simplic.com.br — 45/100 (High privacy risk)

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Simplic (LH1010 SERVIÇOS DE CORRESPONDENTE BANCÁRIO LTDA. and LH1003 SERVIÇOS DE DADOS LTDA.) · simplic.com.br

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High privacy risk

Simplic’s privacy policy is highly invasive for EU users, collecting excessive personal and financial data, sharing it broadly with third parties (including outside Brazil), and lacking GDPR-specific safeguards or opt-outs for AI/model training.

Simplic, a Brazilian financial services platform acting as a banking correspondent, collects extensive personal, financial, and professional data (e.g., CPF, RG, bank details, income, social media data, document copies) for credit intermediation, marketing, and fraud prevention. Data is shared widely with financial partners, credit bureaus (e.g., Serasa, Boa Vista), payment operators, insurers, and even investors or potential buyers, including cross-border transfers. The policy is governed by Brazil’s LGPD, not GDPR, and lacks explicit EU-specific protections (e.g., Standard Contractual Clauses, adequacy decisions) for international transfers. User rights under LGPD are listed, but GDPR rights (e.g., right to object, data portability) are not explicitly addressed for EU users. There is no mention of AI/model training opt-outs, and data retention is vague beyond ‘necessary for purposes.’ The policy is transparent about data uses but fails to meet EU privacy standards for non-Brazilian users.

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Category Assessment

Breakdown of the policy across key compliance areas. Good = strong, fair = mixed, poor = concerning.

Data MinimizationPoor

Collects excessive data (e.g., CPF, RG, bank details, social media data, document copies) far beyond what is necessary for basic services, with no clear justification for all categories under GDPR principles.

TransparencyFair

The policy is detailed about data categories and purposes but is Brazil-centric (LGPD) and lacks clarity on GDPR-specific rights, safeguards, or EU user protections.

Third-party SharingPoor

Data is shared with a vast array of third parties (financial partners, credit bureaus, insurers, investors, payment operators, etc.), including cross-border transfers, with no granular controls or opt-outs for users.

International TransfersPoor

Acknowledges potential transfers outside Brazil but provides no GDPR-compliant mechanisms (e.g., SCCs) or details on safeguards for EU users.

AI/Model TrainingPoor

No explicit mention of AI/model training, but data is used for profiling (credit scoring) and marketing. No opt-out mechanism is provided for such uses.

User RightsFair

Lists LGPD rights (access, correction, deletion, etc.) but does not explicitly address GDPR rights (e.g., right to object, data portability) or how EU users can exercise them.

Key Findings

Notable clauses, issues, or positive practices discovered (critical first)

Critical

Excessive Data Collection Without Clear Necessity

The policy lists extensive data categories collected, including CPF, RG, bank details, income, social media data, and document copies (Section 3). For EU users, this likely violates GDPR’s data minimization principle (Article 5(1)(c)), as much of this data (e.g., social media content, document copies) is not strictly necessary for credit intermediation.

Critical

Broad Third-Party Sharing Without User Control

Data is shared with financial partners, credit bureaus (Serasa, Boa Vista), payment operators, insurers, investors, and ‘any other third parties’ for vague purposes like ‘enrichment of information’ (Section 5). This lacks granularity and user control, violating GDPR’s principles of purpose limitation and transparency (Articles 5(1)(b), 13-14).

Critical

International Transfers Lack GDPR Safeguards

The policy states data ‘may be transferred and stored outside Brazil’ (Section 6) but provides no details on GDPR-compliant mechanisms (e.g., Standard Contractual Clauses, adequacy decisions). This is a critical gap for EU users, as transfers to non-adequate countries require explicit safeguards (GDPR Chapter V).

Warning

No Explicit Opt-Out for Profiling or AI Training

Data is used for credit scoring, fraud prevention, and marketing (Sections 4, 5), which may involve automated profiling. The policy does not mention opt-outs for such processing, violating GDPR’s Article 22 (right to object to automated decisions) and lack of transparency.

Warning

LGPD-Centric Policy Ignores GDPR for EU Users

The policy is framed under Brazil’s LGPD, with no explicit mention of GDPR compliance for EU users. This includes missing lawful bases for processing (e.g., consent, contract), DPIAs for high-risk processing, or special category data protections (e.g., biometric data if collected).

