Privacy Policy

*Effective date: January 01, 2026*

1. Introduction and Scope of Application

This Privacy Policy (the "Policy") describes how the "Vanelton Media" brand ("we," "us," or "our"), currently operated by VANELTON BERTOLDO ROCHA JUNIOR and LUCAS DE MORAIS MENDES, individuals (see the note on legal structure in Section 2), 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, Volcam Studios (subsidiary game company), Vanelton Media Tools, Orbit WorkApps, Vanelton Labs (early access/experimental tools), Vanelton Open Labs (open-source tools), and any other current or future services linked to: https://vaneltonmedia.com.

We are committed to the security and privacy of your data, in strict compliance with the Brazilian General Data Protection Law (LGPD, Law No. 13,709/2018) and other applicable data protection laws.

2. Identification of the Data Controller

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

Responsible Individuals: VANELTON BERTOLDO ROCHA JUNIOR and LUCAS DE MORAIS MENDES
Legal Form: Individuals (natural persons) — as of the effective date of this Policy, Vanelton Media has not been formally incorporated as a legal entity (no CNPJ). The individuals identified above are personally and jointly liable for the data processing described in this Policy, under Brazilian civil law applicable to unregistered business activity.
Country of Jurisdiction: Federative Republic of Brazil
Address: Maceió, AL, Brazil
Activity: Technology project providing services, apps, and games for companies, developers, and general users.

3. Collection of Personal Data (What and How)

We collect the personal data necessary to provide, manage, and improve our Services.

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 (required): email, date of birth, language, and password.
Profile Information (optional): data you choose to add, such as your full name, 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 is processed primarily by Stripe, our payment processing partner; we do not directly store your full payment card details on our own servers.
Your Preferences: settings related to content options and advertisement controls.
Support Communications: records of your communications when you contact our support team (email and message content).

3.2. Data Collected Automatically (Usage and Technical Data)

Certain information is collected automatically by our systems when you access and use the Services, usually while logged in with your Vanelton ID:

Device Information: device model, operating system (e.g., iOS, Android, Windows), and app version.
Usage and Connection Data (Logs): IP address, browser type and language, dates and timestamps of access, and general interaction data (for example, which screens or features you use), to operate the Services, prevent fraud, and improve support.
Vanelton AppHub Library: since Vanelton AppHub is a desktop app and game store, it needs to know which apps and games distributed through it are installed on your device, to manage your library, updates, and uninstalls.
Location Data: if you grant permission through your device settings, we may collect location data for features that depend on it. Without that permission, we do not infer your location by other means.
Cookies: we use cookies and similar technologies for authentication, remembering your preferences, and site administration. See Section 9 for more detail.

Data Not Currently Collected: We do not currently collect data from device sensors (such as accelerometer, gyroscope, or compass), a general list of other software installed on your computer (outside the Vanelton AppHub catalog), or behavioral tracking data across different Services for advertising purposes. If a future feature requires collecting any of this data, we will request your explicit permission at the time that specific feature is used — not merely through a general update to this Policy.

3.3. Data Obtained from Third Parties

We may obtain information about you from external sources to enable specific features:

Social Media: if you link a social media account to your Vanelton ID, we may receive information from that platform, according to its rules and your privacy settings there.
Third-Party Developers: if you use your Vanelton ID to log in to an approved third-party application, the developer may share usage or profile information back to us, in accordance with their policy and our developer agreements.

4. Purposes and Legal Bases of Processing (Why)

We process your personal data only for specific, legitimate purposes, based on the legal bases set out in the LGPD.

Execution and Improvement of the Services: managing your Vanelton ID, ensuring integrated functionality across Services, fixing bugs, and adding new features. Legal basis: performance of contract (LGPD, Art. 7, V).
Single Sign-On (SSO): using your Vanelton ID details to log in across various Vanelton Media Services (e.g., Volcam Studios) without requiring separate accounts. Legal basis: performance of contract (LGPD, Art. 7, V).
Payment Processing: processing purchases, managing subscriptions, and billing linked to your Vanelton ID. Legal basis: performance of contract (LGPD, Art. 7, V).
Communication and Support: sending important Service updates and providing customer support. Legal basis: performance of contract (LGPD, Art. 7, V) and legitimate interest (LGPD, Art. 7, IX).
Support for Third-Party Logins: allowing you to use your Vanelton ID for SSO into approved third-party applications. Legal basis: consent (LGPD, Art. 7, I).
Security and Fraud Prevention: identifying and preventing fraud, security issues, or illegal activity related to Vanelton ID accounts or our Services. Legal basis: legitimate interest (LGPD, Art. 7, IX).
Legal and Regulatory Compliance: fulfilling legal obligations, responding to government requests, and enforcing our Terms and rights. Legal basis: legal obligation (LGPD, Art. 7, II).
Communication and Outreach: sending you news and offers related exclusively to Services you are already linked to, based solely on your consent, which you may withdraw at any time. Legal basis: consent (LGPD, Art. 7, I).

Strict Prohibition for Minors: We expressly prohibit using the personal data of users under 18 for behavioral profiling, hyper-targeted advertising, or emotional analysis. Granular technical data collection and any potentially addictive design features are disabled by default on accounts identified as belonging to children and adolescents (privacy and safety by default).

4.1. Special Provisions for Children's Privacy

We recognize and prioritize protecting the privacy of children and adolescents online.

