/ LEGAL · PRIVACY
Privacy Policy
This page explains, in plain English, what personal data the CORTEX website collects, why it collects it, who it is shared with and what you can demand about it. It follows Brazil's General Data Protection Law (LGPD, Law 13.709 of 2018), which governs this site. In case of doubt, the Portuguese version prevails.
1. Who is responsible for your data
The controller of the personal data processed on this site is CORTEX, a digital marketing agency located at Av. Tancredo Neves, 1632, Salvador Trade Center, Torre Norte, room 1815, Salvador, Bahia, Brazil.
For any matter related to this policy, including exercising your rights, the channel is [email protected].
2. What data this site collects
Nothing here requires an account, and you can browse the whole site without identifying yourself. The data that exists is the following:
Data you type in yourself
In the Contact section form we ask for your name, email, phone (optional) and your message. These fields are filled in by you and sent to [email protected].
It is worth knowing how it works today: the form does not store anything in a database. When you submit, the site assembles the message and opens your own email app, and the sending happens from your side. In practice, we receive a regular email, and it sits in our inbox like any other.
Browsing data
We use Google Analytics 4 to understand how the site is used: which pages were viewed, for how long, from which device and browser, where the visit came from (search, social, direct link) and the approximate location, at city level. Google Analytics 4 does not log the full IP address.
We also use the Meta Pixel, from Facebook and Instagram, which records visits and interactions to measure ad campaigns and build remarketing audiences. It is what makes it possible for you to see one of our ads after visiting this site.
We also record some specific actions: clicks on WhatsApp buttons (and which one), clicks on the phone number and the email, form submissions and the opening of each service in the list. This is aggregate behavior measurement; it does not identify you by name.
Technical data
Like any website, ours receives your IP address and browser information on each visit, processed by Cloudflare and by the hosting provider to deliver the pages and protect against attacks. This is also what the Brazilian Internet Civil Framework (Law 12.965 of 2014) requires application providers to keep.
The site's typefaces are loaded from Google Fonts, which means your IP reaches Google the moment the page opens.
3. What we use it for, and on what legal basis
The LGPD requires every processing activity to rest on a legal basis. Ours are these:
- Replying to your contact and conducting a business conversation. Basis: preliminary contract procedures, article 7, item V.
- Understanding how the site is used and improving what doesn't work well. Basis: legitimate interest, article 7, item IX.
- Measuring and targeting our advertising. Basis: legitimate interest, article 7, item IX, with the right to object described in section 7.
- Keeping the site online and secure, and keeping access logs. Basis: compliance with a legal obligation, article 7, item II, combined with the Internet Civil Framework.
We do not use your data for automated decisions, we do not build individual credit or risk profiles, and we do not sell data to anyone.
4. Cookies
A cookie is a small file a website stores in your browser. The ones that exist here come from the measurement tools mentioned above, from Google and Meta, and serve to tell a new visit from a returning one and to measure campaigns. The site itself does not need cookies to work: without any of them, everything keeps opening normally.
You can block or delete cookies in your browser settings, and each browser explains how. If you prefer to act at the source, Google offers a browser add-on that disables Google Analytics on all websites, and Meta lets you adjust how your data is used for ads in your account settings.
5. Who we share it with
We do not hand your data to third parties interested in it. What exists is the use of services that make the site work, and each of them processes data on its own, under the policy it publishes:
| Service | What for | What it receives |
|---|---|---|
| Google Analytics | Site usage statistics | Browsing, device, approximate city |
| Meta Pixel | Ad measurement and targeting | Browsing and interactions on the site |
| Google Fonts | Loading the typefaces | IP address |
| Cloudflare | Page delivery and security | IP address and request data |
| HostGator | Site hosting | Server access logs |
| Conversation, if you click one of our buttons | Whatever Meta processes on its platform |
We may also share data under a court order or a request from a competent authority, within the limits of the law.
6. International transfers
Google, Meta and Cloudflare are foreign companies and process data on servers outside Brazil. This is an international transfer, provided for in article 33 of the LGPD, and it happens on the basis of the contractual clauses and protection commitments these companies publish. CORTEX keeps an office in Ontario, Canada, and operational information may be accessed from there.
7. Your rights
Article 18 of the LGPD guarantees that you can request, at any time and free of charge:
- Confirmation that we process data about you, and access to it.
- Correction of incomplete, inaccurate or outdated data.
- Anonymization, blocking or deletion of data that is unnecessary, excessive or processed unlawfully.
- Portability to another provider.
- Deletion of data processed with your consent.
- Information about who we share data with.
- Withdrawal of consent, and information about what happens if you do not consent.
- Objection to processing based on legitimate interest, which includes the measurement and advertising described here.
To exercise any of them, write to [email protected] with the subject "LGPD". We reply within 15 days. We may ask for some information to confirm you are who you say you are, precisely so we never hand one person's data to another.
You can also file a complaint with the Brazilian National Data Protection Authority (ANPD), at gov.br/anpd.
8. How long we keep it
- Contact messages: for as long as the business conversation lasts and for the time they may be needed as a record of the relationship.
- Access logs: six months, as required by article 15 of the Internet Civil Framework.
- Measurement data: for the retention period configured in Google Analytics and Meta, after which they delete it.
Once these periods pass, the data is deleted or anonymized, except where the law requires longer retention.
9. Security
The site is served only over an encrypted connection (HTTPS), and administrative access is restricted to those who need it to work. No measure eliminates risk completely: if an incident happens that may create relevant risk to you, we will notify you and the ANPD, as required by article 48 of the LGPD.
10. Children and teenagers
This site is aimed at companies and professionals, and we do not knowingly collect data from anyone under 18. If we find out this happened without the consent of a parent or guardian, we will delete the record.
11. Changes to this policy
When the site changes in a relevant way, this page changes with it, and the last-updated date at the top is what counts. Significant changes will be flagged on the page itself.
12. Talk to us
Questions about this policy, deletion requests, or anything else related to your data: [email protected] · +55 71 9 9389-8989 · Monday to Friday, 9 am to 6 pm.