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Privacy Policy

Polozi Social · Version 1, in force since 13 August 2026

Courtesy translation. This English version is provided for convenience. The service is operated by a Brazilian company under Brazilian law, and the Portuguese version is the binding one. In case of divergence, the Portuguese text prevails.

1. Who the controller is

Polozi Social is operated by VIDA PLENA TREINAMENTOS LTDA, registered under Brazilian company number (CNPJ) 20.329.336/0001-00, with registered office at Av. Joaquim Alves Correa, 2800 — Parque Nova Suíça — Valinhos/SP — ZIP 13271-430, Brazil.

This is the same entity whose business verification with Meta appears under the "Polozi Coaching" portfolio.

Data Protection Officer, under article 41 of the Brazilian General Data Protection Law (LGPD): José Carlos Polozi, polozi@polozi.com.br.

2. What the service is

Polozi Social lets students of the Mestre das IAs course connect their own Instagram professional account and publish to it content that they themselves create and approve, from their own working environment (Claude Code or Codex).

We are not Instagram and we have no corporate relationship with Meta. We act as a Tech Provider under the Meta Platform Terms: we process data obtained from the platform exclusively on behalf of, and under the instruction of, the data subject themselves.

3. What data we process

3.1 Data you already provided as a student

Name, e-mail, phone/WhatsApp and Brazilian taxpayer number (CPF), collected when you registered for an event and purchased the course. On the connection screen we display them so that you can confirm or correct them — a correction updates your record.

3.2 Instagram connection data

DataPurpose
Instagram user ID and usernameidentify which account to publish to
Account type (Business or Creator)validate available features (stories require a Business account)
OAuth access tokenauthorize publishing on your behalf
Granted scopesrecord exactly what you authorized

The token is stored encrypted (AES-256-GCM), with the key kept outside the database. We never have access to your Instagram password.

3.3 Data for each publication

Media type, caption, post ID and permalink, date and time, the identity of whoever approved it, and a cryptographic digest (hash) of the approved content — the last one so we can prove we published exactly what you saw.

3.4 Consent data

Version and hash of the text you read, date and time of acceptance, IP address and browser identification.

3.5 Technical logs

Calls to the Instagram API, error codes and rate-limit indicators, retained for 30 days.

4. What we do NOT process

Your photos and videos are not stored. This is an architectural decision, not a vague promise: in order to publish, Instagram needs to download the file from a reachable address; the file is available only during that window — seconds to a few minutes — at an unguessable address, and is deleted immediately after publishing, with an automatic safety sweep within 24 hours. No table in our database stores the content of your files.

If you need a file later, it is on your own Instagram.

We also do not access your direct messages, your followers, your insights or your ad campaigns. We do not request those permissions.

5. Legal bases (LGPD, article 7)

ProcessingLegal basis
Providing the service to you, an enrolled studentperformance of a contract (art. 7, V)
Publishing to your Instagram on your behalfspecific consent (art. 7, I)
Technical and security logslegitimate interest (art. 7, IX), limited to what is necessary

Consent to publish is separate from the course contract, is specific, and can be withdrawn at any time without affecting your enrolment.

6. Sharing

With whomWhatWhy
Meta Platforms, Inc.approved content + tokenit is the destination of the publication
Infrastructure providerdata at rest and in transithosting the service

We do not sell data. We do not use your data for advertising. We do not use your data or your content to train artificial intelligence models.

7. International transfer (LGPD, article 33)

Meta and our infrastructure providers keep servers outside Brazil. By using the service, your data is transferred internationally, on the basis of the performance of the contract and of your consent, and subject to the contractual safeguards of the respective providers.

8. Retention and deletion

DataPeriod
Media filesdeleted on publishing; sweep within 24h
Access tokendeleted immediately on disconnection or revocation
Publication records12 months after publishing
Consent records5 years after revocation or termination of the service, as proof of compliance
Technical logs30 days

The retention period for consent records follows the 5-year limitation period of article 27 of the Brazilian Consumer Protection Code: it is the proof that authorization to publish existed, and it needs to outlive the consent itself. Deletion of the remaining data at the data subject's request does not depend on that period.

9. Your rights (LGPD, article 18)

Confirmation of processing, access, correction, anonymization, portability, deletion, information about sharing, and withdrawal of consent.

To exercise them: polozi@polozi.com.br, or through the data deletion page. We respond within 15 days.

10. Security

Token encrypted at rest with the key kept outside the database; data isolation between students enforced at the database level; access restricted to named and audited credentials; verified signatures on calls to the Meta API; and least privilege — the publishing service has no technical access to the commercial database.

No system is immune. In the event of an incident with relevant risk, we notify you and the Brazilian data protection authority (ANPD) under article 48 of the LGPD.

11. Changes

Material changes will be communicated in advance. If a change affects the scope of what you authorized, we will ask for new consent — the previous text remains on record and is identifiable by its hash.

12. Contact

VIDA PLENA TREINAMENTOS LTDA · CNPJ 20.329.336/0001-00
Av. Joaquim Alves Correa, 2800 — Parque Nova Suíça — Valinhos/SP — ZIP 13271-430, Brazil
Data Protection Officer: José Carlos Polozi — polozi@polozi.com.br