Age Verification (Law No. 15,211/2025): self-declared age is strictly prohibited for unlocking restricted content. We use facial age verification to unlock access to content, products, or areas of the Services intended for users over 18. Data collected exclusively for this verification process is not permanently stored, commercialized, or cross-referenced, and is securely deleted immediately after validation.
Parental Consent (Under 12): the personal data of users under 12 years of age is only processed with the specific, highlighted consent of a parent or legal guardian, per Article 14 of the LGPD.
Parental Supervision: we do not currently offer a parental control panel that lets a legal guardian link to a teenage User's account and remotely manage its settings. This feature is under evaluation for future versions of the Services.
Services Directed at Children: some of our Services, such as certain Volcam Studios games, may be designed for or appealing to children. Access to these follows the content-separation approach described in our Terms of Service.
Parental Rights: parents and legal guardians may request to review, correct, or delete the personal information we hold about their children linked to our Services.
Contact for Parents: if you are a parent or legal guardian and believe your child provided us with personal data without your authorization (for example, by creating a Vanelton ID while underage), please contact us immediately. We will investigate and take appropriate action, including account deletion.

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

We do not sell your personal data. We share your information only when necessary to operate our Services, enable features you choose to use, or comply with legal obligations.

Internal Vanelton Media Teams: data associated with your Vanelton ID may be shared between our divisions (e.g., Volcam Studios) to provide integrated features (shared progress/settings).
Service Providers: we work with external companies that support our operations, such as cloud hosting providers and payment processors (e.g., Stripe). These companies receive only the data necessary to perform the contracted services 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 through the Vanelton Console. We will request your explicit consent to share specific profile information (name, email, profile photo, user ID) with that developer. The developer's independent use of your data after your authorization is governed by their own privacy policy — we recommend reviewing it before connecting your ID.
Legal Requirements: we share data when required by law (e.g., court order) or when necessary to protect our rights, user safety, investigate fraud, or respond to government requests.
Business Transfers: in the event of a significant change to our business (e.g., formal incorporation, merger, or acquisition), your information may be transferred as part of that transaction.
Other Parties: any other sharing will only be done with your specific permission.

6. International Data Transfer

Our primary datacenter is located in the United States, contracted through a Brazilian company that resells American server infrastructure; User data is stored on that datacenter. Payment processing, carried out by Stripe, may also take place in the United States.

Vanelton Media reserves the right, at any time and at its sole discretion, to fully remove data stored on servers located in the United States and transfer it to a datacenter in any other country, refusing to comply with government requests it considers abusive toward the Company or its Users — including discontinuing the provision of Services in the United States.

When transferring or storing data internationally, we ensure appropriate legal safeguards are in place, in compliance with LGPD Article 33, to guarantee a level of protection equivalent to that provided under Brazilian law. This typically involves standard contractual clauses or verifying that the destination country provides an adequate level of protection.

7. Retention and Deletion of Data (How Long)

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

Active Accounts: generally, your Vanelton ID information is retained 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 requiring us to retain certain information (e.g., for tax, fraud-prevention, or legal compliance purposes). We commit to completing the permanent, irreversible removal of your personal data within fifteen (15) business days of your confirmed request.

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

In compliance with the LGPD, you have the following rights regarding your personal data:

Confirmation and Access: confirm the existence of processing and access the personal data we hold about you.
Correction: request correction of incomplete, inaccurate, or outdated data in your Vanelton ID profile.
Anonymization, Blocking, or Deletion: request the anonymization, blocking, or deletion of unnecessary or excessive data, or data processed in non-compliance with the LGPD.
Portability: receive your personal data in a structured, commonly used, machine-readable format for transfer to another provider.
Objection: object to processing based on a legal basis other than consent or contract (e.g., legitimate interest), where a disproportionate impact is shown.
Withdrawal of Consent: withdraw your consent at any time, where processing is based on consent (this may affect your ability to use certain Services).
Information on Sharing: be informed about the public and private entities with which we share your data.
Information on the Consequences of Denying Consent.

Procedure to Exercise Your Rights: contact us through our dedicated support channel: usersupport@vaneltonmedia.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 use cookies and similar technologies for authentication, remembering your preferences, and administering the Services.

For detailed information about the cookies we use and how you can control them, please see our Cookie Policy at: https://vaneltonmedia.com/cookies

10. Security of Information

We value the security of your Vanelton ID and associated information. We use 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, no online system is 100% secure. While we strive to protect your personal data, we cannot guarantee its absolute security. You also play a key role in security by using a strong password for your Vanelton ID and keeping it confidential.

11. Changes to This Privacy Policy

The digital environment, legal frameworks, and our Services 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 and update the "Effective Date" at the top of the document. If the changes are significant, we will also try to notify you directly via your Vanelton ID email or a prominent notice on the Services.

We recommend checking this page periodically to stay informed about how we protect your information.

12. Applicable Law and Forum

This Policy is governed by and interpreted in accordance with the laws of the Federative Republic of Brazil, specifically the LGPD.

For disputes between Vanelton Media and Developers or business partners — relationships not governed by the Consumer Protection Code — we elect the courts of Maceió, Alagoas, Brazil, as the forum.

For end Users acting as consumers, Article 101, I, of the Consumer Protection Code prevails, which guarantees the consumer the right to bring an action in the forum of their own domicile.

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

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

DPO Name/Title: Vanelton Bertoldo Rocha Junior, Responsible for Vanelton Media
Official Privacy Contact Email: legal@vaneltonmedia.com