Thunder X Privacy Policy

Thunder X · app.thunderx.games · dl.thunderx.games · thunderx.games · installable app
Version 1.8 · in force since October 10, 2026

This is an English translation of the Política de Privacidade, provided for convenience. If the two differ, the Portuguese version prevails.

This page tells what Thunder X does with your data — what the servers and the app really do, not what would sound nice to say. It goes together with the Terms of Use. The original is in Portuguese, and the Portuguese text is the one that counts. You can read it without an account, save it or print it.

You do not need to accept this Policy: it informs (item 2.2).

What is in bold limits a right of yours, creates an obligation or warns of a risk.

The essentials

1. Who answers for your data is Nublify (Nublify Consultoria e Serviços de Tecnologia da Informação Ltda., CNPJ 33.795.677/0001-12), owner of the Thunder X and Zeus brands. To talk about personal data: privacidade@thunderx.games (section 1).
2. You do not "accept" this Policy: it explains what we do. What you accept are the Terms of Use. We only ask for consent in two places: in the pre-registration, at thunderx.games, and in the agreement of the parent or guardian of a child (item 2.3).
3. Thunder X is open to any age. Sign-up asks for name, e-mail, password and date of birth. The date does not bar anyone: it serves to know when the law requires the parent or guardian's agreement (under 12 years old) and to record the acceptance. Each acceptance of the Terms is recorded for 6 months, with the IP address the click came from. The IP is the number of your internet connection: from it one can tell the internet provider and the approximate region, not your name (items 3.3, 3.4 and 3.11).
4. We do not record your game, your voice, your camera or your screen. What you do in the game travels encrypted between you and the cloud computer, and so does the image, except on an old computer (item 3.6). What you put on the Estúdio goes to the platform you chose and does not stay with us. We keep an image of your screen only when you send it in "Fale com a gente" ("Talk to us") (with "Anexar" ("Attach") checked) or in the "Reportar um bug" ("Report a bug") of the overlay (véu) (with "Foto da tela" ("Screenshot") turned on), and when a capture arrives in a report or is taken by the team while investigating one (items 3.7, 3.10, 3.13 and 3.14, section 6).
5. Almost all of the app's chat is the Salas. When you open them, the app passes to the Salas your account number, your name and your e-mail, and there the Salas Policy applies. In a room, voice, camera and screen go from person to person, and whoever is with you can find out your IP address. The Salas chat is not kept (section 9). The voice of "Chamar pro jogo" ("Call into the game") and the site's conversations pass through a server of ours (item 3.8).
6. The store password does not stay with us. You type it on the store's own page — or, on Steam, on Steam's own screen, which runs on the seat — and we do not read it. We keep the key the store gives back, to read your library and open your games, and, on Steam, the login it leaves on the seat. Today, unlinking Steam on the Accounts screen (Contas) does not delete the stored login: for that, ask by e-mail (item 3.5).
7. The installable app comes with three things turned on: the microphone goes to the game from the start of the match; the crash reports, which also record each opening of the app; and the usage log (item 9 and item 3.16). The crash reports and the usage log have a switch in Settings (Configuração); the game microphone, today, only has the mute shortcut. While it is open, the app stays connected to our server to receive the notifications; it does not open by itself with the computer and does not stay in the background (items 3.2, 3.6 and 3.9).
8. We keep the record of each access for 6 months: IP, port, date and time, because the Brazilian Internet Civil Framework (Marco Civil da Internet) requires it; the address requested and the browser, for security. Then we delete it (item 3.11).
9. We do not sell data, do not show paid ads and do not use third-party trackers. The app and the site record, linked to your account, the screens you open, what you click and the errors that appear — never what you type, chat or do inside the game —, to find defects, help you and improve the service; the "Ajudar a melhorar o Thunder X" (Help improve Thunder X) switch, in Settings, turns it off. Our servers also record what your account did on them, for 12 months (item 3.16). We only use necessary cookies; that is why you do not see a cookie banner (sections 6 and 12).
10. There is no button to delete the account or to download the data: ask by e-mail and we reply within 15 days. What we delete still stays in the backups for up to 35 days. And deleting the Thunder X account does not delete the Salas one: ask for both (sections 10 and 14).
11. Data of a child or adolescent never goes to advertising or to profiling — which, here, already applies to everyone. Parents and guardians can ask, at any time, that we delete their child's data (section 11).
12. Your data reaches: the people you play and talk with; the Salas; the stores you linked; Google, if you sign in through it; Stripe, if you buy credits; Spedy, which issues the invoice for the purchase; AWS, which hosts the service in São Paulo and receives the e-mails you send us; Brevo, which sends e-mails; the services the pages' images and videos come from (the stores, Nuuvem, YouTube and the icon services), which see your IP; the streaming platform you choose; and authorities, when the law or a judge orders it. You can complain to Brazil's National Data Protection Agency (ANPD) whenever you want (sections 7, 8 and 17).
13. The card data does not pass through us. Whoever buys credits (TCoin) pays by card or Pix in a Stripe form. For that we send Stripe the e-mail and the account number, the chosen package and the price; from it we receive whether the payment went through. The CPF (the Brazilian individual taxpayer number), the name and the address for the invoice (nota fiscal) are asked only on the Stripe payment page, which requires the CPF (in a field that is not pre-filled), the billing name and the billing address; Stripe keeps them with the payment, and Spedy, which issues the invoice, reads them from there. Thunder X does not ask for or keep this data: what we had kept was deleted on October 6, 2026 (from the backups, it is gone within 35 days). Without a CPF you cannot buy credits. We keep the balance and the statement of the credits, and how many credits each game session spent (item 3.15).

1. Who we are and who to talk to

The one who decides what is done with your data is Nublify, and there are four ways to talk to us.

Thunder X is a service of Nublify.

• Controller (who decides what is done with the data): Nublify Consultoria e Serviços de Tecnologia da Informação Ltda., CNPJ 33.795.677/0001-12, headquartered at Av. Yojiro Takaoka, 4384, sala 701, Alphaville, Santana de Parnaíba/SP, CEP 06541-038.
• Data protection officer (encarregado) (who answers the requests about data and speaks with the ANPD): Fabio Lucinare — privacidade@thunderx.games.
• Reports, warning of a child in danger and copyright: denuncia@thunderx.games.
• Everything else: contato@thunderx.games.
• Inside the app: "Fale com a gente" ("Talk to us"), in the Support (Suporte) item of the menu or on the F1 key. The message arrives identified with your account (item 3.10). The replies that go by e-mail are sent from suporte@thunderx.games.

2. What this Policy covers

It applies to the whole of Thunder X — the site, the installable app and the test versions — except what belongs to the Salas, the stores and the streaming platforms.

