Privacy Policy
Version 1.1, in force since October 15, 2026.
NEXTFIN PRIVACY POLICY
This Privacy Policy (“Policy”) explains how OFERTA FÁCIL LTDA., a privately held legal entity registered with the Brazilian National Register of Legal Entities (CNPJ) under No. 64.347.474/0001-97, with registered office at Rua Teixeira Mendes, No. 153, Apt. 102, Laranjeiras, Rio de Janeiro/RJ, ZIP Code 22245-090 (“NextFin,” “we,” “us,” or the “Company”), processes personal data in connection with the NextFin platform.
The Company operates under the NextHub brand, which encompasses different digital products and services. This Policy applies exclusively to NextFin. Other products in the NextHub ecosystem may have their own privacy policies.
This Policy should be read together with the NextFin Terms of Use and any specific notices presented at the time of collection or in connection with sponsored programs.
1. Key concepts
To make this Policy easier to understand, we use the following concepts:
| Concept | Meaning in this Policy |
|---|---|
| Personal data | Information relating to an identified or identifiable natural person, such as a name, telephone number, email address, CPF number, or account identifier. |
| Processing | Any operation performed on personal data, including collection, use, access, storage, sharing, updating, and deletion. |
| Data Subject | The person to whom the personal data relates, such as a user, visitor, pre-registered beneficiary, or representative of a partner organization. |
| Controller | The party that makes the principal decisions regarding the purposes and means of processing personal data. For NextFin’s own activities described in this Policy, the Controller is OFERTA FÁCIL LTDA. |
| Processor | A service provider that processes personal data on behalf of the Controller and in accordance with its instructions. |
| Sponsoring Organization | A company, entity, institution, or business partner that grants, funds, manages, or arranges access to NextFin for customers, employees, members, or other beneficiaries. |
| Pre-registered Account | A record created using information provided by a Sponsoring Organization before the beneficiary creates credentials and accesses NextFin for the first time. |
2. Who this Policy applies to
2.1. This Policy applies to personal data processing carried out through:
a) the NextFin mobile application;
b) NextFin’s website, authenticated areas, and public pages;
c) registration, authentication, support, and contact channels;
d) subscriptions, purchases, book licenses, certificates, and other platform features; and
e) integrations with Sponsoring Organizations, app stores, payment providers, and technology service providers.
2.2. In sponsored programs, the Company and the Sponsoring Organization may act as independent Controllers, each being responsible for the decisions it makes regarding the data under its responsibility. The specific relationship may be supplemented by the agreement, rules, or privacy notice applicable to the relevant program.
3. How we obtain personal data
We may obtain personal data from the following sources:
| Source | Examples |
|---|---|
| Directly from the Data Subject | Registration, profile updates, code-based authentication, contact, support, questionnaire responses, ratings, preferences, and account-related requests. |
| From the use of NextFin | Learning progress, playback position, content accessed, books added or received, favorites, achievements, certificates, and technical access data. |
| From Sponsoring Organizations | Name, telephone number, email address, CPF number, employee or member ID, customer number or another external identifier, plan granted, and information required to administer the benefit. |
| From app stores and payment providers | Purchase or subscription identifiers, product purchased, originating store, payment status, amounts, currency, dates, renewal, cancellation, and refund. |
| From communications and infrastructure providers | Email and message delivery status, technical failures, security events, and data required to operate the services. |
4. Personal data processed
The categories actually processed vary depending on the features used, access channel, and type of subscription or purchase.
