This document aims to establish the rules for data processing, including, but not limited to, the operations of collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination, or extraction of data collected from USERS, as well as the recording of their activities, in accordance with applicable laws.
By accepting this Privacy Policy, the USER provides their free and explicit agreement with the terms stipulated herein.
1. Glossary
1.1. For the purposes of this document, the following definitions and descriptions should be considered to aid comprehension:
Cookies: Small files or data packets sent by DOUX MARKETING to the USER’s device to identify them and collect information that will assist DOUX MARKETING in improving the services provided to USERS.
Data: A set of Anonymized Data and Personal Data.
Anonymized Data: Information that, individually or combined with other Anonymized Data, does not allow for the identification of a person, considering the use of reasonable and available technical means at the time of its processing. This may include gender, age, geolocation (e.g., city), and statistical data.
Personal Data: Information related to an identified or identifiable natural person. For example, this may include name, address, email, phone number, debit/credit card number, IP address, and geolocation data.
IP Address: Internet Protocol address associated with the device used by the USER. Each IP Address corresponds to an alphanumeric set that, along with other information, uniquely identifies the device the USER is using to access the internet, and therefore, the websites, applications, and services offered by DOUX MARKETING.
Applicable Legislation: The laws applicable to the relationship between DOUX MARKETING and the USER, which may vary based on (i) the location of the services provided; (ii) the place of residence of one of the parties, including the USER; (iii) other factors specified in particular legislations. The DOUX MARKETING website can be accessed in various countries, and it is subject, in addition to Brazilian legislation, to other norms, including the General Data Protection Regulation (GDPR).
Privacy Policy and Terms of Use: Collectively refers to this Privacy Policy – DOUX MARKETING, as well as other documents expressly referenced within this Privacy Policy.
USERS: People who access or interact with the functionalities provided by the websites, applications, and services offered by DOUX MARKETING. The USER must have the legal capacity to accept and consent to this Privacy Policy and other documents from DOUX MARKETING. If the USER lacks such capacity, they declare that they have obtained all necessary authorizations to accept this Privacy Policy and other documents presented by DOUX MARKETING.
2. Data Collection
Summary
We collect USER data provided directly or indirectly during the use of DOUX MARKETING’s websites, applications, and services, or by authorized partners following this privacy policy. Additionally, we explain what cookies are and how USERS can manage them.
2.1. Data will be collected:
(i) When voluntarily entered or submitted by USERS on DOUX MARKETING’s websites, applications, and services, such as during navigation, content interaction, and service acquisition;
(ii) When the USER submits third-party data to DOUX MARKETING (e.g., friends’ data). DOUX MARKETING may use such data under this Privacy Policy, and the USER declares that they are authorized, in accordance with applicable legislation, to submit this data for acknowledgment and registration by DOUX MARKETING, indemnifying DOUX MARKETING;
(iii) When data is automatically submitted without any USER action, such as through cookies; or
(iv) From partners authorized to share data with DOUX MARKETING.
2.2. Information collected by DOUX MARKETING may include, but is not limited to:
(i) Name;
(ii) Gender;
(iii) CPF (Brazilian Taxpayer Registry);
(iv) Email address;
(v) Postal address;
(vi) Phone number and recordings (in case of contact with the USER);
(vii) Date of birth;
(viii) Payment information;
(ix) Browser and operating system information;
(x) IP address;
(xi) Pages visited;
(xii) Clicked links and buttons;
(xiii) Contact list; and
(xiv) Biometric data (e.g., facial photos).
2.3. DOUX MARKETING is not responsible for the truthfulness or updating of the information and data provided by the USER. The USER is responsible for providing accurate and up-to-date information. DOUX MARKETING may periodically request that the USER update the provided information and data.
2.4. DOUX MARKETING uses cookies and anonymous identifiers for audience control, navigation, security, and advertising purposes, and the USER agrees to this usage by accepting this Privacy Policy. Cookies used by DOUX MARKETING can be classified as follows:
(i) Based on validity:
a) Session Cookies: Temporary cookies that remain until the webpage or browser is closed. They may be used in e-commerce (e.g., to ensure the USER does not lose items placed in their cart), to analyze traffic patterns, and to provide a better and more contextualized experience for USERS.
b) Persistent Cookies: These remain even after the browser is closed. They may be used to remember USER login information, passwords, or improve the user experience across sessions.
