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Privacy Policy

Last updated: June 27, 2025


1. Who We Are and Data Controller

PMG Academy Soluções em Treinamento LTDA – ME (São Paulo – Brazil)
Trade Name: PMG Academy
CNPJ: 14.313.454/0001-27

PMG Academy LLC (Delaware – USA)
Trade Name: PMG Academy
EIN-number: 87-2953238
Website: https://www.pmgacademy.com

PMG Academy (“PMG Academy,” “we,” “our,” or “the company”) is the data controller responsible for the personal data collected through our website, platforms, and related services.

Data Protection Officer (DPO):
Adriano Martins Antonio
Contato: co*****@********my.com

We are committed to protecting your privacy and complying with all applicable international data protection laws, including the Brazilian General Data Protection Law (LGPD – Law No. 13,709/2018), the European General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and other relevant legislation.


2. What Personal Data We Collect and Why

2.1 Data Provided Directly by You

  • Full name

  • Email address

  • IP address

  • Browser data (User Agent)

  • Information provided in forms (comments, registrations, profiles)

  • Uploaded photos and images

  • Payment data (via third-party gateways)

  • Additional information you provide in interactions (messages, chats, forum)

2.2 Data Collected Automatically

  • Cookies and digital identifiers (detailed in Section 5)

  • Approximate location data (via IP)

  • Usage and navigation data on the website and applications

  • Device data used to access our services

2.3 Data Collected from Third Parties

  • Social media profiles (when linked)

  • Data obtained from external service providers (Google, Facebook, LinkedIn, etc.) for remarketing and analytics

  • Data obtained through security tools, fraud prevention, and statistical analysis

2.4 Purposes of Personal Data Processing

We process your personal data for the following legitimate and specific purposes:

  • Enable interaction with our website, comments, and community

  • Manage your registration and user profile

  • Personalize content, offers, advertisements, and communications

  • Perform billing and process payments via payment gateways

  • Prevent fraud, abuse, and ensure the security of the website and users

  • Comply with legal, tax, and regulatory obligations

  • Improve our services based on anonymous analyses and statistics

  • Send promotional communications, offers, and educational materials (with opt-out option)

  • Manage commercial relationships and customer support


3. Legal Bases for Data Processing

PMG Academy processes your personal data based on one or more of the following legal grounds:

  • Consent (Art. 7, LGPD; Art. 6.1.a GDPR): for collecting data via forms, comments, marketing, and newsletters. You may withdraw your consent at any time.

  • Contractual necessity (Art. 7, V LGPD; Art. 6.1.b GDPR): to fulfill contractual obligations related to providing services and selling courses/exams.

  • Legal or regulatory obligation (Art. 7, II LGPD; Art. 6.1.c GDPR): to comply with tax, audit, and legal record-keeping requirements.

  • Legitimate interest (Art. 7, IX LGPD; Art. 6.1.f GDPR): for fraud prevention, security, remarketing, service improvement, and data analysis.

  • Credit protection (Art. 7, X LGPD): when applicable.

If no legal basis exists for processing, we will not collect or process your data.


4. How We Collect Your Data

4.1 Directly From You

  • When you create an account, leave comments, send messages, request contact, make purchases, or participate in forums and internal social networks.

4.2 Automatically

  • Through cookies and similar technologies, site usage monitoring, behavior analysis, and performance tracking.

4.3 From Third Parties

  • Social networks, advertising services, payment platforms, analytics tools, and monitoring services.


5. Cookies and Tracking Technologies

We use cookies and similar technologies to improve your experience, analyze site usage, and provide personalized advertising.

5.1 Types of Cookies Used

  • Essential: necessary for site functionality (login, security).

  • Analytical: to collect anonymous information about visits and behavior.

  • Marketing: to deliver personalized ads via Google Ads, Facebook Ads, LinkedIn, etc.

5.2 Control and Management

You can configure your browser to refuse or delete cookies, but this may affect site functionality.

We provide tools to manage ad preferences on Google (https://adssettings.google.com), Facebook (https://www.facebook.com/settings?tab=ads), and others.


6. Data Sharing and Transfer

6.1 Sharing with Third Parties

  • Commercial partners, advertisers, and sponsors (using anonymized or segmented data).

  • Service providers (payment gateways, hosting, security, digital marketing).

  • Legal authorities, as required by law or court order.

6.2 International Transfer

Your data may be transferred to countries outside Brazil, including the United States and the European Union. We ensure that these transfers comply with applicable legal requirements, such as standard contractual clauses and appropriate security measures.


7. Data Security

We adopt technical, administrative, and organizational measures to protect your data against unauthorized access, disclosure, alteration, or destruction. Examples include:

  • Password encryption using secure hashing

  • Protection through firewalls and intrusion detection systems

  • Restricted access control and employee training

  • Secure storage via trusted providers

  • Continuous monitoring and auditing

Despite our efforts, no transmission over the internet is 100% secure. We recommend using strong passwords, not sharing them, and logging out after use.


8. Retention of Personal Data

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including legal, regulatory, contractual, or audit obligations.

Practical Examples of Retention:

  • Comments and metadata: stored indefinitely for recognition and automatic moderation.

  • Registration and profile data: retained while the account remains active.

  • Payment data: stored according to the rules of the payment gateways and tax legislation.

  • Marketing data: retained as long as valid consent or legitimate interest exists.

  • Anonymized data for statistics: stored indefinitely without the possibility of identification.

After the necessary retention period ends, your data will be permanently deleted or anonymized.


9. Your Rights as a Data Subject

Under LGPD, GDPR, and other applicable laws, you have the right to:

  • Confirmation of the existence of processing of your data.

  • Access to your personal data.

  • Correction of incomplete, inaccurate, or outdated data.

  • Anonymization, blocking, or deletion of unnecessary or excessive data.

  • Data portability to another provider or service.

  • Withdrawal of consent at any time (without affecting prior processing).

  • Deletion of personal data processed based on consent.

  • Information about data sharing.

  • Review of automated decisions that affect your interests.

  • The right to file a complaint with the Brazilian National Data Protection Authority (ANPD) or the equivalent authority in your country.


10. How to Exercise Your Rights

You can request the exercise of your rights via:

We will respond to your request within the legal timeframe, generally within 15 business days.

To ensure security, we may request documents to verify your identity.


11. Data of Minors

Our website and services are intended for individuals aged 18 and over. We do not intentionally collect personal data from minors without the consent of their legal guardians.

If you are a minor, please do not provide personal data without permission from your parents or guardians.

If we identify the inadvertent collection of data from minors, we will take immediate measures to delete such data.


12. Use of Third-Party Services and Platforms

12.1 Payment Gateways

Payments are processed by trusted third parties (Stripe, PayPal, PagSeguro, Mercado Pago, etc.). These providers are responsible for the security and processing of financial data.

PMG Academy does not store complete credit card or bank account information.

12.2 Social Networks and Remarketing

We use tools such as Google Ads, Facebook Ads, and LinkedIn Ads for remarketing and personalized advertising.

These platforms use cookies and other technologies to identify visits and interests, enabling the display of relevant ads.

You can manage your preferences directly on these social media platforms.

12.3 Embedded Content

Our website may display videos, images, or articles embedded from third parties (YouTube, Vimeo, social networks).

The processing of your data in these interactions follows the policies of these third parties, for which we are not responsible.


13. Information About Comments, Forums, and Community

Comments submitted are public and visible alongside your name or pseudonym.

  • We reserve the right to moderate, edit, or remove comments that we consider inappropriate, offensive, illegal, abusive, or in violation of this policy.

  • Racist, defamatory, threatening comments, and spam will be removed, and the user may be banned.

  • Comments containing sensitive or confidential personal data should be avoided.

By posting comments, you agree that they may be publicly reproduced with proper credit given.