| Category | Data and examples | Main source |
|---|---|---|
| Registration and identification | Name, telephone number, email address, internal account identifier, language, telephone or email verification indicators, and choice regarding receipt of updates. | Data Subject or Sponsoring Organization. |
| Identification in sponsored programs | External identifier defined by the organization, which may correspond to a CPF number, employee or member ID, telephone number, customer number, or another code; relationship with the partner and the plan granted. | Sponsoring Organization. |
| Authentication and session | Temporary verification codes, tokens and session records, creation and expiration dates, application version, and history of acceptance of legal documents. | Data Subject and NextFin systems. |
| Communications | Destination address, subject and type of message, delivery status, delay, failure, bounce or spam complaint, and identifier assigned by the provider. | Data Subject, NextFin, and communications providers. |
| Learning journey | Courses, learning paths, lessons, articles, and documents started or completed; start, last access, and completion dates; completed units; video or audio position; and progress history. | Use of NextFin. |
| Questionnaires and quizzes | Answers submitted for grading during an attempt, number of correct answers, best score, passing status, and completion date. | Use of NextFin. |
| Library and reading | Books licensed or delivered, source of the license, confirmations or exchanges, favorites, percentage read, page, EPUB position or audiobook timestamp, and start and completion dates. | Use of NextFin, purchase, or sponsored program. |
| Gamification | Aggregated learning journey metrics, such as lessons, courses, articles, quizzes, or books completed, as well as points, badges, goals, and achievements. | Use of NextFin. |
| Certificates | Name recorded on the issue date, course or learning path completed, certificate code and identifier, issue date, validity status, and any reason for revocation. | Use of NextFin and academic records. |
| Subscriptions and transactions | Plan, channel and store where purchased, provider and subscription identifiers, product, status, validity periods, renewal, cancellation, suspension, amounts, currency, taxes, fees, and refunds. | NextFin, Sponsoring Organization, app store, or payment provider. |
| Support and contact | Message subject and content, name, email address, organization, language, application version, support status, and additional information freely provided by the Data Subject. | Data Subject. |
| Technical and security data | IP address and network information that may be recorded by the infrastructure, date and time, route accessed, server response, device type and version, operating system, application version, failures, diagnostics, performance, and internal user identifier in error events. | Device, browser, application, and infrastructure. |
| Local preferences | Language, choice regarding measurement technologies, session state, and other preferences stored in the browser or on the device. | Data Subject’s device. |
| Data Subject requests | Request content, identity verification method, measures taken, date, person responsible for handling the request, and record of data exports. | Data Subject and NextFin team. |
4.1. NextFin does not request the full credit card number, security code, or banking credentials. For web payments, this data is entered directly in the payment provider’s environment. For purchases made through the application, processing is performed by the relevant app store.
4.2. NextFin does not seek to collect sensitive personal data. Data Subjects should avoid including sensitive or unnecessary information in free-text fields, such as support messages. If such information is voluntarily provided, it will be processed only to the extent necessary to respond to the request, comply with a legal obligation, or exercise rights.
5. Questionnaires, scores, and educational recommendations
5.1. Answers selected in quizzes are transmitted to the server for grading and immediate generation of the result. Under the platform’s current configuration, the individual choices for each question are not retained as a permanent history; the highest number of correct answers, passing status, and completion of the activity are recorded.
5.2. NextFin may use browsing and learning history, preferences, progress metrics, and achievements to organize the learning journey, recommend courses, learning paths, articles, or books, and provide gamification features.
5.3. These recommendations are exclusively educational. They do not constitute a recommendation concerning an investment or financial product, nor do they constitute an automated decision capable of producing legal effects or similarly significant effects on the Data Subject.
5.4. If a future feature begins to retain individual answers, use new data, or produce significant effects, this Policy and, where necessary, the product interface will be updated before such processing begins.
