Privacy Policy

GAMINZA LTDA ("GAMINZA," "we," "us," or "our") is a Brazilian limited-liability company registered under CNPJ, with its principal place of business in Brazil. We operate the website at gaminza-us.site (the "Site") to provide information about our services, communicate our expertise, and allow prospective clients and partners to contact us.

This Privacy Policy applies to all personal data processed through the Site and through any communication channels linked to it — including email correspondence initiated via the contact details published here. By accessing or browsing the Site, you acknowledge that you have read and understood the practices described in this document.

Where we act as the entity that determines the purposes and means of processing your personal data, we are the controller (or controlador under LGPD). We do not sell, rent, or trade personal information for commercial purposes, and we process only the minimum data necessary to fulfil the specific purpose for which it was collected.

We collect personal data in two ways: information you actively provide to us, and information collected automatically when you visit the Site.

Information you provide directly

When you reach out to us using the email address or telephone number published on this Site, or when you communicate with us through a social-media channel listed in our footer, you may voluntarily share personal information such as your name, job title, company name, email address, phone number, and the content of your message. We use this information solely to respond to your inquiry and, if relevant, to follow up with you about our services.

Information collected automatically

When you visit the Site, our servers and third-party analytics tools automatically collect certain technical data. This data is used to maintain Site security, analyse traffic patterns, and improve our content. The categories of automatically collected data include:

We do not knowingly collect sensitive personal data (such as health information, financial account numbers, biometric data, or national identification numbers) through the Site. If you inadvertently include such information in a message sent to us, we will treat it with heightened confidentiality and will not process it beyond what is required to respond to your query.

We rely on the following lawful bases to process personal data, as required by LGPD (Art. 7) and GDPR (Art. 6):

• Responding to inquiries (Legitimate Interest / Consent). When you contact us by email or telephone, we process the data you provide to answer your question, discuss a potential engagement, or pass your inquiry to the right team member. Our legitimate interest in providing timely commercial communication constitutes the lawful basis, reinforced by your affirmative act of reaching out to us.
• Site analytics and performance (Legitimate Interest / Consent for cookies). We use aggregated and pseudonymised traffic data to understand which content is most useful to visitors, identify technical errors, and make improvements. Where this relies on cookies, we obtain your consent through our cookie notice before setting non-essential cookies.
• Advertising measurement (Consent). We may use conversion tracking provided by Google Ads to measure whether a visit to the Site followed a click on one of our advertisements. This processing is subject to your cookie consent.
• Security and fraud prevention (Legal Obligation / Legitimate Interest). Server logs and IP data may be retained temporarily to detect and respond to suspicious activity, denial-of-service attacks, or unauthorised access attempts.
• Legal compliance (Legal Obligation). We may process and retain certain data to comply with applicable tax, accounting, or court-ordered disclosure requirements under Brazilian law.

We do not use personal data for automated decision-making or profiling that produces legal or similarly significant effects on any individual. We will never process your data for a new purpose that is incompatible with the purpose for which it was originally collected without first obtaining your explicit consent.

Cookies are small text files stored on your device by a web browser at the instruction of a website. The Site uses cookies and similar technologies — including web beacons and browser local storage — to deliver a functional browsing experience and to gather the analytics data described in Section 2.

Strictly necessary cookies

These cookies are required for the Site to function correctly. They do not store any personally identifiable information beyond what is technically necessary (for example, a session security token). Because they are essential, they are set without requiring your prior consent.

Analytics cookies

We use Google Analytics 4 (GA4) to collect aggregated statistics about how visitors interact with the Site. GA4 uses cookies (including _ga, _ga_[ID], and _gid) to distinguish users and sessions. We have enabled IP anonymisation, which means the last octet of your IP address is masked before any data is stored. Data collected through GA4 is processed by Google LLC, whose privacy practices are governed by the Google Privacy Policy. Analytics cookies are set only after you grant consent through our cookie notice.

Advertising & remarketing cookies

Where we run campaigns through Google Ads, Google may set a conversion-tracking cookie (_gcl_au or similar) on your device when you click on one of our advertisements. This allows us to measure whether a visit to the Site resulted from an ad click, so we can evaluate campaign effectiveness. We do not use this data to identify you personally. These cookies are classified as non-essential and are only placed with your explicit consent.

Managing your cookie preferences

When you first visit the Site, you will be presented with a cookie consent notice allowing you to accept or decline non-essential cookies. You may change your preferences at any time by clearing your browser's cookies and revisiting the Site, or by adjusting your browser settings. Most modern browsers allow you to refuse or delete cookies; please consult your browser's help documentation for specific instructions. Note that disabling certain cookies may affect the availability or quality of some Site features.

You may also opt out of Google Analytics tracking across all websites by installing the Google Analytics Opt-out Browser Add-on, and opt out of personalised Google advertising via Google Ads Settings.

GAMINZA does not sell, lease, or trade personal data. We share information with third parties only in the limited circumstances described below, and always subject to contractual obligations of confidentiality and data protection.

• Service providers and processors. We engage carefully selected companies to help us operate the Site and our business — including web hosting providers, cloud infrastructure services, email delivery platforms, and analytics vendors (notably Google LLC). These entities act as data processors on our behalf and are contractually prohibited from using your data for any purpose other than providing the services we have engaged them for.
• Advertising technology partners. When you consent to advertising cookies, data about your visit may be shared with Google Ads in accordance with your cookie preferences. We do not share your contact details with advertising partners.
• Legal and regulatory authorities. We may disclose personal data to courts, law enforcement agencies, regulatory bodies, or other governmental authorities when required to do so by applicable law, court order, or legally binding governmental request. Where permitted, we will notify you of such a disclosure.
• Corporate transactions. In the event of a merger, acquisition, restructuring, or sale of all or part of GAMINZA's assets, personal data held by us may be transferred to the acquiring entity as part of that transaction. We will notify affected individuals in advance and provide them with the opportunity to exercise their rights before any transfer occurs.
• Professional advisers. We may share limited personal data with our legal, accounting, or auditing advisers who are bound by professional secrecy and confidentiality obligations.

