Privacy Policy

Last Updated: May 29, 2026

1. Introduction

CLUSTER MARKETING LTDA, registered under CNPJ No. 45.515.460/0001-90 (“we,” “our,” “us,” or “the company”), operating through the My Checkout Hub platform (mycheckouthub.com), is committed to protecting your privacy and your personal data.

This Privacy Policy explains how we collect, use, share, and protect your personal information when you access our websites, use our digital products, or perform transactions through our payment platform.

By using our services, you accept the practices described in this Policy. If you do not agree, please do not use our services.

This policy applies to all websites, sales pages, and domains operated by our company, including but not limited to mycheckouthub.com and product pages linked to our payment platform.

2. Information We Collect

2.1 Information Provided Directly by You

When you make a purchase, create an account, or communicate with us, we may collect:

  • Full name
  • Email address
  • Phone number (when provided)
  • Country of residence
  • Payment information (card number, expiration date, security code) — processed exclusively by Stripe, our payment processor. We do not store this data.

2.2 Information Collected Automatically

When you visit our websites, we may automatically collect:

  • IP address and approximate geographic location
  • Browser type, operating system, and device
  • Pages visited, time spent, and browsing patterns
  • Traffic source (where you came to our site from)
  • Service usage data and preferences
  • Cookie identifiers and similar technologies
  • Ad interaction data (clicks, views)

2.3 Subscription and Recurring Payment Information

If you purchase a product with recurring billing (subscription), in addition to the above, we record:

  • Subscription start date
  • Billing frequency (monthly, annual, etc.)
  • History of charges made and their status (successful, failed, refunded)
  • Subscription status (active, canceled, paused, expired)
  • Registered payment method (secure token stored by Stripe, not full card details)
  • Scheduled next renewal date

3. How We Use Your Information

We use your personal information for the following purposes:

  • Processing one-time and recurring payments, and managing your subscriptions
  • Providing access to purchased digital products
  • Sending purchase confirmations, renewal notices, and notifications regarding your subscription status
  • Offering customer support and responding to your inquiries
  • Sending relevant communications about updates to contracted products or services
  • Improving our products, services, and user experience
  • Detecting, preventing, and addressing fraud, unauthorized activities, or illegal actions
  • Complying with applicable legal, tax, and regulatory obligations
  • Conducting internal analysis and statistics on the use of our services

We do not use your personal information to send unsolicited marketing communications without your prior consent.

4. Payment Processing and Subscriptions

4.1 Payment Processor: Stripe

We use Stripe (stripe.com) as our payment processing platform. Stripe is a PCI-DSS Level 1 certified payment processor, the highest level of security certification in the payment industry.

4.2 Card Data and Security

Your complete credit or debit card details are never stored on our servers. All payment information is processed and stored exclusively by Stripe using bank-level encryption and secure tokenization.

For recurring subscriptions, Stripe stores a secure token associated with your payment method, which allows future charges to be made without full card details being accessible by our company.

4.3 Recurring Charges

If you purchase a subscription product:

  • You will be charged automatically according to the established frequency (monthly, annual, or other).
  • You will receive a confirmation email at the time of each charge.
  • You will receive prior notice before each renewal, stating the amount and date of the next charge.
  • If a charge fails (e.g., expired card or insufficient funds), Stripe will perform automatic retries. You will be notified to update your payment method if necessary.

4.4 Stripe Policy

For more information on how Stripe protects your data, please review Stripe’s Privacy Policy at stripe.com/privacy.

5. Cookies and Tracking Technologies

5.1 What We Use

We use cookies and similar technologies to enhance your experience and analyze the use of our services. Specifically, we use:

  • Essential cookies: Necessary for site operation (session, shopping cart, language/currency preferences).
  • Analytical cookies: Google Analytics (analytics.google.com) to understand how visitors interact with our site. Data collected is anonymous and aggregated.
  • Advertising cookies: Meta Pixel (Facebook/Instagram) to measure the effectiveness of our advertising campaigns and display relevant ads. This data may include actions taken on our site (visits, purchases) associated with your Meta profile.
  • Performance cookies: Cloudflare to optimize site speed and security.

5.2 Your Control Over Cookies

You can configure your browser to reject cookies or alert you when cookies are sent. Please note that if you disable cookies, some site features may be affected (for example, automatic local currency detection or session persistence).

For more information about Meta cookies: facebook.com/policies/cookies
For more information about Google Analytics: policies.google.com/privacy

6. Information Sharing

We do not sell, rent, or share your personal data with third parties for direct marketing purposes.

