1. Who We Are

Trampay Ltda. ("the Company," "we," "us," or "our"), with offices at Av. Brigadeiro Faria Lima, 3477, 14 andar, Sao Paulo, SP 04538-133, Brasil, operates gettrampay.com and the Trampay mobile application (together, the "Service"). Trampay is an AI-powered income forecasting and alternative credit-building platform for gig delivery workers in Brazil. We connect to delivery platforms such as iFood, Rappi, Uber Eats, and 99Entregas via read-only API access to read your delivery and earnings history. We do not store your platform login credentials.

Questions about this policy or requests to exercise your rights under Brazil's Lei Geral de Protecao de Dados (LGPD) may be directed to: [email protected] or +55 11 3521 4400.

2. What Data We Collect and Why

Trampay collects the minimum data necessary to deliver income forecasting, shift optimization, and credit-profile building for gig couriers. We are not a bank or lender. Credit decisions are made by partner financial institutions, not by us.

2.1 Account and Identity Data

When you register, we collect your name, email address, and optionally your phone number. This data is used to create and maintain your account, send you income alerts and shift reminders via WhatsApp or email, and enable you to access your forecast and credit profile.

2.2 Delivery Platform Earnings Data

After you authorize a connection, Trampay reads from the APIs of your chosen delivery platforms (iFood, Rappi, Uber Eats, 99Entregas) the following data about your work history: delivery completion records, per-delivery earnings and tips, active hours per shift, and platform-specific performance indicators. This data is read via read-only API access only. We never request, store, or process your platform username or password. We use this earnings history to compute your income forecast, identify the highest-earning shifts available to you, and build the credit profile we report to partner financial institutions you choose to engage through the Trampay marketplace.

2.3 Credit Profile Data

From your accumulated delivery earnings history, the Company derives an alternative credit profile that captures earnings consistency, income trajectory, and platform reliability. This profile is shared only with partner lenders that you specifically choose to engage with through the Trampay loan marketplace. Credit decisions are made by those partner financial institutions. Trampay is not a bank or lender and does not make credit decisions.

2.4 Technical and Usage Data

We collect standard technical data automatically when you use the Service: IP address, browser or app version, device type, pages visited, and session duration. This data is used to operate and improve the Service and to detect security threats. Analytics data is collected in anonymized or pseudonymized form.

2.5 Communications

If you contact us by email, phone, or in-app message, we retain the content of that communication to respond to your inquiry and to improve support quality.

3. Legal Basis for Processing (LGPD)

The Company is subject to Brazil's Lei Geral de Protecao de Dados (LGPD - Lei n. 13.709/2018). We process your personal data under the following legal bases set out in Articles 7 and 11 of the LGPD:

  • Your consent (Art. 7, I): Connecting your delivery platform account is an explicit, informed consent action. You may revoke this connection at any time inside the app.
  • Contract performance (Art. 7, V): Processing account data and earnings history is necessary to deliver the income forecast, shift optimizer, and credit profile you signed up for.
  • Legitimate interest (Art. 7, IX): Technical and usage data is processed to ensure security and improve service quality, where such interests do not override your fundamental rights.

4. How We Use Your Data

We use the data described above exclusively for these purposes:

  • Generating your 7- or 14-day income forecast;
  • Identifying and ranking the highest-earning shifts available on your connected platforms;
  • Building and updating your alternative credit profile for submission to partner lenders you choose;
  • Sending you WhatsApp alerts and email reminders you have opted into;
  • Operating, securing, and improving the Service;
  • Responding to your support inquiries;
  • Meeting legal and regulatory obligations under Brazilian law.

We do not sell your personal data to third parties. We do not use your delivery history or personal data to train machine learning models for any purpose outside of delivering the Service features described above.

5. Sharing Your Data

We share your data only in the following circumstances:

  • Partner lenders: When you actively choose to apply for a loan through the Trampay marketplace, the Company shares the credit profile built from your earnings data with the lender you selected. You will be informed of exactly what is shared before the submission occurs.
  • Service providers: We engage cloud hosting, analytics, and communications providers who process data on our behalf under written data processing agreements that restrict their use of your data to the performance of services for the Company.
  • Legal obligations: We may disclose data to Brazilian authorities, courts, or regulators where required by law or a binding legal order.

We do not share your delivery earnings data with advertisers, data brokers, or other commercial third parties.

6. Data Retention

We retain your account and earnings data for as long as your account is active. If you request deletion of your account, the Company deletes your personal data within 30 days, except where we are required to retain it for a longer period under Brazilian financial regulations or a legal obligation. Anonymized or aggregated statistical data derived from your usage may be retained for internal analysis after deletion of your identifiable data.

7. Security

The Company applies administrative, technical, and physical safeguards designed to protect your personal data from unauthorized access, loss, or disclosure. Platform connections use read-only API tokens that are encrypted at rest. We do not store platform passwords under any circumstances. Our systems are designed with LGPD data-minimization principles in mind. No internet transmission is completely secure; we encourage you to use a strong, unique password for your Trampay account.

8. Your Rights Under the LGPD

As a data subject under Brazil's Lei Geral de Protecao de Dados (LGPD - Lei n. 13.709/2018), you have the following rights with respect to your personal data held by the Company:

  • Access (Art. 18, I): You may request a copy of the personal data we hold about you;
  • Correction (Art. 18, III): You may request correction of incomplete, inaccurate, or outdated data;
  • Anonymization or deletion (Art. 18, IV): You may request that unnecessary or excessive data be anonymized, blocked, or deleted;
  • Portability (Art. 18, V): You may request a structured, machine-readable export of your personal data for transfer to another service provider;
  • Deletion of consented data (Art. 18, VI): You may request deletion of personal data processed on the basis of your consent;
  • Information about sharing (Art. 18, VII): You may request information about public and private entities with which we have shared your data;
  • Revoke consent (Art. 18, IX): You may revoke consent to data processing at any time. Revoking consent to the delivery platform connection will end income forecasting and credit-profile building for that platform, but will not affect data already processed;
  • Review of automated decisions (Art. 20): You may request human review of decisions made solely on the basis of automated processing of your data, including credit-profile scores.

To exercise any of these rights, email [email protected] with the subject line "LGPD Data Request" or call +55 11 3521 4400. The Company will acknowledge your request within 15 days and respond substantively within 30 days, consistent with LGPD requirements. You may also file a complaint with Brazil's Autoridade Nacional de Protecao de Dados (ANPD) at gov.br/anpd.

9. Cookies and Tracking Technologies

We use cookies and similar technologies to operate the Service and measure usage. See our Cookie Notice for full details.

10. International Data Transfers

Your data is stored and processed primarily in Brazil. If any data is transferred to service providers outside Brazil, the Company ensures that such transfers meet the requirements of LGPD Chapter V (International Data Transfers), including use of standard contractual clauses or adequacy decisions where applicable.

11. Children's Privacy

The Service is intended for adults who work as gig delivery couriers. We do not knowingly collect personal data from persons under the age of 18. If you believe a minor has submitted data to us, please contact [email protected] so we can delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or applicable law. Material changes will be communicated by updating the "Last updated" date at the top of this page and, where appropriate, by email or in-app notification. Continued use of the Service after a material change constitutes your acceptance of the updated policy.

13. Contact

Trampay Ltda.
Av. Brigadeiro Faria Lima, 3477, 14 andar
Sao Paulo, SP 04538-133, Brasil
Email: [email protected]
Phone: +55 11 3521 4400