Consumer Takeaway

Avoid using Simplic if you are an EU resident: your data will likely be transferred outside the EU/EEA without clear GDPR-compliant safeguards, shared with numerous third parties, and used for purposes like credit scoring and marketing without explicit opt-outs for AI training or profiling.

Compliance Posture

Non-compliant with GDPR for EU users. The policy is framed under Brazil’s LGPD, with no evidence of GDPR alignment (e.g., lawful bases for EU users, DPIAs, or international transfer mechanisms). Cross-border data transfers are acknowledged but lack specificity on safeguards.

EU Transfers

High risk. Data may be transferred outside Brazil (and thus likely outside the EU/EEA) with no mention of GDPR-approved mechanisms (e.g., SCCs, adequacy decisions, or Binding Corporate Rules). The policy states measures will be taken to protect data but provides no details.

Detected Signals

Specific data points and practices identified in the text

Data Collected
NameEmailPhone numberCPFRGDate of birthPostal addressBank account detailsAgency numberSavings account informationMonthly income declarationEmployment statusEmployer nameMonthly salaryNet worthSocial media dataSocial media contentCopies of RGCopies of CPFCopies of CNHCopies of passportPhotographs
Processing Purposes
User registration and identificationCredit intermediation and proposal submissionCredit analysis and risk scoringFraud prevention and verificationDebt collectionPlatform improvement and maintenanceMarketing and promotional campaignsUser profiling for targeted servicesCompliance with legal and regulatory obligationsData enrichmentInvestor due diligence for corporate transactionsPayment processing
Third-party Sharing
Shared with financial partners (e.g., Banco Afinz)Shared with credit bureaus (e.g., Serasa, Boa Vista)Shared with payment operatorsShared with insurers and insurance brokersShared with group companiesShared with commercial partners and service providersShared with investors and potential buyersShared with government authorities or courtsShared with other credit providersShared with agents acting on Simplic’s behalf
International Transfers
Data may be transferred and stored outside BrazilMeasures will be taken to protect data during transfers

Evidence Snippets

Direct quotes from the policy supporting these findings

Podemos eventualmente compartilhar os seus Dados Pessoais com Instituições Financeiras Parceiras, bem como com os terceiros identificados abaixo para nos apoiar na execução das finalidades indicadas

Os seus Dados Pessoais poderão ser transferidos e armazenados em um destino fora do Brasil, na medida permitida por lei. Se os seus Dados Pessoais forem transferidos para outro país, nós adotaremos as medidas exigidas por lei para assegurar que eles continuem protegidos.

Análise de crédito e verificação de autenticidade das informações e documentos fornecidos, inclusive mediante tratamento e verificação cruzada. Verificação antifraude

A Simplic não tem qualquer responsabilidade ou ingerência sobre os critérios adotados pelas agências para fins de atribuição de credit scoring.

Missing or Unclear

  • No GDPR-specific lawful bases for processing EU user data
  • No mention of Standard Contractual Clauses (SCCs) or other GDPR transfer mechanisms
  • No opt-out for AI/model training or profiling
  • No explicit GDPR rights (e.g., right to object, data portability) for EU users
  • No Data Protection Impact Assessment (DPIA) references for high-risk processing
  • No details on data retention periods for EU users
  • No mention of special category data (e.g., biometric) protections
  • No clarity on whether data is used for AI training

Questions to Ask

  • What GDPR-compliant mechanisms (e.g., SCCs, adequacy decisions) are in place for international data transfers outside the EU/EEA?
  • Does Simplic process EU user data under GDPR lawful bases (e.g., consent, contract), and if so, which ones apply to each processing purpose?
  • Is user data used for AI or machine learning model training, and if so, how can EU users opt out?
  • Are Data Protection Impact Assessments (DPIAs) conducted for high-risk processing activities like credit scoring or fraud prevention?
  • How long is EU user data retained, and what are the specific criteria for deletion under GDPR?
  • How can EU users exercise their GDPR rights (e.g., access, rectification, erasure, objection) if they are not covered by LGPD?
  • Are there any third parties outside Brazil that receive EU user data, and what safeguards are in place to protect it?
  • Does Simplic use biometric or other special category data, and if so, what protections are in place under GDPR Article 9?
This analysis is generated by AI and is not legal advice. Always consult a qualified legal professional for compliance decisions.

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