6. Purposes and legal bases
We process personal data only when there is a legitimate purpose and an applicable legal basis. The main processing activities are:
| Purpose | Data normally involved | Predominant legal basis |
|---|---|---|
| Create, activate, and manage the account | Identification, contact, verification, and session data. | Performance of a contract and preliminary procedures relating to a contract. |
| Authenticate the Data Subject and protect access | Telephone number or email address, temporary codes, tokens, sessions, and technical records. | Performance of a contract and legitimate interest in preventing unauthorized access and fraud. |
| Deliver courses, articles, books, and other benefits | Account, subscription, licenses, library, and usage data. | Performance of a contract. |
| Record progress, grade quizzes, personalize the journey, and operate gamification | Learning journey, scores, metrics, and preferences. | Performance of a contract and legitimate interest in providing and improving the educational experience. |
| Issue certificates and enable their verification | Name, completion, course, code, date, and certificate status. | Performance of a contract and legitimate interest in demonstrating the authenticity of the credential. |
| Process subscriptions, payments, cancellations, and refunds | Registration, subscription and transaction data, and provider identifiers. | Performance of a contract, compliance with a legal or regulatory obligation, and the regular exercise of rights. |
| Administer sponsored programs and benefits | Identification, relationship, external identifiers, plan, licenses, and benefit status. | Performance of a contract, preliminary procedures, and legitimate interest, depending on the applicable relationship. |
| Provide support and respond to requests | Registration data, message, related history, and technical data. | Performance of a contract, legitimate interest, and the regular exercise of rights. |
| Send operational communications | Telephone number or email address, name, language, and data relating to the relevant operation. | Performance of a contract and legitimate interest in communicating events necessary for the service. |
| Send updates and promotional communications | Name, email address or telephone number, and communication preferences. | Consent, where required, which may be withdrawn at any time. |
| Measure operation, prevent fraud, and maintain security | Technical data, logs, identifiers, failures, and security events. | Legitimate interest, compliance with a legal obligation, and the regular exercise of rights. |
| Comply with the law and respond to competent authorities | Data related to the applicable obligation or request. | Compliance with a legal or regulatory obligation and the regular exercise of rights. |
| Produce statistics and improve products | Aggregated, anonymized or, when necessary, pseudonymized usage data. | Legitimate interest and, where the data cannot reasonably identify a person, outside the scope of the LGPD. |
6.1. When processing is based on legitimate interest, we will consider the purpose, necessity, the Data Subject’s expectations, and the risks to their rights and freedoms.
6.2. When consent is the applicable legal basis, it may be withdrawn through the channels indicated in this Policy, without affecting the lawfulness of processing carried out before withdrawal.
7. Pre-registered Accounts and sponsored programs
7.1. A Sponsoring Organization may provide data so that NextFin can create a Pre-registered Account and grant a subscription or benefit before the Data Subject’s first access.
7.2. The record may contain a name, telephone number, email address, and an external identifier defined by the organization, including a CPF number, employee or member ID, customer number, or another code. The Data Subject will only receive access credentials after completing the authentication process made available by NextFin.
7.3. If the benefit includes books or other library items, the corresponding licenses may be linked to the Pre-registered Account immediately. When the Data Subject activates access, items previously delivered will appear in their library.
7.4. The Sponsoring Organization may decide to grant, suspend, change, or terminate the benefit in accordance with the program rules. To administer this relationship, NextFin may provide the organization with identification data, the external reference, plan, subscription status, relevant dates, and a history of operations requested by it.
7.5. Under the configuration currently implemented, the partner integration interface does not provide the user’s learning progress or answers. If a program begins to include usage reports or dashboards, identified or aggregated metrics may be shared, such as activation, access frequency, content started or completed, scores, certificates, and other indicators described in the program notice.
7.6. Sharing individual answers, data that reveals sensitive information, or metrics capable of having a significant impact on the Data Subject will require prominent prior notice, access limitations, a compatible purpose, and an appropriate legal basis.
7.7. The Data Subject may request information about the source of the pre-registration and the Sponsoring Organization linked to their account through the channels described in this Policy.
8. Who we share data with
We do not sell personal data. Data is shared only when necessary for the purposes described in this Policy.
