1. Introduction
Welcome to the Privacy Policy of Chave da Liberdade Empreendimentos e Marketing Digital Ltda. (the “Company”, “we”, “our”, or “us”).
We are committed to protecting the privacy and personal information of our customers, website visitors, users, business partners, and all individuals who interact with our websites, digital products, software applications, services, and online platforms.
This Privacy Policy explains how we collect, use, store, share, and protect personal information across our business operations. It also describes your privacy rights and the choices available regarding the information you provide to us.
We believe that transparency is essential to building trusted relationships. For this reason, we are committed to handling personal information responsibly, securely, and in accordance with applicable privacy and data protection laws.
By accessing or using our websites, digital products, software applications, memberships, digital resources, or other services, you acknowledge that you have read, understood, and accepted the practices described in this Privacy Policy.
2. Who We Are
Chave da Liberdade Empreendimentos e Marketing Digital Ltda. is a Brazilian company dedicated to creating, operating, and managing brands, websites, software applications, digital products, educational resources, e-commerce businesses, and other digital assets for customers worldwide.
The Company owns and operates a growing portfolio of brands, websites, and digital businesses across multiple industries. These operations may include educational content, software tools, memberships, online courses, digital publications, e-commerce stores, and other digital solutions designed to provide practical value to individuals and organizations.
Depending on the website, platform, product, or service you use, Chave da Liberdade Empreendimentos e Marketing Digital Ltda. acts as the data controller responsible for collecting and processing personal information as described in this Privacy Policy.
If you have any questions regarding this Privacy Policy or the processing of your personal information, you may contact us using the information provided in the Contact Us section of this Privacy Policy.
3. Scope of This Privacy Policy
This Privacy Policy applies to the collection, use, storage, disclosure, and protection of personal information processed through the business activities of Chave da Liberdade Empreendimentos e Marketing Digital Ltda.
Unless a separate privacy policy is explicitly provided for a specific product, service, or platform, this Privacy Policy applies to all websites, software applications, digital products, online services, memberships, educational resources, online courses, e-commerce operations, newsletters, mobile applications, and other digital platforms owned or operated by the Company.
This Privacy Policy also applies to the Company’s current and future brands, websites, digital businesses, products, and online services, unless otherwise stated.
Our business may evolve over time through the creation, acquisition, expansion, licensing, operation, or discontinuation of brands, products, services, websites, software applications, digital assets, and other business activities. This Privacy Policy is intended to remain applicable to those operations unless a different privacy policy is expressly provided.
If any specific website, application, product, or service operated by the Company publishes its own privacy policy, that policy will govern the processing of personal information for that particular service to the extent of any inconsistency with this Privacy Policy.
4. Information We Collect
The personal information we collect depends on how you interact with our websites, digital products, software applications, online platforms, and other services.
We may collect information directly from you, automatically through your use of our services, or from third-party sources, where permitted by applicable law.
The categories of personal information we may collect include:
Information You Provide
We may collect personal information that you voluntarily provide when you:
- Contact us through our websites or other communication channels.
- Subscribe to newsletters or email communications.
- Create an account or user profile.
- Purchase products or services.
- Register for memberships, online courses, or educational programs.
- Download digital resources.
- Participate in surveys, promotions, or other voluntary activities.
- Submit customer support requests or other inquiries.
Depending on the circumstances, this information may include:
- Name
- Email address
- Mailing address
- Billing information
- Payment-related information
- Telephone number
- Company or organization name
- Account credentials
- Any other information you voluntarily choose to provide
Information Collected Automatically
When you access our websites, software applications, or online services, certain information may be collected automatically through cookies, server logs, analytics tools, and similar technologies.
This information may include:
- IP address
- Browser type and version
- Device type
- Operating system
- Language preferences
- Time zone
- Pages visited
- Referring website
- Date and time of access
- Session duration
- Clickstream data
- Device identifiers
- General geographic location derived from your IP address
- Diagnostic and technical information
Information From Third Parties
Where permitted by law, we may receive information from third-party service providers, business partners, payment processors, marketing platforms, analytics providers, social media platforms, authentication services, and other publicly available or authorized sources.
Such personal information may be combined with personal information collected directly from you to improve our products, services, security, customer experience, and business operations.
