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Last updated: March 31, 2026

2. Data Controller

This Cookie Policy applies to the website of FTB Strategic Communication and Internal Marketing Consulting (“FTB”), which acts as the Data Controller pursuant to the Brazilian General Data Protection Law (LGPD).

FTB is responsible for decisions regarding the processing of personal data collected through cookies and similar technologies.

2. Definition of Cookies and Similar Technologies

Cookies are text files sent to the user’s device when accessing a website. These files store information related to browsing and enable user recognition in future visits.

We also use similar technologies, such as:

  • Tracking pixels
  • Tags
  • Scripts
  • Web beacons

These technologies perform functions equivalent to cookies for data collection and processing purposes.

3. Nature of the Data Collected

Cookies may collect or store, directly or indirectly, personal data such as:

  • IP Address
  • Device identifiers
  • Approximate geolocation data
  • Browser and operating system information
  • Browsing data (pages visited, time spent, clicks)

When such information allows the identification of an individual, even indirectly, it is treated as personal data under the LGPD.

4. Purposes of Processing

Cookies are used for the following purposes:

4.1 Execution of essential functionalities

To ensure the technical operation of the website, including authentication, security, and navigation integrity.

4.2 Performance and usage analysis

To measure and analyze user behavior for continuous improvement of the digital experience.

4.3 Content personalization

To tailor content and functionalities based on the user’s profile and preferences.

4.4 Marketing and advertising

To conduct targeted campaigns, remarketing, and performance measurement.

5. Legal Bases for Processing

The processing of personal data through cookies is based on the following legal grounds under the LGPD:

5.1 Consent (Art. 7, I)

For non-essential cookies, particularly those related to marketing and personalization.

5.2 Legitimate interest (Art. 7, IX)

For cookies necessary for website improvement, performance analysis, and security, provided that the data subject’s fundamental rights and freedoms are respected.

5.3 Performance of a contract or preliminary procedures (Art. 7, V)

When applicable to the provision of services requested by the user.

6. Classification of Cookies Used

6.1 Strictly necessary cookies

Essential for the operation of the website. They do not require consent.

6.2 Performance cookies

Collect statistical data about website usage, generally in an anonymized or pseudonymized manner.

6.3 Functionality cookies

Enable the storage of user preferences.

6.4 Advertising cookies

Used for ad targeting and campaign measurement.

7. Third-Party Cookies

FTB may use third-party cookies, including but not limited to:

  • Analytics tools
  • Marketing automation platforms
  • Redes de mídia e publicidade

Such third parties may act as independent Data Controllers or Data Processors, as applicable, and are responsible for data processing under their respective privacy policies.

8. Data Sharing

Data collected through cookies may be shared with:

  • Technology service providers
  • Analytics and marketing platforms
  • Business partners, where applicable

Such sharing occurs in compliance with the LGPD and with appropriate contractual and technical safeguards in place.

9. International Data Transfers

Personal data collected may be transferred to and stored on servers located outside Brazil.

In such cases, FTB adopts appropriate safeguards, including:

  • Standard contractual clauses
  • Assessment of the level of data protection in the destination country
  • Assurance of compliance with the LGPD

10. Storage and Retention

Cookies have different retention periods:

  • Session cookies: deleted when browsing ends
  • Persistent cookies: stored for a defined period or until manually deleted

Personal data will be retained only for as long as necessary to fulfill its purposes or comply with legal obligations.

11. Data Subject Rights

Under the LGPD, the data subject may exercise the following rights:

  • Confirmation of the existence of processing
  • Access to data
  • Correction of incomplete, inaccurate, or outdated data
  • Anonymization, blocking, or deletion
  • Data portability
  • Deletion of data processed based on consent
  • Information about data sharing
  • Withdrawal of consent

12. Management and Withdrawal of Consent

The user may, at any time:

  • Manage preferences through the cookie banner
  • Withdraw previously granted consent
  • Configure their browser to block cookies

Withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal.

13. Information Security

FTB adopts appropriate technical and organizational measures to protect personal data against:

  • Unauthorized access
  • Loss
  • Alteration
  • Improper disclosure

14. Updates to this Policy

This Policy may be updated at any time, and periodic review is recommended.

Material changes will be communicated appropriately to users.

15. Data Protection Officer (DPO)

To exercise their rights or clarify any questions, the data subject may contact the Data Protection Officer: https://ftbconsultoria.com.br/en/contato/

16. Effective Date

This Policy is effective as of: 31/03/2026

FTB Consultoria © 2026. All rights reverved.