Privacy Policy

01 Data controller

The controller of the personal data described in this Policy is:

• RGM DIGITAL LTDA — CNPJ 60.559.995/0001-57
• R. General Daltro Filho, 2087 — Lucas Araujo, Passo Fundo/RS, Brazil — ZIP 99074-020
• Email: contato@rgmdigital.com.br

02 Scope

This Policy applies to all websites, landing pages, checkouts, members areas, email communications and digital products operated by RGM Digital, in any language or market where we advertise.

03 Data we collect

3.1 Data you provide

• Identification and contact data — full name, email address, phone or WhatsApp number.
• Transaction data — products purchased, order value, date, payment status, and tax identification number where required by law.
• Support data — the content of messages you send us by email, form or messaging apps.

Card numbers and full banking credentials are never collected or stored by us — they are handled directly by the payment processors.

3.2 Data collected automatically

• Technical data — IP address, browser and version, operating system, device type and screen resolution.
• Navigation data — pages visited, time on page, scroll depth, clicks, referring URL and exit page.
• Campaign data — UTM parameters, click identifiers (such as fbclid and gclid), ad, ad set and campaign of origin.

04 Why we use your data

• To process orders and deliver the digital products you purchased.
• To send transactional communications (access links, receipts, service notices).
• To provide customer support and handle refund requests.
• To send marketing communications about our products, when permitted, always with an unsubscribe option.
• To measure, attribute and optimize our advertising campaigns.
• To prevent fraud, chargeback abuse and unauthorized content sharing.
• To comply with legal, tax and regulatory obligations.

05 Legal bases for processing

Under the LGPD (and, where applicable, the GDPR), we process personal data based on:

• Performance of a contract — to deliver the product you bought and provide support.
• Legal obligation — tax, accounting and consumer-law record keeping.
• Legitimate interest — security, fraud prevention, and measuring and improving our own advertising and products.
• Consent — non-essential cookies, marketing emails and any optional processing. Consent may be withdrawn at any time.

06 Cookies and tracking technologies

We use cookies, pixels, tags, local storage and similar technologies for the following purposes:

• Essential — keep the session, cart and checkout working. These cannot be disabled.
• Analytics — understand aggregate traffic, page performance and content engagement.
• Advertising — measure conversions, attribute sales to campaigns and build custom or lookalike audiences.

You can block or delete cookies in your browser settings at any time. Blocking essential cookies may prevent purchases and product access from working correctly.

07 Advertising and measurement platforms

Because our operation is based on paid media, our pages may load tracking technologies from platforms such as Meta (Facebook and Instagram), Google (Ads and Analytics), TikTok, Microsoft Advertising, Taboola, Outbrain and equivalent networks, as well as attribution and video-hosting tools.

These platforms may collect data directly from your browser under their own privacy policies. Where required, we rely on your consent for these technologies, and you may manage advertising preferences directly in each platform's settings.

08 Who we share data with

We do not sell personal data. We share it only to the extent necessary with:

• Payment and checkout processors — to process transactions, invoices and refunds.
• Hosting, email and members-area providers — to store data and deliver products.
• Advertising and analytics platforms — for conversion measurement and campaign optimization.
• Professional advisors — accounting and legal, under confidentiality obligations.
• Public authorities — when required by law, court order or regulatory request.

09 International transfers

Some of our providers are located outside Brazil. In these cases, transfers are made using safeguards permitted by the LGPD and, where applicable, the GDPR — such as standard contractual clauses or transfers to countries recognized as offering an adequate level of protection.

10 How long we keep data

• Transaction and tax records — for the period required by Brazilian tax and consumer law (generally up to 5 years after the transaction).
• Product access data — for as long as your access to the product remains active.
• Marketing data — until you unsubscribe or request deletion.
• Navigation and advertising data — according to each platform's retention window, typically shorter periods.

After the applicable period, data is deleted or irreversibly anonymized.

11 Security measures

We apply technical and organizational measures appropriate to the risk, including encrypted connections (HTTPS/TLS), restricted access to systems on a need-to-know basis, use of established providers with their own security programs, and periodic review of access permissions.

No system is completely immune to incidents. If a security incident occurs that poses a relevant risk to your rights, we will notify you and the competent authority as required by law.

12 Your rights

Under the LGPD, and equivalent rights under the GDPR, you may request at any time:

• Confirmation that we process your data, and access to it.
• Correction of incomplete, inaccurate or outdated data.
• Anonymization, blocking or deletion of unnecessary or excessive data.
• Portability of your data to another provider.
• Information about the entities with which we shared your data.
• Withdrawal of consent, and deletion of data processed on the basis of consent.
• Objection to processing carried out on the basis of legitimate interest.

To exercise any of these rights, write to contato@rgmdigital.com.br with the subject "Data rights request". We respond within the legal deadline, and may ask for information to confirm your identity before acting.

13 Children's and adolescents' data

Our products are directed at adults. We do not knowingly collect personal data from children or adolescents without the consent of a parent or legal guardian. If you believe we hold such data, contact us and we will delete it.

14 Changes to this Policy

This Policy may be updated to reflect changes in our operation, in the tools we use, or in applicable law. The current version is always published on this page with its "last updated" date.

15 Contact and data protection officer

For any question, request or complaint related to personal data, contact us through our contact page or directly: