MUG IT — header

This Privacy Policy explains how MUGNOS-IT CAPACITACAO E CONSULTORIA LTDA (“Mugnos-IT”, “we”, “us”, or “our”), a company established in Brazil (CNPJ 59.977.699/0001-97, São Paulo, Brazil), collects, uses, shares, and protects your personal data when you use the SRE App mobile application and related services (the “Service”).

Effective date: 2026-06-30
Last updated: 2026-06-30

We act as the data controller for the personal data described below. Because our users are located around the world, this policy is written to comply with both Brazil’s Lei Geral de Proteção de Dados (LGPD, Law No. 13.709/2018) and the EU/EEA/UK General Data Protection Regulation (GDPR), in addition to applicable app-store requirements.

1. Summary

2. Personal data we collect

2.1 Information you provide

2.2 Information from Google Sign-In (if you use it)

If you choose “Sign in with Google”, Google shares your name, email address, and a unique account identifier with us through the AWS Cognito hosted login flow. We do not receive your Google password.

2.3 Learning and usage data

To run the gamified learning experience, we store:

2.4 Device and notification data

2.5 Technical data

We do not intentionally collect special-category/sensitive data (LGPD Art. 5, II / GDPR Art. 9), and you should not submit such data to the Service.

3. How we use your data and our legal bases

PurposePersonal data usedLegal basis (LGPD / GDPR)
Create and manage your account; authenticate youAccount, auth, Google sign-in dataPerformance of a contract (LGPD Art. 7, V / GDPR Art. 6(1)(b))
Deliver lessons and track learning progress / XPLearning and usage dataPerformance of a contract (LGPD Art. 7, V / GDPR Art. 6(1)(b))
Send account emails (verification, password reset)Email addressPerformance of a contract / legitimate interest (LGPD Art. 7, V/IX · GDPR Art. 6(1)(b)/(f))
Send push notifications (streaks, content, events)Device push tokenConsent (LGPD Art. 7, I / GDPR Art. 6(1)(a)) — opt-in via device settings
Secure the Service, prevent abuse, debugTechnical dataLegitimate interest / legal obligation (LGPD Art. 7, IX/II · GDPR Art. 6(1)(f)/(c))
Comply with legal obligationsAs requiredLegal obligation (LGPD Art. 7, II / GDPR Art. 6(1)(c))

We do not use automated decision-making that produces legal or similarly significant effects on you.

4. How we share your data (processors and third parties)

We share personal data only with service providers (“operators”/”processors”) that process it on our behalf under contract:

We do not sell personal data and do not share it with advertisers or data brokers. We may disclose data if required by law, legal process, or to protect our rights, users, or the public.

5. International data transfers

We are based in Brazil, and our infrastructure providers process data in the United States (AWS region us-east-1) and potentially other regions. When we transfer personal data internationally — including from Brazil or the EU/EEA/UK — we rely on appropriate safeguards, such as Standard Contractual Clauses and our providers’ data-processing terms, consistent with LGPD Arts. 33–36 and GDPR Chapter V. You may request more information about these safeguards using the contact details below.

6. Data retention

We keep your personal data for as long as your account is active and as needed to provide the Service. When you delete your account (or request deletion), we delete or anonymize your personal data within 30 days, except where we must retain certain data to comply with legal obligations, resolve disputes, or enforce our agreements.

7. Your rights

Subject to applicable law, you have the right to:

To exercise any right, email contato@mugnos-it.com. We will respond within the timeframes required by law (LGPD: without undue delay; GDPR: within one month).

For any questions about how we handle your personal data, or to exercise your rights, contact our data protection channel at contato@mugnos-it.com.

8. Account and data deletion

You can request deletion of your account and associated personal data at any time by emailing contato@mugnos-it.com with the subject “Account deletion”. We will verify your request and delete your data as described in Section 6.

9. Security

We use industry-standard measures to protect your data, including encrypted transport (HTTPS/TLS), managed authentication via AWS Cognito, and access controls. No method of transmission or storage is 100% secure, but we work to protect your data and to notify you and the relevant authorities of incidents as required by law.

10. Children’s privacy

The Service is not directed to children under 13, and we do not knowingly collect personal data from children under 13. If you believe a child has provided us personal data, contact us at contato@mugnos-it.com and we will delete it. Where stricter local law applies (e.g., a higher age of digital consent in your country), that age applies to you.

11. Changes to this policy

We may update this Privacy Policy from time to time. We will revise the “Last updated” date and, for material changes, provide additional notice (e.g., in the app). Your continued use of the Service after changes take effect constitutes acceptance of the updated policy.

12. Contact

MUGNOS-IT CAPACITACAO E CONSULTORIA LTDA
CNPJ 59.977.699/0001-97 — São Paulo, Brazil
Email: contato@mugnos-it.com
Website: https://mugnos-it.com