2.1 Where it applies

• app.thunderx.games — the site, where you create the account, link the stores, buy credits and play in the browser.
• The installable app for Windows, macOS and Linux, downloaded at dl.thunderx.games. It includes the overlay (véu): the layer of the app that appears on top of the game during the match.
• thunderx.games — the home page and the pre-registration.
• The test versions. The app also comes in two test versions, "Thunder X Homologação" and "Thunder X Developer". They talk to test servers (beta.app.thunderx.games and beta.thunderx.chat) and update through dl.thunder-x.com. Their accounts and data are kept separate from those of production, and this Policy applies to them in the same way.

It does not apply to:

• The Salas (thunderx.chat), even when opened inside the app. They have the Salas Privacy Policy. Section 9 explains what Thunder X does in the link between the app and the Salas — that part is ours and is here.
• The stores, Google, Stripe, the games and the streaming platforms, which have their own rules.

2.2 You do not accept this Policy

You do not "accept" this Policy. It is our explanation of what we do. What you accept are the Terms of Use, by checking at sign-up the box "Li e aceito os Termos de Uso, versão 1.0" ("I have read and accept the Terms of Use, version 1.0").

The Windows installer shows the Terms and this Policy before installing and asks only for "Li e aceito os Termos de Uso" ("I have read and accept the Terms of Use"). That click stays on your computer: it does not reach us, it is not recorded and it does not replace the acceptance of the account. The app's automatic update shows nothing. On macOS and Linux, the installer does not have that page.

2.3 The legal bases

We process what is necessary to deliver what you asked for, to comply with the law or to keep the service secure. The tables in section 3 say, in each row, which basis applies. They are five short names, taken from the Brazilian General Data Protection Law (LGPD, Law 13.709/2018):

• Service — we need the data to deliver what you asked for: playing, talking, having an account (LGPD, Article 7, V).
• Law — a law obliges us to process or to keep it (LGPD, Article 7, II).
• Legitimate interest — security, a brake on abuse, fixing defects, customer support, improving the service and aggregate statistics (LGPD, Article 7, IX). We use only the minimum, and you can object: see section 10.
• Defense of rights — keeping proof of what happened, in case of a lawsuit (LGPD, Article 7, VI).
• Consent — you asked for it, and you can undo it whenever you want (LGPD, Article 7, I; for a child, Article 14, §1). We use it in only two places: the pre-registration, at thunderx.games, and the agreement of the parent or guardian of a child under 12 years old.

Without some data there is no account: the invitation code, the name, the e-mail, the password, the date of birth, the acceptance record and the access log with your IP. If you do not want them to be processed, do not create the account. Your rights over them are in section 10.

What is optional — the photo, the profile phrase, the Estúdio, the linked stores, the crash reports, the usage log of the app and the site — only exists if you use it or leave it turned on, and you change it or turn it off whenever you want. If one day we want to do something beyond what is here, we ask first, and you can say no.

3. What we process, what for, on what legal basis and for how long

Each piece of data has a reason and a time limit: the site session, 30 days; the access log, 6 months; the backups, 35 days. The account stays until you ask to delete it.

The tables below have one row for each piece of data, by place.

3.1 In your browser

There is no advertising or measurement cookie. From third parties, only Stripe's, on the payment page (section 12).

3.2 On your computer, through the installable app

The app keeps on your computer what it needs to work, and some things come turned on. Opening with the computer, the crash reports and the usage log have a switch in Settings (Configuração); the game microphone, today, only has the mute shortcut (item 3.6).

"Sair" deletes the Thunder X session, the Salas area and the store-linking window. It does not delete the settings or the computer's identity.

Today, uninstalling the app does not delete its data folder. To delete everything, delete the "ThunderX" folder (like that, with no space) after uninstalling: on Windows, inside %APPDATA%; on macOS, in ~/Library/Application Support; on Linux, in ~/.config. The test versions use other folders: "Thunder X" (Homologação) and "Thunder X Developer".

The app does not open by itself and does not stay in the background. While the window is open, it stays connected to our server to receive the notifications right away (item 3.8). Closing the window ends the app and the connection. The old versions opened together with the computer and stayed hidden in the icon near the clock; today's version deletes that automatic opening the first time it runs.

Shortcuts and keyboard during the match. While the match lasts, the app reserves its shortcuts — F9 for the overlay (véu), the voice mute one in the Salas and in "Chamar pro jogo" ("Call into the game"), and those of the Estúdio and of the stream measurements. Those keys stop reaching the other programs. On Windows, when you use push-to-talk, a single key as a shortcut or a shortcut the system refused, the app starts listening to all the keys of the computer. It listens only to recognize your shortcut: it does not store, does not send and turns off when the match ends.

The system's notification balloons show an excerpt of the messages that arrive, in view of whoever is near the screen.

Update. The app checks dl.thunderx.games every 6 hours; on Windows, it asks before downloading a new version. The request carries your IP and the app version, like any download. On macOS and Linux, the check also happens, but today there is no automatic update.

3.3 The account and sign-up

To have an account you need an invitation, and sign-up asks for little.

Today the account has no expiry for lack of use: it is kept until you ask to delete it (section 10). The e-mail, once recorded, does not change through the site or the app — only on request. Today there is no e-mail verification or password recovery, and the account does not receive automatic e-mail from us.

The old chat went offline on October 1, 2026. It was at app.thunderx.games/v4 and came before the Salas; each Thunder X account had a partner account in it. The app and the site no longer open it, and that address has stopped working. The attachments of its conversations were deleted on that day. The old chat's database, with the messages, the spaces and the Steam linked there, was deleted on the same day. Whatever is still in a backup is gone within 35 days (section 14). If you used the old chat and want to know what remains of it, write to privacidade@thunderx.games (section 10).

3.4 The acceptance record and the date of birth

We keep the proof of each acceptance for 6 months, and your date of birth serves only two things: knowing when the law requires the parent or guardian's agreement and recording who accepted.

• Nobody checks the sign-up. We do not send a code to the e-mail and we do not ask for a document. The record keeps what the person declared.
• The date of birth does not bar anyone, is not shown to anyone and is not used for anything else: it does not unlock or lock game, conversation, camera, screen or the Estúdio.
• The sign-up e-mail never goes to advertising.
• Whoever already had an account before this version fills in the date of birth and checks the acceptance at the first sign-in after it.
• The click in the Windows installer does not go into this record (item 2.2).
• The Salas have their own sign-up and acceptance record, done at the first room (section 9).

3.5 The store accounts

Linking a store is optional, but without a store there is no game. The store password never stays with us.

