Privacy Policy

1. Introduction and Scope of Application

This Privacy Policy (the "Policy") outlines how VANELTON MEDIA SOFTWARE LTDA (referred to herein as "Vanelton Media," "we," "us," or "our"), a limited liability company incorporated under the laws of Brazil, collects, uses, stores, shares, and otherwise processes the personal data of its users and customers ("you" or "Data Subject").

This Policy applies to all products and services offered by Vanelton Media, including but not limited to Vanelton ID (global login service), Vanelton Console (developer dashboard), Vanelton AppHub (app/game store), Vanelton Connect, Vanelton AI (artificial intelligence services), Volcam Studios (subsidiary game company), Vanelton Media Tools, Orbit Workspace, Vanelton Labs (early access/experimental tools), Vanelton Open Labs (open-source tools), and any other current or future services linked to the URL: https://vaneltongamedev.com.

We are committed to the security and privacy of your data, strictly complying with the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados - LGPD, Law 13.709/2018) and other applicable data protection laws.

2. Identification of the Data Controller

The Data Controller responsible for the processing of your personal data under this Policy is:

• Official Company Name: VANELTON MEDIA SOFTWARE LTDA

• Legal Form: LTDA

• Country of Jurisdiction: Federative Republic of Brazil

• Physical Address: Avenida Bosque das Acácias, Maceió - AL, Brazil

• Purpose: Technology company providing services, apps, and games for all audiences (companies, developers, and general users).

3. Collection of Personal Data (What and How)

We collect personal data that is necessary to provide, manage, and significantly enhance our Services, including those required for our data monetization strategies.

3.1. Data Provided Directly by You (Vanelton ID and Account Details)

When you create or use your Vanelton ID (our universal account system), interact with our support, or purchase services, you provide us with:

• Vanelton ID / Account Details: Name, email, date of birth, language, phone number, and a password.

• Profile Information: Optional data you choose to add, such as a profile photo, nickname, interests, and preferences.

• Payment Details: If you make a purchase or subscribe to a service linked to your Vanelton ID, payment information (such as credit card numbers) is required. This processing is primarily handled by secure, certified payment partners, and in most cases, we do not directly store sensitive payment card details.

• Your Preferences: Settings and preferences related to content options and advertisement controls.

• Support Communications: Records of communication when you contact our support team (name, email, phone number, and the content of the message).

3.2. Data Collected Automatically (Behavioral and Technical Data)

Given our focus on data analytics and service optimization, certain information is collected automatically and continuously by our systems when you access and use our Services, often while logged in with your Vanelton ID:

• Device Information: Device model, operating system (e.g., iOS, Android, Windows), hardware identifiers, network details, battery status, screen resolution, and available storage space.

• Usage and Connection Data (Logs): Internet Protocol (IP) address, browser type and language, Internet Service Provider (ISP), referring/exit pages, dates and timestamps, and detailed interaction data. This includes:

  • Behavioral Patterns: Detailed records of your activity, such as scroll speed and patterns, typing rhythm (keystroke dynamics for security), time spent viewing specific content, in-app feature usage frequency, and mouse movements/touch interactions.

  • In-App/Network Activity: Information about the mobile applications installed on your device, network connection quality (Wi-Fi, cellular, signal strength), DNS lookups, and the history of pages viewed within our Services.

• Location Data: If you grant us permission via your device settings, we may collect precise location data. Even without explicit location permission, we use your IP address and Wi-Fi network information to infer your approximate geographic location.

• Sensor Data: Data collected directly from your device's sensors, including accelerometer (to detect movement), gyroscope, compass, and device orientation.

• Cookies and Tracking: Data collected through "cookies" (small files stored on your device) and similar technologies (pixels, beacons, device fingerprinting) used for authentication, remembering preferences, advanced trend analysis, site administration, and extensive cross-service tracking of your interactions with our content and advertisements.

3.3. Data Obtained from Third Parties

We may obtain information about you from external sources to enrich the data associated with your Vanelton ID:

• Partners and Data Providers: General demographic information, market interests, and other analytical data from business partners or data analytics companies.

• Public Sources: Information that is legitimately available in public sources.

• Social Media: If you link a social media account to your Vanelton ID, we may receive information from that platform according to their rules and your privacy settings on that platform.

• Third-Party Developers: If you use your Vanelton ID to log in to an approved third-party application, the developer may share certain usage or profile information back to us, in accordance with their policy and our developer agreements.

4. Finalities and Legal Bases of Processing (Why)

We process your personal data solely for specific and legitimate purposes based on the legal bases established by the LGPD.

We use this information to Execute and Improve our Services: managing your Vanelton ID, ensuring seamless functionality across different services, fixing bugs, and adding new features. This processing is necessary for the Performance of Contract (LGPD Art. 7, V).

