This website is a digital property managed, operated, and optimized by TiMo Midia Ltda, registered under CNPJ No. 62.179.475/0001-44, with its principal address at Rua Ana de Carvalho Silveira, No. 287, Silveira District, Belo Horizonte/MG, ZIP Code 31.140-440, Brazil (“TiMo Midia”).
Transparency is a fundamental pillar of our operations. This document describes how we collect, use, and protect your personal data.
Regulatory frameworks considered (as applicable): LGPD and Marco Civil da Internet (Brazil), Law 25,326 (Argentina), Law 1581 (Colombia), LFPDPPP (Mexico), CCPA/CPRA and other applicable U.S. state privacy laws, PIPEDA (Canada), and APPI (Japan), among others.
1. CONTROLLER IDENTIFICATION AND CONTACT INFORMATION
This website is a digital property managed, operated, and optimized by:
TiMo Midia Ltda.
CNPJ No.: 62.179.475/0001-44
Address: Rua Ana de Carvalho Silveira, No. 287, Silveira District, Belo Horizonte/MG, ZIP Code 31.140-440, Brazil
Privacy Officer / DPO (Privacy Channel): TiMo Midia Compliance Team
Email: [email protected]
2. SCOPE OF THIS POLICY
This Policy applies to the processing of personal data:
a) within the context of this domain (website) and the technologies used on it; and
b) where applicable, within the context of digital properties and advertising inventory operated and/or monetized by the TiMo Network.
It covers activities such as security, measurement, fraud and invalid traffic prevention, performance improvement, advertising delivery and verification (including programmatic advertising), and user support.
This Policy may be supplemented by specific notices (e.g., cookie banners or preference centers). In case of conflict, the specific notice applicable to the environment you are accessing shall prevail.
3. IMPORTANT DEFINITIONS
- Personal Data: Information that identifies or can reasonably identify an individual, directly or indirectly.
- Sensitive Personal Data: Data concerning racial or ethnic origin, health information, biometric data, political opinions, etc. (where applicable).
- Processing: Any operation performed on personal data (collection, use, storage, sharing, etc.).
- Cookies and Similar Technologies: Cookies, pixels, web beacons, SDKs, tags, and identifiers used for site operation, measurement, security, and advertising.
- Programmatic Advertising: The automated buying and selling of advertising inventory using technology for delivery, measurement, and control (e.g., fraud prevention, frequency capping, reporting).
4. ROLES AND RESPONSIBILITIES (CONTROLLER / PROCESSOR / INDEPENDENT CONTROLLERS)
4.1 TiMo Midia’s Role
TiMo Midia acts as a Controller, particularly for purposes related to:
- website operation and maintenance;
- security and system stability;
- fraud and invalid traffic prevention;
- aggregated measurement and reporting;
- advertising monetization (where applicable).
4.2 Partners and Vendors
Certain technology providers and partners (including advertising and measurement providers) may act:
- as Processors (processing data on behalf of TiMo Midia); and/or
- as Independent Controllers (processing data for their own purposes under their own policies).
Relevant example: Google and its advertising/measurement services may process data under their own policies. For transparency regarding Google’s partner ecosystem, please refer to:
https://policies.google.com/technologies/partner-sites
5. DATA WE COLLECT
5.1 Automatically Collected Data (Logs and Technical Data)
For website operation, security, measurement, and advertising, we automatically collect information such as:
- IP address;
- online identifiers and/or cookie identifiers (where applicable and based on your choices);
- browser type and version;
- Internet Service Provider (ISP);
- date and time of access;
- referring and exit pages;
- clickstream data and event information (e.g., ad impressions, interactions, load events);
- device technical information (e.g., operating system, language, screen resolution, user agent);
- security and integrity indicators (e.g., signals associated with fraud, bots, invalid traffic).
These data are used for system administration, security, fraud prevention, and analytics/reporting (including aggregated reports). Where possible, we use aggregated and/or de-identified data.
5.2 Data You Provide
When you contact us, we may collect:
- name, email address, phone number (if provided);
- message content and attachments;
- information necessary to validate your request (e.g., identity verification when required).
5.3 Sensitive Data and Children
Our services are not directed to individuals under 18 years of age, and we do not knowingly collect personal data from minors. If we identify inadvertent collection, we will take reasonable steps to delete such data.
We do not intentionally request sensitive personal data. If you voluntarily provide such data (e.g., in communications), we will process it solely for responding to your request and with appropriate safeguards.
6. PURPOSES FOR PROCESSING
We use personal and browsing data to:
a) operate, maintain, and improve website functionality;
b) ensure technical stability and security;
c) detect, mitigate, and prevent fraud, bots, and invalid traffic;
d) measure audience and performance (including aggregated statistics);
e) deliver, measure, and optimize advertising (including programmatic advertising);
f) manage ad frequency and improve relevance (where permitted);
g) respond to inquiries and provide support;
h) comply with legal and regulatory obligations and protect the rights of TiMo Midia and third parties.