How the linking happens. In the app, you sign in on the store's own page, in an app window that shows the address in the title. The window starts empty and is wiped at the end: we do not keep the store's cookies. The app reads only the final code the store delivers — on Epic, the text of the final page; on Amazon, the page's address. If that does not work, you paste the code. On the site, you sign in on the store's page in a tab and paste the code.

We only use these keys to read your library and open your games. The link with Epic, Amazon and Xbox uses programs that are not the stores' own; the Terms describe the risk of that. On Amazon, the link registers a new device on your account. Since the Epic, Amazon and Xbox key stays on the seat host computer that handled the request, it may be necessary to link the store again. The key expires from time to time; when it expires, we ask you to link again.

3.6 Playing: queue, session and seat

The seat is the cloud computer where the game runs. What passes between it and you is not recorded.

The microphone goes to the game from the start of the match. It starts turned on, so that the game hears you (the game's own voice chat). You mute it with Ctrl+Alt+Shift+F inside the game. Today there is no switch in the app for it to start turned off. With the Estúdio on air, it also goes to the live stream (item 3.7).

The seat is in São Paulo. Today the catalog's games run on a Linux seat; Windows only exists as a machine with an owner. The Steam login inside the seat is typed by you, on Steam's own screen; we do not read what you type.

3.7 Live: the Estúdio

The Estúdio, in the "Ao vivo" ("Live") section of the app's menu, streams the seat's screen to the platform you choose. We do not keep a copy.

Everything that appears on the seat's screen goes on air, including login windows and notices that come up there. The camera starts turned off; the microphone, turned on.

The platform receives the live stream under its own rules and has its own minimum age. Thunder X does not lock the Estúdio by age (section 11). Today the Estúdio only works on the Windows seats, and Windows today only exists as a machine with an owner (item 3.6). On the shared seat, where the catalog's games run, the app warns that the live stream is not yet available.

3.8 App voice, conversations and notifications

Outside the Salas, what remains in the app is the voice of "Chamar pro jogo" ("Call into the game") and the notifications; on the site, the conversations, the channels and the spaces. They pass through servers of ours.

News and announcements. There are two kinds of notification that do not depend on anything you did. The team announcement marked as essential reaches everyone. The news — new games in the catalog and store offers, with the price — only reaches those who have "Novidades e lançamentos" ("News and releases") turned on, in the site's Settings (Configuração). Today, whoever has never touched that switch counts as turned on — but the switch, in the site's Settings, shows as turned off. To stop receiving, turn the switch on and off once. The installable app does not yet have that switch. The notifications do not use profiling: they go the same to everyone. Nobody pays us for them.

3.9 Crash reports

The app sends reports when something breaks and records each opening. It comes turned on, and the "Enviar relatórios de falha" ("Send crash reports") switch turns everything off.

Without internet, the uploads wait on your computer for up to 7 days. The reports stay on a server of ours, in São Paulo — the crash files, in an encrypted bucket — and in a panel that only the team opens. The site also sends to the same place the errors of the pages, with this browser's number, the browser you use and your account number. The same switch, in the site's Settings (Configuração), turns that sending off.

Turning off the "Enviar relatórios de falha" switch, in the Settings of the app or of the site, stops all the uploads from that app or browser, including the row for each opening.

3.10 "Fale com a gente" ("Talk to us")

Support inside the app arrives identified with your account, and can carry a screenshot.

The screenshot may show messages, names and whatever else is on the screen. Uncheck "Anexar" (or turn off "Foto da tela", in the overlay) if there is something there you do not want to send.

The report stays on our server and in our support system, both in São Paulo. The ones who read it are the support team. The reply arrives in the app's Notifications (Avisos), with a reference number, and you reply in the same conversation. The replies that go by e-mail are sent through Brevo. Today the support system has no backup: if it is lost, the conversation is lost.

3.11 IP address and access logs

Your IP passes through us in almost everything. What the law requires us to keep, we keep for 6 months.

The IP address is the number that identifies your internet connection. From it one can tell your internet provider and your approximate region — not your name or your home address.

The IP also stays in each sign-in to the account (item 3.3).

About the access log. Only the person on the team who administers the servers can read it. It only leaves here with a court order (item 7.10). The log does not carry your name or what you wrote, but it carries the addresses you opened.

3.12 Pre-registration

On the home page (thunderx.games) and on the pre-registration page (thunderx.games/pre-cadastro) you can leave your data to receive the launch notice. It is optional and it is the only place where we use consent to talk to you.

Both forms pass through a program of ours on AWS, in the United States. The one on the pre-registration page is recorded in three places: a raw copy in a bucket of ours on AWS in the United States, a spreadsheet on Google (Forms and Sheets) and the contact list on Brevo, which is the one that sends the e-mails. The field on the home page goes only to the Brevo list. If one of those destinations fails, the registration stays in that program's log, also in the United States, for the same period. Section 8 talks about these transfers.

3.13 When you write to us

3.14 Reports and measures

A report about what happened in a room is investigated under the Salas rules (section 9).

3.15 Credits (TCoin) and payment

Playing spends credits, the TCoin, which you buy or receive from the team. The card data does not pass through us.

How the payment happens. On the site, the buy button takes the browser to the Stripe page. In the app, it opens a window of the app itself with the Stripe form inside a page of ours. In both cases, the program that shows the form is Stripe's and comes from its servers, which see your IP and set its cookies, against fraud. Stripe processes the payment data under its rules (Stripe's policy); the receipt, when it sends one, goes to the account's e-mail.

Each purchase is a new payment. We do not keep a card for the next purchase and there is no automatic charge.

Complimentary credits. The team can give credits to an account, without payment. The statement keeps the note and who gave them.

When the balance runs out. In the session paid with credits, the server deducts the minutes played; when the balance does not pay for the next minute, a program ends the session (section 10). With no balance, the next session is free, with reduced image and time.

3.16 Usage log and account log

We record what you do in the app and on the site, and what your account does on our servers. That is how we find the defect you saw, answer "what happened at 2 p.m.?" and understand where the service fails.

What does not go in: what you type (password, message, what you write to the assistant), what you say, what appears in the game and what you do inside it, the mouse position, the CPF and the card data. The server accepts only a closed list of names and fields and throws away whatever comes outside it, and anything that looks like an e-mail, CPF, card or password.

The switch. "Ajudar a melhorar o Thunder X" (Help improve Thunder X), in the Settings of the app and of the site, comes turned on and turns off the usage log of that app or browser. The account log does not turn off: it is how the service knows what happened to the account.

Who sees it. Only the team, on a panel screen that asks for the password again and records who opened it. Both logs stay on our server in São Paulo; no third-party program receives anything from them. You can ask for a copy (section 10).

4. What others see of you

What belongs to the profile is seen by whoever uses Thunder X; the e-mail, the date of birth and the keys are not.