14. User Profile Removal and Deletion

You may delete your profile at any time through your account.

However, deleting your profile does not guarantee the complete removal of all your historical data, such as:

  • Comments made in forums, posts, and communities;

  • Photos, videos, or files already shared;

  • Data stored in backups or logs for audit and security purposes.

After deletion, your profile will be deactivated, and you will lose access to PMG Academy resources and services, including purchases and community participation.


15. Information Security

PMG Academy maintains strict technical, administrative, and physical measures to protect your personal data, including:

  • Encryption of sensitive data, such as passwords, using modern and secure hash functions;

  • Restricted access control to information, with permissions based on the need to know;

  • Continuous system monitoring to detect and prevent unauthorized access attempts, intrusions, data leaks, or cyberattacks;

  • Use of firewalls, antivirus software, and intrusion detection systems;

  • Ongoing training of staff to ensure compliance and best practices in data protection;

  • Internal policies on privacy, security, and confidentiality;

  • Partnerships with trusted and certified providers for hosting, processing, and backup;

  • Protocols for rapid response in case of security incidents, minimizing risks and damages.

Despite all efforts, data transmission over the internet is not absolutely secure. We recommend that you adopt good practices, such as keeping your password confidential and updated, and logging out after use.


16. Privacy Policy Updates

We may update this Privacy Policy periodically to reflect changes in laws, technologies, business practices, or services offered.

The updated version will always include the date of the latest revision.

If there are significant changes that affect your rights or how we use your data, we will inform you via notice on our website, email, or other available communication channels.

We recommend that you review this policy regularly to stay informed.


17. International Data Transfers

As we operate internationally, your data may be transferred and stored on servers located in other countries, including outside Brazil, the European Union, and the United States.

We ensure that such transfers comply with applicable laws by adopting appropriate protective measures, such as:

  • Contracts with standard contractual clauses approved by the ANPD and/or the European Commission;

  • International security certifications of our partners;

  • Risk assessments and internal protection policies.


18. Legislações Aplicáveis e Conformidade

This policy has been developed in compliance with the following data protection laws and regulations:

  • Brazilian General Data Protection Law (LGPD) – Brazil (Law No. 13,709/2018)

  • General Data Protection Regulation (GDPR) – European Union (Regulation (EU) 2016/679)

  • California Consumer Privacy Act (CCPA) – United States (Cal. Civ. Code §§ 1798.100 et seq.)

  • Other relevant laws in countries where we operate or have users.

We are committed to respecting the rights of data subjects as provided in all these regulations and to following international best practices in data protection and information security.


19. User Responsibilities

By using our services, you agree to:

  • Provide truthful, up-to-date, and complete information;

  • Safeguard your access credentials (login and password) and not share them with third parties;

  • Respect community rules, comment policies, and other regulations;

  • Immediately notify PMG Academy of any unauthorized use of your account;

  • Comply with applicable laws regarding privacy and data protection.


20. Contact and Inquiries

If you have any questions, requests, complaints, or wish to exercise your rights regarding your personal data, please contact us:

Data Protection Officer (DPO)
Email: ad*****@********my.com
Phone: +55 (11) 3395-1599
Address: 3 Germay Dr Ste 4 – Wilmington, DE 19804-1127 – USA
and Avenida Paulista, 1636 – Suite 4, 15th Floor – São Paulo, SP – Brazil

To facilitate service, we recommend including your full name, the email address used on the site, and a clear description of your request.


21. Consent and Use of Data for Marketing

By registering on our website or providing your contact information, you express your consent to receive communications from PMG Academy, such as:

  • Information about courses, events, and news;

  • Promotional offers and educational materials;

  • Invitations to participate in surveys and provide feedback.

You may opt out of receiving these communications at any time via the unsubscribe link in the email footer or by contacting us directly.

We do not share your personal data for marketing purposes with third parties without your prior authorization.


