Privacy policy

Last updated: November 1, 2026.

1. Who we are

Memberfy is a platform to build and run communities: spaces, content, courses, events, messaging, payments and team tools. It is operated by:

• Memberfy, Inc., a Delaware C Corporation, United States, Delaware file number 10796969; and
• LUMA VENTURES LTDA - ME, CNPJ 21.951.820/0001-39, Brazil.

Customers outside Brazil contract with Memberfy, Inc.; customers in Brazil contract with LUMA VENTURES LTDA. "Memberfy", "we" and "our" mean both companies, each for its own part. This policy complements the Terms of use.

2. Two roles: controller and processor

As a processor, Memberfy processes personal data only on the community's documented instructions and under the Data Processing Agreement. Requests about that data should go to the community first; if they reach us, we forward them and help the community respond.

Memberfy remains a controller, even inside a community, for what the platform needs to run securely: authentication, fraud and abuse prevention, security logs, legal obligations and the collection of the platform fee.

3. Data we process

What is actually collected depends on the modules each community turns on.

Account and profile. Name, email, password (stored only as a hash), phone, photo, display name, bio, country, languages, job title, company, links, experience and any registration fields the community creates. Each person chooses what their member page shows, within what the community allows. Accounts are per community: joining two communities means two separate registrations.

Payments. To buy: name, email, tax ID, phone and, when the product ships, address. Memberfy does not store card numbers: the card is entered and tokenized at the payment provider; we keep only the brand, the last four digits and the provider reference. We also keep purchase, subscription, refund and coupon history (with the IP used to redeem a coupon, to prevent fraud).

Community payouts (KYC). For a community to receive payments, we collect from its administrators what the payment provider and regulation require: legal name, tax ID, date of birth, address, phone, bank details and business partners.

Content. Posts, comments, reactions, courses, lessons, events, files, images, videos, form and survey answers, proposals, listings and anything you publish.

Messages. Private conversations are visible only to the two participants. The community team has no access to their content through any screen, API or AI assistant. Available to chat shows other members when you are online; you can turn it off anytime.

Attendance, time clock and work (when the community uses these modules).

• Time clock: date and time of each punch, Brazilian CPF, IP, browser, origin and, when the community sets an allowed area, the device location at the moment of the punch (latitude, longitude, accuracy). Location is requested only when punching, never continuously.
• Attendance and visitors: check-in and check-out, visitor name and company, and parcel records.
• Performance reviews, 1:1s, development plans and feedback: the reviews, notes and agreements you and your coworkers record, visible under each module's rules.

Photo location. When you upload an image, Memberfy re-encodes it and removes EXIF metadata, including GPS location, before storing it.

Usage and security. IP address (for security, rate limiting and country lookup; analytics keep only the country, not the IP), browser, operating system, device type, pages visited, referrer and campaign parameters, and audit logs of team actions in the community. Raw browsing events are deleted after 30 days; only daily totals remain.

Communications. Emails we send on behalf of the community and the platform, with delivery, open, bounce and spam-complaint records; your email preferences per category; your verified phone number and your consent to SMS or WhatsApp (with date and IP of consent); and, if you enable browser or mobile notifications, the delivery endpoint, keys and a device label.

Artificial intelligence. When you use AI features (such as Improve with AI or Drops captions), the text, instruction or audio is sent to an AI provider only to produce the suggestion. Memberfy does not keep that content; it records only the usage (who, which community, when). If you connect an AI assistant to your account through MCP, it acts with your permissions, and Memberfy logs its actions for auditing.

Abandoned checkout. When a signed-in member opens checkout for a paid product and does not buy, we keep name, email, phone, product, amount and dates so the team can see it and, if the community enables it, send one recovery email. Deleted after 90 days or when the person leaves the community.

Sensitive data and children. Memberfy does not ask for sensitive data (health, religion, biometrics, etc.) and does not use facial recognition. Communities may create their own fields or forms and are responsible for having a legal basis for what they ask.

4. Purposes and legal bases (GDPR art. 6 / LGPD art. 7)

Memberfy does not sell personal data and does not use it for third-party advertising.

5. Sharing

• The community you belong to. The team sees what each module shows it (registration, purchases, sign-ups, attendance, time clock, answers), never your private messages.
• Other members. They see what you publish and what you choose to show on your profile.
• Service providers (sub-processors). Only what each service needs:

The current list, naming each sub-processor, is in Annex 3 of the Data Processing Agreement.

• Integrations chosen by the community. Webhooks, the community's own Google Analytics, its own AI keys in automations and other integrations receive the data the community configured, at the community's choice and responsibility.
• Authorities, when required by law or a valid order.
• Corporate transactions (merger, acquisition), with the same safeguards as this policy.

6. International transfers

Memberfy operates in Brazil and the United States, and the providers above may process data in other countries. Data is hosted mainly in the United States. Transfers out of the EEA, UK or Brazil rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses, the UK Addendum, the EU-US Data Privacy Framework where the recipient is certified, and the ANPD standard clauses.

7. Retention

We keep data while the account exists and while needed for its purpose, then for as long as the law requires.

When you leave a community (or the team removes you), your registration there is deactivated and hidden, and the following are actually deleted: your certificates, your identified survey answers, your push subscriptions and abandoned checkouts; your messaging sessions are closed. The rest of the registration and content is kept, inactive, for legal periods and the integrity of the community's records (such as purchases and payments). Requests to erase the rest are handled through the email in section 9.

8. Cookies and device storage

The app uses the browser's local storage, not advertising cookies:

• Essential: the session token (to keep you signed in), the open community and interface preferences such as light or dark theme and a collapsed menu.
• Platform statistics: a session identifier kept only while the tab is open (removed when you close it or sign out).
• Third parties, at the community's choice: if a community sets up its own Google Analytics, Google may set its cookies; the community is responsible for that.

You can clear this storage in your browser; you will be signed out and lose your preferences.

9. Your rights

Under the GDPR (arts. 15 to 22) and the LGPD (art. 18) you may request access, rectification, erasure, restriction, portability, objection to processing based on legitimate interests, information about who we share data with, review of automated decisions, and withdraw consent where consent is the basis.

Much of this you can do yourself in the app: edit your profile, choose what it shows, turn off chat availability, change email preferences, remove notification devices and leave a community.

For anything else, write to [email protected]. We reply within one month (GDPR) or 15 days (LGPD). If the request concerns data a community controls, we forward it to that community. You may also lodge a complaint with your local data protection authority in the EU/EEA, the UK ICO, or Brazil's ANPD.

10. Data protection officer and EU representative

Data protection officer: David Ruiz, [email protected].

11. Security

We apply technical and organizational measures appropriate to the risk: encrypted connections, hashed passwords, role-based access in each community, separation of each community's data, audit logs of team actions, security review before each release and certified payment providers for card data. No system is infallible; if an incident creates a relevant risk, we notify affected people, communities and authorities within the legal deadlines.

12. Changes

We may update this policy. The date is at the top; material changes are announced by email or in the app before they take effect.

13. Contact

Privacy: [email protected] · Abuse reports: [email protected].