1. Who are we?

1.1) We are a company dedicated to offering educational content and digital tools that help users on their journey of learning and professional development.
1.2) Our courses and info-products have been designed to empower our clients with knowledge and skills applicable to various areas of activity.
1.3) Impulse acts as Controller of your Personal Data, determining the purposes and means of Processing this information, as permitted by law.

2. What personal data do we process?

2.1) a. Registration data:

2.1.1) Full name

2.1.2) CPF

2.1.3) date of birth

2.1.4) gender

2.2) b. Contact details:

2.2.1) E-mail

2.2.2) landline or cell phone

2.3) c. Payment data:

2.3.1) Credit/debit card information

2.3.2) PIX

2.3.3) bank account

2.3.4) transactions carried out

2.4) d. Technical data:

2.4.1) IP address

2.4.2) type of device

2.4.3) operating system

2.4.4) browser

2.4.5) geolocation data (if authorized)

2.4.6) cookies

2.4.7) device ID

2.4.8) interactions made on the Platform

2.5) Sensitive data:

2.5.1) Impulse does not collect sensitive personal data such as racial or ethnic origin

2.5.2) religious beliefs

2.5.3) political opinions

2.5.4) trade union membership

2.5.5) information about health or sex life

2.6) Data from minors:

2.6.1) Impulse does not process the personal data of minors under the age of 18

2.6.2) If we identify that data has been provided by minors, we reserve the right to delete these records from our systems without prior notice

3. How do we use your personal data?

3.1) Impulse processes your Personal Data for various purposes, always respecting the principles of transparency, necessity and adequacy established by the LGPD.
3.2) Enabling the provision of contracted services

3.2.1) Identify the User and register on the Platform

3.2.2) Allow access to the courses and info products purchased

3.2.3) Process payments made by the User on our Platform

3.3) Fraud prevention

3.3.1) To protect the security of the User and third parties during transactions carried out on the Platform

3.3.2) Preventing fraud, especially related to the purchase of courses and services

3.4) Communication and advertising

3.4.1) Send information about our courses, new launches, events and institutional updates by e-mail, text messages (SMS or apps) or phone calls

3.4.2) Carry out promotional campaigns, unless the User expressly requests not to be contacted for these purposes

3.4.3) Provide invitations to events and surveys organized by Impulse

3.5) Improving services and management of the Platform

3.5.1) Improve the courses, content and services offered by Impulse based on User data and interactions

3.5.2) Customize the User's experience on the Platform to suit their preferences

3.5.3) Carrying out internal analyses and performance reports to optimize business processes and strategies

3.5.4) Identify and solve technical or security problems in the Platform

3.6) Compliance with legal and regulatory obligations

3.6.1) Issuing invoices and complying with legal or regulatory obligations required by the competent tax, judicial or administrative authorities

3.6.2) Complying with requests and orders from government authorities

3.7) Regular exercise of rights

3.7.1) Use Personal Data for the defense of Impulse's rights, including as evidence in judicial, administrative or arbitration proceedings, whenever necessary

3.8) Credit protection

3.8.1) In the event of default, the Personal Data may be used to contact the User in order to seek regularization of payments

3.8.2) Registering the User with credit protection agencies, where applicable, in compliance with legal regulations

4. Who do we share your personal data with?

Impulse may share your Personal Data with third parties, always limited to the minimum necessary to fulfill the purposes described in this Policy. We guarantee that all sharing is carried out in accordance with the guidelines of the LGPD and other applicable legislation, adopting measures to protect your data and limit its use to the specific purposes previously informed. Below are the main situations in which your Personal Data may be shared:

4.1) With companies in the economic group

4.1.1) We may share your Personal Data with our group companies when necessary to operate the Platform, provide our courses and services, or comply with legal and regulatory obligations.

4.1.2) Sharing may also occur in cases of corporate changes at Impulse, such as mergers, spin-offs, acquisitions, restructurings or transfers of control, observing the principles and rules of this Policy.

4.2) With business partners

4.2.1) Your Personal Data may be shared with commercial partners in order to offer courses, events and promotions or to carry out sweepstakes and related activities, but not limited to.

4.2.2) In all cases, we will ensure that the data is used exclusively for the purposes previously agreed and informed.

4.3) With service providers

4.3.1) We may share your Personal Data with companies and providers contracted to provide technical and operational support to the Platform, including but not limited to:

4.3.2) Information technology (IT) service providers;

4.3.3) Marketing and communication service providers;

4.3.4) Accreditors and payment intermediaries;

4.3.5) Cloud service providers;

4.3.6) Customer service companies and satisfaction surveys.

4.3.7) These companies will be contractually obliged to protect your Personal Data and use it only for the purposes defined by Impulse.

4.4) With public authorities and regulatory bodies

4.4.1) We may share your Personal Data with public authorities, governmental or regulatory bodies in the following cases:

4.4.2) To fulfill court orders, legal legal or regulations;

4.4.3) To investigate, prevent or act against illegal activities, suspicions or violations of rights;

4.4.4) To allow the regular exercise of Impulse's rights in administrative, judicial or arbitration proceedings;

4.4.5) To respond to requests from consumer protection bodies or inspections.