(ii) Based on ownership:
a) First-party Cookies: Owned by DOUX MARKETING, which has full control over them.
b) Third-party Cookies: Owned by third parties but embedded on the USER’s device via DOUX MARKETING’s websites, applications, and services.
(iii) Based on purpose:
a) Strictly Necessary Cookies: Essential for enabling the USER to utilize DOUX MARKETING’s websites, applications, and services, which cannot function correctly without them. These are usually Session and First-party Cookies.
b) Performance Cookies: Collect anonymous information about how USERS interact with DOUX MARKETING’s websites, applications, and services, helping to recognize profiles and count visits and interactions. These are usually First-party Cookies.
c) Functionality Cookies: Allow DOUX MARKETING to remember choices made by USERS (such as login or location) to provide a more personalized experience. These may include anonymized data that does not track activity outside of DOUX MARKETING’s platforms. These are typically First-party and Persistent Cookies.
d) Analytics and Advertising Cookies: Enable DOUX MARKETING’s advertisers to deliver relevant ads to USERS. They are also used to limit the frequency of certain ads and measure campaign effectiveness. These are generally Persistent and may be Third-party Cookies (e.g., Google Analytics).
e) Social Media Cookies: Allow USERS to connect with social media platforms like LinkedIn, Twitter, Facebook, Pinterest, and Instagram. These are generally Persistent and Third-party Cookies.
f) Security Cookies: Help DOUX MARKETING monitor fraudulent activity and protect USER data from unauthorized access. These are generally Persistent and Third-party Cookies.
2.5. The USER may choose not to accept cookies while using DOUX MARKETING’s platforms; however, in such cases, DOUX MARKETING cannot guarantee proper functioning. Cookies can be managed via the USER’s browser tools.
2.6. DOUX MARKETING uses partners for data collection and processing. Third parties may place cookies on your browser for analysis or use web beacons to collect information as part of delivering advertisements on our website. Learn more about how Google uses data when you use our partners’ apps or websites.
2.7. DOUX MARKETING may record USER activities on its websites, applications, and services by creating logs that may include:
(i) USER IP address;
(ii) Actions performed by the USER on DOUX MARKETING’s platforms;
(iii) Pages and screens accessed by the USER;
(iv) Dates and times of each action;
(v) Information about the device used, operating system version, browser, and other installed applications/software;
(vi) Session and User ID (when available);
(vii) Connection type (e.g., Wi-Fi, EDGE, 3G, 4G); and
(viii) Geolocation.
2.8. Additional technologies may be used to collect USER navigation data, respecting the terms of this Privacy Policy and the USER’s preferences. Should new data types be collected, the USER will be informed in advance. Data collected by DOUX MARKETING may be combined with data from other legitimate sources or technologies.
3. Use of Data
Summary
Data will only be accessed by DOUX MARKETING, partners, subcontractors, and authorities. If USERS access third-party functionalities, they are subject to the practices and policies of those third parties. Below are the purposes for which USER data may be used.
3.1. Collected USER data may be used for the following purposes:
(i) Identification, authentication, and authorization;
(ii) Responding appropriately to requests, queries, and providing support;
(iii) Maintaining updated records for communication via phone, email, SMS, or other means;
(iv) Enhancing the interactive experience during navigation;
(v) Conducting statistics, studies, research, and planning activities based on anonymized data;
(vi) Promoting DOUX MARKETING services and those of its partners, and providing relevant updates and news;
(vii) Safeguarding DOUX MARKETING’s rights and obligations;
(viii) Complying with judicial orders or administrative authority requests;
(ix) Processing USER payments;
(x) Sending newsletters and emails expressly agreed upon by the USER;
(xi) Managing risks, detecting, preventing, or remediating fraud or other illegal activities;
(xii) Facilitating payment processes and enhancing USER experience.
