Privacy Policy

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1. Introduction

COMERCIAL DISKOL LTDA ("Comercial Diskol", "we", "us", or "our"), registered under CNPJ 03.353.087/0001-79 and headquartered at Rua Raimundo Nonato de Souza, 280, Bela Vista, Ribeirão das Neves – MG, Brazil, is committed to protecting and respecting your privacy.

This Privacy Policy explains how we collect, use, store, share, and protect your personal data when you access or use our digital applications, subscription platforms, and related services (collectively, "Services"). Please read this policy carefully before using our Services.

By using our Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any part of this policy, you should discontinue use of our Services immediately.

2. Information We Collect

We may collect and process the following categories of personal data:

• Identity Data: full name, date of birth, gender, and similar identifiers you provide when creating an account.
• Contact Data: email address, phone number, and billing address.
• Account Data: username, encrypted password, subscription tier, account preferences, and platform history.
• Payment Data: billing and transaction information processed securely by our third-party payment processors. We do not store full card details on our systems.
• Usage Data: pages visited, features accessed, content consumed, session duration, device type, browser type, operating system, referring URLs, and IP address.
• Communications Data: messages sent to our support team, responses to surveys, and any other communications you initiate with us.
• Technical Data: cookies, device identifiers, and similar tracking technologies as described in our Cookie Policy.

We collect this data directly from you when you register, subscribe, or interact with our Services, and automatically through your use of our platforms.

3. How We Use Your Information

We use your personal data only for legitimate purposes, including:

• Providing, maintaining, and improving our digital applications and subscription services.
• Processing transactions, managing subscription billing cycles, and issuing receipts.
• Communicating with you about your account, service updates, and changes to our terms or policies.
• Personalizing your experience and delivering relevant content on our platforms.
• Responding to your inquiries and providing customer support.
• Detecting and preventing fraud, abuse, or violations of our Terms of Service.
• Complying with legal obligations applicable to our business operations in Brazil and internationally.
• Analyzing usage patterns to improve platform performance and user experience.

We will not use your personal data for any purpose that is incompatible with the purposes described in this policy without obtaining your prior consent.

4. Legal Basis for Processing

We process your personal data in compliance with Brazil's Lei Geral de Proteção de Dados (LGPD — Law 13,709/2018). The legal bases we rely on are:

• Contract performance: processing necessary to deliver the subscription services you have signed up for.
• Consent: where you have provided explicit consent, such as for marketing communications or optional data collection. You may withdraw consent at any time.
• Legal obligation: processing required to comply with applicable laws and regulations.
• Legitimate interests: processing necessary for our legitimate business interests — such as preventing fraud, improving our services, and securing our platforms — provided those interests do not override your fundamental rights.

5. Data Retention

We retain your personal data for as long as your account remains active or as needed to provide our Services. If you cancel your subscription, we retain your data for a reasonable period to fulfill any legal or contractual obligations before deletion.

Upon account deletion request, we will delete or anonymize your data within 30 calendar days, unless we are required by applicable law to retain certain information for a longer period (such as financial records required for tax purposes).

6. Sharing of Information

We do not sell, rent, or trade your personal data to third parties. We may share your information with trusted service providers solely as necessary to operate our Services:

• Payment processors (e.g., Stripe) — to handle secure payment transactions.
• Cloud infrastructure providers (e.g., AWS, Google Cloud) — to host and operate our platforms.
• Analytics providers — to understand platform usage in aggregate and anonymized form.
• Customer support tools — to manage support tickets and communications.
• Legal authorities — when required by applicable law, court order, or governmental authority.

All third-party service providers are contractually required to process your data only for the specified purposes and to maintain appropriate security measures.

7. Your Rights

Under the LGPD and other applicable data protection laws, you have the following rights regarding your personal data:

• Right of access: request a copy of the personal data we hold about you.
• Right to correction: request correction of inaccurate or incomplete data.
• Right to deletion: request deletion of your personal data, subject to legal retention requirements.
• Right to restriction: request that we limit the processing of your data in certain circumstances.
• Right to portability: request your data in a structured, machine-readable format.
• Right to object: object to processing based on legitimate interests.
• Right to withdraw consent: withdraw consent at any time where consent is the legal basis for processing.

To exercise any of these rights, please contact us at comercialdiskol@gmail.com. We will respond to your request within 15 business days. We may need to verify your identity before processing your request.

8. Security

We implement industry-standard technical and organizational security measures to protect your personal data against unauthorized access, loss, alteration, or disclosure. These include:

• Encrypted data transmission using TLS/HTTPS protocols.
• Encrypted data storage at rest.
• Strict access controls and role-based permissions.
• Regular security assessments and vulnerability testing.
• Employee training on data protection practices.

While we take all reasonable precautions to protect your data, no method of transmission over the internet or electronic storage is 100% secure. We will notify affected users in the event of a data breach as required by applicable law.

9. Cookies

We use cookies and similar tracking technologies to operate and improve our Services. Please see our Cookie Policy for full details on the types of cookies we use and how to manage them.

10. International Transfers

Your data may be processed and stored on servers located outside of Brazil. Where we transfer data internationally, we ensure that appropriate safeguards are in place in accordance with applicable data protection law.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. We will notify you of material changes by posting the updated policy on this page with a revised effective date. We encourage you to review this policy periodically.

12. Contact Us

For any privacy-related inquiries, data subject requests, or concerns, please contact us: