Privacy and Personal Data Protection Policy
Rosi Martin Platform
Version: 04.05.2026
Last updated: 04.05.2026
The Rosi Martin Platform, operated by Martin Apoio Administrativo Ltda, registered with the CNPJ under No. 53.844.535/0001-05, headquartered in the city of Assis/SP, Brazil, is committed to protecting the privacy, intimacy, and personal data of its users, clients, consultation clients, specialists, consultants, partners, and visitors.
This Privacy and Personal Data Protection Policy explains how we collect, use, store, share, and protect personal data processed within the scope of the Rosi Martin Platform, including, but not limited to:
I. use of the website rosimartin.com.br;
II. use of applications, pages, member areas, communities, digital channels, or partner platforms;
III. hiring of consultations, services, mentoring sessions, courses, content, digital products, or services offered by the Platform;
IV. user participation in events, groups, live sessions, communities, forms, surveys, promotional campaigns, or Platform communications;
V. interaction with specialists, consultants, therapists, mentors, attendants, collaborators, or partners linked to the Platform.
By accessing, using, registering, or hiring any service from the Rosi Martin Platform, the user declares that they are aware of and agree with this Policy, the Terms of Use, and other applicable documents.
In the event of any conflict between this Privacy Policy and other internal regulations of the Platform, the provisions of this Policy shall prevail with regard to the processing of personal data.
1. Important Definitions
For the purposes of this Policy:
Personal data means information related to an identified or identifiable natural person, such as name, CPF, e-mail, telephone number, address, image, voice, payment data, access data, and digital identifiers.
Sensitive personal data means data that may reveal racial or ethnic origin, religious belief, political opinion, trade union membership, health data, sex life, genetic or biometric data, among others provided for under applicable law.
User, client, or consultation client means the person who accesses, uses, purchases, schedules, participates in, or interacts with the Platform.
Specialist, consultant, mentor, therapist, or service provider means the person who offers consultations, content, guidance, or services through the Platform.
Controller means the company responsible for decisions related to the processing of personal data.
Processors means companies or persons that process personal data on behalf of the Platform, such as payment gateways, e-mail marketing tools, hosting providers, support tools, CRM systems, video platforms, automation tools, and analytics tools.
Person responsible for the privacy channel means the person or channel appointed by the Platform to receive requests, questions, and communications related to the processing of personal data.
2. Registration on the Platform
To use certain services of the Rosi Martin Platform, the user may need to create an account or provide data through a form, WhatsApp, e-mail, telephone, payment page, checkout, member area, or another official channel.
As a rule, only one registration per user will be permitted, unless expressly authorized by the Platform.
The user undertakes to provide truthful, complete, up-to-date information that belongs to them. The user is responsible for the accuracy of the data provided.
The Rosi Martin Platform may, when necessary, request additional confirmation of identity, contact, payment, or ownership, with the aim of preventing fraud, protecting users, avoiding unauthorized access, complying with legal obligations, and ensuring the security of transactions.
The Platform may refuse, suspend, or cancel registrations, purchases, consultations, or access when there is suspicion of fraud, misuse, violation of the Terms of Use, inconsistent registration data, an attempt to bypass rules, or a risk to the security of users, specialists, or the Platform itself.
3. What Personal Data We May Collect
The Rosi Martin Platform may collect personal data provided directly by the user or generated during their use of the services.
We may collect, as applicable:
a) full name;
b) CPF, RG, or another identification document;
c) date of birth;
d) residential or business address, when necessary for billing, tax document issuance, or service provision;
e) telephone number, WhatsApp, and e-mail;
f) registration data, login, access credentials, and password protected by encryption, hash, or equivalent technology;
g) payment, billing, and purchase history data;
h) scheduling, consultation, service, or mentoring data;
i) messages, requests, reports, form responses, and communications sent to the Platform;
j) preferences, interests, survey responses, and browsing history;
k) technical data, such as IP address, device identifiers, browser, operating system, approximate location, date, and time of access;
l) cookies, pixels, tags, advertising identifiers, and similar technologies;
m) image, voice, or recording, when there are classes, meetings, events, mentoring sessions, or consultations recorded with prior notice;
n) support data, complaints, requests, and interactions with the team;
o) information necessary for issuing invoices, complying with legal, accounting, tax, or regulatory obligations.
Depending on the nature of the service hired, the user may voluntarily share intimate, emotional, spiritual, family, affective, professional, behavioral, or personal life-related information. Such information will be treated confidentially and only for the purposes stated in this Policy.
The Platform does not require the user to share sensitive personal data to complete basic registration. When the user chooses to voluntarily share intimate, spiritual, religious, emotional, or personal life-related information during consultations, such data will be treated confidentially and only for the purpose of the hired service.
