[Template] Data Privacy Policy. Important: This document serves as a basic template for a privacy policy. If you are located in a country or region with specific laws regarding the management of personal data, it is recommended that you seek professional guidance to draft your policy. Sagui.AI provides only the platform for creating your website and does not offer any kind of legal support. Below is a template to be filled in and reviewed with the support of legal professionals. 1. Introduction Welcome to the website of [company name]. At [company name]… (insert brief description). The processing of personal data is a condition for using the portal, features, or site ('platform') of [company name], and it is not possible to offer the benefits of our services, promotions, and access to free content without access to your personal data. We at [company name] understand that your personal data ('Data') are valuable assets and must be securely maintained. Therefore, in this Policy, we will strive to make it clear how and why we use your data. 2. Key concepts 2.1. What is personal data? Personal data is information that identifies a natural person, for example: email, identification document, phone number, and address. When Personal Data pertains to racial or ethnic origin, religious belief, political opinion, union membership, or to an organization of a religious, philosophical, or political nature, data relating to health or sex life, genetic or biometric data, when linked to a natural person, are considered Sensitive Personal Data and must be treated even more carefully by companies. 2.2. What are cookies? While browsing the internet, when you access social media sites, news, online stores, among others, they may send small text files (cookies) to your browser to record your behavior. Among other purposes, they serve to identify the user and their preferences, adjust the language once chosen by you, measure and analyze activity on the site for navigation improvements, and display ads according to the user's specified profile. 2.3. What is LGPD? [Brazil] LGPD stands for Lei Geral de Proteção de Dados (General Data Protection Law, Law No. 13.709/2018). LGPD establishes rules on the collection, storage, and sharing of personal data, attributing and guaranteeing the protection of personal data of Brazilian citizens within and outside Brazil. 3. How and what data do we collect? 3.1. Through your registration on [company name] platforms and projects When you create a user on the course platform or in promotional forms (free or paid period), we may ask for your full name, email, ID, cell phone number, full address, date of birth, credit card details, and creation of login and password. Additionally, we may ask you if you want to include your photo (when the condition in the form exists) to customize your client area, but this item is not mandatory. 3.2. Through navigation on the platform When you browse our platform, fill out forms, participate in promotions and online events, and other interactions you may have in our services. Also, when you access through different devices such as: notebook, computer, cell phone, or other access device. The Data we collect in this case are: your approximate location (latitude and longitude), your IP address, information about your access device (type of operating system, device model), information about your internet connection; type of browser and the pages and content you access on our Services. 3.3. Through third parties We may also use some of your Data through publicly available sources, service providers, and our partners. 3.4. Through cookies Through the use of cookies, we identify your visit habits, preferences, deliver ads, and audience analysis. - What are cookies? Cookies are small text files sent and stored on your computer. These small files are used to recognize, track, and store your browsing as a user on the Internet. - How does our site use cookies and other tracking technologies? We use cookies and other tracking technologies to identify you and your interests, remember your preferences, and track the use of our platform. We also use cookies and other tracking technologies to control access to certain content on our platform, protect them, and process any requests you make to us. - What are the categories and purposes of cookies? Strictly necessary/technical Necessary for the operation of the platform, without them it becomes impossible to execute some functionalities of the platform. They allow you to navigate and use the services and resources (for example, security cookies to authenticate users, prevent fraudulent use of login credentials, and protect user data from unauthorized third parties). Therefore, it is not possible to refuse these cookies if you want to browse and consume our content. Analytics/Performance Collect information anonymously, that is, the results we receive from this analysis are provided in an aggregated form and do not allow direct or indirect identification of the User. These cookies allow us to determine information such as the number of visitors to a page, how visitors came to the site, and the pages accessed. For example, these cookies track the pages that are visited most frequently and the location of our visitors. These cookies include, for example, Google Analytics cookies. Functionality Cookies in this category allow us to operate the platform with the choices you make. They allow us to 'remember' your previous visits to the platform. For example, we will recognize your username and remember how you customized your content within the platform, allowing us to offer you, whenever you return to the platform, the same customizations made previously. Advertising and targeting These cookies collect information about your activities on the platform and on other websites to provide targeted advertising. We may also allow our third-party service providers to use cookies on the platform for the same purposes identified above. Third-party service providers generating these cookies, such as Google, Facebook, among others, have their own privacy policies and may use their cookies to target advertising to you on other websites based on your visit to our platform. - Use of third-party cookies Service providers, with our authorization, may use their own cookies on the Services. Such cookies collect your Data on our properties for the purposes set forth in this policy. 