LGPD · Law 13.709/2018
Privacy Policy
This policy explains which personal data Publicidade UP processes on the website publicidadeup.com.br and on the UP Marketing platform (marketing.publicidadeup.com.br), what it is used for, who it is shared with and how you can exercise your rights. This English version is provided for convenience; if there is any conflict, the Portuguese version prevails.
1. Who we are
The data controller is PUBLICIDADE UP LTDA, CNPJ 13.123.482/0001-19, headquartered at Av. Paulista, 1636, Suite 1105, Bela Vista, São Paulo/SP, Brazil, ZIP 01310-200 ("Publicidade UP", "we").
We provide ad management services on Google Ads and Meta Ads (Facebook and Instagram). The UP Marketing platform is used by our team and our clients to follow campaign results.
2. Data we process
Website visitors
- Contact: name, phone, email and the message you send us via WhatsApp, phone or email.
- Browsing: IP address, browser, pages visited, traffic source and events (such as a click on the WhatsApp button), collected by cookies and pixels (see item 8).
Clients and users of the UP Marketing platform
- Registration: company name, CNPJ, name, email and phone of the person in charge and of the users the client company adds.
- Access: password (stored only as an irreversible hash), login records, IP address and date and time of actions.
- Support: messages and files sent in "Chat with the manager", conversations with the artificial intelligence assistant, campaign ratings, budget top-up and plan change requests, and the record of acceptance of the terms.
- Advertising data: metrics from the client's ad accounts (spend, impressions, clicks, conversions, leads, campaigns, budgets and balance), read from Google Ads and Meta with the agency's authorization.
We do not intentionally collect sensitive personal data or data of children and teenagers. We ask users not to send this kind of data through the platform.
3. How we use the data and legal basis
| Purpose | Legal basis (LGPD, art. 7) |
|---|---|
| Provide the service hired: manage campaigns, show results on the portal, generate reports and support through the chat | Performance of contract |
| Create and protect access to the platform, prevent fraud and keep security records | Legitimate interest and compliance with legal obligation (Brazilian Internet Civil Framework) |
| Respond to contacts and send proposals to those who asked | Pre-contractual procedures |
| Measure website performance and advertise Publicidade UP | Legitimate interest; consent, where required for cookies |
| Issue invoices and meet tax and accounting obligations | Compliance with legal obligation |
We do not sell personal data and we do not use our clients' data to advertise to third parties.
4. Data received from Google (Google Ads API)
The UP Marketing platform connects to the Google Ads API with an OAuth authorization given by Publicidade UP itself, from the agency's manager account (MCC). Access is read-only (scope https://www.googleapis.com/auth/adwords) and reaches only client ad accounts linked to our MCC.
- What we read: account name and currency, campaigns and their status, budgets, daily metrics (impressions, clicks, cost, conversions and conversion value) and the account budget, when there is one.
- What we use it for: only to show the agency and the client itself the results of the client's account, calculate indicators (such as cost per lead), generate reports and balance alerts, and answer the client's questions about its own figures.
- What we do not do: we do not change campaigns through the API, we do not sell this data, we do not use it for advertising and we do not share it with third parties, except the providers in item 7 needed to operate the service.
- Retention: metrics are kept while the client's agreement lasts and for the period in item 9. The authorization is stored encrypted on our server.
The UP Marketing platform's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
The authorization can be revoked at any time at myaccount.google.com/permissions or with the "Disconnect" button in the platform settings.
5. Data received from Meta (Facebook and Instagram)
The platform reads, in read-only mode (ads_read permission), the metrics and campaigns of the client ad accounts assigned to Publicidade UP's Business Manager, with the same purposes and limits as item 4, following Meta's Platform Terms.
6. Artificial intelligence
The platform uses an artificial intelligence provider to:
- write drafts of ad copy, which the team reviews before use;
- suggest replies in the chat, always reviewed by the team before sending;
- answer the client's questions about its own results.
For this, we send the provider only what is needed for each answer: that client's campaign figures and the text of the question or conversation. The provider is hired under commercial API terms that do not allow it to use this content to train its models.
Conversations with the assistant are recorded, may be read by the Publicidade UP team to improve support and are deleted after 12 months. After that, only a summary is kept. Artificial intelligence can make mistakes: the official figures are those on the results pages.
7. Who we share data with
We share data only with providers needed to operate the service, acting as processors under our instructions:
- Hosting and email: Publicidade UP's own server in Brazil, where the website, the platform and the database are.
- Google and Meta: platforms where the ads run and where the data in items 4 and 5 comes from.
- Artificial intelligence provider: Anthropic (Claude), for the features in item 6.
- WhatsApp (Meta): when you talk to us there or when we send platform access through this channel.
- Authorities: when there is a legal obligation or court order.
Some of these providers are outside Brazil, mainly in the United States. These international transfers follow art. 33 of the LGPD, with contractual clauses and data protection safeguards offered by these providers.
8. Cookies and pixels on the website
- Google Analytics and Google Ads (gtag): measure visits and conversions, such as a click on WhatsApp.
- Meta Pixel and Conversions API: measure visits and contacts and help show Publicidade UP ads. Some of these events are sent by our server, with IP and browser, so that Meta counts each event only once.
You can block or delete cookies in your browser settings and adjust ad personalization at adssettings.google.com and in the Facebook and Instagram ad settings. The UP Marketing platform uses only cookies needed to keep you logged in and remember the light or dark theme.
9. How long we keep data
- Registration and results data: while the agreement lasts and then for the period needed for legal and tax obligations and for defense in proceedings (usually up to 5 years).
- Access records: at least 6 months, as required by the Brazilian Internet Civil Framework.
- Messages with the AI assistant: 12 months. After that, only a summary is kept.
- Files sent in the chat: 12 months, organized by month. Text messages are kept while the agreement lasts.
- Contacts who did not become clients: up to 2 years, or until you ask for deletion.
10. Security
We use encrypted connections (HTTPS), passwords with irreversible hashing and optional two-step verification. Integration tokens and keys are stored encrypted in the database, each user sees only their own company, administrative actions are recorded in an audit trail and uploaded files are kept outside the public area of the server. No system is completely immune to incidents: if one happens and may bring relevant risk, we will notify the affected data subjects and the ANPD, as required by the LGPD.
11. Your rights
Under the LGPD (art. 18), you can ask at any time for:
- confirmation that we process your data and access to it;
- correction of incomplete, inaccurate or outdated data;
- anonymization, blocking or deletion of unnecessary data or data processed in breach of the law;
- portability of the data to another provider;
- deletion of data processed based on your consent and withdrawal of that consent;
- information about who we share your data with.
We respond within 15 days. You can also file a complaint with the Brazilian National Data Protection Authority (ANPD) at gov.br/anpd.
12. Contact and data protection officer
To exercise your rights or ask questions about this policy, contact Publicidade UP's data protection officer:
- Email: contato@publicidadeup.com.br
- WhatsApp: +55 11 96829-5762 · Phone: +55 11 2110-5799
- Address: Av. Paulista, 1636, Suite 1105, Bela Vista, São Paulo/SP, Brazil, ZIP 01310-200
We may update this policy. The date of the latest version is always at the top of the page. In case of a significant change, we will notify clients on the platform or by email.
See also the Terms of Use.