When such information is considered sensitive personal data, the Platform will adopt additional care measures and will only process it when there is an appropriate legal basis, such as specific consent, compliance with a legal obligation, protection of life, health protection, regular exercise of rights, or another legal basis provided for under applicable law.
4. Consultation, Service, and Communication Data
Information exchanged in consultations, services, mentoring sessions, messages, chats, forms, or communications with specialists may be stored by the Platform for the following purposes:
a) to enable the provision of the hired service;
b) to maintain service history for the user;
c) to ensure service security, quality, and traceability;
d) to resolve questions, complaints, disputes, refunds, or conflicts;
e) to comply with legal or regulatory obligations;
f) to protect the rights of the Platform, the user, specialists, or third parties;
g) to improve the experience and quality of services, whenever possible in anonymized or aggregated form.
Access to this information will be restricted to authorized persons, observing criteria of necessity, confidentiality, and purpose.
Specialists, consultants, and service providers who operate through the Platform must respect confidentiality, secrecy, and the rules of this Policy, and may not use user data for their own purposes, unauthorized external contact, improper client acquisition, disclosure, sale, exposure, or any use incompatible with the hired service.
5. How We Use Personal Data
The Rosi Martin Platform may use personal data for the following purposes:
a) to create, validate, and manage user accounts;
b) to enable login, access to the member area, and use of the Platform;
c) to process payments, charges, refunds, credits, subscriptions, or purchases;
d) to schedule, confirm, carry out, and monitor consultations, services, mentoring sessions, courses, or events;
e) to send transactional communications, such as purchase confirmations, reminders, access links, invoices, technical notices, or service changes;
f) to provide support, answer questions, complaints, and requests;
g) to personalize the user experience;
h) to recommend content, services, specialists, products, or events compatible with the user’s profile and interests;
i) to send promotional communications, newsletters, campaigns, offers, invitations, or news, when authorized or when there is an applicable legal basis;
j) to prevent fraud, unauthorized access, misuse, chargebacks, scams, or unlawful activities;
k) to comply with legal, tax, accounting, judicial, administrative, or regulatory obligations;
l) to exercise rights in judicial, administrative, arbitral, or extrajudicial proceedings;
m) to conduct audits, analyses, research, metrics, reports, and internal improvements;
n) to protect the security of users, specialists, collaborators, partners, and the Platform;
o) to comply with determinations from public, judicial, administrative, or regulatory authorities.
The Platform may use anonymized or aggregated data for statistical purposes, product improvement, performance analysis, development of new services, internal studies, and presentation of results, without direct identification of users.
6. Legal Bases for Data Processing
The Rosi Martin Platform will process personal data based on the legal bases provided under applicable law, according to the purpose of each processing activity, including:
a) consent of the data subject;
b) performance of a contract or preliminary procedures related to a contract;
c) compliance with a legal or regulatory obligation;
d) regular exercise of rights;
e) protection of life or physical safety;
f) health protection, when applicable and under the terms of the law;
g) legitimate interest of the Platform or third parties, while respecting the fundamental rights and freedoms of the data subject;
h) credit protection and fraud prevention, when applicable.
When processing depends on consent, the user may revoke it at any time, subject to the legal effects and the need to retain certain data for compliance with legal obligations, exercise of rights, or legitimate purposes.
The user may exercise the rights provided under applicable law, including confirmation of processing, access, correction, anonymization, blocking, deletion, portability, information about sharing, withdrawal of consent, and objection, as applicable.
7. Payment Data
Payments made on the Rosi Martin Platform may be processed by intermediaries, gateways, banks, acquirers, sub-acquirers, checkout platforms, card operators, digital wallets, or other financial partners.
The Platform may collect or receive information related to the transaction, such as:
a) payer’s name;
b) CPF or CNPJ;
c) e-mail;
d) telephone number;
e) billing address, when necessary;
f) purchase amount;
g) product or service purchased;
h) payment status;
i) date and time of the transaction;
j) purchase identifier;
k) payment method used;
l) data necessary for tax document issuance, refund, chargeback, dispute, or fraud prevention.
As a rule, full credit card data, such as the complete card number, security code, and banking password, are processed directly by the contracted payment providers. When payment method storage is available for future purchases, such storage must occur through tokenization, encryption, or equivalent technology provided by the payment provider.
The Platform will not request banking passwords, full security codes outside a secure payment environment, authentication codes, or data incompatible with the purpose of the transaction.
8. Cookies and Similar Technologies
The Rosi Martin Platform may use cookies, pixels, tags, web beacons, device identifiers, scripts, analytics tools, and similar technologies.
These technologies may be used to:
a) enable the proper functioning of the website and member area;
b) remember user preferences;
c) maintain authenticated sessions;
d) measure audience, performance, and browsing behavior;
e) improve content, pages, products, and services;
f) personalize communications and offers;
g) carry out marketing, remarketing, and advertising campaigns;
h) prevent fraud, abuse, and unauthorized access.
