Global Policy Privacy and Data Security

Voxus is a technology company that connects brands and consumers with intelligence, efficiency, and responsibility. Our programmatic media operations strictly comply with global privacy standards, ensuring full compliance with the General Data Protection Law (LGPD – Law No. 13.709/2018, Brazil), the General Data Protection Regulation (GDPR, European Union), and the California Consumer Privacy Act (CCPA/CPRA, USA).

1. Data Collection and Processing

Voxus acts as a Data Controller or Processor (depending on the campaign context) and uses technology based on pseudonymized online identifiers. We do not collect direct real-world identifiers (such as names, emails, physical addresses, or phone numbers).

What we collect (Categories of Personal Information - CCPA/GDPR):

In the past 12 months, we have collected the following categories of information:

• Online Identifiers: IP addresses, cookie identifiers, mobile advertising IDs (MAIDs), and User Agents.
• Internet or Network Activity: Pseudonymized browsing data, interactions with ads, and advertiser partner pages.

Data Sources:

We collect this information automatically through our technologies (Voxus Tag) integrated into the websites of our partners and advertisers.

Purpose and Legal Basis for Data Use (GDPR/LGPD):

• Measurement and Optimization: Optimization of media delivery algorithms and audience measurement.
• Behavioral Advertising and Segmentation: Digital behavior prediction and audience segmentation.

Legal Basis: The processing occurs based on Consent (collected through the Consent Management Platforms of partner sites) or, when applicable, on our legitimate interest or that of our clients, always respecting the fundamental rights of users.

Data Retention, Disposal, and International Transfer

Data is securely stored for a limited time (maximum of 15 days), according to our strict retention policy.

International Transfer: For users in the European Union, data may be transferred and processed in the US or Brazil. We ensure that such transfers occur under appropriate safeguards, such as the Standard Contractual Clauses (SCCs) approved by the European Commission.

2. Information Security

Data security is a non-negotiable commitment for Voxus. We use enterprise infrastructure to prevent leaks and unauthorized access.

• Risk Reduction: IPs and identifiers are actively obfuscated and processed to make direct re-identification impossible without strict security keys.
• Encryption: We use HTTPS with TLS 1.2 and 1.3 across all traffic, along with integrity validation.
• Secure Storage: Cloud servers (AWS) with international certifications (SOC 2). Encrypted backups and automated deletion.
• Governance and Access Control: Multi-Factor Authentication (2FA), principle of least privilege, and 100% auditable logs.
• Audits: Periodic penetration tests conducted by globally renowned specialized companies (e.g., Bishop Fox).

3. Global User Rights (LGPD, GDPR, CCPA)

Voxus offers clear mechanisms for privacy management, regardless of your location:

Your Rights:

• Access and Portability: Know what categories of data we hold about you.
• Rectification and Erasure: Request the correction or deletion of your online identifiers from our systems (Right to be Forgotten).
• Restriction and Objection (GDPR): Object to data processing for marketing purposes and request restriction of processing.
• Non-Discrimination (CCPA): Exercising your privacy rights will not result in any penalty or discriminatory treatment.

Specific Rights for California Residents (CCPA/CPRA):

• Do Not Sell or Share My Personal Information: Voxus's cross-context behavioral advertising may be considered a "sale" or "sharing" under California law. You have the right to absolutely Opt-Out of this practice at any time.

How to exercise your rights:

• Advertising Opt-Out: You can opt out of being tracked by accessing our Official Opt-Out Page / Link to Do Not Sell or Share.
• Contact and Questions: To exercise your deletion, access rights, or ask questions, contact our Data Protection Officer (DPO) through the exclusive channel: dadospessoais@voxus.tv.
• Supervisory Authorities: If you reside in the European Union or Brazil and feel that your rights have not been met, you have the right to file a complaint with the Data Protection Authority (DPA / ANPD) of your country.

4. Ethics and Operational Compliance

Voxus operates with responsibility and full alignment with the standards of the global digital advertising industry (IAB, NAI).

• ❌ We do not collect or use Sensitive Personal Information (such as race, religion, health data, or sexual orientation) for targeting.
• ❌ We do not process data of individuals known to be under 16 years of age.
• ✅ We maintain formal security documentation (Due Diligence) and only work with certified partners in compliance with applicable laws.