Sensitive Personal Information
Our websites and services are generally not intended to collect sensitive personal information.
Please do not submit sensitive personal information unless it is specifically requested and necessary for the provision of a particular product or service.
If sensitive personal information is collected, it will be processed only when permitted or required by applicable law and subject to appropriate safeguards.
5. How We Use Your Information
We may use the personal information we collect for the following purposes:
Providing Our Products and Services
To operate our websites, software applications, digital products, memberships, online courses, e-commerce platforms, educational resources, and other services, and to provide the products, features, or information you request.
Processing Transactions
To process purchases, subscriptions, payments, refunds, invoices, and other transactions related to our products and services.
Managing Customer Accounts
To create, maintain, authenticate, and manage user accounts, customer profiles, memberships, and access to restricted areas of our websites and platforms.
Customer Support
To respond to inquiries, provide technical assistance, resolve issues, and communicate with you regarding your requests or purchases.
Communications
To send important administrative communications, account notifications, security alerts, service updates, policy changes, and other information related to your relationship with the Company.
Where permitted by applicable law or with your consent, we may also send newsletters, educational content, promotional communications, marketing materials, and information about products, services, or events that may be of interest to you.
You may unsubscribe from marketing communications at any time by following the unsubscribe instructions included in our emails or by contacting us directly.
Improving Our Business
To better understand how our websites, digital products, and services are used, improve user experience, develop new features, enhance existing products, analyze performance, and support business planning and decision-making.
Personalization
To personalize content, recommendations, educational resources, product suggestions, and user experiences based on your interactions with our websites, digital products, and services.
Security and Fraud Prevention
To protect our websites, customers, users, employees, business partners, and operations from unauthorized access, fraud, abuse, security incidents, or other unlawful activities.
Legal and Regulatory Compliance
To comply with applicable laws, regulations, legal obligations, court orders, governmental requests, and other lawful requirements.
Protecting Our Rights
To establish, exercise, or defend the legal rights, property, intellectual property, security, and legitimate business interests of the Company whenever necessary.
6. Legal Basis for Processing Personal Information
To the extent required by applicable privacy and data protection laws, the Company processes personal information only when a valid legal basis exists.
Depending on the circumstances and the applicable laws, the legal bases for processing personal information may include:
Consent
Where required, we process personal information based on your freely given, specific, informed, and unambiguous consent. You may withdraw your consent at any time, although such withdrawal will not affect the lawfulness of any processing carried out before the withdrawal.
Performance of a Contract
We may process personal information when necessary to enter into, perform, manage, or fulfill a contract with you, including providing products, services, memberships, software applications, online courses, customer support, and related business activities.
Compliance with Legal Obligations
We may process personal information when necessary to comply with applicable laws, regulations, court orders, governmental requests, tax obligations, accounting requirements, or other legal responsibilities.
Legitimate Business Interests
We may process personal information when necessary for our legitimate business interests, provided that those interests are not overridden by your fundamental rights and freedoms.
These legitimate interests may include improving our products and services, maintaining website security, preventing fraud, protecting our intellectual property, conducting business analysis, improving customer experience, and supporting the efficient operation of our business.
Protection of Vital Interests
In limited circumstances, we may process personal information when necessary to protect the vital interests of an individual or another natural person, where permitted by applicable law.
Other Lawful Bases
Where permitted by applicable law, we may also process personal information on other lawful grounds recognized by the applicable privacy and data protection legislation.
7. Cookies and Similar Technologies
Our websites, software applications, and online services may use cookies and similar technologies to enhance functionality, improve user experience, analyze website performance, maintain security, and support our business activities.
Cookies are small text files that are stored on your device when you visit a website. Similar technologies may include web beacons, pixels, tags, local storage, scripts, software development kits (SDKs), and other technologies that perform comparable functions.
We use these technologies for purposes including:
- Ensuring the proper operation of our websites and services.
- Remembering user preferences and settings.
- Maintaining security and preventing fraudulent activity.
- Measuring website traffic and user engagement.
- Understanding how visitors interact with our websites and services.
- Improving website functionality, content, and performance.
- Supporting marketing, advertising, and communication activities where permitted by applicable law.