'Third-party cookies' are cookies that third parties place on your device through our platform, for the purpose of helping us measure and improve the effectiveness of our communications. For more information on how these companies collect and use information on our behalf, see their respective privacy policies at: Google and Facebook - What cookies do we use? Name: Active Campaign Provider: Active Campaign Purpose: Mail Marketing Validity: 60 days for users who have not had any interaction Type: Marketing Name: Facebook Ads Provider: Facebook Purpose: Ads Validity: We do not have individualized data Type: Marketing Name: Google Ads Provider: Google Purpose: Ads Validity: We do not have individualized data Type: Marketing Name: Google Analytics Provider: Google Purpose: Statistics Validity: We do not have individualized data Type: Statistics Name: Google Optimize Provider: Google Purpose: Statistics Validity: We do not have individualized data Type: Statistics Name: Google Tag Manager Provider: Google Purpose: Statistics Validity: We do not have individualized data Type: Statistics - How do I change or block cookies? Browsers are usually set to accept cookies. However, you can change these settings at any time to block or alert you when a cookie is being sent to your device. There are several ways to manage cookies: you can block cookies from a specific site, block third-party cookies in relation to a site, or even block all cookies. But be aware, blocking all cookies will affect the functioning of your experience, as it will not be possible to identify your preferences on the platform or recommend relevant content and advertising to you. To learn more about cookie settings, see your browser's instructions, and remember that you must make this chosen configuration on all devices used to access the Services (such as computers, smartphones, tablets). Check the respective settings of the main browsers at: Internet Explorer, Edge, Chrome, Safari, Firefox, and Opera. 4. For what purposes do we use your Data? 4.1. Provide personalized services to you We collect your Data so that we can deliver content, process payments, and direct Services of interest to you. Your Data helps us create a personalized experience according to your interests. 4.2. Communicate with you differently We collect your Data to improve our Services, improve our technical and operational support by responding as soon as possible to your requests when you contact us. 4.3. Increase security and protect your rights Some Data are kept stored to prevent illegal and suspicious activities. 4.4. Improve and develop new services We use your Data in data research and analysis (analytical intelligence) to improve and offer new services. 4.5. Fulfill legal obligations We keep your Data so that, if necessary, we can fulfill legal and regulatory obligations, judicial or administrative. 5. How do we treat children's Data? We seek not to collect data from children (individuals under 13 years of age). The minimum age to use our platform, participate in promotions, and offers is 13 years old. Before storing data, we request age validation, at the time of registration, the ID and date of birth of the user. 6. Who do we share your Data with? 6.1. We share with third parties We share your Data with some of our partners who help us execute our Services, such as partners: payment method providers and integrators, credit card companies, marketing and advertising service providers, judicial, police, or governmental authorities, service providers for maintenance of our platform, data analysis aiming at enriching the database for customization and improvement of services. All service providers are contractually obligated to confidentiality, as well as to respect the applicable Law and the terms of our Policy. 7. Hyperlinks to other internet sites Our platform may contain access links to other internet sites (hyperlinks). Remember that our Policy applies only to our platform for accessing our Services. We recommend that when clicking on a link to another site, you read their privacy policy. 8. How do we protect your Data? We use market technical standards to maintain the security and privacy of your Data. We have comprehensive actions in technology and organizational processes. We adopt measures to preserve your Data against unauthorized access, alteration, use, and destruction, including: access management, physical asset management, encrypted communications, and internal cybersecurity policies. 9. You in control - Your user rights At any time, you can decide on the update and treatment we may give to your Data. You can, free of charge, revoke a previously given consent, correct, update, or delete your Data. To do so, if you wish to perform any of the previous actions, or even if you just want to understand more, ask questions or confirm the existence of any treatment, please contact our privacy team at [company contact email]. If you request the update, correction, or even the deletion of your Data, we will meet the request within 15 days. After deletion, we may retain your Data only (a) for the period necessary for judicial, administrative, and arbitral proceedings, (b) to comply with legal and/or regulatory obligations, (c) for the regular exercise of rights, such as enforcing rights based on the subscription contract and/or applicable Terms or (d) in anonymized format. We store your data for the entire period you browse our platform and use our services, or if you are a potential customer and want to follow our news. If you remain inactive on our platform for a period of 1 (one) year from the last visit you make to us, we will delete your data from our database. 10. International Data Transfer To offer our services, some of your Data may be transferred to other countries; this transfer will occur when we use cloud services for data processing or storage located outside Brazil. Rest assured, in these situations, we will also meet all the requirements established in the current Law and in this Policy, in addition to adopting the best market practices to ensure the protection and privacy of your Data. 11. Contact Get in touch with us if you have any requests, questions, or suggestions regarding our Policy. Data protection officer [contact email of the responsible person] Support team [support email of your company] Or access the frequently asked questions section on our website.