7. LEGAL BASES FOR PROCESSING
Depending on the jurisdiction and purpose, processing may be based on:
- Consent (e.g., advertising or personalization cookies where required);
- Compliance with legal or regulatory obligations;
- Performance of a contract or pre-contractual measures;
- Legitimate interests (e.g., security, fraud prevention, service improvement, measurement), subject to balancing tests and transparency measures.
In certain jurisdictions, advertising practices and/or cookies require prior, express, and informed consent. Where required, appropriate consent and opt-out mechanisms are implemented.
8. COOKIES AND SIMILAR TECHNOLOGIES
We use cookies, pixels, and similar technologies for site functionality, measurement, security, and advertising.
8.1 Cookie Categories
a) Strictly Necessary Cookies
Essential for site functionality, security, and stability.
b) Performance/Analytics Cookies
Help us understand website usage and improve performance (often in aggregated form).
c) Advertising/Marketing Cookies
Used to deliver, measure, and optimize ads, potentially including personalization where permitted.
8.2 Managing Preferences
- Cookie Banner/Preference Center (when available): Accept, reject, or customize categories.
- Browser/Device Settings: You may block or delete cookies through your browser settings.
Disabling cookies may impact certain site features.
9. PROGRAMMATIC ADVERTISING, GOOGLE (AD MANAGER/ADX), AND CONSENT MODE
TiMo Midia uses advertising platforms including Google Ad Manager and Google Ad Exchange (AdX), and may operate within the Google ecosystem (e.g., MCM/AdX).
Where applicable, we implement Google Consent Mode (including Consent Mode v2) to adjust tag behavior according to user choices, including signals such as:
- ad_storage
- analytics_storage
- ad_user_data
- ad_personalization
If consent is denied, tags may operate with limited functionality (e.g., cookieless pings). In such cases, providers may rely on aggregated data and statistical modeling for reporting and measurement.
For more information about Google’s data processing practices on partner sites, please visit:
https://policies.google.com/technologies/partner-sites
10. DATA SHARING
We may share data, as necessary and consistent with your preferences, with:
- hosting, infrastructure, and technical support providers;
- analytics and measurement tools;
- advertising technology partners (AdTech);
- fraud and invalid traffic prevention service providers;
- consultants and auditors (with safeguards);
- competent authorities when legally required.
In certain jurisdictions (e.g., California), sharing identifiers for cross-context behavioral advertising may be considered a “sale” or “sharing.” Where applicable, we provide opt-out mechanisms.
11. INTERNATIONAL DATA TRANSFERS
Due to our global operations and technology providers, data may be processed or stored outside your country of residence.
Where required, we implement appropriate safeguards such as contractual clauses and legally recognized transfer mechanisms.
12. DATA RETENTION
We retain personal and browsing data for as long as necessary to:
- fulfill the purposes described in this Policy;
- comply with legal/regulatory obligations;
- enable audits and security analysis;
- prevent fraud and protect rights.
Data will be deleted or anonymized when no longer necessary, subject to legal requirements.
13. YOUR PRIVACY RIGHTS
You may exercise your rights free of charge by contacting:
[email protected]
Depending on your jurisdiction, rights may include:
- access;
- correction;
- deletion;
- portability;
- objection;
- withdrawal of consent;
- information about data sharing;
- limitation or review of automated decisions (where applicable).
U.S. residents may have additional rights under applicable state laws (e.g., California residents under CCPA/CPRA), including the right to opt out of sale or sharing.
14. U.S. – RIGHT TO OPT OUT (“DO NOT SELL OR SHARE”)
Where applicable (e.g., California residents), you may:
- opt out of the sale or sharing of personal data for cross-context behavioral advertising;
- request access, correction, or deletion;
- limit the use of sensitive personal information (where applicable).
You may exercise these rights via the cookie preference center (when available) or by emailing [email protected].
15. DIGITAL ACCESSIBILITY (BRAZIL)
We strive to maintain digital interfaces aligned with international accessibility best practices and, where applicable, standards such as WCAG 2.2 AA.
16. INFORMATION SECURITY
We implement reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure. Our controls are aligned with recognized best practices and, where applicable, international standards such as ISO/IEC 27001 and 27701.
No system is entirely risk-free. In the event of a relevant security incident, we will take appropriate containment and notification measures as required by law.
17. POLICY UPDATES
This Policy may be updated at any time to reflect operational, regulatory, or technological changes. We encourage periodic review.
18. CONTACT US
To exercise your rights or submit inquiries:
Email: [email protected]
Address: Rua Ana de Carvalho Silveira, No. 287, Silveira District, Belo Horizonte/MG, ZIP Code 31.140-440, Brazil.
