1. Who We Are and Scope
This Policy describes how SupremeTracking (legal entity and tax ID to be provided) handles personal data, in accordance with Brazil's General Data Protection Law (Law No. 13.709/2018 — "LGPD"). It applies to our website, account creation, and plan licensing and billing.
2. The Two Data Layers (read first)
SupremeTracking's architecture clearly separates two types of data:
a) Data we handle (control plane): your account and commercial-relationship data — name, email, billing details, your Node's domain and support communications. For this data, we are the controller.
b) Data your Node handles (data plane): your end users' events and personal data are processed and stored exclusively on the server that you contract and operate. For that data, you are the controller and we have no access to it — this is what we call a zero-knowledge architecture. The Console reads that data directly from your Node, in your browser, without passing through us.
3. Data We Collect (control plane)
We collect only what is necessary to operate the Service: (a) registration data — name, email and credentials; (b) billing data — processed by payment providers, which return to us only subscription status and metadata; (c) license technical data — Node domain, version and operating status; (d) support communications; and (e) website usage data, described under Cookies.
4. How We Use Data
We use data to: create and authenticate your account; issue and validate your license; process payments; provide support; send operational and, where authorized, marketing communications; prevent fraud and abuse; and comply with legal obligations.
5. Legal Bases (LGPD)
We process data based on: performance of a contract (operating the Service you contracted); compliance with legal or regulatory obligations; legitimate interest (security, fraud prevention and Service improvement); and consent, where applicable (for example, marketing communications), which may be withdrawn at any time.
6. Sharing with Third Parties
We do not sell personal data. We share control-plane data only with strictly necessary processors: payment providers (for example, Stripe and Hotmart), our website and system hosting provider, and support and communication tools. These third parties process data according to our instructions and their respective policies. We may disclose data where required by law or by order of a competent authority.
7. Cookies and Tracking on the Website
Our own website uses SupremeTracking to measure visits and conversions, with first-party identifiers (for example, a user cookie and a session cookie). We do not place sensitive personal data in cookies. You can manage cookies in your browser settings; disabling them may affect functionality.
8. Security
We adopt reasonable technical and organizational measures to protect control-plane data against unauthorized access, loss or alteration. As for your end users' data, the security of the environment where your Node runs is your responsibility, as it is infrastructure contracted and operated by you.
9. Retention
We retain control-plane data for as long as necessary for the purposes of this Policy and to comply with legal obligations. Once the relationship ends and legal periods elapse, data is deleted or anonymized. Data residing on your Node remains under your control and subject to your own retention policy.
10. Your Rights as a Data Subject
Under the LGPD, you may request: confirmation of processing; access; correction; anonymization, blocking or deletion of unnecessary data; portability; information about sharing; and withdrawal of consent. To exercise these rights regarding data we handle, use the contacts below. For your end users' data, requests must be directed to you, as the controller.
11. International Transfer
Some processors may handle data outside Brazil. In such cases, we adopt safeguards compatible with the LGPD to ensure an adequate level of protection.
12. Data Protection Officer and Contact
For privacy and data protection matters, or to exercise your rights, contact us by email at contato@supremetracking.io or via our WhatsApp.
13. Changes to this Policy
We may update this Policy from time to time. The last-updated date is shown at the top of this page. Material changes will be communicated by reasonable means.