4.5) With law firms and external legal advisors

4.5.1) Your Personal Data may be shared with law firms or external legal advisors, whenever necessary for the defense of Impulse's rights, for the prevention of fraud or for the fulfillment of legal and contractual obligations.

4.6) With third parties in international transfers

4.6.1) If it is necessary to share Personal Data with third parties located outside Brazil, we will ensure that the international transfer is carried out on the basis of one of the legal hypotheses provided for by the LGPD, including the adoption of specific contractual clauses for data protection.

4.6.2) All third parties with whom we share your Personal Data, whether they are public or private entities, are contractually obliged to adopt the best data security and protection practices, as required by legislation and the contracts signed with Impulse.

5. Cookies

5.1) By contracting Impulse's services, the User consents to the use of cookies.

5.1.1) Cookies are identifiers (in text file format) that can be generated, or collected, from your cell phone or browser that allow us to offer a personalized access experience for you, helping us to analyze where you browse on the Internet and, thus, we can offer you products that are compatible with your searches.

5.1.2) Cookies do not give us access to your computer or cell phone and they do not reveal information other than that which you have chosen to share with us.

5.2) Managing cookies

5.2.1) You can manage or disable cookies in your browser settings.

5.2.2) However, we remind you that, as some of them are necessary to enable you to use our website, if you disable all cookies you may not be able to fully access our website.

5.3) Types of cookies used and their purposes

5.3.1) Grouped into groups, below we list the types of cookies used and their purposes.

5.4) Necessary/Essential

5.4.1) These are essential cookies to enable the proper functioning of our website, as well as to allow you to make use of all available features.

5.5) Performance/Analysis

5.5.1) These are cookies that help us understand how visitors interact with our website, providing information on the areas visited, the time spent visiting the website and any problems that may be encountered.

5.6) Functional

5.6.1) These are cookies that allow us to remember your previous choices, such as browsing language.

5.6.2) They are responsible for providing a personalized experience.

5.7) Marketing/Advertising

5.7.1) These cookies are used to provide more content that is relevant and specific to your interests.

5.7.2) They can also be used to show you more targeted advertising or limit the number of times it is shown.

5.7.3) They also allow the effectiveness of a campaign to be measured.

5.8) Necessary cookies

5.8.1) We would like to point out that the necessary cookies are essential for the normal operation of our website.

5.8.2) This means that if you object to the use of this tool, this may result in your experience being unfeasible or your access being suspended.

5.9) First-party and third-party cookies

5.9.1) It is also worth noting that our website may contain cookies directly installed by Impulse (first-party cookies) or those linked to third-party domains (third-party cookies).

5.9.2) The latter, although installed by other companies, offer some functionalities on the website, particularly in relation to advertising.

5.10) Security of information

5.10.1) All your information collected on our website is protected by our certified information security controls.

5.10.2) If, however, the User does not feel comfortable using this tool, cookies can be easily disabled by configuring the browser.

5.10.3) In these cases, the Platform may not operate correctly or may take too long to load content.

6. How do we protect your personal data?

6.1) Impulse adopts strict security measures to protect the Personal Data you provide, ensuring that it is treated securely and in compliance with applicable legislation. All information sent through the Platform is transmitted via encrypted protocols, such as HTTPS, and stored in protected databases, inaccessible to unauthorized persons or any external environment. This encryption prevents malicious agents from intercepting or deciphering the data.
6.2) Access to Personal Data is restricted to authorized Impulse employees and contracted service providers, who use the information exclusively for the purposes previously described in this Policy. To prevent unauthorized access, we use firewalls and other security mechanisms that operate continuously, protecting our servers and systems from threats.
6.3) Impulse does not sell or rent your Personal Data to third parties under any circumstances. Any sharing of information is carried out within the limits described in this Policy and always with the aim of guaranteeing the execution of the contracted services or compliance with legal and regulatory obligations.
6.4) As for communications sent by the User, all e-mails or messages received by Impulse are treated confidentially. We do not add e-mail addresses to our distribution lists without the express consent of the User. In specific situations, such as requests related to newsletters or subscriptions, we may request additional information to verify the identity of the sender, thus reinforcing the security of the data processed.
6.5) Impulse has a strict policy against the use of unsolicited e-mail messages to promote its services and products. We only send communications to Users who have previously consented to receive them. Violation of this policy by third parties, such as partners or affiliates, will result in the immediate termination of the partnership and the adoption of appropriate measures.

7. How long do we store your personal data?

7.1) Impulse will store your Personal Data for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required to comply with legal obligations, safeguard our rights, comply with judicial or extrajudicial agreements, or for auditing and compliance purposes.
7.2) To determine the retention period of your Personal Data, we consider criteria such as:

7.2.1) 1. The existence of legal or contractual obligations requiring the retention of data.

7.3.1) 2. The need to preserve information for investigation, litigation or audit purposes.

7.4.1) 3. The importance of data for keeping accurate business and financial records.