Whoever uses Thunder X sees: your display name, your photo, your phrase, the colors, the badge, the frame and the profile card, and the game you chose to show; in the voice channels of the app and of the site, whether you are there and whether your microphone, your camera or your screen is on; what you write in the public channels and in the spaces you take part in; and the names of the channels and spaces you created.

The photo and the cover you put on the profile stay at a public address. The address is random, hard to guess, but whoever has it opens the image without an account. Changing or removing the image makes the old address stop working.

Whoever searches for people can find your account by typing your name or a piece of your e-mail. And, if the account has no name, the beginning of your e-mail appears — what comes before the @.

Your friends also see: whether you are online, whether you are playing and which game, how many hours you have played each game on Thunder X (from half an hour up, on the game's page) and what you write in the conversation between you.

In the Salas, whoever is in the room sees your account's name and what the Salas rules show (section 9).

Whoever watches your Estúdio live stream sees and hears everything that is on the seat's screen, your voice and, if on, your camera (item 3.7).

Nobody sees: your password, your date of birth, your store accounts and their keys, your credit balance and statement, the detail of your session history (dates and seats) and your library — except what you yourself show, for example by choosing a game for the profile card. Your e-mail does not appear on the profile, with the caveats of the search, above. Your IP does not appear, with the caveat of the Salas (section 5).

The stores see that Thunder X read your library with your authorization and, on the seat, that your account signed in from a computer in São Paulo, as they would see from any PC. What you do inside the game — the game's voice chat, matches, purchases — is between you, the game and the store, under their rules.

What you say, show on camera and share on screen reaches everyone in the channel or in the room. Any of them can record or photograph with outside programs. The Terms forbid recording or disclosing someone without authorization, but we have no way to prevent it or to know.

A tip: use a nickname. Do not put your full name or another person's data in the name, in the phrase or in the name of a channel or space.

5. Voice, camera and screen: what passes through us and what goes direct

There are different paths in the app, and they treat your IP in different ways.

In the Salas, audio, video and screen go straight from your computer to that of each person in the room. For that, the computers exchange IP addresses. Result: whoever is in the room with you can, with some technical knowledge, find out your IP. In an open room, that includes strangers.

To not show your IP, enter the room through the relay, a server of ours. In the Salas tab and in the browser, the site itself offers this: the "Ir pela passagem, sem mostrar o IP" ("Go through the relay, without showing the IP") button, when you create a room, and the "entre pela passagem" ("enter through the relay") link, in the "Antes de entrar" ("Before entering") notice at the room's door. In the overlay, today there is no way: there, assume that the connection may be direct.

In the app voice, our server sees the audio and the video pass through, but does not record them: there is no record button, there is no file and nobody on the team watches. If one day there is recording, this Policy and the Terms change first.

Inside the game, the microphone goes to the seat, and the game can carry it to its voice chat, to whoever plays with you; with the Estúdio on air, it also goes to the live stream (item 3.7).

6. What we do not process

What we do not collect, we do not have to lose, sell or hand over.

• Recording of the game, the voice, the camera or the screen. It does not exist. That is why we have no way to review, recover or hand over to anyone what was played, said or shown — not to you, not to an authority. What you put on the Estúdio stays with the platform you chose, under its rules. The exceptions are the screenshot you send through "Fale com a gente" ("Talk to us") or through "Reportar um bug" ("Report a bug") (item 3.10) and the captures of a report and of its investigation (items 3.13 and 3.14).
• Your store password. You type it on the store's page or, in the case of Steam, on Steam's own screen inside the seat. We do not read it and do not keep it.
• Your keystrokes. The keyboard goes to the seat only for the game, and the app listens to the keyboard during the match only to recognize your shortcuts (item 3.2). None of that is stored.
• Advertising and profiling. There is no paid ad, sale of data or sharing for advertising. The usage log (item 3.16) serves to find defects, help you and improve the service, not for ads. The news notifications go the same to everyone (item 3.8).
• Third-party trackers. The pages and the app do not load any third-party tracking program. The usage log is ours and goes only to our server (item 3.16). The only outside program is Stripe's, and only on the payment page (item 3.15). Images and videos also come from outside: the games' artwork, from the stores' servers; the YouTube trailers, on each game's page; the store icons on the site's Accounts screen (Contas); and the images of the Nuuvem showcase, on the Store screen (Loja) (item 7.9). Whoever loads an image or a video from outside leaves their IP with whoever serves it.
• Your card data. You type it in the Stripe form. It does not reach our servers (item 3.15).
• ID document and phone. We do not ask for them. The CPF, the name and the address on the invoice, only when buying credits, are asked on the Stripe payment page, for the invoice (the next item), and we do not keep them. When buying credits, whatever Stripe asks for is between you and it. The phone, only if you leave it in the pre-registration. The date of birth, yes: it is in item 3.4, and only for what is there.
• CPF (the Brazilian individual taxpayer number), name and address when buying credits. Thunder X (the app, the site and our servers) does not ask for or keep the CPF, the name or the address for the invoice. The Stripe payment page asks for everything the invoice needs: the CPF, in a required field ("CPF (para nota fiscal)") that is not pre-filled, and the billing name and address, always required, for card and for Pix. Stripe keeps them with the payment, and Spedy, which issues the invoice, reads them from there (item 7.12). They are for the invoice (nota fiscal) of the purchase, which the law obliges us to issue (LGPD, Article 7, II). Since October 1, 2026 the city hall does not issue the electronic invoice (NFS-e) without the buyer's CPF, and the address is there because, since the tax reform, the service invoice for an online service needs the buyer's address (the tax is due where the buyer lives). That is why you cannot buy credits without a CPF: in practice, only people with a CPF can buy, and someone outside Brazil who has no CPF cannot buy. We send Stripe only the e-mail and the account number, the package and the price, and we no longer create a customer record there (the ones created between October 4 and 6, 2026, with the name and the e-mail and, in some, the address, remain there, with the payments). The CPF, name and address for the invoice that we had kept, on the account and with each purchase, between October 4 and 6, 2026, were deleted on October 6, 2026 (from the backups, they are gone within 35 days, section 14): our servers no longer keep any of them. On crediting the purchase, our servers only read the typed CPF to see whether it is valid, and log, without the number, when it is not (the invoice would not be issued). They exist only at Stripe, with the payment, and in the issued invoice, which is a tax document. Stripe only checks that the CPF has 11 digits; if it is not a real CPF, the invoice is not issued, and the team needs to contact you. Apps installed before this version may still show the old "Dados para a nota fiscal" dialog: what you type in it is ignored and not kept, and its postal-code lookup no longer works. Everything is asked on the Stripe payment page.
• Your location. The app does not ask for it and refuses the location request of any page it opens.
• Your Google contacts, files or calendar. We do not ask for access.
• Automatic reading of the conversations. Today no filter reads what you write. If that changes, this Policy changes first.