The categories of cookies and similar technologies used across our websites and services include:
Essential Cookies
These cookies are necessary for the operation, security, and basic functionality of our websites and services. Without them, certain features may not function properly.
Functional Cookies
These cookies allow our websites to remember your preferences and provide enhanced functionality and a more personalized experience.
Analytics Cookies
These cookies help us understand how visitors use our websites, identify trends, measure performance, and improve the quality of our products and services.
Performance Cookies
These cookies collect information about the performance of our websites and services, helping us optimize speed, reliability, and overall user experience.
Advertising and Marketing Cookies
Where applicable, these cookies may be used to deliver relevant advertising, measure the effectiveness of marketing campaigns, limit repetitive advertisements, and better understand user interests.
Depending on your location and applicable law, you may have the ability to manage, refuse, or delete certain cookies through your browser settings, our cookie management tools, or other consent mechanisms made available on our websites.
Please note that disabling certain cookies may affect the functionality, availability, or performance of some features of our websites and services.
8. Sharing of Information
We value your privacy and do not sell your personal information to third parties.
We may share personal information only when necessary to operate our business, provide our products and services, comply with legal obligations, protect our legitimate interests, or where required or permitted by applicable law.
Personal information may be shared with the following categories of recipients:
Service Providers
We may share personal information with trusted third-party service providers that support the operation of our websites, digital platforms, products, services, and other business activities.
These providers may perform services such as:
- Website hosting
- Cloud storage
- Payment processing
- Order fulfillment
- Customer support
- Email communications
- Marketing services
- Analytics and reporting
- Security monitoring
- Fraud prevention
- Technical infrastructure
- Software development
- IT support
These service providers are authorized to process personal information only as necessary to perform services on our behalf and are expected to protect that information in accordance with applicable laws and contractual obligations.
Business Partners
We may share personal information with business partners when necessary to provide products, services, joint initiatives, promotional campaigns, educational programs, or other business activities.
Legal Requirements
We may disclose personal information when we believe such disclosure is necessary to:
- Comply with applicable laws or regulations.
- Respond to lawful requests from governmental authorities.
- Comply with court orders or legal proceedings.
- Protect the rights, property, safety, or security of the Company, our customers, users, employees, business partners, or others.
- Investigate fraud, security incidents, or unlawful activities.
Corporate Transactions
If the Company undergoes a merger, acquisition, investment, financing, restructuring, sale of assets, transfer of business operations, or other corporate transaction, personal information may be transferred as part of that transaction, subject to applicable legal requirements.
With Your Consent
We may share personal information for other purposes when you have provided your consent or when otherwise permitted by applicable law.
9. International Data Transfers
As an international business, the Company may process, store, transfer, or access personal information in countries other than the country in which you reside.
Our operations rely on trusted service providers, technology platforms, cloud infrastructure, payment processors, communication services, analytics providers, and other third-party partners that may operate in multiple jurisdictions around the world.
As a result, your personal information may be transferred to, stored in, or processed in countries whose data protection laws may differ from those of your country of residence.
Whenever personal information is transferred internationally, we take reasonable steps to ensure that appropriate safeguards are implemented in accordance with applicable privacy and data protection laws. These safeguards may include contractual protections, technical and organizational security measures, and other legally recognized mechanisms designed to protect personal information.
By using our websites, digital products, software applications, or services, you acknowledge that your personal information may be transferred and processed internationally as described in this Privacy Policy.
10. Data Retention
We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, including providing our products and services, operating our business, complying with legal obligations, resolving disputes, enforcing our agreements, protecting our legal rights, and maintaining legitimate business records.
The length of time we retain personal information depends on several factors, including:
- The nature of the information collected.
- The purpose for which the information was collected.
- Whether an ongoing customer relationship exists.
- Applicable legal, regulatory, accounting, or tax requirements.
- Security, fraud prevention, and business continuity needs.
- The exercise or defense of legal claims.
When personal information is no longer required for the purposes for which it was collected, we will take reasonable steps to securely delete, anonymize, or otherwise dispose of the information, unless continued retention is required or permitted by applicable law.
In certain circumstances, anonymized or aggregated information that no longer identifies an individual may be retained for research, statistical analysis, business planning, product improvement, or other lawful business purposes.
11. Your Privacy Rights
Depending on your country of residence and the privacy laws that apply to you, you may have certain rights regarding your personal information.