Where personal data is transferred outside of Brazil or the European Economic Area — for instance, when data flows to Google's servers in the United States — we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses approved by the relevant supervisory authority, or that the recipient country provides an adequate level of data protection as recognised by Brazil's National Data Protection Authority (ANPD).

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law, whichever is longer. The following general retention periods apply:

• Correspondence and contact data — messages and email correspondence are retained for up to 24 months from the date of last interaction, after which they are securely deleted unless an ongoing business relationship requires a longer retention period, or a legal obligation mandates otherwise.
• Analytics data — data collected through Google Analytics is retained for 14 months within the GA4 platform, in line with our GA4 data retention configuration. Aggregated, non-identifiable reports may be kept indefinitely for internal benchmarking purposes.
• Server and access logs — technical access logs are retained for up to 90 days for security and diagnostic purposes and are then deleted on a rolling basis.
• Cookie identifiers — session cookies expire when you close your browser. Persistent cookies have varying lifespans (from a few days to up to 2 years depending on the cookie), as documented in the cookie notice displayed on the Site.
• Legal and compliance records — where we are obliged to retain data by Brazilian commercial, tax, or labour law (typically 5 to 10 years depending on the category), we will retain the minimum information required to satisfy that obligation.

At the end of the applicable retention period, personal data is either securely and irreversibly deleted, anonymised so that it can no longer be associated with any individual, or destroyed in accordance with our internal data disposal procedures.

We implement a range of technical and organisational measures designed to protect personal data against accidental loss, unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS 1.2 or higher) encryption for all data transmitted between your browser and our servers, enforced via an HTTPS-only connection.
• Access controls that restrict internal access to personal data on a strict need-to-know basis, supported by strong authentication requirements for our team members.
• Regular review of third-party service providers to ensure they maintain equivalent or superior security standards, including the signing of Data Processing Agreements where required.
• Periodic vulnerability assessments and software patching to maintain up-to-date security across all systems that store or process personal data.
• Internal data minimisation practices — we actively avoid collecting personal data that is not necessary for the stated purpose, reducing the potential impact of any security incident.

Despite these measures, no method of data transmission over the internet or electronic storage is completely secure. If you have reason to believe that your personal data has been compromised through your interaction with us, please notify us immediately at contato@gaminza-us.site so that we can investigate and take appropriate remedial action. In the event of a data breach that poses a high risk to individuals' rights and freedoms, we will comply with our notification obligations under LGPD and GDPR, notifying the relevant supervisory authority and affected individuals within the timeframes required by law.

Depending on your place of residence and the applicable legal framework — Brazil's LGPD (Art. 18), the EU/UK GDPR (Art. 15–22), or equivalent legislation — you may have some or all of the following rights with respect to the personal data we hold about you:

To exercise any of the rights listed above, please contact us using the details provided in Section 11. We will acknowledge your request within 5 business days and aim to fulfil it within 30 calendar days of receiving sufficient information to identify you and process your request. In complex or high-volume cases, we may extend this period by a further 30 days, in which case we will notify you in writing. There is no charge for exercising your rights unless requests are manifestly unfounded, excessive, or repetitive, in which case we may charge a reasonable administrative fee or decline to act.

We may need to verify your identity before fulfilling a rights request to protect your data from unauthorised disclosure. We will ask for the minimum information necessary to do so and will not retain that verification data beyond what is required.

The Site and all of GAMINZA's services are directed exclusively at businesses and adult professionals. We do not knowingly collect, use, or disclose personal data from individuals under the age of 18. The Site contains no content targeted at minors, and we do not market our services to children.

If you believe that a child has provided us with personal data without appropriate parental or guardian consent, please contact us immediately at contato@gaminza-us.site and we will take prompt steps to identify and delete that information from our systems. Under Brazil's Statute of Children and Adolescents (ECA) and LGPD's specific provisions for child data (Art. 14), we treat such data with the highest level of protection.

We may update this Privacy Policy from time to time to reflect changes in our data practices, the services we offer, or updates to applicable law. Each new version will be published on this page with a revised "Last updated" date at the top of the document. Where a change is material — meaning it significantly affects how we process personal data or alters your rights — we will take reasonable steps to bring it to your attention, such as displaying a prominent notice on the Site.

We encourage you to review this page periodically to stay informed about how we are protecting your information. Your continued use of the Site following the publication of a revised Policy constitutes acknowledgement of the updated terms to the extent permitted by applicable law. If you object to any change, you are free to discontinue use of the Site and to contact us to exercise your data rights.

All previous versions of this Privacy Policy can be made available upon written request submitted to the contact address in Section 11.

For any questions, concerns, or requests relating to this Privacy Policy or to the way we process your personal data — including the exercise of any of your rights described in Section 8 — please contact us directly. We are committed to responding promptly and working with you to resolve any concern.

If you are located in the European Union or European Economic Area and believe we have not adequately addressed your privacy concern, you have the right to escalate your complaint to the data protection supervisory authority in your country of residence. If you are located in Brazil, you may contact the Autoridade Nacional de Proteção de Dados (ANPD) at www.gov.br/anpd.