7. Who we share with

Your data goes to these places, and to no other.

7.1 The other people on Thunder X. They see what is in section 4.

7.2 The Salas. They are a service of ours, from the same company, with their own account base and Policy. When you open the Salas in the app, your account number, your name and your e-mail go there (section 9).

7.3 The stores: Valve (Steam), Epic Games, Amazon Games and Microsoft (Xbox). When you link a store, it is you who talks to it, on its page, under its rules (Steam, Epic Games, Amazon, Microsoft). We receive what is in item 3.5 and, on the seat, its launcher runs with your key, as it would run on your PC. The stores are in the United States.

7.4 Google. The sign-in with Google happens in its window, under its rules (Google's policy); we only keep what is in item 3.3. The pre-registration records a row in a Google spreadsheet (item 3.12). And each game's page loads the cover image of the YouTube trailer, and the video, if you click; YouTube belongs to Google, which sees the IP of whoever opens the page.

7.5 Amazon Web Services (AWS). It hosts our servers, the seats, the Steam vault, the crash reports, the logs and the support, in the São Paulo region — including the e-mails that arrive at the @thunderx.games addresses: AWS receives them and keeps a copy, as it arrived, in a bucket of ours for 30 days; the pre-registration, in the United States; and it delivers the app downloads through servers spread around the world. It works for us and only processes the data as contracted (the law calls this a processor).

7.6 Brevo. It sends our e-mails (the launch notice and the support replies) and keeps the pre-registration list. It is in France. It is also a processor.

7.7 Our support system. The contato@, privacidade@ and denuncia@ mailboxes are ours: the messages arrive through AWS (item 7.5) and are read in our support system, in São Paulo. The replies by e-mail are sent through Brevo (item 7.6).

7.8 The streaming platform you choose. Twitch, YouTube, Kick or the server you indicate receive your live stream when you use the Estúdio. The one who chooses the platform is you, and it processes what it receives under its rules. It is not a processor of ours.

7.9 Image and video services. The games' artwork comes from the stores' servers; the store icons on the site's Accounts screen (Contas) come from icon services (simpleicons.org and jsDelivr); the trailers, from YouTube; the images of the Nuuvem showcase, from its servers. They see the IP and the browser of whoever loads the image or the video, and nothing else.

7.10 Authorities.

• Access logs, conversations, e-mail and the other account data: only with a court order (Marco Civil da Internet, Article 10).
• Registration data: the law allows certain authorities to request, without a court order, the personal identification (name, marital status, profession), the parentage and the address of a specific person. Of all that, we only have the name the person themselves wrote, typed by the person, and nobody checked it. The e-mail and the date of birth are not on that list. A generic or collective request, we refuse.
• At a formal request from the police, the Public Prosecutor's Office (Ministério Público) or an administrative authority, we keep logs for longer, confidentially, while the court order does not come. Handing them over still depends on a court order.
• When the law obliges, we report on our own initiative signs of sexual exploitation or abuse, grooming or kidnapping of a child or adolescent (ECA Digital, Article 27). What the law requires to be reported about the case goes along. The account data, the conversations and the access logs are preserved for the period set by the law; whatever goes beyond what the law requires to be reported only leaves with a court order.
• What we do not have, we do not hand over: a recording of game, voice, camera or screen does not exist.

7.11 Stripe. It processes the purchase of credits, by card or Pix. It receives from us the e-mail and the account number, the package and the price (we do not send your name, your address or your CPF, and we no longer create a customer record there; the ones created between October 4 and 6, 2026 remain there); from you, in its form, the payment data, which does not reach us, and, always, the CPF (the required "CPF (para nota fiscal)" field, not pre-filled), the billing name and the billing address, which are the ones on the invoice; and it sees your IP. It returns to us whether the payment went through, and keeps the payment record, with the CPF, name and address typed, under its rules (Stripe's policy). We do not keep the CPF, the name or the address. Stripe also processes this data outside Brazil, in the United States. The details are in item 3.15.

7.12 Spedy. It issues the invoice (the NFS-e) for the purchase of credits. It reads from Stripe the purchase data, the CPF and the billing name and address you typed on the payment page, besides the e-mail and the amount, and issues the invoice through the national NFS-e system, with the city hall. The issued invoice is a tax document, kept by the tax authorities and by Spedy for the period set by tax law. It is Spedy Desenvolvimento de Software Ltda, a Brazilian company based in Cuiabá (MT) (Spedy's policy); its policy does not say in which country the data is stored. It is also a processor.

7.13 Nobody else. The "Loja" ("Store") screen shows a Nuuvem showcase: the list and the prices are a fixed copy, with a date, and the images come from Nuuvem's servers, which see your IP and the browser, as in item 7.9. Nothing else of yours goes there. If you click to buy, the Nuuvem page opens in your browser, and from there on its rules apply. The links pasted in the conversations lead to third-party sites, with their own rules.

8. Data outside Brazil

Thunder X keeps your data in Brazil, with few exceptions, and each one is here.

• The product is in São Paulo. Accounts, conversations, the credit wallet, Steam vault, store keys, crash reports, logs, voice, seats and support are in the AWS São Paulo region.
• Stores, Google and Microsoft (United States). The ANPD has not yet recognized the United States as a country with protection equivalent to Brazil's. When you link a store or sign in with Google, it is you who talks directly to them, in their window, under their rules; we only receive the result. On the seat, the store's launcher talks to it as it would from your PC.
• Stripe (United States). When you buy credits, the e-mail and the account number, the package and the price go to Stripe, and you type the payment data, the CPF, the billing name and the billing address in its form. Stripe also processes this data in the United States. The basis is delivering the purchase you asked for (LGPD, Article 33, IX, with Article 7, V).
• Spedy. It issues the invoice for the purchase of credits, with the CPF, the name, the address and the purchase data it reads from Stripe (item 7.12). It is a Brazilian company, but its policy does not say in which country the data is stored.
• Streaming platforms. They are wherever they are. The live stream goes there because you chose it.
• Pre-registration (United States and France). Both forms pass through a program of ours on AWS in the United States; the raw copy of the pre-registration stays in a bucket of ours there, and the spreadsheet, on Google. Both forms say, before the button, that the data goes to servers in the United States (AWS and Google) and to Brevo, in France, and carry the link to this Policy and a box of their own, unchecked: "Concordo que os meus dados sejam guardados nos Estados Unidos (AWS e Google) para receber o aviso do lançamento" ("I agree that my data be stored in the United States (AWS and Google) to receive the launch notice"). Only with it checked does the data go there. It is with this request of yours, made after the notice, that it goes (LGPD, Article 33, VIII). The e-mail list stays with Brevo, in France.
• Brevo (France). Besides the pre-registration list, it sends the support replies by e-mail. France is part of the European Union, whose data protection the ANPD recognizes as adequate (LGPD, Article 33, I).
• Trailers, images, icons and downloads. Each game's page loads the cover image of the YouTube trailer (Google, United States), and the video, if you click. The site's Accounts screen (Contas) loads icons from simpleicons.org and jsDelivr. The images of the Nuuvem showcase, on the Store screen (Loja), come from its servers, which may be outside Brazil. And the installer and the app updates are delivered by the AWS server nearest to you, which may be outside Brazil. In these cases, they receive your IP, the browser and the address requested. The basis is delivering what you asked for when opening the page or downloading the app (LGPD, Article 33, IX, with Article 7, V).
• E-mail. The messages to contato@, privacidade@ and denuncia@ arrive through AWS, in São Paulo (item 7.5), and are read in our support system, also in São Paulo. The replies are sent through Brevo, in France.
• People from other countries who are in a channel or in a room see the same as any participant — including, in the Salas, your IP. They are people, not companies we hire.
• If we hire another company from outside Brazil to process your data, this Policy changes first.

