PRIVACY POLICY
Last Updated: March 10, 2026

The Creative Pulse portal establishes this Privacy Policy to reaffirm its commitment to security, transparency, and respect in the processing of user data. This document details how data is processed, in strict compliance with the Brazilian General Data Protection Law (Law No. 13.709/18 – LGPD) and global Google Publisher Policies guidelines.

1. TRANSPARENCY: WHO IS RESPONSIBLE FOR THIS PLATFORM?

1.1. Controller Identification: This financial news and education platform is owned and operated by SPUN MIDIA LTDA, registered under CNPJ No. 43.629.487/0001-89, with its administrative headquarters in Rio Grande do Sul, Brazil. For legal purposes, this company acts as the “Data Controller” of the collected data.

1.2. Communication Channel (DPO): In compliance with Article 41 of the LGPD, we have appointed a Data Protection Officer (DPO) to act as the communication channel between the platform, users, and the Brazilian National Data Protection Authority (ANPD). Requests can be sent to: [email protected].

2. TARGET AUDIENCE AND AGE RESTRICTION

2.1. Scope: This Privacy Policy applies to all individuals who access any website, portal, or digital platform owned by SPUN MIDIA LTDA or companies within its holding and economic group.

2.2. Adults Only: The financial education and news content provided by this platform is intended exclusively for individuals aged 18 (eighteen) years or older.

2.3. Protection of Minors: We do not knowingly collect or request data from children or adolescents. If underage registration is identified, all associated data will be promptly deleted from our databases without prior notice, ensuring the best interest of the minor in accordance with Article 14 of the LGPD.

3. DATA CATEGORIES AND PURPOSES OF PROCESSING

We process only the data strictly necessary for the operation of the platform, as detailed below:

3.1. Provided Personal Data

Data:

• Full name
• Email address

Purpose: Subscription to our mailing list for newsletters, market alerts, educational materials, and general email marketing.

Legal Basis: Free and Informed Consent (Article 7, I, LGPD).

3.2. Automatically Collected Data

• IP address
• Browser type
• Operating system
• Pages visited
• Time spent on pages
• Website interactions
• Cookie data and online identifiers

Purpose: Identification of access for cybersecurity purposes, fraud prevention, and compliance with legal obligations for log retention.

Legal Basis: Legal Obligation (Article 15 of the Brazilian Internet Civil Framework) and Fraud Prevention (Article 11, II, “g” of the LGPD).

3.3. Browsing and Profiling Data (Cookies)

Data:

• Page view history
• Interaction with banners
• Time spent on the site

Purpose: Audience analytics and advertising personalization through interest-based segmentation.

Legal Basis: Legitimate Interest (Article 7, IX, LGPD).

4. ADVERTISING, GOOGLE ADS, AND THIRD PARTIES

To ensure free access to our content, we use third-party advertising technologies:

4.1. Third-Party Vendors: Google, as an advertising provider, uses cookies to display ads based on prior visits to this and other websites.

4.2. Advertising Cookies: These cookies allow Google and its partners to show ads relevant to your interests and browsing behavior.

4.3. User Control: You have the right to disable personalized advertising by accessing Google Ads Settings.

5. DATA SHARING WITH THIRD PARTIES AND STAFF

5.1. Employees and Collaborators: Access to your data is restricted to authorized personnel who require it for technical and administrative purposes. All personnel are bound by strict confidentiality obligations and receive data protection training.

5.2. Limited Use: Service providers are required to use shared data exclusively for the purposes outlined in this Policy. The use of data for their own purposes or resale to third parties is strictly prohibited.

5.3. Legal Requests: We may disclose data to law enforcement, judicial, or administrative authorities when required by law or court order.

6. DATA RETENTION AND LIFECYCLE

We follow the principle of necessity, retaining data only as long as required:

6.1. Personal Data: Name and email remain in our active database while there is user interest in our content. Deletion occurs upon user request (opt-out), processed as quickly as possible.

6.2. Connection Logs: Retained for at least 6 (six) months, in accordance with the Brazilian Internet Civil Framework.

6.3. Tracking Data: Cookies may have variable durations, up to 24 months.

6.4. Exceptional Retention: Data may be retained beyond these periods when necessary to comply with legal obligations, court orders, or defense in administrative proceedings.

7. INTERNATIONAL DATA TRANSFERS AND SECURITY

7.1. Global Infrastructure: As we use cloud services and international analytics tools (such as Google servers), your data may be processed outside Brazil. We ensure that these providers follow international security and privacy standards.

7.2. Security Protocols: We implement robust technical measures, including HTTPS (SSL/TLS) encryption, to ensure that communication between your device and our servers remains secure and confidential.

8. DISCLAIMER AND AFFILIATE LINKS

8.1. External Navigation: This platform is informational and educational. When clicking on links to banks or financial institutions, you will be redirected to external websites.

8.2. Limitation of Responsibility: We do not control the privacy practices of third-party websites. Once you leave our domain, responsibility for data processing lies solely with the destination site. We strongly recommend reviewing their Privacy Policies.

9. DATA SUBJECT RIGHTS

In accordance with Article 18 of the LGPD, users (or their legal representatives) have the following rights:

• Confirmation and Access: Know what data we process and request a copy
• Correction: Update incomplete or inaccurate data
• Deletion: Request deletion of data processed under consent
• Withdrawal: Revoke consent for email marketing at any time

To exercise any of these rights, please contact our official DPO channel: [email protected].
You may also unsubscribe directly using the opt-out option available in our emails.