Privacy Policy

1. Who we are

This Privacy Policy explains how TEA FORMATION LTDA ("TEA Formation"), registered under CNPJ no. 63.403.293/0001-78, processes personal data related to the use of its institutional website. TEA Formation acts as controller for operations whose purposes and means of processing it determines.

Registered office: Rua Victor Meirelles, 385, Centro, Videira/SC, CEP 89560-184.

Contact: adm@teaformation.com.

2. Scope of this Policy

This Policy covers the TEA Formation institutional website, including its institutional pages, catalog, e-book presentation pages, and website-related communications. Sending a message to the contact channel does not subscribe the person to an email list or authorize marketing communications.

It does not govern processing carried out within TEAFlow and does not replace the policies and terms of external platforms such as Hotmart. When a visitor is redirected to an external platform, processing carried out in that environment is also subject to the rules and responsibilities applicable to that platform, without prejudice to TEA Formation's legal responsibilities.

3. Personal data we may process

On the institutional website, processing may involve:

• identifiers and browsing events associated with Google Analytics 4;
• UTM parameters and other campaign identifiers used to measure traffic sources and referrals;
• technical data, such as IP address, access date and time, and browser and device information, to the extent necessary for the website's operation, security, and delivery;
• email address received through the commercial operation to send purchased files or, when a person voluntarily contacts adm@teaformation.com, their email address, message content, and any attachments.

The institutional website does not create user accounts, does not provide login, and does not directly collect payment data or record purchases. Buyer identification, payment, and commercial operation take place on Hotmart; for the current adult pre-sale, TEA Formation uses the email address associated with the purchase to send the three PDF files included in the offer.

4. Purposes and legal bases

The legal basis depends on the purpose of processing under the LGPD. Legitimate interests are limited to strictly necessary non-sensitive data and must respect the data subject's expectations and rights. The applicable purposes and bases are:

• provide and protect the website, based on the legitimate interest in maintaining a functional and secure service;
• measure traffic, performance, navigation, and campaign attribution through non-essential analytics, based on the visitor's consent;
• understand how pages are used and improve the experience through authorized analytics, based on consent;
• fulfil the purchased offer and email the three PDF files, based on performance of the contract;
• respond to voluntary communications: performance of a contract or preliminary steps requested by the data subject for purchase-related enquiries; legitimate interests in responding to the requested communication for other institutional enquiries;
• prevent abuse, investigate failures, and maintain operational security, based on the legitimate interest in protecting the website and its visitors;
• comply with legal or regulatory obligations, based on the applicable obligation, and retain data necessary for the regular exercise of rights in judicial, administrative, or arbitration proceedings, where applicable.

5. Cookies and similar technologies

The website uses cookies or similar technologies that are strictly necessary for its operation and may use measurement and analytics mechanisms when authorized by the visitor.

Google Analytics 4 is a non-essential analytics technology and is activated only after the visitor consents to analytics. If the visitor rejects analytics or makes no selection, GA4 remains disabled and no measurements are sent to that service, including cookieless measurements. Rejection does not prevent access to public content or redirection to Hotmart.

Visitors can change their choice and withdraw consent through the privacy controls available on the website. Withdrawal stops new analytics collection; rights concerning data already processed can be exercised through the channel indicated in section 8.

6. Sharing and service providers

TEA Formation may use service providers necessary for the website's operation and the commercial journey, including:

• Cloudflare, for website infrastructure, hosting, and security;
• Hostinger, for the email service supporting the public contact channel;
• Google Analytics 4, for measurement and analytics after consent;
• Hotmart, for checkout, payment, and the commercial operation of e-books.

A provider acts as a processor when processing data on behalf of TEA Formation and under its instructions. When determining its own purposes or meeting obligations assigned to it, the provider may act as controller for that operation. Hotmart has its own responsibilities for checkout, payment, and management of the purchaser's account; the operational separation does not remove TEA Formation's legal responsibilities.

Use of these services may involve transmitting, storing, or accessing data outside Brazil for the purposes described in this Policy and for the periods indicated in section 7. Transfers under TEA Formation's responsibility require a valid mechanism under the LGPD, such as an adequacy decision or applicable contractual safeguards. Consent to analytics does not, by itself, constitute specific consent to an international transfer.