9. The Salas inside the app

The Salas tab and the overlay (véu) open the Salas site, with your account. There the Salas rules apply; the link between the app and the Salas is ours, and it is here.

9.1 What belongs to the Salas

Almost all of the app's chat is the Salas. The "Salas" ("Rooms") tab, in the menu, and the overlay, during the match, open the Salas site: thunderx.chat in production, and beta.thunderx.chat in the test versions. Inside a room, the Terms of Use and the Salas Privacy Policy apply, not the ones here.

At the first room you enter or create, the Salas ask for their own sign-up: the e-mail (the app already brings it filled in with your account's), the date of birth and, if the date gives less than 12 years, the parent or guardian's box; and the acceptance of their Terms, in the "Li e aceito os Termos de Uso" ("I have read and accept the Terms of Use") box. The name comes from your account. The record of that acceptance, with the IP, stays with the Salas for 6 months. They are two sign-ups and two records: that of Thunder X (item 3.4) and that of the Salas.

9.2 What Thunder X does: the bridge

• 2-minute ticket. When you open the Salas in the app, the app asks our server for a ticket that is valid for 2 minutes and hands it to the Salas. The Salas ask our server whose ticket it is, and it answers only with your account number, your name and your e-mail, as they are in the account at that time. The password, the date of birth, the photo, the stores, the credits and the history do not go. An expired ticket, or one from a blocked account, opens nothing.
• A Salas account linked to yours. With that, the Salas open — or reopen — an account of theirs linked to your Thunder X account by the number. The Salas account you may have opened through Google, on their site, is another one, and stays separate: the e-mail that goes from the app does not join the two.
• A separate area on your computer. The app keeps the Salas session in an area of its own (item 3.2). "Sair" ("Sign out") deletes that area.
• The overlay has no guest. In the overlay, you always enter the Salas with your account. In the Salas tab, if the sign-in through the account fails, it opens the Salas session that is already on this computer; if there is none, you can enter as a guest or through Google, as on their site.
• The screen during the match. Outside the match, when you turn on the screen in a room, the app shows a picker, and you choose the window or the monitor. During the match, the app chooses the game's window by itself, with no picker; if it does not find it, it shares the entire monitor. The sound does not go along.

Legal basis: Service — you opened the Salas in the app to talk with your account. If you do not want your data to go to the Salas, do not open the Salas tab or the overlay's rooms; the rest of the app works without them.

9.3 Voice, camera, screen and chat in the Salas

• Voice, camera and screen go from person to person, and whoever is in the room with you can find out your IP (section 5). The relay (passagem) avoids this, and the Salas tab offers it; in the overlay, today, no.
• The Salas chat is not kept. Only the last messages of each room stay, in memory, and they are gone with the room. If you need proof of a conversation, take a screen capture at the time.
• The Salas do not record audio, video or screen.

9.4 Deleting

Today, deleting the Thunder X account does not delete your account on the Salas or their acceptance record. They are two requests. Write to privacidade@thunderx.games asking for both things in the same message, and we delete both. When the request comes from the father, the mother or the guardian of a child, we delete both without a separate request being needed (section 11).

10. Your rights and how to exercise them today

You can see, correct, take and delete your data. Today this is done by e-mail, by a person.

There is no button, on the site or in the app, to delete the account, to download the data or to change the e-mail.

How to ask. Write to privacidade@thunderx.games from the account's e-mail: that is how we know it is you. Or use the app's "Fale com a gente" ("Talk to us"), which already arrives with your account. To be sure, we always reply to the e-mail recorded in the account — never to another address — and, before deleting the account or sending the copy of the data, we ask you to confirm by replying there. Lost access to that e-mail? Write anyway: we arrange another way to confirm, asking for the minimum. We do not delete an account at the request of someone we cannot confirm.

Deadlines. To confirm whether we process your data, or for a simple summary of what we have, you can ask for the reply in simplified format, which the LGPD requires to be given promptly (Article 19, I). The complete reply, with the origin, the criteria and the purpose, comes in up to 15 days (Article 19, II). We use the same 15-day deadline for the other requests. A request to delete the account gets a first reply within 5 days. It is free of charge.

You can ask to:

