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Privacy

Privacy Policy

This Policy describes how we handle the personal data of anyone who accesses The Cost of Selling, an editorial publication by CWS Platform.

We take privacy seriously. We collect only what is necessary, use it solely for the purposes described here, and never sell personal data to third parties.

1. Who is the data controller

The controller of the personal data processed in this publication is:
CWS Digital Plataforma e Serviços S.A.
CNPJ 16.756.261/0001-76
Av. Osvaldo Reis, 3385, 11th floor, Suite 1111 — Praia Brava, ZIP 88306-773, Itajaí/SC, Brazil

For any question about data processing, or to exercise your rights, contact our data protection officer:

Contact: privacidade@cws-platform.com

2. What data we collect

We collect only two types of data:

a) Data you actively provide. When you subscribe to our newsletter, we collect your email address. We do not ask for your name, phone number, job title, or any other data to subscribe.

b) Navigation data collected automatically. When you access the site, we record technical data such as IP address, browser type, pages visited, and date/time of access, generated by our hosting and content delivery infrastructure for security, fraud prevention, and proper functioning of the site.

We do not collect sensitive data (racial origin, political opinion, health, etc.) and we do not direct this publication at minors.

3. How we use the data

  • Send the newsletter you subscribed to — email
  • Confirm subscription (double opt-in) and process cancellations — email
  • Keep the site online, secure, and stable — navigation data

We do not use your email for third-party advertising, we do not profile you for sale, and we do not share your subscription list with other companies.

4. Legal basis for processing

We process your data under the following LGPD legal bases:

  • Consent (art. 7, I) — for sending the newsletter. You consent when you subscribe and may withdraw consent at any time, free of charge, through the unsubscribe link present in every email.
  • Legitimate interest (art. 7, IX) — for the navigation data necessary for the security, stability, and improvement of the site, always respecting your rights and reasonable expectations.

5. Who we share data with (processors)

We do not sell or rent personal data. To operate the publication, we rely on service providers (processors) that handle data on our behalf, under contract and instructions:

  • Resend — sending newsletter emails.
  • Lovable Cloud — application hosting and database.
  • Cloudflare — content delivery network (CDN), security, and protection against attacks.

These processors handle only the data strictly necessary for their functions.

6. International data transfer

Some of the processors listed in section 5 process data on servers located outside Brazil (including the United States). By using this publication and subscribing to the newsletter, part of your data may be transferred and stored internationally.

These transfers are carried out in accordance with the LGPD, with providers that adopt adequate security and data protection safeguards.

7. Cookies

We use only cookies strictly necessary for the functioning and security of the site, including those set by our content delivery network (Cloudflare). At this time, we do not use advertising, remarketing, or third-party audience measurement cookies.

Should we adopt lead capture, content promotion, or audience measurement tools that use non-essential cookies, this Policy will be updated and, where required by law, we will request your consent beforehand.

8. How long we keep data

  • Newsletter email: kept while you remain subscribed. After cancellation (unsubscribe), the record is deleted within 90 days.
  • Navigation data: kept for the period necessary for security and stability purposes, according to our processors' terms.

9. Your rights

Under article 18 of the LGPD, you may, at any time:

  • confirm whether your data is being processed;
  • access your data;
  • correct incomplete, inaccurate, or outdated data;
  • request the anonymization, blocking, or deletion of unnecessary data or data processed in non-compliance;
  • request data portability;
  • withdraw consent and request the deletion of data processed on that basis;
  • obtain information about whom we share your data with.

To exercise any of these rights, use the contact in section 1. To cancel the newsletter, simply click the unsubscribe link at the bottom of any email.

10. Security

We adopt technical and administrative measures to protect your data against unauthorized access, loss, alteration, or improper disclosure. No system is 100% immune, but we work to maintain a level of protection appropriate to the sensitivity of the data processed.

11. Changes to this policy

We may update this Policy periodically. Relevant changes will be flagged on the site and, where appropriate, communicated by email. The version in force is always the one published on this page.

12. Governing law

This Policy is governed by Brazilian law, in particular the LGPD (Law No. 13.709/2018).