LGPD is mostly a contractual standard for a Bubble app. Bubble lists Brazil's law in its "Other frameworks" page for information only, and the standard Bubble DPA can be adapted to LGPD's transfer mechanics under ANPD Resolution 19/2024. For most Brazilian deals, Bubble Enterprise plus an LGPD-aware DPA addendum and a Brazilian DPO appointment is enough. A rebuild only earns its keep when the buyer insists on São Paulo-region data residency, which Bubble's shared tier can't deliver.
The honest verdict
Not officially. Not the way you’d ship LGPD in production.
Bubble has no public stance. The platform's architecture makes a real audit hard. Bubble lists LGPD in its "Other frameworks" page as a one-line description of Brazil's law, without claiming the platform itself meets the standard. Brazilian residency isn't on the shared tier — only Enterprise dedicated lets you pick an AWS region, and São Paulo isn't named among the worked examples in the manual. The controller-side work belongs to the developer.
National data privacy and protection law in Brazil
Reviewed by
Greg· Founder, bubbletocode.com — has migrated 30+ Bubble apps to code
Bubble's stance
Silent
Listed in "Other frameworks" for information
Worst-case penalty
R$50M / infraction
Up to 2% of prior-year Brazilian revenue
Industries impacted
B2B SaaS · Consumer · Fintech · Retail · AI / data
Compliant rebuild
$40k–$100k · 6–14 weeks
Only when Brazilian residency forces it
What LGPD actually requires
LGPD is Brazil's GDPR-style law. The Autoridade Nacional de Proteção de Dados (ANPD) enforces it. Simple fines run up to 2% of an entity's prior-year Brazilian revenue (net of taxes), capped at R$50 million per infraction, plus daily fines, publicity, and processing bans.
Process personal data only under one of the ten lawful bases in Article 7 (or Article 11 for sensitive data) and document the basis (LGPD Art. 7; Art. 11).
Give data subjects clear information and honour rights of access, correction, deletion, portability, and objection within statutory timeframes (LGPD Arts. 9, 18).
Appoint a Data Protection Officer (Encarregado), including a substitute, on the terms required by ANPD guidance (LGPD Art. 41; ANPD Resolution CD/ANPD No. 18/2024).
Adopt technical and administrative security measures sized to the risk and the volume and sensitivity of the data (LGPD Arts. 46–47).
Notify the ANPD and affected data subjects of security incidents that may cause risk or significant harm (LGPD Art. 48; ANPD Resolution CD/ANPD No. 15).
Use a valid international-transfer mechanism — the new ANPD Standard Contractual Clauses (Resolution No. 19/2024, replacement deadline Aug 22, 2025), BCRs, or adequacy (LGPD Arts. 33–36).
Official source: gov.br
Why Bubble fails LGPD
Every reason below comes from Bubble’s published platform limits or their own documentation. Reading the list top-to-bottom tells you which one will bite you first.
Shared-tier apps live in US AWS, full stop. LGPD does not require local residency, but a São Paulo buyer's procurement team often does — especially in regulated sectors. Bubble Enterprise dedicated lets you pick an AWS region, but the manual's worked examples for Enterprise regions don't name Brazil, so you have to confirm with Sales before promising sa-east-1 to a buyer.
Sources[03]
Bubble's "Other frameworks" page lists LGPD with a one-line description and no claim of compliance. The standard Bubble DPA covers GDPR-style transfers, but adapting it to LGPD's new ANPD SCCs (Resolution 19/2024, replacement deadline Aug 22, 2025) and naming the Encarregado is on the developer and a willing Bubble Sales contact.
Bubble's continuous point-in-time backups default to a 20-year window on Enterprise dedicated. LGPD Article 18 deletion rights apply across copies, so the controller has to document how erasure is squared with the backup chain. Shared-tier shops have even less control — backup-window configuration is an Enterprise option, not a shared one.
Sources[04]
LGPD Article 48 and ANPD Resolution CD/ANPD No. 15 expect notification of incidents that may cause risk or significant harm. Bubble publishes an annual pen-test programme and a 99.9% uptime SLA for Enterprise dedicated but no contractual hours-based breach SLA. Your IR playbook needs to assume you may not get a same-day Bubble confirmation of an incident.
Sources[06]
Third-party Bubble plugins load JavaScript into the user's browser and may ship server actions on Bubble's servers. Each is a separate operator / sub-operator relationship under LGPD that the controller has to inventory and contract with. Bubble's DPA does not extend to plugins, so the Brazilian DPO needs to assess each one independently.
Sources[05]
Bubble vs a compliant stack
The same 7requirements an auditor will ask about, scored on both stacks. Read across each row — every red cell is a deal you can’t close on Bubble.
