Data Protection

Privacy Policy

Last updated: April 20, 2026

1. Controller Identity

The personal data controller is Avory Global Ltda, a Brazilian limited liability company registered under CNPJ 64.150.817/0001-29, with registered address at R. Evaristo da Veiga, 417, Jardim Carvalho, Ponta Grossa – PR, CEP 84.016-030, Brazil. Contact: avoryglobal@gmail.com.

2. Scope

This Privacy Policy describes how Avory Global Ltda ("we", "us", "our") collects, uses, stores, and shares personal data when you access our websites, platforms, or services. It applies to all users, customers, partners, and visitors.

3. Data We Collect

Identification data: full name, CPF or CNPJ, date of birth.
Contact data: email address, phone number, mailing address.
Transactional data: purchase history, orders, and invoices.
Browsing data: IP address, browser type, device identifiers, pages visited, and access logs.
Cookie data: session and persistent cookies, analytics identifiers.
Communications: messages, inquiries, and support tickets you send us.

4. Legal Bases for Processing (LGPD)

We process personal data exclusively on the following legal bases established by Brazilian Federal Law 13.709/2018 (Lei Geral de Proteção de Dados – LGPD):

Consent of the data subject (Art. 7, I) — where explicitly collected.
Performance of a contract or pre-contractual procedures (Art. 7, V).
Compliance with a legal or regulatory obligation (Art. 7, II).
Legitimate interests of the controller, when not overridden by the data subject's rights (Art. 7, IX).

5. Purposes of Processing

To create and manage user accounts and registrations.
To process orders, payments, and service deliveries.
To fulfill legal, tax, and regulatory obligations.
To send transactional communications related to your account or orders.
To send promotional and marketing communications (only with your prior consent).
To improve our products, services, and platform security.
To prevent fraud, abuse, and unauthorized access.
To conduct internal analytics and business reporting.

6. Data Sharing

We do not sell, rent, or trade your personal data to third parties. We may share your data only in the following circumstances:

With service providers and processors who assist our operations (e.g., payment processors, hosting providers, logistics), under strict data processing agreements.
With government authorities, courts, or regulators when required by applicable law or legal process.
With potential acquirers or investors in the event of a merger, acquisition, or sale of assets, subject to confidentiality obligations.

7. International Data Transfers

Your data is primarily processed in Brazil. If any international transfer is necessary, it will be carried out in accordance with Chapter V of the LGPD, including the use of appropriate safeguards such as standard contractual clauses or transfers to countries with an adequate level of protection as recognized by the ANPD.

8. Data Retention

Personal data is retained for as long as necessary to fulfill the purposes for which it was collected, to comply with legal obligations (Brazilian tax law requires a minimum retention period of 5 years for fiscal records), or until you validly request deletion where permitted by law. After the retention period, data is securely deleted or anonymized.

9. Your Rights as a Data Subject

Under the LGPD (Art. 18), you have the following rights regarding your personal data:

Confirmation of the existence of processing and access to your data.
Correction of incomplete, inaccurate, or outdated data.
Anonymization, blocking, or deletion of unnecessary or unlawfully processed data.
Portability of your data to another service or product provider.
Deletion of data processed based on your consent.
Information about third parties with whom your data has been shared.
Withdrawal of consent at any time, without affecting the lawfulness of prior processing.
Opposition to processing carried out on grounds other than consent, in case of non-compliance with the LGPD.
The right to lodge a complaint with the ANPD (Autoridade Nacional de Proteção de Dados — www.gov.br/anpd).

To exercise any of these rights, contact us at avoryglobal@gmail.com. We will respond within 15 business days.

10. Cookies

Our platforms use the following types of cookies:

Essential cookies: necessary for the platform to function properly. Cannot be disabled.
Functional cookies: remember your preferences and settings.
Analytics cookies: help us understand how users interact with our platform (e.g., Google Analytics).
Marketing cookies: used to deliver relevant advertising (only with your consent).

You may control non-essential cookies through your browser settings at any time. Disabling certain cookies may affect platform functionality.

11. Security

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or alteration. These measures include encryption of data in transit (TLS/SSL), access controls, and regular security assessments. However, no method of transmission over the internet is 100% secure, and we cannot guarantee absolute security.

12. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have inadvertently collected data from a minor, we will take immediate steps to delete such data.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised "Last updated" date. We encourage you to review this Policy periodically. Continued use of our services after changes are posted constitutes acceptance of the revised Policy.

14. Contact & Data Protection Officer (DPO)

For any questions, requests, or concerns regarding this Privacy Policy or the processing of your personal data, please contact our Data Protection Officer:

Company: Avory Global Ltda
Email: avoryglobal@gmail.com
Address: R. Evaristo da Veiga, 417, Jardim Carvalho, Ponta Grossa – PR, CEP 84.016-030, Brazil

Avory Global Ltda · CNPJ 64.150.817/0001-29 · Ponta Grossa, PR, Brazil