Through adm@teaformation.com, data subjects may request information about destination countries, responsibilities, and applicable safeguards. When a transfer relies on contractual clauses, data subjects may request a full copy, subject to commercial and industrial secrecy, to be provided within 15 (fifteen) days unless a different period is established by specific regulation.

7. Processing period and retention

Data is kept only for as long as necessary for the stated purposes, operation and security, compliance with legal or regulatory obligations, and the regular exercise of rights. For user-level and event data subject to the Google Analytics 4 retention setting, TEA Formation adopts a retention period of 2 (two) months.

Contact messages are retained while the enquiry is being handled and, after closure, only to the extent necessary to document the response, meet an applicable obligation, or exercise legal rights. Excessive attachments and information are deleted after triage unless there is a justified need to retain them.

Technical data and security logs follow mandatory retention periods where applicable; other records are kept only while necessary for operation, investigation of failures, or abuse prevention. The GA4 retention setting does not determine the lifetime of cookies or of aggregated reports that do not allow an individual to be identified.

When data is no longer necessary, it will be deleted or anonymized, subject to legal grounds for retention.

8. Your rights

Under the LGPD, data subjects may exercise the following rights free of charge, where applicable:

• confirmation of whether processing exists;
• access to personal data;
• correction of incomplete, inaccurate, or outdated data;
• anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;
• information about sharing;
• portability, where applicable and in accordance with regulation;
• deletion of data processed based on consent, in the cases provided by law;
• information about the possibility of withholding consent and its consequences;
• withdrawal of consent, where consent is the applicable legal basis;
• review of decisions based solely on automated processing that affect their interests, where such decisions occur;
• objection to processing carried out on a basis that does not require consent, in the event of non-compliance with the LGPD.

Requests may be sent by the data subject or a legally authorized representative to adm@teaformation.com. To protect the data, TEA Formation may request only reasonable information necessary to verify identity and, where relevant, authority to represent the data subject.

Confirmation of processing or access will be provided immediately in a simplified format or through a clear and complete declaration within 15 (fifteen) days of the request, subject to applicable legal rules and exceptions. Other requests follow the relevant specific deadlines; this period is not applied indiscriminately to all rights. If the requested action cannot be taken immediately, the factual or legal reasons will be explained or, where possible, the responsible processing agent will be identified.

Data subjects may also petition ANPD and contact consumer protection bodies, where applicable. Refusing or withdrawing consent to analytics does not prevent the exercise of these rights.

9. Security

TEA Formation adopts technical and administrative measures proportionate to operational risks to protect personal data against unauthorized access, loss, alteration, destruction, or improper or unlawful processing.

No digital environment is completely free of risk. Incidents will be handled in accordance with applicable legal obligations.

10. Children's and adolescents' data and sensitive data

The institutional website does not provide clinical care and was not designed to receive health information through the public contact channel. Presenting children's works does not constitute a request for children's or adolescents' personal data. Any processing of data concerning this group must respect their best interests and the applicable legal bases and specific safeguards; where the law requires a parent or guardian's authorization, a child's cookie selection does not replace it.

Do not send clinical information, health documents, or other sensitive personal data, whether your own or concerning other people of any age, to the general contact address. Where there is a legitimate need for such information, processing requires an appropriate purpose, legal basis, and channel.

Access to unsolicited sensitive information will be restricted for triage, minimization, and deletion, except where indispensable retention is supported by a legal ground applicable to sensitive data. Sending such information does not authorize its use for clinical, promotional, or incompatible purposes.

11. Changes to this Policy

This Policy may be updated to reflect changes to the website, services used, legislation, or TEA Formation's practices.

The current version and its update date will be made available on the website. Material changes will be prominently communicated; where a new purpose requires consent, it will be requested before the new processing begins.

12. Contact

Questions, privacy-related requests, and requests to exercise rights may be sent to:

TEA FORMATION LTDA

CNPJ 63.403.293/0001-78

Rua Victor Meirelles, 385, Centro, Videira/SC, CEP 89560-184

adm@teaformation.com