Privacy & Governance
This page describes what this site does with the personal data of the people who visit it, on what legal grounds, and how you exercise your rights. The short answer today is that the site collects nothing of its own accord, and the text below explains exactly what that means and what still exists regardless.
1. Who the controller is
Meta 3 Digital Serviços de Marketing LTDA — CNPJ 45.964.223/0001-07 is the controller of the personal data processed in connection with this site, being the party that decides on the purpose and the means of that processing. Contact for any privacy matter: contato@agenciam3.com.br.
Legal basis: Lei 13.709/2018 (the LGPD, Brazil's general data protection act), art. 5, VI, which defines the controller as the party to whom decisions about processing belong.
2. What this site collects on its own
Nothing that identifies you. There is no sign-up form, no tracking cookie and no audience measurement tool installed: no Google Analytics, no Meta Pixel, no Hotjar, nothing equivalent. There is also no advertising cookie and no browsing profile being built.
That absence is a decision, not an oversight: the LGPD requires processing to be limited to the minimum necessary for the intended purpose, and the purpose of this site is to present services, not to watch the people reading about them.
Legal basis: LGPD, art. 6, III (necessity) and art. 6, I (specific, disclosed purpose).
3. Site access logs
Like any application on the internet, the server that delivers these pages automatically records technical data for each request: IP address, date and time with time zone, and the page requested. These logs are not used to identify visitors, are not cross-referenced against any other database and feed no commercial analysis.
Keeping those logs is not optional for us. Brazil's Marco Civil da Internet requires an application provider incorporated as a for-profit legal entity to retain application access logs for six months, in a controlled and secure environment, and prohibits handing them to third parties outside the cases the law allows.
Legal basis: Lei 12.965/2014 (Marco Civil da Internet, Brazil's internet civil rights framework), art. 15, main paragraph and §2, and Decreto 8.771/2016, arts. 13 to 15, on security standards for retention. Under the LGPD, the ground is art. 7, II, compliance with a legal obligation by the controller.
4. What happens when you use the contact buttons
The diagnosis buttons open a WhatsApp conversation with the message already written. Nothing is sent until you send it yourself, and none of your data passes through this site on the way: the link simply opens the app, without telling WhatsApp which page you came from.
From that point the conversation happens inside WhatsApp, a Meta group service, which is an independent controller of the processing carried out on its own platform and has its own privacy policy. Because Meta operates servers outside Brazil, this step involves an international transfer of data, governed by the LGPD's own chapter on the subject. Whatever you write to us is used only to reply to you and to assess a possible engagement.
The email address in the footer works the same way: it opens your own mail program with the recipient filled in, and the message travels through your provider.
Legal basis: LGPD, art. 7, V, where the contact relates to pre-contractual steps taken at your request, and art. 7, IX, legitimate interest, where it is simply a matter of replying to a message from you. International transfer: arts. 33 to 36.
5. Who else touches this data
The site content and the technical logs sit with the infrastructure providers that host the application and its content database. They act as processors, meaning they handle the data on our behalf and under our instructions, with no purpose of their own. We do not sell, assign or share personal data with third parties for commercial purposes.
Legal basis: LGPD, art. 5, VII (processor) and art. 39, which binds the processor to the controller's instructions.
6. How long we keep it
Application access logs are kept for the statutory period of six months and then deleted, barring a court order to the contrary. The messages you send us are kept for as long as the conversation lasts and for as long as we need them to defend a legal right, and are deleted after that.
Legal basis: Marco Civil, art. 15, main paragraph, and LGPD, art. 15, I and IV, and art. 16, which allows retention to comply with a legal obligation and for the regular exercise of rights.
7. Security and incidents
We apply technical and administrative measures to protect data against unauthorised access and against accidental or unlawful situations. Site traffic is encrypted, and the internal routes that receive editorial content require token authentication, compared in constant time so that nothing leaks through response timing.
Should a security incident occur that is capable of causing you relevant risk or harm, we will notify Brazil's Autoridade Nacional de Proteção de Dados (ANPD) and the affected data subjects within a reasonable period.
Legal basis: LGPD, arts. 46 to 49 (security and good practice) and art. 48 (incident notification).
8. Your rights
At any time, and at no cost, you may ask us for: confirmation that processing exists; access to the data; correction of incomplete, inaccurate or outdated data; anonymisation, blocking or deletion of data that is unnecessary, excessive or processed unlawfully; portability to another provider; deletion of data processed with your consent; information about who we share it with; information about your option to withhold consent and the consequences of doing so; and withdrawal of consent.
To exercise any of these, write to contato@agenciam3.com.br. We reply immediately in simplified form, or in full within fifteen days of your request. If you object to processing grounded in legitimate interest, simply say so and we will reassess it.
You may also petition the Autoridade Nacional de Proteção de Dados directly against the controller if you believe one of your rights has not been honoured.
Legal basis: LGPD, art. 18, I to IX, art. 19, I and II (reply deadlines), art. 18, §1 (petition to the ANPD) and art. 18, §2 (objection to processing that does not require consent).
9. Data protection channel
The address contato@agenciam3.com.br is the official channel for communication about data protection, and it is where the ANPD and data subjects should reach us. We operate at a scale consistent with that of a small-scale processing agent, a condition under which formally appointing a data protection officer is optional, but maintaining this channel is not.
Legal basis: LGPD, art. 41, and Resolução CD/ANPD nº 2/2022, art. 11, which exempts small-scale agents from appointing an officer provided they maintain a communication channel.
10. Operations in the European Union
Part of our operation sits in Valencia, Spain. To the extent that data processing occurs in the context of the activities of that establishment, the European General Data Protection Regulation applies as well, cumulatively with the LGPD. Where the two diverge in scope, the one more protective of you prevails.
Under the GDPR the grounds for the processing described here are the same, read through the corresponding provisions: performance of pre-contractual steps at your request, compliance with a legal obligation, and legitimate interest. Your rights include, in addition to those listed above, restriction of processing, objection to processing based on legitimate interest, and the right not to be subject to a decision based solely on automated processing which produces legal effects concerning you. This site makes no such decisions.
If you are in the European Union and believe one of your rights has not been honoured, you may lodge a complaint with the supervisory authority of your country. In Spain, that authority is the Agencia Española de Protección de Datos.
Legal basis: Regulation (EU) 2016/679 (GDPR), art. 3(1), on processing in the context of the activities of an establishment in the Union; art. 6(1)(b), (c) and (f), on lawful grounds; arts. 15 to 22, on data subject rights; and art. 77, on the right to lodge a complaint with a supervisory authority. Under the LGPD, art. 3, I and II.
11. When this changes
The text above describes the situation as it stands today. If we start using measurement tools, non-essential cookies or forms on the site, we will update this page before the change goes live, with the date at the top marking the revision, because prior and adequate information about processing is a right of the data subject and not a courtesy.
This English text is a translation provided for convenience. The Portuguese version of this page is the governing one, and in the event of any discrepancy it prevails.
Legal basis: LGPD, art. 6, VI (transparency) and art. 9, which guarantees facilitated access to information about the processing.