7.5) Once the purpose for processing has been exhausted or legal obligations have been met, Personal Data will be deleted by means of secure disposal methods or anonymized for exclusive use in statistical analyses and studies.
7.6) Users' Personal Data is stored on cloud computing servers located in Brazil or abroad, always in compliance with the requirements of the applicable legislation. To protect the integrity and confidentiality of the information, Impulse adopts the best security and privacy practices, ensuring that the data is secure and accessible only by authorized persons or systems.

8. What are your rights and how can you exercise them with Impulse?

8.1) Regardless of your relationship with Impulse, you are guaranteed all the rights relating to your Personal Data provided for in the General Data Protection Law (LGPD). Among the rights guaranteed are the right to request confirmation that your data is being processed, to access the information collected and to correct incomplete, outdated or incorrect data.
8.2) You can also request the deletion, blocking or anonymization of data that is unnecessary, excessive or processed in breach of the law, as well as request the transfer of data to another institution, if applicable.
8.3) It is your right to receive clear information about the public or private entities with which we share your Personal Data, as well as to request a review of automated decisions that may affect your interests.
8.4) To exercise any of these rights, you can contact Impulse's Personal Data Controller by emailing contact.us@incimpulse.com. When making your request, you must provide your full name, registered e-mail address and an identification document. In addition, you must specify the measure requested and, if applicable, indicate the data that is the subject of the request.
8.5) Impulse will analyze your request and respond within 15 days, unless the law sets a different deadline. In specific situations, it may be necessary to extend the response period for the same period. If we are unable to respond to your request, we will explain the reasons for this decision.
8.6) Important: please note that requests involving third-party data can only be fulfilled by power of attorney, parental authority or other legal authorization.
8.7) There are circumstances in which Impulse will need to keep your data, even in the face of a request for deletion or alteration, such as in cases where it is necessary to comply with legal obligations or comply with court orders.
8.8) Impulse may occasionally use your name and e-mail address to send you information related to the courses and info-products available, as well as other communications that may be of interest to you. If you wish to be removed from our communications list, you can make this request by emailing contact.us@incimpulse.com.
8.9) Similarly, if you no longer wish to receive messages via WhatsApp or other communication channels, simply send us an email with your request.

9. Links to Third Party Sites

9.1) Impulse may provide links to other websites or platforms that are not operated or controlled by us. These third-party websites or platforms are beyond our control, and we have no control over the content they offer or how they collect, store and use your Personal Data.
9.2) Consequently, we do not endorse or guarantee the security or reliability of these platforms, nor do we make any representations about their quality or integrity.
9.3) Third-party websites may have their own privacy policies and terms of use, which determine how Users' Personal Data is handled. We therefore strongly recommend that you read these documents carefully before browsing or interacting with such platforms. This will allow you to understand how your information may be collected, used and shared by these third parties.
9.4) The use of links provided by Impulse is your sole responsibility. We are not responsible for any damage, harm or inconvenience arising from interaction with third-party websites or platforms accessed through our Platform.

10. GENERAL QUESTIONS

10.1) If You have any questions, complaints or wish to exercise Your rights in relation to Your Personal Data, You can contact Impulse through our official channels, or send an e-mail to contact.us@incimpulse.com.

11. CHANGES TO THIS PRIVACY POLICY

11.1) Impulse reserves the right to modify these rules on the site at any time and without prior notice, in particular to adapt them to developments in the service provided, either by drawing up new provisions or by deleting or modifying existing ones. We therefore recommend that you check this page periodically.

12. GLOSSARY

12.1) National Data Protection Authority (ANPD)

12.1.1) This is the federal public administration body responsible for ensuring the protection of Personal Data and for regulating, implementing and overseeing compliance with the General Personal Data Protection Law (Federal Law No. 13,709/2018) in Brazil.

12.2) Personal Data

12.2.1) Information relating to an identified natural person or which allows them to be identified, directly or indirectly.

12.2.2) In addition to basic identification information, such as name, identification number, location data, other data relating to a natural person, such as their consumption habits, appearance and aspects of their personality, are also considered Personal Data.

12.3) Sensitive Personal Data

12.3.1) Any Personal Data concerning racial or ethnic origin, religious conviction, political opinion, membership of a trade union or religious, philosophical or political organization, as well as data concerning health or sex life, genetic or biometric data.

12.4) Third Parties

12.4.1) Refers to, but is not limited to, any and all natural or legal persons that Impulse relates to or will relate to, service providers, suppliers, consultants, partners, third party contractors or subcontractors.

12.5) Data Subject

12.5.1) Natural person to whom the Personal Data refers.

12.6) Processing

12.6.1) Any activity carried out with Personal Data, such as collection, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, updating, communication, transfer, sharing and extraction.

12.7) You or User

12.7.1) Individuals who use the website and the products made available by Impulse.

12.8) Impulse

12.8.1) IMPULSE EDUCAÇÃO LTDA., a legal entity governed by private law, registered with the CNPJ/ME under No. 37.837.482/0001-49, with headquarters at Av. Carlos Gomes, No. 281, Sala 601, Mon't Serrat neighborhood, Porto Alegre/RS, CEP 90.480-003.