data was submitted improperly, we will take reasonable steps to delete it.

10. Security, cookies and updates
    We use reasonable administrative, technical and organizational safeguards, but no online service can guarantee absolute security. Cookies and similar technologies used on the website are described in our Cookie Policy. We may update this Policy and will show the latest revision date.

Controller and contact
Kess Company LTDA — CNPJ 23.838.862/0001-93
Privacy requests: contact@upelia.com