We require your data to Enable Universal Access (Single Sign-On - SSO): using your Vanelton ID details for login across various Vanelton Media services (e.g., Volcam Studios, Vanelton AI) without requiring separate accounts. This is also necessary for the Performance of Contract (LGPD Art. 7, V).

We process data for Payment Processing: handling purchases, managing subscriptions, and handling billing associated with your Vanelton ID. This is necessary for the Performance of Contract (LGPD Art. 7, V).

We use data for Personalization and Marketing: displaying customized content, features, or advertisements based on your profile and extensive Vanelton ID activity, and sending marketing communications. This is based on our Legitimate Interest (LGPD Art. 7, IX) or Consent (LGPD Art. 7, I) for direct marketing.

Crucially, we rely heavily on data for Usage Analysis and Development (Data Business): analyzing detailed user behavior and interaction to improve our Services, develop new technologies, and significantly enhance our AI models and open-source projects. This data is also used to generate aggregated and anonymized insights, which form a key part of our data business strategy. This processing is based on our Legitimate Interest (LGPD Art. 7, IX) and, where applicable, Consent (LGPD Art. 7, I).

We communicate with you for Communication and Support: sending important Service updates, customer support assistance, and sharing news. This is based on the Performance of Contract (LGPD Art. 7, V) and our Legitimate Interest (LGPD Art. 7, IX).

We use data for Support for Third-Party Logins: allowing you to use your Vanelton ID for Single Sign-On into approved third-party applications, which requires your Consent (LGPD Art. 7, I).

We process data for Security and Fraud Prevention: identifying and preventing fraud, security issues, or illegal activities related to Vanelton ID accounts or our Services. This is based on our Legitimate Interest (LGPD Art. 7, IX).

Finally, data is processed for Legal and Regulatory Compliance: fulfilling legal obligations, responding to government requests, and enforcing our terms and rights. This is based on Legal Obligation (LGPD Art. 7, II).

4.1. Special Provisions for Children's Privacy

We recognize and prioritize the extreme importance of protecting the privacy of children online.

• Minimum Age for Vanelton ID: The minimum age for creating a Vanelton ID is 13 years old. However, creation may have further age restrictions depending on your region and applicable laws (such as the Children's Online Privacy Protection Act - COPPA, and the LGPD).

• General Services: Most of our Services linked to the Vanelton ID are intended for a general audience and are not specifically directed at children under the age of 13 (or the relevant age of digital consent in your jurisdiction). We do not knowingly collect personal information from children in these general services without verifiable parental consent, when required.

• Services Directed at Children: Some of our Services, such as certain Volcam Studios games, may be designed or attractive to children. Access to these may require parental Vanelton ID identification or follow specific procedures for child accounts, if available.

• Compliance and Parental Consent: When a Service is directed at children under the age of digital consent, we strictly follow specific rules such as COPPA and the LGPD. For these services or features, we do not knowingly collect personal information (beyond what is strictly necessary for basic functionality) without first obtaining verifiable parental consent. If more information is required, we will clearly request consent and explain the data we are collecting and its purpose.

• Parental Rights: Parents and legal guardians can request to review, amend, or delete the personal information we hold about their children linked to our services.

• Contact for Parents: If you are a parent or guardian and believe your child has provided us with personal information (perhaps by creating an underage Vanelton ID or using a service without your authorization), please contact us immediately! We will investigate the case and take appropriate measures, including account deletion.

5. Sharing of Data with Third Parties (With Whom)

We do not sell your personal data in the traditional sense, but the data collected (including anonymized and aggregated behavioral data) is a core component of our business operations. We share your information only when necessary to operate our Services, enable features you choose, or comply with legal obligations.

Internal Vanelton Media Teams: Data associated with your Vanelton ID is shared between our divisions (e.g., Volcam Studios, Vanelton AI, Vanelton Labs) to provide integrated features (shared progress/settings) and operate effectively. We maintain Joint/Shared Control within the same corporate group for these internal transfers.

Service Providers: We work with external companies that assist our operations, such as cloud hosting providers, payment processors, data analytics platforms, customer support tools, and email services. They receive only the necessary data to perform services for us and are contractually bound to maintain confidentiality and security, acting as Processors on behalf of Vanelton Media.

Certified Third-Party Developers (via Vanelton ID Login): This sharing is Optional. You may choose to use your Vanelton ID to log in to external applications integrated via the Vanelton Media Console. We will request your explicit consent to share specific profile information (name, email, profile photo, user ID) with that developer. The Developer's Policy Governs: While we manually approve and certify developers, their independent use of your data after your authorization is governed by their own privacy policies and practices. We strongly recommend reviewing their policies before connecting your ID.

Legal Requirements: We share data when required by law (e.g., court order, subpoena) or when necessary to protect our rights, user safety, investigate fraud, or respond to government requests. This is mandated by Legal Obligation.

