Privacy Policy
Last Updated: March 10, 2026
The Creative Pulse 23 portal establishes this Privacy Policy to reaffirm its commitment to security, transparency, and respect in handling user data. This document explains how data is processed in strict compliance with Brazil’s General Data Protection Law (LGPD – Law No. 13,709/18) and Google Publisher Policies.
1. TRANSPARENCY: WHO OPERATES THIS PORTAL?
1.1. Data Controller Identification
This news and financial education portal is owned and operated by SPUN MIDIA LTDA, registered under CNPJ No. 43.629.487/0001-89, with administrative headquarters in Rio Grande do Sul, Brazil. For legal purposes, this company acts as the Data Controller of the collected data.
1.2. Communication Channel (DPO)
In compliance with Article 41 of the LGPD, we have appointed a Data Protection Officer (DPO) to serve as a point of contact between the portal, users, and the Brazilian Data Protection Authority (ANPD). Requests can be sent to:
[email protected]
2. TARGET AUDIENCE AND AGE RESTRICTION
2.1. Scope
This Privacy Policy applies to all individuals who access any website, portal, or digital platform owned by SPUN MIDIA LTDA or companies within its corporate group.
2.2. Adults Only
The financial education and news content on this portal is intended exclusively for individuals aged 18 years or older.
2.3. Protection of Minors
We do not knowingly collect or request data from children or minors. If our systems identify that a minor has provided personal data, such information will be immediately deleted from our databases without prior notice, in accordance with Article 14 of the LGPD.
3. DATA CATEGORIES AND PURPOSES OF PROCESSING
We only process data strictly necessary for the operation of the portal, as outlined below:
3.1. Personal Data Provided by Users
Data Collected:
- Full name
- Email address
Purpose:
Registration in our mailing list for newsletters, market alerts, educational materials, and general email marketing.
Legal Basis:
Free and informed consent (Article 7, I, LGPD).
3.2. Automatically Collected Data
- IP address
- Browser type
- Operating system
- Pages visited
- Time spent on the site
- Site interactions
- Cookie data and online identifiers
Purpose:
To identify access for cybersecurity purposes, fraud prevention, and compliance with legal obligations for log retention.
Legal Basis:
Legal obligation (Article 15 of the Brazilian Internet Civil Framework) and fraud prevention (Article 11, II, “g”, LGPD).
3.3. Browsing Data and Profiling (Cookies)
Data Collected:
- Page view history
- Interaction with banners
- Time spent on pages
Purpose:
Statistical audience analysis and personalized advertising based on user interests.
Legal Basis:
Legitimate interest (Article 7, IX, LGPD).
4. ADVERTISING, GOOGLE ADS, AND THIRD PARTIES
To keep our content free, we use third-party advertising technologies:
4.1. Third-Party Vendors
Google, as a third-party vendor, uses cookies to serve ads based on a user’s prior visits to this and other websites.
4.2. Advertising Cookies
These cookies allow Google and its partners to display ads relevant to your interests and browsing behavior.
4.3. User Control
You may opt out of personalized advertising by visiting Google Ads Settings.
5. DATA SHARING WITH THIRD PARTIES AND STAFF
5.1. Employees and Contractors
Access to your data is restricted to employees and contractors of the Data Controller who need it to perform technical or administrative duties. All personnel are bound by strict confidentiality agreements and data protection training.
5.2. Limited Use
All service providers are required to use shared data solely for the purposes defined in this policy. The use of data for their own purposes or resale is strictly prohibited.
5.3. Legal Requests
We may disclose data to law enforcement, judicial, or administrative authorities when required by law or court order.
6. DATA RETENTION AND LIFECYCLE
We follow the principle of necessity, retaining data only as long as required:
6.1. Personal Data
Name and email remain in our active database as long as the user maintains interest in our content. Data is deleted upon request (opt-out) as quickly as possible.
6.2. Connection Logs
Stored for a minimum of six (6) months, as required by the Brazilian Internet Civil Framework.
6.3. Tracking Data
Cookies may remain active for up to 24 months, depending on their type.
6.4. Exceptional Retention
We may retain data beyond these periods when required to comply with legal obligations, court orders, or for defense in legal or administrative proceedings.
7. INTERNATIONAL DATA TRANSFERS AND SECURITY
7.1. Global Infrastructure
As we use international cloud services and analytics tools (such as Google servers), your personal data may be processed outside Brazil. We ensure that such providers follow international security and privacy standards.
7.2. Security Protocols
We implement robust technical measures, including HTTPS (SSL/TLS) encryption, to ensure secure and private communication between your device and our servers.
8. DISCLAIMER AND AFFILIATE LINKS
8.1. External Navigation
Our portal is educational and informational. When you click on links to banks or financial institutions, you will be redirected to external websites.
8.2. Limitation of Liability
We have no control over third-party privacy practices. Once you leave our domain, responsibility for your data lies solely with the destination website. We recommend reviewing their Privacy Policies.
9. DATA SUBJECT RIGHTS
In accordance with Article 18 of the LGPD, users (or their legal representatives) have the following rights:
- Confirmation and Access: Know what data we process and request a copy
- Correction: Update incomplete or inaccurate information
- Deletion: Request deletion of data processed based on consent
- Withdrawal of Consent: Opt out of email marketing at any time
To exercise any of these rights, contact our DPO:
[email protected]
You may also unsubscribe directly using the opt-out link included in our emails.