Free21 mobile application

Privacy Policy

This Privacy Policy explains how Free21 collects, uses, stores, and protects information when you use our mobile application, website, and related services.

Effective August 30, 2026Last updated August 30, 2026
Who is responsible for your data

Free21 is operated by PAC EDUCAÇÃO E TREINAMENTOS LTDA, a company registered in Brazil under CNPJ 52.631.716/0001-90. In this policy, “Free21,” “we,” “us,” and “our” refer to this company.

1. Information we collect

The information we collect depends on the features you use and the permissions you grant. It may include:

  • Account information: name, email address, profile details, authentication data, and account preferences.
  • Habit and progress information: habits you select, goals, streaks, check-ins, progress, time or money estimates, and other information you choose to record.
  • User content: content you submit through community, feedback, support, or other interactive features.
  • Device and usage information: device type, operating system, app version, language, approximate region, identifiers, diagnostics, crash data, and interactions with the service.
  • Purchase information: subscription status and transaction identifiers. Payments are processed by Apple App Store or Google Play; we do not receive your full payment card number.
  • Communications: messages and information you send when contacting support or exercising a privacy right.

Some habit information may reveal sensitive personal details. We use it only to provide the features you request and as otherwise described in this policy. Free21 is a wellness and habit-support tool and is not a substitute for medical care.

2. How we use information

We use information to:

  • create and manage your account;
  • provide habit tracking, progress, community, gamification, audio, and subscription features;
  • personalize your experience and remember your preferences;
  • process and verify subscriptions and purchases;
  • maintain security, prevent fraud, troubleshoot, and improve performance;
  • respond to support requests and service communications;
  • comply with legal obligations and enforce our terms.

3. How we share information

We do not sell your personal information. We may share limited information with service providers that help us operate Free21, such as hosting, analytics, authentication, customer support, communications, crash reporting, and payment-platform providers. These providers may process information only for the services they perform for us and under appropriate safeguards.

We may also disclose information when required by law, to protect users or the service, in connection with a corporate transaction, or with your direction or consent. Information you intentionally post in a community area may be visible to other users according to the feature's settings.

4. Data retention

We retain personal information only for as long as needed to provide the service, maintain legitimate business and security records, resolve disputes, and meet legal requirements. Retention periods vary by the type of information and purpose. When data is no longer required, we delete or anonymize it, subject to lawful backup and recordkeeping periods.

5. Your choices and privacy rights

Depending on where you live, you may have the right to access, correct, delete, or receive a copy of your personal information; object to or restrict certain processing; withdraw consent; and appeal a privacy decision. You may also control device permissions through your device settings.

Delete your account or data

Send a request from the email associated with your Free21 account. We may need to verify your identity before completing the request.

Request deletion

6. Children's privacy

Free21 is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided us with personal information, contact us so we can investigate and delete it as appropriate. Additional age restrictions may apply depending on local law.

7. Security

We use reasonable administrative, technical, and organizational measures designed to protect personal information. No method of storage or transmission is completely secure, so we cannot guarantee absolute security.

8. International data transfers

Free21 may use service providers in countries other than your own, including Brazil and the United States. When required, we use appropriate legal safeguards for international transfers of personal information.

9. Changes to this policy

We may update this Privacy Policy as Free21 evolves or legal requirements change. We will publish the revised version here and update the date above. When required, we will provide additional notice through the app or another appropriate channel.

Privacy contact

10. Contact us

For privacy questions, data requests, or complaints, contact:

PAC EDUCAÇÃO E TREINAMENTOS LTDA
CNPJ 52.631.716/0001-90
Rua 9, nº 2109, Andar 3, Sala 301, Edifício Marista Center Mall
Setor Marista, Goiânia, GO, 74150-130, Brazil
lucas@free21app.com.br