LGPD-flavoured DPA / processor terms
Partial
Adapt standard DPA via addendum
ANPD Resolution 19/2024 alignment is on you
Pass
LGPD-native DPA with your host
Brazilian data residency
Partial
Enterprise dedicated only, confirm with Sales
Shared tier stays in the US
Pass
sa-east-1 pinned in your contract
Encarregado / DPO appointment + records
Partial
Yours to appoint and register
Partial
Yours to appoint and register
Article 18 deletion across backups
Partial
20-year default; 8-day minimum
Enterprise only
Pass
Backup window under your control
ANPD breach-notification path
Fail
No hours-based SLA documented
Pass
Contracted hours-based SLA
International transfer mechanism (Res. 19/2024)
Partial
Add via DPA addendum
Pass
SCCs annex in your DPA
Long-retention audit trail for ANPD inquiries
Fail
Logs limited to two weeks
Pass
Immutable log shipped to long-term store
What it costs your business
LGPD deals usually die in legal review when the buyer's DPO asks for an LGPD-flavoured DPA, an ANPD-aligned transfer mechanism, and a named Brazilian Encarregado. Bubble Enterprise plus a well-drafted LGPD addendum to the DPA covers the legal asks. The ANPD has gone from quiet to active — R$98 million in fines from 2023 to 2025 and the Meta suspension in 2024 made the point.
A Brazilian retailer's DPO blocks the contract on an LGPD-flavoured DPA addendum and a named Encarregado — the standard Bubble DPA needs to be supplemented with ANPD-specific clauses.
A São Paulo enterprise buyer requires data to land in Brazil — only Bubble Enterprise dedicated lets you pick a region, and you'll need Sales to confirm sa-east-1 is on the menu.
An incident triggers Article 48 notification and the controller can't evidence the breach window because Bubble's log search is limited to two weeks — the ANPD inquiry escalates.
An LGPD Article 52 simple fine reaches up to 2% of prior-year Brazilian revenue, capped at R$50 million per infraction — and the ANPD's R$98M of fines from 2023–2025 (Baker McKenzie Global Data & Cyber Handbook) shows enforcement is real, not theoretical.
Three honest paths forward
We don’t recommend a rebuild for every founder. Below: what each path costs you, what it preserves, and where it breaks for LGPD.
Cheapest now · riskiest later
ViableSign Bubble's DPA, attach an LGPD addendum aligning with ANPD Resolution 19/2024 SCCs, appoint a Brazilian Encarregado, ship an LGPD-aware privacy policy, and document the incident-notification path. Move to Bubble Enterprise on a Brazilian or LatAm AWS region if the buyer requires residency.
Pros
Cons
Phased · auditor-defensible
Partial fitKeep Bubble for most of the app; move only the tables a buyer requires kept in Brazil to a separate Next.js service on AWS São Paulo (sa-east-1) or GCP São Paulo under your own LGPD-aligned DPA.
Pros
Cons
Highest upfront · clean audit
ViableOnly justified when the buyer mandates Brazilian residency Bubble can't confirm, or LGPD is layered with another standard that already forces a rebuild. Target stack: Next.js on AWS sa-east-1 (São Paulo) or GCP southamerica-east1 under your own DPA with the ANPD SCCs annex.
Pros
Cons
Composite case study
B2B SaaS · 12 months on Bubble · Brazilian retail enterprise pilot
Founder had three Latin-American customers and a Brazilian retailer in late-stage procurement when the buyer's DPO asked for an LGPD-flavoured DPA addendum, a named Encarregado, and an ANPD Resolution 19/2024-aligned transfer clause. The team negotiated the LGPD addendum on top of Bubble's DPA with Sales, retained a Brazilian Encarregado, drafted an LGPD-aware privacy policy in Portuguese, and inventoried plugins for additional-operator relationships. Brazilian residency wasn't a hard requirement, so the app stayed on Bubble Enterprise on a US AWS region with the SCCs annex doing the transfer work.
Outcome: Brazilian DPO approval in 18 working days; the same artefact pack helped close two more LatAm pilots in the same quarter.
Composite case study assembled from patterns we've seen across multiple LatAm privacy migrations. Anonymised for client privacy — happy to walk you through the actual ANPD-aligned playbooks on a scoping call.
Frequently asked
Pulled from real conversations with founders running healthcare, fintech, and B2B SaaS apps off Bubble. Every answer is grounded in the source we cited above — no marketing fluff.
Sources
The numbered references in the body link here. We cite first-party documents — regulator guidance, vendor manuals, industry standards — never marketing copy.
Bubble Group Inc.manual.bubble.io
Bubble Group Inc.bubble.io
Bubble Group Inc.manual.bubble.io
Bubble Group Inc.manual.bubble.io
Bubble Group Inc.manual.bubble.io
Bubble Group Inc.manual.bubble.io
Autoridade Nacional de Proteção de Dadosgov.br
Presidência da República — Casa Civilplanalto.gov.br
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