Privacy Policy

1 · Introduction

Luciana Reynaud ("Luciana", "we", "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you interact with our Platform.

2 · Scope

This Policy applies to personal data processed when you (a) visit our websites; (b) create an account; (c) use our APIs or hosted services; (d) communicate with us; or (e) receive marketing from us.

3 · Information We Collect

Category	Examples	Source
Identifiers	Name, email, telephone, IP address, device ID	You / Automatic
Commercial Info	Subscription level, billing address, transaction history	You
Usage Data	Log files, clickstream, feature usage, AI prompts	Automatic
Geolocation	Approximate location inferred from IP	Automatic
Professional Data	Company name, role, industry	You

We do not knowingly collect data from children under 13.

4 · Legal Bases for Processing (GDPR & LGPD)

We process personal data on the following bases:

• Consent — for direct marketing communications;
• Contract — to provide and maintain the Platform;
• Legitimate Interests — to improve services, prevent fraud, and ensure security;
• Legal Obligation — to comply with tax, accounting, and regulatory requirements.

5 · How We Use Personal Data

• To create and manage accounts;
• To deliver, maintain, and improve the Platform;
• To train, fine‑tune, and evaluate AI models only on data expressly provided for that purpose or anonymised aggregated data;
• To provide customer support and technical notices;
• To send marketing communications where permitted by law;
• To detect, investigate, and mitigate fraudulent or abusive activity.

6 · AI Model Training and Guardrails

Prompt data and model outputs may be temporarily stored for the purpose of security auditing, bias mitigation, and performance tuning. You can withdraw your consent at any time by emailing reynaud.luciana@gmail.com

7 · Data Sharing

We share personal data only with:

• Service Providers — hosting, payment processors, analytics (bound by contractual obligations of confidentiality and data protection);
• Affiliates & Subsidiaries — consistent with this Policy;
• Legal Authorities — when required to comply with applicable law or protect rights, property, or safety;
• Business Transfers — in connection with a merger, acquisition, or sale of assets, subject to appropriate safeguards.

We never sell personal data for monetary consideration.

8 · International Transfers

Where data is transferred outside Brazil, the EEA, or the UK, we rely on adequacy decisions, Standard Contractual Clauses, or other lawful transfer mechanisms.

9 · Data Retention

We retain personal data only as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, or resolve disputes. Back‑ups are subject to secure retention schedules.

10 · Security

Luciana Reynaud employs industry‑standard administrative, technical, and physical safeguards, including encryption in transit and at rest, least‑privilege access controls, and regular penetration testing.

11 · Your Rights

Depending on your jurisdiction, you may have rights to:

• Access, correct, or delete your personal data;
• Object to or restrict processing;
• Port your data to another controller;
• Withdraw consent at any time;
• Lodge a complaint with a supervisory authority.

To exercise these rights, contact reynaud.luciana@gmail.com

12 · Cookies and Similar Technologies

We use cookies, pixels, and local storage to (a) authenticate users, (b) remember preferences, (c) analyse site traffic, and (d) provide personalised content. You can manage cookies through browser settings.

13 · Marketing Communications

We send promotional messages only with your consent or as otherwise permitted by law. You may unsubscribe at any time via the link in each email or by contacting us.

14 · Children's Privacy

The Platform is not directed to children under 13, and we do not knowingly process their personal data.

15 · Changes to This Policy

We may update this Policy to reflect changes in law or our practices. Material changes will be announced via the Platform or email.

16 · Contact

For questions about this Policy or our privacy practices, contact our Data Protection Officer at reynaud.luciana@gmail.com

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