| Recipient or category | Data shared | Purpose and notes |
|---|---|---|
| Sponsoring Organizations and business partners | Registration data, external identifier, relationship with the program, subscription, licenses, and operations performed; usage metrics, when enabled for the relevant program. | Create accounts, grant and administer benefits, match users and subscriptions, and produce reports provided for by the program. |
| Vercel | Requests, technical data, pages, and information processed by the hosted applications. | Hosting and operation of the website, portals, and API. |
| Neon and PostgreSQL database providers | Data stored in NextFin databases. | Database hosting, availability, backup, and operation. |
| Amazon Web Services and S3-compatible providers | Files and media objects; telephone number and operational message content when Amazon SNS is used. | Storage and delivery of images, documents, audio, and video; sending codes by SMS. |
| Twilio, when configured as the SMS provider | Telephone number, message content, identifiers, and delivery status. | Sending authentication codes and transactional messages. |
| Resend | Name, email address, message content, language, identifiers, and delivery, bounce, or complaint events. | Sending and tracking registration, access, and welcome emails. |
| Stripe | Internal user identifier, email address when available, plan, price, subscription identifiers, and data required for checkout. | Hosted checkout, web subscription billing, cancellations, and refunds. Full card details are collected directly by Stripe. |
| RevenueCat | Internal user identifier, product, subscription, store, transactions, status, and purchase events. | Management and validation of subscriptions purchased through app stores. |
| Apple App Store and Google Play | Data defined and collected by the app stores themselves, as well as purchase information required for the subscription. | Application distribution, purchase processing, and mobile subscription management. These companies may also act as independent Controllers. |
| Sentry | Internal user identifier, exceptions, diagnostics, performance, application version, environment, and navigation trail related to the failure. | Detection, investigation, and correction of application failures. NextFin configures the service not to automatically attach a name, telephone number, or email address. |
| Upstash/QStash | Technical identifiers and the minimum data required for queued tasks. | Running subscription, renewal, and benefit delivery routines. |
| Vercel Analytics | Technical events and browsing metrics in a format designed for aggregated measurement. | Measuring website usage and performance. Under the current configuration, the tool is used without advertising cookies. |
| Channel configured for the institutional contact form | Name, email address, organization, message, and contact date. | Delivering the request submitted through the public form to the responsible team. |
| Advisors, auditors, and professional service providers | Data strictly necessary for the contracted service. | Legal and accounting advice, auditing, security, fraud prevention, and defense of rights. |
| Public authorities and authorized third parties | Data covered by a valid obligation, order, or request. | Compliance with the law, a court order, or a request from a competent authority; protection of rights and security; and prevention of unlawful acts. |
8.1. Some providers are optional or replaceable and receive data only when the corresponding feature is enabled. NextFin may replace service providers, provided that an appropriate level of protection is maintained and this Policy is updated when the change is relevant to the Data Subject.
8.2. Partners responsible for books and other content do not automatically receive users’ reading data. Any sharing for licensing, fraud prevention, or compliance with a contractual obligation will be limited to what is necessary and disclosed when it may affect the Data Subject’s expectations.
9. Certificates and public information
9.1. Certificates issued by NextFin have an identifier and a public verification page. While the certificate remains active, anyone with access to the relevant link or code may view data such as the Data Subject’s name, credential obtained, course or learning path, issue date, issuer, and validity status.
9.2. If the certificate is revoked, the page may continue to state that it is invalid, so that a revoked credential is not mistaken for a valid authentic credential.
9.3. When the account is deleted, certificates will be marked inactive and will no longer appear on the public verification page. The historical issuance record, including the name recorded on the issue date, may be retained internally for integrity, audit, fraud prevention, and the regular exercise of rights.
10. Technologies on the website and in the application
10.1. NextFin uses local storage technologies and equivalent mechanisms to maintain the session, remember the language, record preferences, and enable the platform to operate.
| Technology | Purpose | Data Subject control |
|---|---|---|
| Local session storage | Keep the user signed in on the website or application and retain essential account information on the device. | Sign out or clear application/browser data. |
| Language preference | Display the interface in the selected language. | Change it in the settings or browser. |
| Privacy choice record | Remember the choice presented in the measurement technology notice. | Change the choice when the control is available or clear website data. |
| Aggregated website measurement | Understand usage and performance through Vercel Analytics. | As permitted by the technical controls offered by the browser and platform. |
| Application diagnostics | Identify failures and measure performance through Sentry. | May vary depending on the operating system and device settings. |
| Local notifications | Display reminders and achievements scheduled on the device itself. | Revoke permission in the operating system settings. |
10.2. Under the configuration currently identified, NextFin does not use third-party behavioral advertising cookies.
10.3. Browsers, operating systems, and app stores may provide their own controls. Blocking strictly necessary technologies may prevent parts of the platform from working.
11. International data transfers
11.1. Some service providers identified in this Policy operate infrastructure or teams in other countries. Personal data may therefore be stored, processed, or accessed outside Brazil.
11.2. International transfers will be carried out for legitimate purposes and using a valid mechanism provided for under the LGPD and the regulations of Brazil’s National Data Protection Authority (ANPD), such as standard contractual clauses, an adequacy decision, or another applicable legal basis.
11.3. We seek to limit transfers to the minimum necessary and require recipients to implement security, confidentiality, and protection measures compatible with the nature of the data and the risks involved.
12. Data retention
Data is retained for as long as necessary for the stated purposes and may remain for an additional period to comply with legal obligations, conduct audits, prevent fraud, resolve disputes, and regularly exercise rights.
| Category | Retention criterion |
|---|---|
| Authentication codes | Have a short operational validity period, currently 10 minutes. Technical records may remain for an additional period for security, auditing, and abuse prevention. |
| User sessions | Remain while valid or until sign-out, revocation, or account deletion, without prejudice to technical records required for security. |
| Account and profile | For the duration of the relationship with the Data Subject. After deletion, direct registration identifiers are removed or replaced, except for records that must be preserved. |
| Progress, library, metrics, and achievements | While necessary to provide the service and maintain the user’s history; after deletion, they may be retained in pseudonymized or aggregated form for operational, contractual, and statistical records. |
| Permanent book licenses | For as long as necessary to evidence and provide the access right, including after the subscription ends, subject to the offer terms and legal obligations. |
| Certificates | For the period necessary to evidence issuance, preserve record integrity, prevent fraud, and regularly exercise rights. After account deletion, they are no longer publicly displayed. |
| Subscriptions, payments, and provider events | For as long as necessary to perform the transaction and, afterward, for the applicable legal, tax, accounting, regulatory, and defense-of-rights periods. |
| Acceptance of legal documents | For as long as necessary to demonstrate the version accepted, date, language, source of acceptance, and compliance with applicable obligations. |
| Support, contact, and Data Subject requests | For as long as necessary to provide assistance and, afterward, for a period compatible with auditing, fraud prevention, and the regular exercise of rights. |
| Logs, diagnostics, and security events | For the shortest period compatible with security, incident investigation, availability, and defense of rights, considering the retention periods of the providers involved. |
12.1. The end of a subscription does not result in account deletion or automatic data deletion. Likewise, account deletion does not delete records that must be preserved to comply with a legal obligation or for the regular exercise of rights.
12.2. Data that has been effectively anonymized, with no reasonable possibility of association with a person, may be retained and used for statistical, research, security, and product improvement purposes.
13. Data Subject rights
Under applicable law, the Data Subject may request:
| Right | What it means |
|---|---|
| Confirmation and access | Confirm whether we process their data and obtain access to the corresponding information. |
| Correction | Update incomplete, inaccurate, or outdated data. |
| Anonymization, blocking, or deletion | Request measures regarding data that is unnecessary, excessive, or processed in violation of the law. |
| Portability | Request data portability, subject to applicable regulations, commercial and industrial secrets, and technical feasibility. |
| Information about sharing | Learn which public and private entities have received shared use of the data. |
| Information and withdrawal of consent | Learn the consequences of refusal and withdraw consent when it is the legal basis for processing. |
| Objection | Object to processing based on a legal basis other than consent when the LGPD has been violated. |
| Review of automated decisions | Request information and review in the cases provided for by law. |
| Right to petition | Lodge a complaint with Brazil’s National Data Protection Authority or consumer protection agencies, as applicable. |
13.1. The application and website provide a function to export account data in a structured format. To use it, access My Account or Settings, select the export option, and follow the instructions displayed.
