Privacy Policy

Last updated: July 2026

1. Purpose of this Privacy Policy

Smartmetrics Analytics LTDA, referred to in this Privacy Policy as “Smart Metrics Analytics” or “we,” is committed to protecting the privacy and personal data of its website users, clients, prospective clients, suppliers, business partners, and representatives of organizations that interact with us.

This Privacy Policy explains, in a clear and transparent manner, how we collect, use, store, share, and protect personal data in connection with our activities.

Smart Metrics Analytics provides services related to MarTech consulting, data analytics, customer intelligence, predictive models, data and cloud architecture, process optimization, Customer Data Platforms, customer journey orchestration, training, and ongoing team support.

For questions or requests related to the processing of personal data, please contact us at contato@smartmetricsanalytics.com.br.

2. Smart Metrics Analytics’ Role in Data Processing

Smart Metrics Analytics may act as either a data controller or a data processor, depending on the nature of the activity performed.

We act as a data controller when we make decisions regarding the processing of personal data used for our own activities, including:

• Website management;

• Responding to inquiries and requests;

• Business relationship management;

• Preparation of commercial proposals;

• Contract management;

• Invoicing and payment collection;

• Communications with clients, partners, and suppliers.

In certain consulting, data analytics, technology implementation, customer intelligence, CDP, predictive modeling, or process optimization projects, Smart Metrics Analytics may act as a data processor on behalf of its clients.

In such cases, personal data will be processed in accordance with the client’s instructions, the agreement entered into between the parties, and applicable legislation. The client will be responsible for determining the purposes and essential means of the processing.

3. Personal Data We Process

Depending on how you interact with us, we may process the following categories of personal data:

Identification and contact information

• Full name;

• Email address;

• Telephone number;

• Company or organization;

• Job title or professional role;

• City, state, or country;

• Information provided through forms, messages, or meetings.

Professional and business information

• Employer or organization;

• Industry or area of activity;

• Job title;

• Information regarding business needs;

• History of contacts, meetings, and negotiations;

• Information related to proposals, contracts, invoices, and payments.

Website and usage information

• IP address;

• Device type;

• Browser;

• Operating system;

• Pages visited;

• Date and time of access;

• Referral source;

• Interactions performed on the website;

• Information collected through cookies and similar technologies.

Data processed in client projects

Depending on the scope of a project, Smart Metrics Analytics may have access to data provided by a client for the performance of analytics, integration, modeling, segmentation, customer intelligence, customer journey, platform implementation, or predictive modeling services.

Such data may include information related to the client’s customers, users, consumers, leads, employees, or business partners.

Whenever possible, we recommend and adopt data minimization, anonymization, pseudonymization, or aggregation practices in connection with these projects.

Smart Metrics Analytics will not use data provided by its clients for independent purposes that are incompatible with the services contracted.

4. How We Collect Personal Data

Personal data may be collected:

• Directly from the Data Subject through forms, emails, messages, meetings, or business communications;

• Through the company or organization with which the Data Subject is affiliated;

• During the provision of contracted services;

• Through analytics tools, cookies, and technologies used on our website;

• Through business partners and service providers;

• From legitimate publicly available sources;

• Through systems, platforms, or databases made available by clients in connection with contracted projects.

5. Purposes and Legal Bases for Processing

Smart Metrics Analytics may process personal data for the following purposes:

• Responding to inquiries and contact requests;

• Providing business assistance;

• Understanding the needs of prospective clients;

• Preparing, reviewing, and negotiating commercial proposals;

• Entering into and performing agreements;

• Providing MarTech consulting and data analytics services;

• Developing customer intelligence and predictive modeling projects;

• Implementing, integrating, or optimizing platforms, systems, and processes;

• Conducting meetings, training sessions, videoconferences, and presentations;

• Providing technical support and project assistance;

• Managing relationships with clients, partners, and suppliers;

• Issuing invoices and managing billing and payment collection;

• Sending institutional, commercial, or informational communications;

• Improving the user experience and operation of our website;

• Producing statistical analyses regarding website usage;

• Preventing fraud, abuse, and security incidents;

• Complying with legal or regulatory obligations;

• Exercising rights in judicial, administrative, or arbitration proceedings.

Processing may be based on the Data Subject’s consent, the performance of a contract or preliminary procedures related to a contract, compliance with a legal or regulatory obligation, the exercise of legal rights, or the legitimate interests of Smart Metrics Analytics or third parties, provided that the Data Subject’s fundamental rights and freedoms are respected.

