Privacy policy

1. Who is responsible for your data

ER35 Growth Marketing (56.706.564 LUCAS ORLANDO RUDI), CNPJ 56.706.564/0001-07, Garopaba – SC, Brasil ("we") is the controller of the personal data processed on https://agenciaer35.com.

Data protection officer (DPO): Lucas Orlando Rudi — lucas@agenciaer35.com.

2. What we collect

• Anonymous browsing (always): pages viewed, buttons clicked, videos watched, source campaign (UTM) and approximate country/region. No cookie and nothing that identifies you.
• With your marketing consent: a visitor code, Meta (_fbp, _fbc) and Google (_ga, gclid) identifiers, IP address, browser and approximate city.
• Data you give us: name, email, phone and your answers in the booking form (e.g., revenue range and whether you already advertise).
• Payments: processed by Stripe. We receive name, email, amount and product. We never receive your card number.

3. Why we use it and on what legal basis

• Run the site and count visits anonymously — anonymous data is not personal data.
• Measure which ad brought you here and show more relevant ads (Meta and Google) — your consent, which you can withdraw at any time.
• Reply to you, schedule and hold meetings and send proposals — steps taken at your request before a contract.
• Billing and tax obligations — contract performance and legal obligation.
• Prioritize follow-up based on your booking answers (interest score) — legitimate interest. A person always reviews it, and you can ask for a review.

4. Who we share it with

We do not sell your data. We share it only with the providers needed for the purposes above:

• Meta (Facebook/Instagram) and Google (Analytics and Ads): only with your marketing consent. Email, phone, name and location are sent hashed (SHA-256), never in plain text.
• Calendly (bookings) and Stripe (payments).
• Vercel (hosting) and Supabase (database).

5. International transfers

These providers store data on servers outside your country (mainly in the United States), relying on the contractual safeguards they offer.

6. How long we keep it

• Browsing events: 13 months.
• Inactive visitor code: 13 months, then deleted.
• IP, browser and ad identifiers linked to bookings and purchases: 90 days.
• Contacts who did not become clients: 24 months, then anonymized.
• Purchases: 5 years (tax obligation), then anonymized.
• Records of your consent and your requests: 5 years, as proof.

7. Cookies

• _er35_consent (necessary, 12 months): stores your banner choice.
• _trck, _er35_gc (marketing, up to 13 months / 90 days): visitor code and Google ad click.
• _fbp, _fbc (Meta, marketing, 90 days) and _ga, _ga_* (Google, marketing, up to 2 years).
• To change your choice, use the "Cookie preferences" link in the site footer.

8. Your rights

You can ask for: confirmation that we process your data, access, correction, anonymization, blocking or deletion, portability, information about who we share it with, withdrawal of consent, objection and review of automated decisions.

Use the form below or email lucas@agenciaer35.com. We reply within 15 days, after confirming the request is really yours (so nobody can access or delete someone else's data).

You can also complain to your data protection authority (in Brazil: ANPD, www.gov.br/anpd).

9. A limit we need to explain

When we delete your data, we delete or anonymize everything we hold. What was already sent to Meta and Google with your consent follows their rules and cannot be deleted by us: use their privacy settings. Calendly and Stripe also keep their own copies; we ask them when applicable.

10. Security

Encrypted connections (HTTPS), encrypted passwords and access keys, team-only access and automatic deletion within the periods above.

11. Changes

When this policy changes materially, we update the date above and ask for your choice again in the banner.