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Privacy policy

Last updated: August 5, 2026 · aligned with Brazil’s LGPD and international transparency expectations.

Controller

INSTITUTO DE LIDERANÇA E EVOLUÇÃO CORPORATIVA LTDA (“ILEC”), CNPJ 23.119.739/0001-12, headquartered at Av. Francisco Gaetani, No. 1424, Major Prates, Montes Claros/MG, Brazil, ZIP 39.403-202 — contato@faggundes.com · +55 (38) 99201-9034.

1. Scope

This policy describes processing of personal data through the ILEC institutional website at faggundes.com/ilec, including informational pages, the Doug product page at faggundes.com/ilec/doug, and contact channels published there.

The Doug application (Android, iOS and web dashboard) has its own notice at faggundes.com/doug/privacidade. This policy covers only the product page on the Site.

Third-party platforms you may use alongside our Site (Meta, TikTok, Google/YouTube, etc.) have their own notices.

2. Categories of data

  • Identity & contact details you submit voluntarily;
  • Technical data such as IP, device/browser, pages viewed;
  • Cookies and similar technologies;
  • Communications you send us, including messages started from the WhatsApp and Telegram buttons on the Site;
  • Doug waiting list: name, email and — when provided — WhatsApp and Telegram, plus a record of your consent, the page language and the originating page. The form is protected by an anti-bot check (Cloudflare Turnstile).

Beyond cookies, the Site stores a few preferences in your browser’s localStorage: the measurement consent choice, the selected language, and doug.tour.v1, which only records that the guided-tour invitation was already shown. These never leave your device and can be cleared at any time from your browser settings.

3. Purposes & legal bases

We process data to respond to inquiries, schedule conversations, deliver contracted services where applicable, improve security and UX, comply with law, and pursue legitimate interests compatible with LGPD.

4. Sharing & processors

We do not sell personal data. We may use hosting, email, CRM and analytics vendors under confidentiality commitments.

4.1. PostHog measurement

When optional measurement is enabled, we may use PostHog as an analytics provider to understand pages viewed, approximate time spent browsing, clicks on links and buttons, and aggregated heatmaps. It loads only after your authorization through the banner; session recording/replay is not used at this stage.

The technical design limits collection to allowed operational events and avoids sending form fields, name, email, phone number, typed text, URL query strings, or fragments. We do not use this integration to identify you or create person profiles. You can refuse or withdraw authorization through the “Privacy” button; withdrawal stops new browser-side capture.

PostHog may process data outside Brazil according to the project region selected by the controller. Event retention is set in the provider project and will be limited to the period needed for measurement and improvement purposes, subject to this policy’s review and applicable international-transfer safeguards.

4.2. Doug waiting list (Supabase and Cloudflare)

Data submitted through the “join the list” form on the Doug page is received by a server function operated by Supabase, Inc. as a processor and stored in the project database. The legal basis is consent, given by ticking the box and submitting the form, for the purpose of inviting you to the pilot group and announcing product availability.

The browser carries no database credential: the submission goes through an intermediate function that validates the fields before writing, and the page exposes no read key and offers no way to query the list. Before submission, Cloudflare, Inc. runs an anti-bot check (Turnstile), processing technical browsing data only — never form content.

Data may be processed outside Brazil under the safeguards in section 5. To be removed from the list at any time, write to contato@faggundes.com.

5. International transfers

Where applicable, we adopt LGPD-compatible safeguards.

6. Security & retention

Reasonable measures; retention limited to purposes and legal duties.

7. Your rights (LGPD)

You may exercise LGPD rights by emailing contato@faggundes.com.

8. Third-party login

Social logins may involve additional processing under the provider’s policy.

Privacy contact: contato@faggundes.com · +55 (38) 99201-9034 · Brazil.