Cookies may be classified as:
Necessary cookies: essential for the functioning of the Platform.
Performance and analytics cookies: help us understand how users use the website.
Functionality cookies: remember preferences and settings.
Marketing and advertising cookies: allow personalization of ads, campaigns, and performance measurement.
The user may manage cookies in their browser settings, in the consent banner, when available, or through tools offered by the Platform. Disabling necessary cookies may affect website functionality or prevent the use of certain services.
Non-necessary cookies, such as marketing, advertising, behavioral analytics, or personalization cookies, may depend on the user’s consent, in accordance with applicable law and the settings made available on the website.
The Platform will seek to observe good transparency and consent practices in the use of cookies and similar technologies, especially when involving advertising, tracking, or personalization.
9. Communications, E-mails, and Promotional Messages
The Rosi Martin Platform may send communications by e-mail, WhatsApp, SMS, telephone, push notifications, social media, messaging applications, or other channels provided by the user.
Communications may include:
a) registration, purchase, payment, or scheduling confirmations;
b) reminders for consultations, classes, events, or mentoring sessions;
c) notices about account, security, support, or changes to terms;
d) delivery of materials, content, bonuses, certificates, or access;
e) offers, promotions, campaigns, launches, news, and recommendations;
f) satisfaction surveys and experience improvement initiatives.
The user may request cancellation of promotional communications at any time through the unsubscribe link, by replying to the message, contacting support, or through another mechanism made available.
Even after unsubscribing from promotional communications, the Platform may continue to send essential, transactional, legal, contractual, or security-related communications.
10. Sharing Data with Third Parties
The Rosi Martin Platform will not sell users’ personal data.
Data may be shared with third parties only when necessary for the purposes described in this Policy, such as:
a) hosting, cloud, database, and infrastructure providers;
b) gateways, banks, payment platforms, and anti-fraud providers;
c) e-mail marketing, CRM, automation, customer service, and support tools;
d) member area, streaming, video conference, community, or course platforms;
e) accountants, lawyers, auditors, consultants, and administrative service providers;
f) specialists, consultants, therapists, mentors, or professionals responsible for the hired service;
g) analytics, metrics, advertising, remarketing, and performance companies;
h) public, judicial, administrative, tax, or regulatory authorities, when required by law or competent order;
i) third parties involved in corporate reorganization, merger, acquisition, asset sale, portfolio assignment, investment, or similar operation.
Whenever possible, sharing will be limited to the minimum necessary, with partners who assume confidentiality, security, and proper data processing obligations.
11. International Data Transfer
Some suppliers of the Rosi Martin Platform may store or process data on servers located outside Brazil, especially cloud, e-mail, CRM, automation, payment, analytics, video conference, and advertising services.
When there is international data transfer, the Platform will adopt measures compatible with applicable law, seeking to use suppliers that offer adequate standards of security, privacy, contractual clauses, protection mechanisms, and applicable compliance.
12. Personal Data Security
The Rosi Martin Platform adopts technical, administrative, and organizational measures to protect personal data against unauthorized access, loss, destruction, alteration, improper disclosure, misuse, or any form of inadequate processing.
These measures may include, as applicable:
a) access control;
b) use of passwords and authentication;
c) encryption or equivalent protection;
d) storage in secure environments;
e) backups;
f) restriction of access based on necessity;
g) monitoring of suspicious activities;
h) internal confidentiality policies;
i) guidance for collaborators and service providers;
j) periodic review of suppliers and tools.
Even so, no system is absolutely secure. The user must also adopt protection measures, such as keeping login and password confidential, not sharing access, using strong passwords, avoiding insecure devices, and immediately reporting any suspicion of misuse of their account.
In the event of a security incident that may create relevant risk or damage to data subjects, the Platform will adopt the appropriate measures and may notify affected users and competent authorities, when required by applicable law.
13. Data Storage and Retention
Personal data will be stored for the time necessary to fulfill the purposes described in this Policy, provide the hired services, maintain the relationship with the user, comply with legal, tax, accounting, regulatory, contractual obligations, or exercise rights.
Data may be retained, for example, to:
a) prove hiring, payment, or service delivery;
b) maintain service history requested by the user;
c) comply with tax and accounting obligations;
d) prevent fraud and abuse;
e) resolve disputes, complaints, chargebacks, or proceedings;
f) comply with legal or regulatory determinations;
g) safeguard the rights of the Platform, users, specialists, or third parties.
When the data is no longer necessary, it may be deleted, anonymized, or blocked, according to technical, legal, and operational criteria.
Deletion of the user’s account does not necessarily imply immediate deletion of all data, as some records may be retained for the period necessary to comply with legal obligations or the regular exercise of rights.
