Privacy Policy & Legal Notice

01

Legal Notice

This website is operated by Innobera Consultoria de Inovação e Digitalização Ltda., a company incorporated under the laws of Brazil.

The content of this website is provided for informational purposes only and does not constitute a contractual offer. Innobera reserves the right to modify, update, or remove any content at any time without prior notice.

02

Data Controller

For the purposes of the Brazilian Lei Geral de Proteção de Dados (LGPD — Law 13.709/2018) and, where applicable, the European General Data Protection Regulation (GDPR — Regulation 2016/679), the data controller is:

Given that Innobera operates across Brazil and Europe and may provide services to individuals located in the European Economic Area, this policy is designed to comply with both the LGPD and the GDPR.

03

Data Collected

This website does not use cookies, tracking pixels, analytics tools, or any form of automated data collection. No personal data is collected passively by visiting this site.

Personal data is collected only when you choose to contact us directly, through the following channels:

• Email sent to [email protected] — your email address and the content of your message
• WhatsApp contact — your phone number and the content of your messages

The data collected is limited strictly to what you voluntarily provide. No sensitive data (as defined by LGPD Art. 11 or GDPR Art. 9) is requested or processed.

04

Legal Basis for Processing

The processing of personal data submitted through contact channels is based on the following legal grounds:

Under LGPD (Brazil)

• Art. 7, II — compliance with a legal obligation
• Art. 7, V — execution of a contract or pre-contractual procedures at the data subject's request
• Art. 7, IX — legitimate interest of the controller

Under GDPR (European Economic Area)

• Art. 6(1)(b) — processing necessary for the performance of a contract or pre-contractual steps
• Art. 6(1)(f) — legitimate interests pursued by the controller

05

Use of Data

Personal data submitted through contact channels is used exclusively for:

• Responding to your inquiry or request
• Evaluating and pursuing a potential professional engagement
• Following up on ongoing business conversations

Your data is never sold, rented, or shared with third parties for commercial or marketing purposes. Data may be shared with third-party service providers (such as email hosting) strictly to the extent necessary to deliver the services described above, and only with providers that offer equivalent data protection guarantees.

06

Data Retention

Personal data is retained only for as long as necessary for the purposes for which it was collected:

• Inquiries that do not result in an engagement: up to 12 months from last contact
• Data related to an active or completed engagement: up to 5 years, in accordance with applicable commercial law obligations in Brazil and the European Union

After the applicable retention period, data is permanently deleted or anonymized.

07

Your Rights

Under the LGPD and GDPR, you have the following rights regarding your personal data:

• Access — obtain confirmation of whether data about you is being processed and receive a copy
• Correction — request correction of inaccurate or incomplete data
• Deletion — request erasure of your data, subject to legal retention obligations
• Portability — receive your data in a structured, machine-readable format
• Opposition / Objection — object to processing based on legitimate interest
• Revocation of consent — where processing is based on consent, withdraw it at any time

To exercise any of these rights, contact us at the address below. Requests will be answered within 15 business days (LGPD) or 30 calendar days (GDPR).

If you are located in Brazil, you may also file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD) at gov.br/anpd. If you are located in the European Economic Area, you have the right to lodge a complaint with the supervisory authority of your country of residence.

08

International Data Transfers

Innobera operates across Brazil and Europe. Personal data may be transferred between these jurisdictions in the course of business. Such transfers are carried out in compliance with LGPD Chapter V and GDPR Chapter V, relying on adequacy decisions or appropriate safeguards as applicable.

No personal data is transferred to countries or organizations that do not provide an adequate level of data protection without appropriate contractual safeguards in place.

09

Contact & Data Protection Officer

For any questions about this policy, to exercise your rights, or to report a data protection concern, please contact:

This policy was last updated in February 2026. Innobera reserves the right to update this policy at any time. Material changes will be reflected in the date shown at the top of this page.