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Privacy Policy

This website is a digital property managed, operated and optimized by TiMo Midia Ltda, registered with CNPJ under number 62.179.475/0001-44, with its headquarters at Rua Ana de Carvalho Silveira, nº 287, Silveira neighborhood, Belo Horizonte/MG, CEP 31.140-440 (“TiMo Midia”).

Transparency is a fundamental pillar of our operations. This document describes how we collect, use and protect your personal data.

Laws and regulatory references considered (as applicable): LGPD and Marco Civil da Internet (Brazil), Ley 25.326 (Argentina), Ley 1581 (Colombia), LFPDPPP (Mexico), CCPA/CPRA and other state laws (USA), PIPEDA (Canada) and APPI (Japan), among others.

1. IDENTIFICATION OF THE CONTROLLER AND CONTACT

This website is a digital property managed, operated and optimized by:

TiMo Midia Ltda., registered with CNPJ under number 62.179.475/0001-44

Address: Rua Ana de Carvalho Silveira, nº 287, Silveira Neighborhood, Belo Horizonte/MG, CEP 31.140-440 (“TiMo Midia”).

Data Protection Officer/DPO (Privacy Channel): TiMo Midia Compliance Team

E-mail: [email protected]

2. WHO THIS POLICY APPLIES TO (SCOPE)

This Policy applies to the processing of personal data:

a) in the context of this domain (website) and the technologies used therein; and

b) when applicable, in the context of digital properties and advertising inventories operated/monetized by the TiMo Network.

It covers activities such as: security, measurement, fraud prevention and invalid traffic, performance improvement, delivery and verification of advertising (including programmatic) and customer support.

This Policy may be supplemented by specific notices (e.g.: banner/cookie preference center). In case of conflict, the specific notice of the website/environment in which you are located shall prevail.

3. IMPORTANT DEFINITIONS

  • Personal data: information that identifies or may identify a person, directly or indirectly.
  • Sensitive personal data: data regarding racial/ethnic origin, health, biometrics, political opinion, etc. (when applicable).
  • Processing: any operation with data (collection, use, storage, sharing, etc.).
  • Cookies/similar technologies: cookies, pixels, web beacons, SDKs, tags and identifiers used for operation, measurement, security and advertising.
  • Programmatic advertising: automated buying and selling of advertising inventory, using technology for delivery, measurement and control (e.g.: fraud prevention, frequency, reporting).

4. ROLES AND RESPONSIBILITIES (CONTROLLER/PROCESSOR/INDEPENDENT CONTROLLERS)

4.1. Role of TiMo Midia

TiMo Midia acts as a controller especially for purposes related to:

  • operation and maintenance of the website;
  • security and stability;
  • fraud prevention and invalid traffic;
  • measurement and aggregate reporting; and
  • advertising monetization (when applicable).

4.2. Partners and suppliers

Certain suppliers and technology partners (including advertising and measurement providers) may act as:

  • PROCESSORS (processing data on behalf of TiMo Midia); and/or
  • INDEPENDENT CONTROLLERS (processing data for their own purposes, according to their policies).

Relevant example: Google and advertising/measurement services may process data according to their own rules. For transparency regarding the Google ecosystem on partner sites, please visit:

https://policies.google.com/technologies/partner-sites

5. WHAT DATA WE COLLECT

5.1. Automatic collection (logs and technical data)

For website operation, security, measurement and advertising, we automatically collect information such as:

  • IP address;
  • online identifiers and/or cookie identifiers (when applicable and according to your choice);
  • browser type and version;
  • internet service provider (ISP);
  • date and time of access;
  • referral and exit pages;
  • information on clicks, events and navigation (e.g.: ad impressions, interactions, loading events);
  • technical device information (e.g.: operating system, language, resolution, user agent);
  • security and integrity indicators (e.g.: signals associated with fraud, bots, invalid traffic).

This data is used for system administration, security, fraud prevention and analysis/reporting (including aggregated). When possible, we seek to use data in an aggregated manner and/or with identification minimization.

5.2. Data provided by you

When you contact us, we may collect:

  • name, e-mail, telephone (if provided);
  • content of the message and attachments sent;
  • data necessary to validate your request (e.g.: identity verification, when necessary).

5.3. Sensitive Data and Children/Adolescents

Our services are not directed to individuals under 18 years of age and we do not intentionally collect personal data from minors. If we identify inadvertent collection, we will adopt reasonable measures for deletion.

