1. About this Policy
This Privacy Policy explains how Turbo Engage ("Turbo Engage", "we") collects, uses, shares, and protects personal data on our websites, member areas, and applications related to our courses.
We comply with the General Data Protection Law (Law No. 13.709/2018 — LGPD).
2. Controller and Data Protection Officer (DPO)
Controller
Turbo Engage
Address: California, US
General email: contact@turboengages.site
DPO
Name: Your DPO
Email: dpo@turboengages.site
3. Personal data we collect
- Registration: name, email, phone, tax ID (if required for invoices), address.
- Payment: transaction and billing data. Card information is processed by third parties and is not stored on our servers.
- Platform usage: enrolled courses, progress, certificates, grades, forum interactions, support.
- Technical: IP address, device identifiers, logs, cookies, browsing data.
- Communication: support messages, emails, satisfaction surveys.
- Marketing: communication preferences, campaign history.
- Minors: our courses are for individuals 18+. If we identify data from minors, we remove it after review.
4. Purposes and legal bases (LGPD)
| Purpose | Data | Legal basis |
|---|---|---|
| Create accounts, sell courses, issue invoices and certificates | Registration, payment, usage | Contract performance (Art. 7, V) |
| Customer service, support, and operational communication | Registration, communication | Legitimate interest (Art. 7, IX) and/or contract |
| Security, fraud prevention, and compliance | Technical, logs, transactions | Legal obligation (Art. 7, II) and legitimate interest |
| Marketing and recommendations | Contact, preferences, usage | Consent (Art. 7, I) and/or legitimate interest |
| Platform improvement and statistics | Technical, usage | Legitimate interest |
When the legal basis is consent, you may withdraw it at any time through unsubscribe links or by contacting the DPO.
5. Cookies and similar technologies
We use cookies for authentication, preferences, analytics, and marketing. You can manage preferences in the banner or your browser settings.
| Category | Examples | Duration |
|---|---|---|
| Essential | Login, session management | Session |
| Functional | Remember preferences | Up to 12 months |
| Analytics | Measure traffic and performance | Up to 24 months |
| Marketing | Measure campaigns | Up to 24 months |
6. Data sharing
We share data with:
- Processors: hosting, email, CRM, support, analytics, payment providers.
- Authorities: when required by law, court order, or to protect rights.
- Academic partners: when necessary for joint certifications.
List your main providers here, e.g., payment gateway, email platform, hosting.
7. International transfers
If data is transferred outside Brazil, we adopt safeguards such as standard contractual clauses and adequacy assessments.
8. Retention
We retain data for as long as necessary for the purposes and legal obligations. Examples:
- Tax and billing records: per applicable legal deadlines.
- Inactive accounts: reviewed after 24 months for anonymization or deletion, unless legally required otherwise.
- Access logs: per the Brazilian Internet Civil Framework and other regulations.
9. Information security
We apply technical and organizational controls, including encryption in transit (HTTPS), access controls, backups, and monitoring. No method is 100% secure, but we aim for adequate levels based on risk.
10. Your rights (LGPD)
You may exercise, among others, the following rights:
- Confirmation of processing and access to data.
- Correction of incomplete, inaccurate, or outdated data.
- Anonymization, blocking, or deletion of unnecessary or excessive data.
- Data portability, when applicable.
- Information about sharing and the option not to provide consent.
- Withdrawal of consent.
- Review of automated decisions affecting your interests.
To exercise rights, contact dpo@turboengages.site. We may request identity verification.
11. Marketing communications
We send emails and messages about courses, content, and offers only with your consent or legitimate interest. You can unsubscribe anytime via email links or by contacting the DPO.
12. Payments and refunds
Payments are processed by certified intermediaries. We do not store full card details. Turbo Engage offers full refunds within 7 days of purchase, in line with our Refund Policy and the Consumer Defense Code. See our Refund Policy for details.
13. Third-party websites and content
Our services may contain links to third-party websites. We are not responsible for their privacy practices. Read their policies.
14. Changes to this policy
We may update this policy to reflect legal, technical, or business changes. We will notify you of relevant updates through appropriate channels. The effective date indicates the current version.
15. How to contact us
DPO email: dpo@turboengages.site
General email: contact@turboengages.site
Address: California, US.