22. Limitation of Liability

Although we adopt best practices to protect your personal data, PMG Academy is not responsible for:

  • Damages caused by third parties due to security breaches beyond our control;

  • Misuse or unauthorized use of your account resulting from personal negligence;

  • External technical interruptions or failures that affect our services


23. Acceptance of Terms

Use of our services implies full acceptance of this Privacy Policy.

If you do not agree with any part, we kindly ask that you do not use our websites or services.


24. General Provisions

  • This policy is part of our Terms of Use and other agreements established with users.

  • PMG Academy may modify, adapt, and update this policy at any time, with prior notice when required by law or necessary to improve our services.

  • This policy is written in Portuguese, and translated versions may be provided to facilitate understanding for international users. In case of discrepancies, the Portuguese version shall prevail.


25. Glossary

  • Personal Data: information relating to an identified or identifiable natural person.

  • Data Subject: the natural person to whom the personal data relates.

  • Controller: the natural or legal person who determines how and why personal data is processed.

  • Processor: the natural or legal person who processes personal data on behalf of the controller.

  • Consent: a free, informed, and unequivocal expression by which the data subject agrees to the processing of their personal data.


ADDITIONAL SECTIONS


Contact Forms

Our website uses forms to facilitate contact, support, and registrations for our courses and events.

Personal data collected through these forms include name, email, phone number, and submitted messages. This information is stored for up to 6 months for service, control, and communication history purposes.

We do not use form data for marketing purposes without explicit consent.

The collected data is accessible only by authorized PMG Academy personnel and is protected according to our security policy.


Analytics Services

We use Google Analytics to understand visitor behavior on our website.

This service collects anonymous data such as pages visited, visit duration, approximate location, and device used.

You can opt out of Google Analytics tracking by installing the official opt-out browser add-on available at: https://tools.google.com/dlpage/gaoptout

For more details, please refer to Google Analytics’ privacy policy: https://policies.google.com/privacy

If we use other analytics services, they will be disclosed in this section.


Cookies and Tracking Technologies of Plugins and Embedded Media

In addition to the essential and marketing cookies described in the main section, our plugins use specific cookies for functionality and translation:

  • WPML: Cookies to identify the selected language, logged-in user, and synchronization between sites.

  • Slider Revolution: Cookies and connections for Google Web Fonts, YouTube, and Vimeo to load multimedia content with quality.

  • YouTube and Vimeo: Plugins that establish direct connections to display videos, which may collect data such as IP address and user behavior. We recommend logging out of these platforms to avoid associating your activity with your personal profile.

  • SoundCloud: Integration with audio content that may collect information via direct connection to the SoundCloud server.

For more information, please consult the respective privacy policies of these providers.


Data Breach Procedures

A PMG Academy mantém um plano de resposta a incidentes de segurança para identificar, conter e corrigir eventuais violações de dados pessoais.

Em caso de incidente que possa causar risco ou dano aos titulares, notificaremos os órgãos reguladores competentes (como a ANPD no Brasil e autoridades na UE) e os titulares afetados, respeitando prazos legais, geralmente em até 72 horas após a detecção.

Implementamos ações corretivas para evitar recorrências e protegemos seus direitos durante todo o processo.


Automated Decision-Making and Profiling

We do not perform automated decisions that significantly affect users’ rights, such as credit approval or service exclusion without human intervention.

However, we use automated analyses for segmenting advertising campaigns based on demographic and behavioral data, always respecting legal limitations.

You have the right to request information about the use of these analyses and to contest decisions based on profiling.


Data Received from Third Parties

We may receive personal data from partners, affiliates, or third-party platforms for marketing, integration, and customer support purposes.

Such data is processed in accordance with this policy, ensuring the same level of protection and respecting the applicable legal bases.


Regulated Sectors

We operate in the educational sector, offering online courses and training. We comply with applicable regulations for digital education and data protection to ensure security and transparency.


Thank you for trusting our work.
Here at PMG Academy, your privacy and security are our top priorities. We are always available to clarify any questions and ensure you have a transparent and secure experience.

Thank you for being part of our community!

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