We do not request sensitive data as a rule. If, by exception, such data is sent by you (e.g., in contact), we process it only for the purpose of service delivery and with applicable safeguards.

6. HOW WE USE DATA (PURPOSES)

We use personal data and navigation data for:

a) operate, maintain and improve website functionality;

b) ensure security, stability and technical integrity;

c) detect, mitigate and prevent fraud, bots and invalid traffic;

d) measure audience and performance (including by aggregated statistics);

e) deliver, measure and optimize advertising (including programmatic);

f) limit ad frequency and improve relevance (when applicable and permitted);

g) respond to requests, support and communications;

h) comply with legal/regulatory obligations and safeguard the rights of TiMo Mídia and third parties.

7. LEGAL BASES (ACCORDING TO PURPOSE AND JURISDICTION)

Processing may occur based on one or more legal grounds, as applicable:

  • Consent (e.g., advertising/personalization cookies, when required);
  • Compliance with legal or regulatory obligation;
  • Contract execution/preliminary procedures (e.g., requested service);
  • Regular exercise of rights (proceedings and legal protection measures);
  • Legitimate interest (e.g., security, fraud prevention, service improvement, measurement), with balance assessment and transparency measures.

Note: in certain jurisdictions, certain advertising practices and/or use of cookies/identifiers require prior, express and informed authorization. In such cases, we will operate with appropriate consent/opt-out mechanisms.

8. COOKIES AND SIMILAR TECHNOLOGIES

We use cookies, pixels, tags and similar technologies for website functionality, measurement, security and advertising.

8.1. Cookie Categories

a) Necessary Cookies

Essential for functionality, security, stability and abuse prevention.

b) Performance/Measurement Cookies

Help us understand how the website is used and improve performance, with statistics and reports (whenever possible, in aggregated form).

c) Advertising/Marketing Cookies

Used to deliver, measure and optimize ads, and may involve advertising personalization when applicable and permitted.

8.2. How to Manage Preferences

  • Banner/Preference Center: when available, you can accept, refuse or adjust categories.
  • Browser/Device: you can block or delete cookies in your browser settings.

Disabling cookies may affect some functionality and degrade the experience.

9. PROGRAMMATIC ADVERTISING, GOOGLE (AD MANAGER/ADX) AND CONSENT MODE

9.1. Google Ad Manager and Google AdX

TiMo Mídia uses ad technology platforms, including Google Ad Manager and Google Ad Exchange (AdX), and may operate as a partner in the Google ecosystem (e.g., MCM/AdX), as applicable.

9.2. Google Consent Mode (Consent Mode v2) and Consent Signals

When applicable, we use Google Consent Mode to adjust tag behavior according to your choice, including the signals:

  • ad_storage (storage for advertising);
  • analytics_storage (storage for measurement/analytics);
  • ad_user_data (sending/use of user data for advertising purposes);
  • ad_personalization (advertising personalization).

9.3. Operation with Consent Refusal and “Cookieless Pings”

If you deny certain consents, tags may operate with restrictions (for example, without cookies for that purpose) and send only signals/pings with storage limitations. In these scenarios, certain providers may use data in aggregate form and/or statistical modeling for reporting and measurement, without equivalent to full use of identifiers/cookies for personalized advertising.

9.4. Transparency on Google Partners

For details on how Google may process data on partner sites, please consult:

https://policies.google.com/technologies/partner-sites

9.5. Third-party Cookies and Technologies

Other advertising and measurement technology partners may use cookies/IDs on this website for:

  • campaign measurement;
  • ad verification;
  • security and fraud prevention;
  • reporting, frequency control and (when applicable) personalization.

TiMo Mídia does not directly control third-party technologies, which may process data according to their own policies.

10. DATA SHARING (RECIPIENT CATEGORIES)

We may share data, to the extent necessary and in accordance with your choice/settings, with:

  • hosting providers, infrastructure, security and technical support;
  • measurement and analytics tools;
  • advertising technology partners (AdTech), including ad management, delivery and verification platforms;
  • fraud prevention and invalid traffic service providers;
  • consulting and audit services (when necessary, with safeguards);
  • public authorities and competent bodies, pursuant to legal obligation, court order or valid request.

Important Note (USA/California and other jurisdictions):

The sharing of identifiers and browsing data with advertising partners may be interpreted as “sale” and/or “sharing” for behavioral advertising under certain local laws. Where applicable, we provide opt-out mechanisms through cookie preferences, browser settings and/or contact channel.