3.2. The use, access, and sharing of the database created under this Privacy Policy will follow DOUX MARKETING’s operational purposes and applicable laws. Data may be shared with partners, suppliers, service providers, subcontractors, or authorities, as required by law or court order. Sensitive data (e.g., racial origin, health information, or biometrics) will only be shared with the USER’s consent.
3.2.1. USER data may be shared with entities outside the USER’s country of residence. Transfers from the European Economic Area (EEA) to non-adequate countries will adhere to the applicable regulations, including the use of Standard Contractual Clauses.
3.3. DOUX MARKETING may anonymize personal data, enrich its database with information from legitimate sources, and process personal data based on legitimate interest, as permitted by applicable law. By agreeing to this Privacy Policy, the USER consents to these activities.
4. Data Storage
Summary
Collected data is stored securely. USERS can request access, correction, or deletion of their data at any time. However, data may be retained for legal or audit purposes.
4.1. Collected data will be stored in a secure and controlled environment. However, DOUX MARKETING is not responsible for breaches caused by failures, viruses, or database invasions unless negligence or willful misconduct is proven. USERS will be notified if breaches occur.
4.2. Data may be stored on DOUX MARKETING’s servers or third-party servers located in Brazil or abroad, potentially through cloud computing. These third parties will meet applicable legal standards.
4.3. Through DOUX MARKETING’s service tools, USERS may:
(i) Request data access, correction, or deletion;
(ii) Request the deletion of all personal data, provided the contractual relationship has ended and legal retention periods have passed;
(iii) Revoke consent for future data collection or processing;
(iv) Request data portability;
(v) Request that personal data no longer be used for marketing purposes.
4.3.1. Even if the USER has requested the deletion of their data and revoked consent, in certain specific cases, DOUX MARKETING may be subject to laws and regulations that prevent the deletion/revocation of data.
4.3.2. Personal Data will also be deleted when they are no longer necessary, except in cases where there is a legal or contractual justification for their retention (e.g., compliance with a legal obligation to retain data or the need to preserve data to protect legitimate rights and interests of either party).
4.4. The USER’s privacy settings and the products and features they use will influence the data obtained by DOUX MARKETING.
4.5. For auditing and rights preservation purposes, DOUX MARKETING may retain the USER’s data history, and the company reserves the right to delete it permanently at its discretion or when required by law or regulatory standards. DOUX MARKETING may also maintain anonymized data and anonymized versions of the USER’s data for statistical and research purposes, even after a deletion request or the expiration of the legal retention period.
5. General Provisions
Summary
This document may be updated at any time. Therefore, we recommend checking it regularly. If any activity is outsourced, the contracted companies will adhere to the provisions of this document.
5.1. The content of this Privacy Policy may be updated or modified at any time, as deemed necessary by DOUX MARKETING or to ensure compliance with legal requirements. It is the USER’s responsibility to verify the document whenever accessing DOUX MARKETING’s websites, applications, or services.
5.1.1. In case of updates to this document, DOUX MARKETING will notify the USER through the tools available on its websites, applications, and services and/or via the contact details provided by the USER. The USER will be bound to the updated terms of this document once notified of the changes.
5.2. The designated contact for inquiries is contato@douxmarketing.com.br. USERS may reach out to this email address for any questions regarding the provisions of this Privacy Policy.
5.3. If the USER believes that DOUX MARKETING has violated any legal provision or this Privacy Policy, they have the right to file a complaint with the appropriate supervisory authority, in addition to contacting DOUX MARKETING directly.
5.4. If third-party companies process any data collected by DOUX MARKETING, they must comply with the conditions outlined in this document and adhere to DOUX MARKETING’s Information Security standards.
5.5. If any provision of this Privacy Policy is deemed illegal or invalid by an authority in the USER’s locality or connection, the remaining provisions will remain in full force and effect.
6. Governing Law and Jurisdiction
Summary
For any legal actions, Brazilian law and the jurisdiction of the city of São Paulo will apply, except for specific exceptions dictated by applicable law (e.g., the USER’s place of residence).
6.1. This Privacy Policy will be interpreted under Brazilian law, in Portuguese, with the courts of the city of São Paulo being chosen to resolve any disputes or controversies involving this document, except for specific jurisdictional provisions dictated by applicable law.