These rights may include the ability to:
- Request access to the personal information we hold about you.
- Request correction of inaccurate or incomplete personal information.
- Request deletion of your personal information, subject to applicable legal limitations.
- Request restriction of the processing of your personal information in certain circumstances.
- Object to the processing of your personal information where permitted by applicable law.
- Request the transfer or portability of your personal information where applicable.
- Withdraw your consent at any time when processing is based on your consent. The withdrawal of consent will not affect the lawfulness of processing carried out before such withdrawal.
- Request information about how your personal information is collected, used, shared, and protected.
- Submit a complaint to the appropriate supervisory or regulatory authority if you believe your privacy rights have been violated.
To exercise any of your privacy rights, please contact us using the information provided in the Contact Us section of this Privacy Policy.
Before processing certain requests, we may need to verify your identity to protect your personal information and prevent unauthorized access.
Please note that some requests may be limited or denied where permitted or required by applicable law, including situations involving legal obligations, fraud prevention, security requirements, the protection of the rights of others, or the establishment, exercise, or defense of legal claims.
We will respond to privacy-related requests within the timeframes required by applicable law.
12. Data Security
We take the security of personal information seriously and implement reasonable administrative, technical, organizational, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, loss, misuse, or destruction.
Our security measures are designed to reflect the nature of our business, the sensitivity of the information we process, and applicable legal requirements. We continually review and improve our security practices as our business, technologies, and regulatory obligations evolve.
While we strive to protect personal information using commercially reasonable security measures, no method of transmitting information over the Internet or storing electronic information can be guaranteed to be completely secure. Accordingly, we cannot guarantee the absolute security of any personal information.
If we become aware of a security incident involving personal information, we will respond in accordance with applicable laws and take appropriate measures to investigate, mitigate, and address the incident.
13. Children’s Privacy
Our websites, digital products, software applications, and services are intended for a general audience and are not directed toward children.
We do not knowingly collect personal information from children in violation of applicable law.
If you believe that a child has provided personal information through our websites or services without appropriate authorization, please contact us. If we become aware that personal information has been collected from a child in violation of applicable law, we will take reasonable steps to delete that information as required.
Parents and legal guardians who have questions regarding a child’s personal information may contact us using the information provided in the Contact Us section of this Privacy Policy.
14. Third-Party Links
Our websites, digital products, software applications, and services may contain links to third-party websites, applications, services, marketplaces, or other external resources provided solely for your convenience or informational purposes.
We do not own or control these third-party services and are not responsible for their privacy practices, content, security, availability, or policies.
We encourage you to review the privacy policies and terms of service of any third-party website or service before providing personal information or engaging in any transaction.
The inclusion of a link to a third-party website does not constitute an endorsement, recommendation, or approval of that website, its products, or its services unless expressly stated by the Company.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our business activities, products, services, technologies, legal requirements, or privacy practices.
When we make material changes to this Privacy Policy, we will publish the updated version on this page and revise the Last Updated date accordingly. Where required by applicable law, we may also provide additional notice through our websites, email communications, or other appropriate channels.
Your continued use of our websites, products, software applications, services, or other business activities after an updated Privacy Policy becomes effective constitutes your acknowledgment of the revised Privacy Policy, to the extent permitted by applicable law.
We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, protect, and manage personal information.
16. Contact Us
If you have any questions, requests, concerns, or comments regarding this Privacy Policy or our privacy practices, please contact us:
Chave da Liberdade Empreendimentos e Marketing Digital Ltda.
Email: contact@chavedaliberdade.com
We will make reasonable efforts to respond to privacy-related inquiries as promptly as possible and in accordance with applicable privacy and data protection laws.
17. Governing Law
This Privacy Policy shall be governed by and interpreted in accordance with the laws applicable to the business operations of Chave da Liberdade Empreendimentos e Marketing Digital Ltda., without prejudice to any mandatory rights or protections granted to individuals under the applicable privacy and data protection laws of their country or jurisdiction.
Nothing in this Privacy Policy is intended to limit or exclude any rights that cannot be waived or restricted under applicable law.
Last Updated: July 31, 2026
This Privacy Policy represents the Company’s current privacy practices and supersedes all previous versions unless otherwise stated.