11. INTERNATIONAL DATA TRANSFER

Due to global operations and use of technology providers and partners, data may be processed and stored outside the user’s country of residence.

Where applicable, we adopt safeguards for international transfers, including:

  • transfer to countries/organizations with adequate level of protection; and/or
  • contractual clauses and mechanisms recognized under applicable standards (in Brazil, in accordance with ANPD regulations on international transfers and standard contractual clauses).

12. RETENTION AND DISPOSAL

We retain personal data and browsing records for the time necessary to:

  • fulfill the purposes of this Policy;
  • meet legal/regulatory obligations;
  • permit audits and security analyses;
  • prevent fraud and safeguard rights.

After the necessary period, data will be deleted or anonymized, where technically possible and compatible with legal obligations.

Brazil (where applicable): we observe minimum record retention periods provided for in the Internet Civil Rights Law and other applicable standards, especially for application access records.

13. RIGHTS OF DATA SUBJECTS (PRIVACY) AND RESPONSE PERIODS

You may exercise your rights free of charge by emailing [email protected]. For your security, we may request additional information to verify identity and validate the request.

Rights generally included (varying by jurisdiction): confirmation/processing, access, correction/rectification, anonymization/blocking/deletion, portability, objection, withdrawal of consent, information on sharing and review of automated decisions (where applicable).

13.1. Response Periods by Jurisdiction (operational reference)

  • Brazil (LGPD): simplified format, where possible, immediately; and, upon clear and complete statement, within 15 days from the request, observing trade/industrial secrets.
  • Argentina (Ley 25.326): access within 10 calendar days; rectification/update/deletion within 5 business days (observing legal requirements). Free access may have a minimum interval of 6 months, unless legitimate interest exists.
  • Colombia (Ley 1581): inquiries within 10 business days (extendable for up to 5 business days, with justification); complaints within 15 business days (extendable for up to 8 business days, with justification).
  • Mexico (LFPDPPP): decision within 20 days (from receipt); if granted, execution/implementation within 15 days after communication of response (periods may vary according to applicable rules and exceptions).
  • USA (CCPA/CPRA and state laws): generally, response within 45 calendar days for verified requests, with possibility of extension as permitted.
  • Canada (PIPEDA): response within 30 calendar days, with possibility of extension in specific circumstances and notice to the data subject.
  • Japan (APPI): service within reasonable period, in accordance with legal requirements, including rights of disclosure, correction and cessation of use where applicable.

Note: periods may vary according to the nature and complexity of the request, need for verification, legal retention hypotheses and exceptions provided for in law. We will always seek to respond within applicable legal periods.

14. USA – RIGHT TO OPT-OUT (“DO NOT SELL OR SHARE”) AND BEHAVIORAL ADVERTISING

Where applicable (e.g., California residents and other jurisdictions with specific rules), you may:

  • opt out of allowing “sale/sharing” of data for behavioral advertising;
  • limit the use/disclosure of sensitive information (where applicable);
  • request access, correction and deletion as permitted.

You may exercise these rights:

a) through the cookie preference center/button (where available); and/or

b) by emailing [email protected].

15. DIGITAL ACCESSIBILITY (BRAZIL)

In compliance with Brazilian inclusion legislation and aiming for accessibility, we seek to maintain our interfaces aligned with international best practices and, when applicable, to ABNT NBR 17225:2025 and WCAG 2.2 AA guidelines.

Accessibility commitments (objectives):

  • Keyboard navigation (without “focus traps”) and visible focus;
  • Responsive design with content/function preservation on small screens (e.g., 320px CSS);
  • Use of adequate semantics (headings, lists, tables) for assistive technologies.

16. INFORMATION SECURITY

We adopt reasonable technical and organizational measures to protect data against unauthorized access, destruction, loss, alteration, communication or improper dissemination. We seek to align our controls with recognized best practices and, when applicable, to international security and privacy standards (e.g., ISO/IEC 27001 and 27701).

Despite our efforts, no environment is completely risk-free. Should we identify relevant incidents, we will adopt containment and communication measures as required by applicable legislation.

17. UPDATES TO THIS POLICY

This Policy may be updated at any time to reflect operational, regulatory or technological changes. We recommend periodic review.

The “Last updated” date at the top of the document indicates when the most recent version came into effect.

18. HOW TO CONTACT US

To exercise rights, clarify doubts or submit requests:

Email: [email protected]

Address: Rua Ana de Carvalho Silveira, nº 287, Bairro Silveira, Belo Horizonte/MG, CEP 31.140-440, Brasil.