13.2. Rights may also be exercised by emailing contato@next-hub.ai. To protect the Data Subject, we may request reasonable information to confirm identity and prevent data from being delivered, changed, or deleted at the request of unauthorized third parties.
13.3. A request may be granted in full or in part, or it may be denied with reasons, where there is a legal obligation to retain data, a need to preserve the rights of the Company or third parties, a security risk, a commercial or industrial secret, or another circumstance authorized by law.
14. Account deletion
14.1. The Data Subject may request deletion directly through NextFin:
a) access My Account, Profile, or Settings;
b) select Delete account and data;
c) read the consequences presented and check the confirmation box; and
d) select Delete my account.
14.2. Deletion may also be requested by emailing contato@next-hub.ai if the Data Subject is unable to access the account.
14.3. Once deletion is confirmed:
a) the account is closed and active sessions are invalidated;
b) the name, email address, and telephone number in the registration are removed or replaced with values that no longer directly identify the Data Subject;
c) the choice to receive updates is disabled;
d) certificates are marked inactive and no longer appear on the public verification page; and
e) progress, license, subscription, transaction, acceptance, support, certificate, and audit records may be retained, in pseudonymized form where possible, for the periods required for the purposes set out in Section 12.
14.4. Account deletion does not automatically cancel outstanding obligations with app stores, payment providers, or Sponsoring Organizations. The Data Subject must follow the cancellation process applicable to the relevant subscription.
14.5. Data retained in backups will be deleted or overwritten according to the systems’ secure retention cycle and will remain protected and unavailable for ordinary use while in that state.
15. Children and adolescents
15.1. NextFin is intended for persons 18 years of age or older and does not knowingly seek to collect data from children or adolescents.
15.2. A contractual age declaration alone does not replace the technical and organizational measures required by law. NextFin may use age signals provided by app stores or operating systems and implement proportionate age-assurance mechanisms, preferably minimizing data and avoiding document collection where a reliable and less intrusive alternative is available.
15.3. If we identify that an account belongs to a child or adolescent in violation of the service rules or applicable law, we may restrict access, request strictly necessary additional information, delete data, or take other measures appropriate to protect the Data Subject.
15.4. Parents, legal guardians, or Data Subjects may report such a situation by emailing contato@next-hub.ai.
16. Information security
16.1. We implement technical, administrative, and organizational measures designed to protect personal data against unauthorized access, destruction, loss, alteration, communication, or improper disclosure. Depending on the context, these measures include access controls, segregation between environments and organizations, authentication, session management, webhook signature verification, audit records, failure monitoring, and backup routines.
16.2. No system is completely secure. Data Subjects must also protect the device, email account, telephone number, and authentication codes used to access the account and must immediately report any suspected misuse.
16.3. Security incidents involving personal data will be assessed and, where required by law, reported to Brazil’s National Data Protection Authority and the affected Data Subjects.
17. Artificial intelligence
17.1. Some NextFin educational materials may be produced or reviewed with the assistance of artificial intelligence. Under the platform configuration currently identified, users’ registration data, progress, or answers are not sent to an artificial intelligence provider to generate such content.
17.2. If NextFin begins to use personal data in interactive artificial intelligence features, the processing will be preceded by an assessment of purpose, necessity, security, and legal basis, and this Policy will be updated or a specific notice will be presented where necessary.
18. Changes to this Policy
18.1. This Policy may be updated to reflect legal, regulatory, technological, commercial, or operational changes.
18.2. The current version and last updated date will remain available on NextFin. When a change is relevant to the Data Subject’s rights or expectations, we may provide a prominent notice and, where necessary, request a new indication of agreement.
19. Contact
For questions, requests, or the exercise of rights relating to privacy and personal data protection, please contact:
OFERTA FÁCIL LTDA.
CNPJ: 64.347.474/0001-97
Rua Teixeira Mendes, No. 153, Apt. 102
Laranjeiras — Rio de Janeiro/RJ
ZIP Code: 22245-090
Email: contato@next-hub.ai
The channel above receives Data Subject requests and communications addressed to the person responsible for privacy and data protection at the Company.