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Privacy

Privacy policy

Version 2.0 · Last updated: 2026-05-17

[v2 draft — final legal review pending]

Who we are

Apex Labs (apxlbs) is a digital infrastructure studio operated by Rodrigo Teixeira. We are the data controller for the personal information described in this policy.

Encarregado de dados (DPO) / Privacy contact: [email protected] (Rodrigo Teixeira). Inquiries acknowledged within 5 business days, resolved within 30 days per LGPD Art. 18 and GDPR Art. 12.

What we collect

We collect the minimum needed to operate the site and respond to inquiries:

  • Form submissions — name, email, company, role, project details, budget band, timeline. Voluntary; collected only when you fill a form.
  • Newsletter email — only if you subscribe. One-click unsubscribe in every email.
  • Anonymous analytics — page views, referrers, viewport, device class via Vercel Analytics. No cookies, no cross-site tracking, no device fingerprinting.
  • Server logs — IP address, user-agent, request paths. Used for security + abuse prevention; rotated every 30 days.
  • Authentication state — for admin/portal users only: a session cookie + (for admins) a 12-hour 2FA freshness cookie. See/cookiesfor the complete cookie inventory.

We do not sell, rent, or trade personal information. Period.

Sub-processors (who we share data with)

Per LGPD Art. 39, here is the complete list of processors who handle data on our behalf:

ProcessorPurposeRegion
VercelHosting + CDN + analyticsUS/EU multi-region
NeonPostgres databaseUS (us-east-1)
CloudflareDNS + WAF + edge cacheGlobal
Resend (when active)Transactional email + newsletterUS
Stripe (when active)Payment processing for paid diagnosticsUS/global
Google (SMTP, when active)Magic-link sign-in deliveryGlobal
PostHog (optional)Product analyticsUS
Sentry (when active)Error monitoringUS

Each sub-processor is contractually bound to act only on our instructions. Most are outside Brazil; international transfers occur under the standard contractual clauses published by each provider (LGPD Art. 33 §IV).

How we use it

Form submissions are used solely to evaluate engagement fit, respond to your inquiry, and — if you opted in — send Lab Notes. The legal basis is your consent (the act of filling the form) or our legitimate interest in operating the business (responding to inbound business inquiries).

For paid engagements, the legal basis becomes contract (LGPD Art. 7 §V / GDPR Art. 6(1)(b)).

Automated decisions

Per LGPD Art. 20: when you submit an application form, we apply an automated lead-scoring routine that combines your budget band, revenue range, and timeline to assign a tier (priority / qualified / review). The score does not auto-reject anyone — it only routes the inquiry for human review.

You can request human review of any automated classification by emailing [email protected].

Retention

  • Form submissions — indefinite while engagement is active or being evaluated; deleted on request.
  • Newsletter subscribers — until you unsubscribe (one-click).
  • Server access logs — 30 days, then automatically rotated.
  • Audit log of sensitive actions — 12 months, then archived.
  • Authentication sessions — 30 days max from creation; you can sign out earlier.
  • Two-factor secrets — until you disable 2FA on your account.

Your rights

Per LGPD Art. 18 and GDPR Art. 15-22, you can:

  • ▸ Confirm whether we process your data (access)
  • ▸ Receive a copy of your data (portability)
  • ▸ Correct inaccurate data (rectification)
  • ▸ Request deletion (erasure / right to be forgotten)
  • ▸ Anonymize, block, or restrict processing
  • ▸ Object to processing or revoke consent
  • ▸ Be informed of sub-processors who received your data
  • ▸ Request human review of automated decisions

Email [email protected] with the subject line “Privacy request” and we'll respond within 30 days.

Security

All traffic is TLS 1.2+; sessions are HttpOnly + Secure + SameSite cookies; two-factor secrets are AES-256-GCM encrypted at rest; recovery codes are bcrypt-hashed; passwords are not used anywhere. Read more in our security disclosure and security.txt.

In the event of a data breach affecting your personal information, we will notify you within 72 hours of detection per LGPD Art. 48 / GDPR Art. 33.

Cookies

We use only strictly-necessary cookies (authentication + CSRF + anonymized analytics). No advertising cookies, no third-party tracking pixels, no behavioral profiling. Full inventory at /cookies.

Children

This site is intended for business operators. We do not knowingly collect information from anyone under 18.

Changes

If this policy changes materially, we publish a new version with a fresh “last updated” date. Material changes are emailed to admin-allowlisted users. Non-material clarifications are tracked in the git history of this repository.