• Know whether we process your data and see what it is. We send a copy of what we have of your account: profile, friends, conversations, session history, the credit balance and statement, linked stores (without the keys, which are a secret between you and the store), the date of birth, the rows of the acceptance record, the usage log and the account log (item 3.16) and the conversations with support.
• Correct. Name, photo, phrase, colors and card you change yourself on the profile page. The CPF, the name and the address on the invoice you type at each purchase on the Stripe payment page, and that is where you correct them, on your next purchase. The e-mail and the date of birth, only on request.
• Ask us to anonymize, block or delete a piece of data that is unnecessary, excessive or processed outside what the law allows, even without deleting the account.
• Delete the account. A person on the team deletes it, within 15 days. What goes with it: the store keys, the Steam login kept in the vault and its preferences, the profile (with the photo and the cover), the friends, the conversations, the history, the notifications, the wallet with the credit balance and statement, and the certificates kept with the game sessions. What stays kept: the payment record, at Stripe, with the CPF, name and address for the invoice, under its rules; the access log, until it completes 6 months (the law requires it) and is gone at 190 days; the logs of the attack filter and of the network, up to 180 days; the programs' logs, up to 30 days; the voice server's log, with the IP, up to 30 days (item 3.11); the backups, up to 35 days (section 14); the old versions of the Steam preferences, up to 30 days; the crash reports, until they expire (item 3.9), and the deleted crash file, for another 7 days; the account log, without the account number, until it completes 12 months (item 3.16); the acceptance record, up to 6 months, if you do not ask to delete it; the "Fale com a gente" conversations in the support system, with the screenshot and the log attached, if you do not ask to delete them too (item 3.10); the invitation that brought you, in the team's panel, with the e-mail it was given to; the e-mails you sent us: the incoming copy for 30 days, and the rest for the period in table 3.13; whatever is on your own computer (item 3.2); and, on a machine with an owner, whatever is on its disk until it is erased. The Salas account is a separate request (item 9.4).
• Delete the acceptance record. We delete the rows with your e-mail, except those we need to keep to defend a right in an open case — and then we say which ones and until when.
• Take your data. We send it in an open-format file.
• Know who we share with. It is in section 7.
• Object to what we do on legitimate interest: the measured stream quality, the crash reports (which you turn off yourself in the app), the usage log (which you turn off yourself in the app and on the site), the account log, the request limit, the security logs beyond what the law requires, the list of closed accounts and the news notifications (which you turn off in the site's Settings (Configuração); see the warning in item 3.8). We analyze your case and reply with the reason.
• Undo a consent. In the pre-registration, by leaving the list. In the parent or guardian's agreement, by asking, and then we delete the child's account.
• Know what happens if you do not give a consent. In the pre-registration, you just do not receive the launch notice. In the parent or guardian's agreement, the account of someone under 12 years old is not created.
• Ask that a person review an automated decision. There are four, all part of how the service works (Terms of Use, item 4.3): the request limit, which can hold back for a few minutes someone who shares the network with a lot of people; the loss of the place in the queue, when the app or the site stops checking it for 2 minutes; the end of the game session after 2 minutes without contact (item 3.6); and the deduction of the credits per minute played, with the end of the session when the balance runs out (item 3.15). No measure against an account is taken by a program.
• Leave the pre-registration list. Through the link at the end of any of its e-mails, or by writing.

If we cannot fulfill it, we say why. You can also complain to the ANPD (section 17).

11. Children and adolescents

Thunder X is open to any age. The date of birth does not bar anyone: with it we know when to ask for the parent or guardian's agreement.

If you are under 12 years old, read this with your parent or guardian. For you to play, we keep your name, your e-mail (or your parent or guardian's), your date of birth, where you connect from and what you do here: the games, the matches and the messages you write outside the Salas. We do not record your voice, your camera or your screen; we only keep a screenshot if you send one in "Fale com a gente" ("Talk to us") or in "Reportar um bug" ("Report a bug"), or if it arrives in a report. Nobody sees your date of birth. The other people see your name and your photo, and your friends see whether you are playing. Whoever is with you in a room or in a conversation reads what you write, hears your voice and sees your camera and your screen, when you turn them on, and can record without us knowing. In the Salas, that person can also find out where you connect from. The microphone goes to the game as soon as the match starts, and in the game there may be people you do not know listening. We do not sell any of this and do not use it for advertising. If you or your parent or guardian wants to delete everything, your parent or guardian writes to privacidade@thunderx.games.

For those under 18 the same applies as for everyone — the minimum, only for the service to work — plus these safeguards of the law:

• Best interest. Data of a child or adolescent is processed in their best interest (LGPD, Article 14). It never goes to advertising or to behavior profiling — which, here, already applies to everyone. The news notifications do not use age or profiling: they go the same to everyone who has the switch turned on (item 3.8).
• Children (under 12). The LGPD requires that the father, the mother or the guardian agree to the use of a child's data. When the date of birth gives less than 12 years, sign-up shows one more box — "O meu pai, a minha mãe ou o meu responsável está comigo, leu os Termos e concorda com o uso dos meus dados" ("My father, my mother or my guardian is with me, has read the Terms and agrees to the use of my data") —, and without it the account is not created. The account's e-mail can be the parent or guardian's. The record keeps that the box was checked (item 3.4). Nobody checks who checked it. If we learn that an account belongs to a child without the parent or guardian's agreement, we delete the account.
• The store accounts. Each store has its minimum age and its rules for a child's account — Steam, for example, does not accept an account from someone under 13 years old. They apply when the account is linked. For a child, we recommend using the parent or guardian's store account or a family account of the store. Thunder X does not check which store account is linked. On Steam, the family controls stay in the account, and it is Steam's program that opens the game on the seat. On Epic and Amazon, the game opens through a program that is not the store's: assume that the age-based game blocking they do in their own program does not apply on the seat. If the store account has a card or balance, the child is able to buy inside the seat.
• Games and age rating. Each game's age rating (classificação indicativa) appears on its info sheet, as information. It does not bar anyone. The ones who control what the child plays and buys are the parent or guardian and the store account — on Steam, with its family controls. Thunder X does not use the date of birth for that.
• The Estúdio. The streaming platforms have their own minimum age. Thunder X does not lock the Estúdio by age: it is up to the parent or guardian.
• There is no parental supervision tool inside Thunder X. The parent or guardian does not have today a panel to see or limit the use of a child's account.
• Parents and guardians can ask, at any time, that we delete their child's data — the account, the acceptance record and whatever there is of it. Write to denuncia@thunderx.games with the subject "URGENTE · MENOR NO THUNDER X" ("URGENT · MINOR ON THUNDER X") (or to privacidade@thunderx.games, which we handle the same way) saying who you are, whether you are the father, the mother or the guardian, the account's e-mail and, if you know it, the name your child uses here. We do not ask for a document at the start; we ask only for what is necessary to find the account. A person replies within 24 hours. We also delete their account on the Salas, the app's chat, if there is one: you do not need to ask separately (item 9.4).

If a report involves a violation of the rights of a child or adolescent, we preserve what we have and notify the authorities, as the law requires (item 7.10).

12. Cookies and what stays on your computer

We use only necessary cookies. There is nothing to accept or refuse.

What else stays on the computer through the installable app is in item 3.2. The Salas have their own cookies, described in the Salas Policy.

There is no advertising or measurement cookie. The usage log (item 3.16) uses no cookie: it goes with the session you already have. From third parties, only Stripe's, which are necessary for the payment and only appear when you buy credits. That is why we do not show a cookie banner: there is nothing for you to accept or refuse. If one day there is, we ask first.

You can delete the cookies and the site's data in the browser's settings; when you delete them, you are signed out of the account. In the app, "Sair" deletes the session kept on the computer, and uninstalling does not delete the data folder (item 3.2).

On a shared computer — school, internet café, event booth, a friend's house —, click "Sair" before you leave. Otherwise, your account stays open to whoever uses the computer afterwards.

