PRIVACY POLICY AND PERSONAL DATA PROTECTION

1. INFORMATION COLLECTED

1.1. 1.1. To provide and improve our services, Intellux collects the following information from Users:

• Registration Data: Name, email address, phone number and access password.
• Advertising Platform Credentials: Permissions and tokens granted by You for integration with third-party advertising platforms such as Meta Ads and Google Ads.
• Advertising Campaign Data: Data related to your advertising campaigns, including statistics, metrics, performance data, ad spend, creative content and audience information accessed via integrated advertising platforms.
• Platform Usage Information: Data about how you interact with our Platform, including features used, clicks, navigation paths and session duration.
• Technical and Browsing Information: Cookies, IP address, browser type, device information (operating system, device identifiers) and interactions within the Platform.
• Information for AI Processing: Data derived from your campaign performance and Platform usage, which may be used to train and improve our AI models (as detailed below).

1.2. 1.2. Data collection occurs with your express consent when registering and using the Platform, or as necessary for the performance of our Services. This collection aims to provide our Services, improve your User experience and optimize the performance of your digital marketing campaigns.

1.3. 1.3. Personal Data Processing: means any operation performed with Personal Data, such as those related to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

2. PURPOSE AND LEGAL BASIS FOR DATA PROCESSING

2.1. 2.1. Your data is collected and processed for the following purposes and based on the specified legal bases:

• Service Provision: To operate and maintain your account, enable integrations with advertising platforms and allow you to manage and optimize your advertising campaigns using the Intellux Platform (Legal basis: Contract performance).
• AI-Powered Optimization and Insights: To leverage our artificial intelligence algorithms to analyze your campaign data, provide performance insights, automated optimization suggestions and personalized recommendations to improve your marketing strategies (Legal basis: Contract performance; Legitimate interest in improving our services).
• Training and Improvement of AI Models: To use anonymized and aggregated data, and in some cases, personal data (with consent when necessary), derived from your campaigns and Platform usage to train, develop and improve our AI models and the overall effectiveness of the Platform. You may have options to manage the use of your data for model improvement when applicable, by contacting us (Legal basis: Legitimate interest; Consent when applicable).
• Personalization: To personalize your experience on the Platform, including providing personalized recommendations and reports (Legal basis: Legitimate interest).
• Communication: To send service-related communications, updates, security alerts and support messages (Legal basis: Contract performance; Legitimate interest).
• Security and Authentication: To ensure the security of our Platform, prevent fraud and verify user identity (Legal basis: Legal obligation; Legitimate interest).
• Legal Compliance: To comply with applicable legal obligations, court orders or requests from competent authorities (Legal basis: Legal obligation).

2.2. 2.2. Automated Decision-Making and Profiling: Our AI may perform automated analysis and make recommendations. While our AI assists in decision-making, you generally maintain control over the implementation of these suggestions. When automated decisions significantly affect you, you may have the right to obtain human intervention, express your point of view and contest the decision.

2.3. 2.3. Data Controller and Processor: For your Registration Data and direct interactions with Intellux, we act as data controller. For Advertising Campaign Data that you provide or make accessible through third-party platforms for processing within Intellux, you are the data controller (or act on behalf of the controller), and Intellux acts as data processor, processing such data on your behalf and according to your instructions or as necessary to provide the services. When necessary, a separate Data Processing Addendum (DPA) will govern such processing.

2.4. 2.4. Your data is not sold to third parties. We do not share your personal information with third parties, except in situations described in this policy or with your explicit consent.

3. SHARING WITH META AND GOOGLE ADS (AND OTHER ADVERTISING PLATFORMS)

3.1. 3.1. To enable integration with Meta Ads, Google Ads and similar advertising platforms, Intellux requests specific permissions and access tokens from you. The use of data by these platforms is governed by their respective policies.

3.2. 3.2. You may revoke Intellux's access to your advertising platform accounts at any time through the respective platforms' settings or within your Intellux account settings.

3.3. 3.3. Intellux does not modify campaigns without your authorization (either directly or through pre-defined automation rules that you configure) and only processes data necessary for performance analysis, optimization and reporting as permitted by you.

4. DATA STORAGE, SECURITY AND RETENTION

4.1. 4.1. Security Measures: Intellux employs robust administrative, technical and physical security measures to protect your data against unauthorized access, disclosure, alteration, loss or destruction. These measures include encryption of data in transit and at rest, access controls, secure server infrastructure, regular security assessments and staff training.

4.2. 4.2. Data Storage: Your data is stored on secure servers, which may be located in various jurisdictions, including the United States. Access to this data is restricted to authorized personnel who need it to perform their job functions.

