Privacy Policy

This is a translation of the Portuguese original. Where the two differ, the Portuguese version prevails.

This Privacy Policy explains how 6PS MEDIA GROUP LTDA (“6PS”, “we”), registered under CNPJ 12.829.681/0001-84, with its registered office at Rua Bananeiras, 361, Sala 101, Caixa Postal 279, Manaíra, João Pessoa/PB, CEP 58038-170, Brazil, handles personal data on its website, in its support channels, and in delivering its technology services.

It is written to comply with Law 13.709/2018 (Brazil’s General Data Protection Law, the LGPD), the Marco Civil da Internet (Law 12.965/2014) and, where they apply, other data protection laws binding on 6PS or its clients.

1. Who we are and who this Policy covers

6PS is a technology company that develops, integrates, operates and maintains digital solutions, including custom software, our own platforms, applications, APIs, integrations between systems, automation, artificial intelligence solutions, digital communication, and data and infrastructure services (the “Services”).

This Policy covers:

visitors to 6ps.group and to pages and domains 6PS operates;
clients, prospective clients, partners and suppliers, and their representatives;
users of platforms, applications and systems developed or operated by 6PS;
people whose data 6PS processes on behalf of clients.

Specific products or services may carry additional privacy notices. Where they conflict, the specific notice prevails on whatever it covers in more detail.

2. Our role in the processing

As controller: where we decide on the processing, for example data from our website, commercial contacts, contracts, billing, and our own platforms offered directly to the public.
As processor: where we process data on behalf of a client, following their instructions, for example when developing, hosting or operating systems, integrations and automation for them. In those cases the client is the controller and answers to the data subjects; 6PS acts under the contract and our Data Processing Agreement (DPA).

If you are an end user of a solution 6PS operates for another company, we suggest you also read that company’s privacy policy.

3. Data we handle

Depending on the Service and on our relationship with you, we may handle:

Identification and contact: name, email, phone number, company, job title, and CPF or CNPJ where contracting requires it.
Contractual and financial data: billing information, invoices, payment history. Card data is processed directly by payment providers and is not stored by 6PS.
Account and access data: login, credentials held in protected form, permissions, authentication records.
Content and communications: messages, files, forms, support requests and other content you send or that the systems we operate process.
Technical and usage data: IP address, device identifiers, browser, operating system, access and event logs, date and time, pages visited, performance metrics.
Data received from third party platforms: where you or the client authorise a Service to integrate with external platforms, for example messaging providers, social networks, CRMs, ERPs, payment services, cloud or AI services, we handle the data those platforms make available, limited to the authorised scope.
Cookies and similar technologies: see section 9.

We do not set out to handle sensitive personal data, or data of children and adolescents. Where a Service requires it, it happens only on an adequate legal basis and with additional safeguards.

4. Purposes and legal bases

Purpose	Legal basis (LGPD, art. 7)
Providing, running, maintaining and supporting the contracted Services	Performance of a contract
Answering enquiries, proposals and requests	Preliminary procedures to a contract, legitimate interest
Billing, collection and tax and accounting obligations	Compliance with a legal obligation, performance of a contract
Security, prevention of fraud and abuse, availability monitoring	Legitimate interest, legal obligation
Keeping application access records	Legal obligation (Marco Civil, art. 15)
Improvement, development and statistics on the Services, preferably on aggregated or anonymised data	Legitimate interest
Communications about the Services and news to clients	Legitimate interest, with an unsubscribe option
Marketing to non-clients, non-essential cookies	Consent
Exercising rights in court, administrative or arbitration proceedings	Regular exercise of rights
Processing on behalf of clients	The controller’s instructions, on a legal basis the client defines

We do not use client data we handle as a processor for our own purposes, or to train general purpose artificial intelligence models, unless the client expressly authorises it.

We do not sell personal data. We share it only where necessary, with:

Suppliers and sub-processors that help us deliver the Services, such as hosting and cloud, storage, email, communication, monitoring, support, payments, artificial intelligence and development tools, under contractual confidentiality and security obligations;
Third party platforms you or the client chose to integrate with a Service. In that case the processing by those platforms also follows their own terms and policies;
Clients, where we process data on their behalf;
Public authorities, under a legal obligation, court order or request from a competent authority;
Successors, in a corporate reorganisation, merger or acquisition, with the guarantees in this Policy preserved.

6. International transfers

Some suppliers and platforms may store or process data outside Brazil. In those cases the transfer follows article 33 of the LGPD and the ANPD’s rules, through contractual clauses, adequate safeguards or another applicable legal ground.

7. Retention

We keep data for as long as the stated purposes require, taking into account:

the term of the contract and applicable limitation periods;
legal and tax obligations, for example access records for at least 6 months and tax documents for their legal periods;
the client’s instructions, where we act as processor.

Once the period ends, data is securely deleted or anonymised.

8. Security

We apply technical and administrative measures proportionate to the nature of the data and the Services, such as encryption in transit and, where applicable, at rest; least privilege access control; strong authentication; event logging and monitoring; environment segregation; backups; and supplier management. No system is entirely free of risk. Should a security incident arise that may carry relevant risk or harm, we will take the steps the LGPD requires, including notifying the ANPD and the data subjects where that applies.

9. Cookies

Our website may use essential cookies, for operation and security, performance cookies, for usage statistics, and marketing cookies. Non-essential cookies depend on your consent and can be refused or removed at any time through the cookie banner, where available, or through your browser settings.

10. Your rights

Under article 18 of the LGPD you may request: confirmation that processing exists; access; correction of incomplete, inaccurate or out of date data; anonymisation, blocking or deletion of unnecessary data or data processed unlawfully; portability; deletion of data processed on the basis of consent; information about sharing; information about the option not to consent; withdrawal of consent; and review of decisions taken solely by automated processing.

To exercise your rights, write to dpo@6ps.group. We may ask for information to confirm your identity. We answer within the legal deadlines. Where the processing is carried out on behalf of a client, we pass the request to the responsible controller and support them in answering it.

You may also complain to Brazil’s National Data Protection Authority (ANPD).

11. Data deletion

You can ask us to delete the personal data 6PS holds about you, including data obtained through login or integration with third party platforms, as follows:

Send an email to dpo@6ps.group with the subject “Data deletion request”.
Give your name, the email, phone number or identifier used in the Service and, if you know it, the name of the Service, application or company involved.
We confirm receipt and may ask for further details to verify your identity.
We complete the deletion within 15 (fifteen) days of that verification, and you receive a confirmation.

If you connected a Service to a third party platform, you can also revoke access directly in that platform’s settings. Data we are required to keep by law or to exercise our rights is retained only for as long as necessary and deleted afterwards.

12. Data Protection Officer

José Wilker T. de Araujo Email: dpo@6ps.group Address: Rua Bananeiras, 361, Sala 101, Caixa Postal 279, Manaíra, João Pessoa/PB, CEP 58038-170, Brazil

13. Changes

We may update this Policy to reflect changes in the Services, in the law, or in our practices. The version in force is always on this page, with the date it was updated. Significant changes are communicated to clients through the usual channels.

14. Language

This Policy may be made available in other languages. Where versions differ, the Portuguese one prevails.