13. Security

We do what is below, and we do not promise what we do not have.

What we do:

• Everything works only over an encrypted connection (HTTPS). The voice and the conversations also travel encrypted, and so does the game stream, with the caveat of item 3.6.
• The account password is stored scrambled (scrypt), with no way to read it back. The store password never reaches us.
• The store keys stay outside the accounts database: those of Epic, Amazon and Xbox, on an encrypted disk, in a folder that is yours alone on the seat host computer; the Steam login, in a separate vault (the AWS Parameter Store, encrypted), and its preferences, in an encrypted bucket with public access blocked.
• The databases and their backups are encrypted. Today, the copy of the disk of a machine with an owner, when taken during a change or a maintenance, is not encrypted; it is deleted within 30 days (item 3.6).
• The card data never reaches our servers: the payment form is Stripe's (item 3.15).
• The profile photo and cover stay at a public, random address, with no list to browse (section 4).
• The access log is locked against deletion before the deadline, and only the person who administers the servers reads it.
• A filter at the entrance blocks known attacks, and there is a request limit against bots.
• The shared seat is erased entirely at the end of each session. The program that streams the game only accepts your computer, by the certificate the app sends at each match (item 3.2).
• There is a lock of one seat per account.
• The installable app has the code of the main process protected. The update comes only from our address (dl.thunderx.games; in the test versions, dl.thunder-x.com), and the app checks the file before installing.

No system is proof against everything. We have no security certification. The Windows installer is not yet digitally signed: the system's warning at the first installation ("editor desconhecido", "unknown publisher") is because of that.

14. Backup

The account has a backup for 35 days, and that is why what you delete takes up to 35 days to be gone for good.

The Thunder X databases — accounts, profiles, friends, game sessions and sign-ins to the account (with the IP), linked stores, conversations, notifications, the credit wallet, the profile photo and cover, the "Fale com a gente" ("Talk to us") reports (with the screenshot), the crash reports, the acceptance record and the team's panel — have an automatic backup, kept for 35 days, encrypted, in São Paulo. The vault of these backups has a lock against deletion.

The copies of the disk of the machines with an owner, when they exist, follow item 3.6.

The other side: of the account or the message you delete, whatever is in a backup is only gone when it expires, within 35 days. In that time, the backup is not used for anything, except to recover the service after a loss. This also applies to what we delete by deadline (items 3.4, 3.6 and 3.9): after the deadline, it still stays up to 35 days in the backup.

These have no backup: the support system (item 3.10) and the Epic, Amazon and Xbox keys, which stay on the disk of the seat host computer. If they are lost, the conversation is lost and you link the store again.

15. If there is an incident

A security incident is a leak, improper access or loss of data. If one happens that may bring relevant risk or harm to you, we notify the ANPD and we notify you. The deadline is the one in the regulation: today, 3 business days, counted from when we learn that personal data was affected.

How we notify: by e-mail, to the account's address; and with a notice on the site and in the app, which stays up for at least 3 months. If a store key or the Steam login may have leaked, we notify you separately, unlink the store and ask you to change the password at the store.

We keep the record of every incident for 5 years.

16. Changes to this Policy

We give notice beforehand, saying what changes.

• A change that affects the use of your data — new purpose, new sharing, longer period: we give notice on the site, in the app's Notifications (Avisos) and on this page, at least 30 days in advance, saying what changes and when. It is the same deadline and the same path as the Terms. If the change also touches the Terms, they ask for a new acceptance, as their rules on changes say.
• The Windows installer shows the texts when you install the app; the macOS one and the Linux one do not, and the automatic update shows nothing. That is why the notice of change comes in the app itself and on the site.
• A text correction, a requirement of law or a security measure may take effect right away, with notice.
• If the change creates a use that depends on your consent, we ask first.
• The version and the date stay at the top. The history stays at the end of this page, and the full text of each version stays online, at its own address (for example, /privacidade/1.0).

17. ANPD and other ways to complain

Talk to us first, if you want: privacidade@thunderx.games. You can also complain to the National Data Protection Agency (Agência Nacional de Proteção de Dados, ANPD), the Brazilian data protection authority — gov.br/anpd — and to the consumer protection bodies, such as Procon (the consumer protection agency). Talking to us first is not mandatory.

18. Version history

• 1.0 — October 2, 2026 — First version: open to any age, with the date of birth at sign-up, the parent or guardian's agreement for under 12 years old and the acceptance record with the IP for 6 months.
• 1.1 — October 4, 2026 — When buying credits, we ask for the name and, if you want, the CPF, only to issue the invoice (nota fiscal). It takes effect immediately, as a legal requirement, with notice (item 16), and does not ask for a new acceptance (item 2.2).
• 1.3 — October 4, 2026 — The invoice name also goes to Stripe, in a customer record, so the invoice (nota fiscal) carries it without you typing it again on the payment page. It takes effect immediately, as a legal requirement, with notice (item 16), and does not require a new acceptance (item 2.2).
• 1.2 — October 4, 2026 — The CPF becomes required when buying credits and goes to Stripe, in the field of the payment page, from which Spedy, which issues the invoice (nota fiscal), reads it. It takes effect immediately, as a legal requirement, with notice (item 16), and does not ask for a new acceptance (item 2.2).
• 1.4 — October 4, 2026 — When buying credits we now ask for the address (postal code, number and complement), which the invoice for an online service requires since the tax reform. The postal code is looked up at BrasilAPI or ViaCEP, and the address goes to Stripe and to Spedy. It takes effect immediately, as a legal requirement, with notice (item 16), and does not require a new acceptance (item 2.2).

• 1.5 — October 5, 2026 — The Stripe payment page now always asks for the billing name and address, and that address is the one that goes on the invoice (nota fiscal). It takes effect immediately, as a legal requirement, with notice (item 16), and does not require a new acceptance (item 2.2).
• 1.6 — October 6, 2026 — The app now asks only for the CPF when buying credits; the name and the address on the invoice are asked only on the Stripe payment page. It takes effect immediately, as a legal requirement, with notice (item 16), and does not require a new acceptance (item 2.2).
• 1.7 — October 6, 2026 — The app no longer asks for or keeps the CPF, the name and the address for the invoice: everything is asked on the Stripe payment page, and Spedy reads it from there. The invoice data we had kept was deleted (from the backups, it is gone within 35 days); the customer records created at Stripe between October 4 and 6 remain there. It takes effect immediately, as a legal requirement, with notice (item 16), and does not require a new acceptance (item 2.2).
• 1.8 — October 10, 2026 — The usage log of the app, the site and the overlay, linked to the account, with the "Ajudar a melhorar o Thunder X" switch to turn it off, and the log of what the account does on our servers, for 12 months (item 3.16). In force from this date.