4.3. 4.3. Data Retention: We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including during the time your account is active, to provide our Services, comply with our legal obligations (e.g.: tax, accounting), resolve disputes, enforce our agreements and for the continued operation and improvement of our AI models. Data used primarily for AI model training may be anonymized or aggregated and retained for longer periods. You may request deletion of your account and associated personal data as described in Section 5.

4.4. 4.4. International Data Transfers: Your information, including Personal Data, may be transferred to, stored and processed in countries other than yours, including the United States, where our servers or those of our service providers may be located. These countries may have different data protection laws than those in your country. We will take all reasonably necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

4.5. 4.5. Data Breach Notification: In the event of a Personal Data breach that may result in high risk to your rights and freedoms, a notice will be posted on our website. In addition, affected users will be notified directly by email.

5. YOUR DATA PROTECTION RIGHTS

5.1. 5.1. Depending on your location and applicable data protection laws (such as LGPD – General Data Protection Law in Brazil, GDPR – General Data Protection Regulation in the European Union (EU), CCPA/CPRA – California Consumer Privacy Act/California Privacy Rights Act - in the US), you may have the following rights regarding your Personal Data:

• Right of Access: Request access to personal data we hold about you.
• Right of Rectification: Request correction of inaccurate or incomplete personal data.
• Right to Erasure (Deletion): Request deletion of your personal data, subject to certain legal limitations.
• Right to Restrict Processing: Request restriction of our processing of your personal data in certain circumstances.
• Right to Data Portability: Request to receive your personal data in a structured, commonly used and machine-readable format, and transmit it to another controller.
• Right to Object: Object to our processing of your personal data, particularly for direct marketing or when processing is based on legitimate interests.
• Right to Withdraw Consent: Withdraw your consent at any time when we rely on consent to process your personal data.
• Rights Related to Automated Decision-Making: Not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on you or similarly significantly affects you, except under certain conditions.
• Right to Opt-Out of Sale or Sharing (for CCPA/CPRA): If applicable, the right to opt-out of the "sale" or "sharing" of your personal information for cross-context behavioral advertising. (Intellux confirms that we do not "sell" personal data in the traditional sense. For details about "sharing", contact us).
• Right to Non-Discrimination: Not to be discriminated against for exercising your privacy rights.

5.2. 5.2. To exercise these rights, or if you have questions about them, contact us at support@intellux.com. We will respond to your request in accordance with applicable data protection laws. We may need to verify your identity before processing your request. support@intellux.com.

6. USE OF COOKIES AND TRACKING TECHNOLOGIES

6.1. 6.1. Cookies are text files stored in the browser that collect data when you visit any web page or platform. Their main use is to store data for each visit made to the page, which can be used for advertising purposes, identifying User preferences, to optimize the performance of our website or Platform, as well as those strictly necessary to allow navigation and access to Services and features that may be made available. Intellux uses cookies, web beacons and similar tracking technologies to collect information about your browsing activities, improve your user experience, analyze Platform usage and assist in our marketing efforts.

6.2. 6.2. You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform.

7. SUB-PROCESSORS AND THIRD-PARTY LINKS AND SITES

7.1. 7.1. Intellux may hire third-party companies and individuals (sub-processors) to facilitate our Platform (e.g.: cloud hosting providers such as AWS or Google Cloud, analytics services, customer support tools). These sub-processors may have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We maintain a list of our main sub-processors and ensure they adhere to data protection standards comparable to ours.

7.2. 7.2. Our Services, Website and Platform may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We encourage you to review the Policies and Terms of Use of each site you visit. We have no control over and assume no responsibility for the content, privacy policies, other policies or practices of any third-party sites, services or platforms and service providers.

8. CHILDREN'S PRIVACY

8.1. 8.1. The Intellux Platform is not intended for or directed to individuals under 18 years of age (or the relevant age of digital consent in your jurisdiction). We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected personal data from a child without verification of parental consent, we will take steps to delete such information from our servers promptly. If you know of any minor who has accessed the site or Platform, please contact us immediately by email: privacy@intellux.com privacy@intellux.com

9. CHANGES TO THIS PRIVACY POLICY

9.1. 9.1. Intellux may update this Policy periodically to reflect changes in our practices, services or applicable laws. In the event of significant changes, we will notify users through the Platform or by email.

9.2. 9.2. Your continued use of the Platform after such modifications will constitute your acknowledgment of the modified Policy and agreement to abide by and be bound by the new terms. We encourage you to review this Policy frequently to stay informed about how we are protecting your information.

10. CONTACT US

10.1. 10.1. For questions or requests about this Privacy Policy, contact us by email at support@intellux.com. Provide your full name, company name, contact information and details of your request. support@intellux.com.