We may share your information only with:

  • Stripe: For payment processing and subscription management.
  • Technical service providers: Who assist us in business operations (web hosting, email delivery, data analysis) under strict confidentiality obligations.
  • Advertising platforms: Meta (Facebook/Instagram) and Google, strictly for campaign measurement and retargeting, using anonymized or pseudonymized data.
  • Legal authorities: When required by law, court order, or when necessary to protect our legal rights, prevent fraud, or ensure the safety of our users.

7. International Data Transfers

Our company is headquartered in Brazil. Your personal data may be transferred to and processed in countries other than your own, including Brazil and the United States (where Stripe maintains its primary infrastructure).

When performing international data transfers, we ensure that adequate safeguards are in place, such as standard contractual clauses or compliance with internationally recognized data protection frameworks.

8. Data Security

We implement technical and organizational measures to protect your personal information, including:

  • SSL/TLS encryption on all data transmissions
  • Payment processing on PCI-DSS certified servers (via Stripe)
  • Restricted access to personal information (authorized personnel only)
  • Protection against DDoS attacks and unauthorized access (via Cloudflare)
  • Periodic backups and secure storage
  • Continuous security monitoring

Despite our best efforts, no data transmission or storage system is completely secure. In the event of a security breach affecting your personal data, we will notify you as required by applicable law.

9. Data Retention

We retain your personal information for as long as necessary to:

  • Provide contracted services and maintain your active subscription
  • Comply with legal, tax, and accounting obligations
  • Resolve disputes, prevent fraud, and enforce our agreements

Following the cancellation of your account or subscription, your data may be retained for the legally required period (generally between 5 and 10 years for tax records) and will subsequently be securely deleted or anonymized.

You may request the early deletion of your data at any time, subject to legal retention obligations.

10. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

10.1 For All Users

  • Access the personal data we hold about you
  • Correct incomplete or inaccurate data
  • Request the deletion of your data (subject to legal retention obligations)
  • Revoke your consent for data processing at any time
  • Request information about who we share your data with
  • Cancel your subscription at any time

10.2 Additional Rights for European Union Residents (GDPR)

If you reside in the European Union (including Spain), you also have the right to:

  • Request the portability of your data to another provider
  • Object to the processing of your data for marketing purposes
  • Request the restriction of the processing of your data
  • Lodge a complaint with your national data protection authority

The legal basis for processing your data is: (a) performance of the service agreement; (b) your consent; (c) our legitimate interests; and (d) compliance with legal obligations.

10.3 Additional Rights for Residents of Brazil (LGPD)

If you reside in Brazil, pursuant to the General Data Protection Law (Law No. 13,709/2018), you also have the right to:

  • Confirm the existence of processing of your data
  • Request anonymization, blocking, or deletion of unnecessary or excessive data
  • Obtain information about public and private entities with which we share your data
  • Request the review of automated decisions affecting your interests

10.4 How to Exercise Your Rights

To exercise any of these rights, please send an email to: [email protected]

We will respond to your request within the timeframes established by applicable legislation (generally 15 business days).

11. Minors

Our products may include content related to eating habits and wellness. However, contracting our services and providing personal data must be conducted exclusively by individuals aged 18 or older (or the legal age of majority in your jurisdiction).

We do not knowingly collect personal data from minors without verifiable parental or legal guardian consent. If we identify the collection of data from a minor without appropriate consent, we will take immediate steps to delete such information.

12. Modifications to this Policy

We may update this Privacy Policy periodically to reflect changes in our practices, applicable legislation, or services offered.

When material changes occur, we will notify you by email or via a prominent notice on our website. Continued use of our services after such modifications constitutes your acceptance of the updated policy.

We encourage you to review this policy periodically.

13. Contact Information

If you have questions, concerns, or requests related to this Privacy Policy or the processing of your personal data, you may contact us at:

CLUSTER MARKETING LTDA
CNPJ: 45.515.460/0001-90
Address: Estrada Francisco da Cruz Nunes, 3095, Sala 209, Itaipu, Niterói – RJ, CEP 24340-000, Brazil
Email: [email protected]
Data Protection Officer (DPO / Encarregado LGPD): [email protected]

This Privacy Policy was drafted in compliance with the European Union General Data Protection Regulation (GDPR), the Brazilian General Data Protection Law (LGPD — Law No. 13,709/2018), and applicable data protection regulations in the jurisdictions where we operate.

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