Where processing is based on consent, the Data Subject may withdraw such consent at any time.

6. Sharing of Personal Data

Smart Metrics Analytics may share personal data with third parties when necessary for the performance of its activities, including:

• Cloud hosting and infrastructure providers;

• CRM, marketing automation, and customer service platforms;

• Data analytics and business intelligence providers;

• Videoconferencing and communication platforms;

• Technology, software, and systems providers;

• Accounting, financial, legal, and administrative service providers;

• Financial institutions and payment service providers;

• Partners involved in the delivery of projects;

• Public authorities, regulatory bodies, or government entities, when required or permitted by law.

Any sharing will be limited to the information necessary for the relevant purpose.

Smart Metrics Analytics does not sell personal data.

7. International Data Transfers

Some technology, cloud, communication, analytics, or data storage providers used by Smart Metrics Analytics may be located outside Brazil or may use servers located in other countries.

As a result, personal data may be transferred internationally.

Smart Metrics Analytics will adopt appropriate measures to ensure that such transfers are performed in accordance with applicable legislation, including contractual provisions, security safeguards, and other mechanisms recognized under Brazilian data protection law.

8. Data Retention and Deletion

Personal data will be retained only for as long as necessary to fulfill the purposes described in this Privacy Policy.

Retention periods may take into consideration:

• The duration of the business or contractual relationship;

• The time required to provide the contracted services;

• Legal and regulatory obligations;

• Tax, accounting, and statutory limitation periods;

• Fraud and security incident prevention;

• The exercise of Smart Metrics Analytics’ legal rights;

• Client instructions when we act as a data processor.

When personal data is no longer required, it may be deleted, anonymized, or securely retained where its preservation is permitted or required by applicable law.

9. Data Subject Rights

Subject to applicable legislation, Data Subjects may request:

• Confirmation that their personal data is being processed;

• Access to their personal data;

• Correction of incomplete, inaccurate, or outdated data;

• Anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;

• Data portability, where applicable;

• Deletion of data processed based on consent, subject to legal exceptions;

• Information regarding the entities with which personal data has been shared;

• Information regarding the possibility of refusing consent and the consequences of such refusal;

• Withdrawal of consent;

• Objection to processing performed in violation of applicable legislation;

• Review of decisions made exclusively through automated processing that affect their interests, where applicable;

• Submission of a complaint or petition to the Brazilian Data Protection Agency, ANPD.

Certain rights may be restricted where the retention of personal data is necessary to comply with legal, regulatory, or contractual obligations, protect trade secrets, or exercise legal rights.

To exercise your rights, please contact us at contato@smartmetricsanalytics.com.br. We may request additional information to confirm the identity of the requesting individual and protect personal data against unauthorized access.

10. Information Security

Smart Metrics Analytics adopts reasonable technical, administrative, and organizational measures to protect personal data against unauthorized access, loss, destruction, alteration, disclosure, or any other form of inappropriate or unlawful processing.

Such measures may include access controls, permission management, authentication, monitoring, backups, encryption, and internal security policies.

Although we adopt security practices appropriate to our activities, no digital environment is entirely free from risk.

If a security incident that may create a relevant risk or harm to Data Subjects is identified, appropriate measures will be adopted in accordance with applicable legislation.

11. Cookies

The Smart Metrics Analytics website may use cookies and similar technologies to ensure its proper operation, understand how users navigate its pages, and improve the user experience.

The cookies used may include:

• Necessary cookies, which are essential for the operation and security of the website;

• Functionality cookies, which store user preferences;

• Analytics or performance cookies, which measure visits, interactions, and page performance;

• Third-party cookies used by tools integrated into the website.

Where required by applicable legislation, non-essential cookies will only be used after the user has provided consent.

Users may manage or disable cookies through the preference banner available on the website or through their browser settings.

Disabling certain cookies may affect the operation of some website features.

12. Third-Party Websites and Services

Our website may contain links to or integrations with third-party websites, platforms, and services.

Smart Metrics Analytics does not control and is not responsible for the privacy practices of such third parties. We recommend reviewing their respective privacy policies before providing personal data or using their services.

13. Changes to this Privacy Policy

Smart Metrics Analytics may amend this Privacy Policy whenever necessary to reflect changes to its activities, services, technologies, or legal obligations.

The updated version will be published on this page together with the date of the latest revision.

14. Contact

For questions, requests, or further information regarding this Privacy Policy or the processing of personal data, please contact us:

Email: contato@smartmetricsanalytics.com.br