14. User Rights
Under applicable law, the user may request:
a) confirmation of the existence of processing of their personal data;
b) access to the personal data processed;
c) correction of incomplete, inaccurate, or outdated data;
d) anonymization, blocking, or deletion of unnecessary, excessive data or data processed in non-compliance with the law;
e) data portability, when applicable;
f) information about data sharing with third parties;
g) information about the possibility of not providing consent and the consequences of refusal;
h) withdrawal of consent;
i) deletion of data processed based on consent, subject to legal exceptions;
j) objection to processing carried out based on an applicable legal basis, when there is non-compliance with the law;
k) review of automated decisions, when applicable.
Requests must be sent to:
E-mail: [email protected]
WhatsApp/SAC: +351 934 797 020
Person responsible for the privacy channel: Rosi Martin
To protect the user’s own security, the Platform may request identity confirmation before responding to certain requests.
15. Access, Update, and Correction of Data
The user may update their data directly in their account, when this functionality is available, or request an update through the official customer service channels.
It is the user’s responsibility to keep their data correct, complete, and up to date, especially e-mail, telephone number, billing data, and information necessary to access consultations, courses, events, or hired services.
16. Data Deletion and Account Closure
The user may request the deletion of their account and personal data through the Platform’s official channels.
The Platform will assess the request and may retain certain data when retention is necessary for:
a) compliance with legal or regulatory obligations;
b) issuance or retention of tax documents;
c) regular exercise of rights;
d) fraud prevention;
e) resolution of disputes;
f) contract performance;
g) protection of the Platform, users, specialists, or third parties.
When possible, the data will be deleted or anonymized.
17. Children and Adolescents’ Data
The Rosi Martin Platform is not intended for persons under 18 years of age.
Registration, hiring, or use by children and adolescents may only occur in specific situations, with express authorization from parents or legal guardians, and when the Platform provides a service appropriate for this purpose.
When there is processing of children’s or adolescents’ data, the Platform will adopt the measures required by applicable law, including specific consent from at least one parent or legal guardian, when necessary.
If the Platform identifies registration or hiring carried out by a minor without proper authorization, it may suspend access, cancel the account, or request additional documentation.
18. Location Services
The Platform may collect approximate location data, such as city, state, country, IP address, time zone, or region of access, for security purposes, fraud prevention, content personalization, statistical analysis, legal compliance, or experience improvement.
When precise real-time location is collected, the user will be informed and may manage permissions directly on the device, browser, or application used.
19. Social Media, Communities, and Public Areas
The Rosi Martin Platform may maintain profiles, groups, communities, forums, comments, live sessions, or channels on social media and third-party applications.
When interacting in public or shared environments, the user must be aware that information voluntarily published may be viewed, copied, commented on, or used by other people.
The Platform is not responsible for personal data that the user chooses to publish in public areas, comments, open groups, social media, or external communities.
Users are advised not to publicly share sensitive data, financial information, documents, passwords, intimate data, or any information they wish to keep private.
20. Obligations of Specialists, Consultants, and Service Providers
Every specialist, consultant, mentor, therapist, attendant, collaborator, or service provider who works through the Rosi Martin Platform must:
a) respect this Privacy Policy;
b) process user data only for the purpose of the hired service;
c) maintain secrecy and confidentiality regarding information received;
d) not sell, share, expose, disclose, or use user data for their own purposes;
e) not transfer consultations, contacts, or data outside the Platform without authorization;
f) not approach users for purposes incompatible with the hiring;
g) adopt reasonable security measures on their own devices and channels;
h) immediately report any incident, unauthorized access, loss, or suspected data breach;
i) comply with applicable Brazilian law, including personal data protection legislation.
The specialist or service provider who fails to comply with these obligations may be suspended or removed from the Platform, without prejudice to civil, administrative, or judicial liability.
21. Changes to this Policy
The Rosi Martin Platform may amend this Privacy Policy at any time, especially to reflect legal, regulatory, technological, operational, commercial, or security changes.
The updated version will be published on the website, application, member area, or another official channel.
When changes are relevant, the Platform may notify users by e-mail, message, internal notice, banner, or another appropriate means.
Continued use of the Platform after publication of the new version will be considered acknowledgment of the updated Policy.
22. Privacy Contact Channel
In case of questions, requests, complaints, or exercise of rights related to personal data, the user may contact the channels below:
Controller: Martin Apoio Administrativo Ltda
CNPJ: 53.844.535/0001-05
Privacy e-mail: [email protected]
SAC/WhatsApp: +351 934 797 020
Headquarters: Assis/SP, Brazil
Person responsible for the privacy channel: Rosi Martin
23. Final Provisions
This Policy shall be interpreted in accordance with Brazilian law, especially the Brazilian General Personal Data Protection Law.
By using the Rosi Martin Platform, the user declares that they have read, understood, and accepted this Privacy and Personal Data Protection Policy.