Business Transfers: In case of a major business change (merger, acquisition, bankruptcy), your information may be transferred as part of that transaction, based on Legitimate Interest/Legal Requirement.

Other Parties: Any other sharing will be done only with your specific permission, requiring Consent.

6. International Data Transfer

While our main datacenter is located in Brazil, your personal data may be transferred to and processed in datacenters located in the United States, Canada, and the Netherlands.

Specific Restriction on US Data Transfer: Due to our internal risk analysis and political considerations, we reserve the right to block the transmission, access, or storage of data for users originating from non-US jurisdictions to datacenters located within the United States.

Notwithstanding the above restriction, when transferring data internationally, including the global transfer of data belonging to users originating from the United States, VANELTON MEDIA SOFTWARE LTDA ensures that appropriate legal safeguards are in place, in compliance with LGPD (Art. 33), to guarantee a level of protection at least equivalent to that provided by Brazilian law. This typically involves using standard contractual clauses or verifying that the destination country or international organization provides an adequate level of protection.

7. Retention and Elimination of Data (How Long)

We retain your personal data (including your Vanelton ID data) only for the time necessary to fulfill the purposes described in this Policy, or as required by law.

• Active Accounts: Generally, your Vanelton ID information is maintained while your account is active.

• Deletion: If you request the deletion of your account, we will delete or anonymize your personal data, subject to legal exceptions that require us to retain certain information (e.g., for fiscal, fraud prevention, or legal compliance purposes). We commit to completing the permanent and irreversible removal of your personal data within a maximum period of fifteen (15) business days following your confirmed request.

8. Rights of the Data Subject and How to Exercise Them

In compliance with the LGPD and other applicable data protection regulations, you have the following rights regarding your personal data:

• Confirmation and Access: The right to confirm the existence of processing and to access the personal data we hold about you (associated with your Vanelton ID).

• Correction: The right to request the correction of incomplete, inaccurate, or outdated data in your Vanelton ID profile or associated records.

• Anonymization, Blocking, or Deletion: The right to request the anonymization, blocking, or deletion of unnecessary, excessive data, or data processed in non-compliance with the LGPD.

• Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format for transfer to another service provider.

• Objection: The right to object to the processing of your data based on an LGPD legal base other than Consent or Contract (e.g., Legitimate Interest), if there is a demonstrated disproportionate impact.

• Revocation of Consent: The right to withdraw your consent at any time, when processing is based on consent (this may affect your ability to use certain Services).

• Information on Sharing: The right to information about the public and private entities with which we share your data.

• Information on Consequences of Denying Consent: The right to be informed about the consequences of denying consent.

Procedure to Exercise Rights

To exercise any of these rights, please contact us using the dedicated user support channel:

• User Support Email for Rights Requests: usersupport@vaneltongamedev.com

We will respond to your requests in accordance with applicable law and within the legally established timeframes.

9. Use of Cookies and Tracking Technologies

We utilize cookies and similar tracking technologies to analyze trends, administer the Services, track users' movements around the Services, and gather demographic information about our user base as a whole.

• Cookie Policy: For detailed information about the cookies we use, the purposes of their use, and how you can control them, please consult our dedicated Cookie Policy at: https://support.vaneltongamedev.com/cookies

10. Security of Information

We value the security of your Vanelton ID and associated information. We employ reasonable technical and organizational security measures (such as encryption, access controls, and secure login procedures) designed to protect your data against unauthorized access, use, modification, or loss.

However, it is important to remember that no online system is 100% secure. While we strive to protect your personal data, we cannot guarantee its absolute security. You also play a crucial role in security by using a strong password for your Vanelton ID and maintaining its confidentiality.

11. Changes to This Privacy Policy

The digital environment, legal frameworks, and our Services (including Vanelton ID features) are constantly evolving. As such, we may need to update this Privacy Policy periodically.

When we make changes, we will publish the new version here, ensuring that the "Effective Date" at the top of the document is updated. If the changes are significant (especially those that materially affect how we handle your Vanelton ID data), we will also endeavor to notify you directly via your Vanelton ID email or through a prominent notice on our Services.

We recommend that you check this page periodically to stay informed about how we protect your information.

12. Applicable Legislation and Forum

This Policy is governed by and interpreted in accordance with the laws of the Federative Republic of Brazil, specifically the LGPD. Any disputes arising under this Policy shall be submitted to the courts of Maceió, State of Alagoas, Brazil, with the exclusion of any other, however privileged it may be.

13. Contact Information of the Data Protection Officer (DPO)

For specific questions or concerns related to this Policy, the protection of your personal data, or the processing activities, you may contact our Data Protection Officer (DPO):

• DPO Name/Title: Sócio Administrador, Vanelton Media: Vanelton Junior

• Official Privacy Contact Email: legal@vaneltongamedev.com