Pupila Brand Studio
HOW THIS NOTICE IS ORGANIZED
PUPILA BRAND STUDIO LTDA (“PUPILA”) is a platform for brand assets and guidelines that streamlines marketing efforts and empowers teams to collaborate smoothly and increase brand consistency. Thus, to enable the provision of PUPILA’s services and access to our Platform, we process personal data of our clients, following the provisions of the law and always adopting the best practices available in the market.
Through this Privacy Notice (“Notice”), we seek to present to you, in a simple, clear and objective manner, which of your personal data we collect, for what purposes, how they are used and stored, with whom they may be shared and how they are protected, including when transferred to other countries, in accordance with the provisions of privacy laws, especially Brazilian Federal Law No. 13,709/2018 – General Data Protection Law (“LGPD”) and, where applicable, the privacy laws of other countries.
As PUPILA works with clients and data subjects located in different countries, this Notice contains specific sections for data subjects in Brazil, in the European Union, the European Economic Area and the United Kingdom, and in the United States of America (Section 13), observing, respectively, the LGPD, the European General Data Protection Regulation (“GDPR”) and the applicable U.S. privacy legislation.
This Privacy Notice is not related to PUPILA’s Terms of Use, which is a separate document. The Terms of Use set out the legal agreement between you and PUPILA for using the Platform. They also describe PUPILA’s rules and your rights as a user.
For us, the priority is to safeguard the privacy and security of your personal data. Thus, any information you provide to us will be treated in accordance with the limits established in this document and the terms of the applicable legislation.
We do not intend to collect or otherwise process personal data of individuals under 18 (eighteen) years of age, as our services are intended only for companies and adults. Therefore, if we become aware that we have collected personal data from an individual under 18 (eighteen) years of age, we will disregard the information provided and will not keep it in our databases.
We recommend that you read the terms of this Notice carefully and in full. If you have any questions or suggestions, or wish to exercise any of your rights as a data subject, please contact us at privacy@pupila.ai.
To make this Notice easier to understand, we provide a summary table of the information that will be presented to you in this document:
Topic
Summary
Who will process your personal data?
PUPILA is the entity responsible for the Processing of Personal Data and determines its purposes and means. Registered with the CNPJ/MF under No. 54.172.052/0001-74, headquartered in São Paulo, at Rua Pereira Leite, nº 442, Sumarezinho, CEP 05.442-000.
How do we collect your personal data?
The information we process about you may have been provided directly by you to PUPILA, provided by USERS who submit images of you to the Platform, or collected automatically through our Platform.
What data will be processed?
Registration data: full name; Contact information: phone number and email; Images and biometric data: photographs and images of people submitted to the Platform; and Attributes associated with your electronic devices: internet service provider, operating system, browser (type, version, enabled options and installed plugins), display settings (size/resolution and number of colors), date and time of access, pages viewed through cookies, characteristics of the access device; IP address (with date and time); IP origin; language preference; country setting; click information and geolocation.
Why do we need your personal data?
We use your Personal Data to serve a specific purpose:
How long will your data be kept?
We store your Personal Data for as long as necessary to achieve the purposes for which it was collected. Whenever possible, we will keep Personal Data in anonymized form, observing the highest level of care and security in the market.
When may your personal data be shared? Is there an international transfer?
We may share your Personal Data with Third Parties to achieve the purposes for which it was collected. In addition, sharing may occur when necessary to comply with requests from judicial authorities or to meet legal or regulatory obligations.
We may transfer data to other countries (including the United States and European Union countries), always with appropriate safeguards, as described in Section 10.
How can you exercise your rights as a data subject?
We are committed to honoring all of your rights as a data subject and have a communication channel to resolve any questions, suggestions or requests regarding the Processing of the Personal Data collected, under the terms applicable to your country, as described in Section 13. Contact us by email: privacy@pupila.ai.
This Notice is addressed to all data subjects, natural persons, who use PUPILA’s services through our Platform (“USER”), as well as to people whose images are submitted to the Platform by USERS, regardless of the country in which they are located.
Your personal data will be processed by PUPILA. We act predominantly as the Personal Data Controller, which means we decide how your personal data will be processed, applying good data protection practices and following the provisions of the LGPD and other applicable laws.
With regard to images submitted to the Platform, the USER is responsible for the content they upload and for obtaining, prior to submission, the acknowledgment and consent of the individuals portrayed, through the term described in Section 6. PUPILA recommends that no personal data of third parties be uploaded that is unnecessary for the purpose of using the Platform and/or has not been expressly consented to.
The information we process about you may have been provided directly by you to PUPILA, provided by USERS, or collected automatically through our Website or Platform. Let’s take a closer look at each of these data collection situations:
From the beginning of your interaction with us, you voluntarily provide us with information about yourself. For example, when you register to use our Platform, contact us through social media or our customer service channels, when you interact with the content of our Website or Platform, by email or through other tools.
In some situations, we may also collect personal data automatically through the devices you use to access our Platform and Website. This information helps us generate access statistics and thus better understand our audience. This is important so that we can improve our services and adapt them to different audiences. Some of this data may be collected through cookies or similar technologies, as we will explain in a separate topic below.
When a USER submits photographs or images of other people to the Platform, we process the personal data of these data subjects, which may include biometric data. This submission must be preceded by a term of acknowledgment and consent signed by the individual portrayed, as described in Section 6.
To respect your privacy, we understand that all processing of personal data must be limited to the minimum necessary, in a relevant and proportional manner, to allow the intended purpose to be achieved.
Therefore, the personal data we collect about you will vary depending on the relationship you choose to have with us. Below, grouped by category, we present the main personal data that may be processed by us and the purpose of the processing:
As a rule, we do not collect sensitive personal data on our Website. However, as detailed in Section 6, the images submitted to the Platform may involve the processing of biometric data, which is considered sensitive personal data.
The Platform allows USERS to submit photographs and other images of people in order to achieve the purpose expected by PUPILA. These images may contain facial and physical characteristics that, when subjected to specific technical processing to reproduce a person’s features in the generated images or to uniquely identify them, may be considered biometric data and, therefore, Sensitive Personal Data under the LGPD and other applicable laws.
Images of people may only be submitted to the Platform with the prior acknowledgment and the specific and highlighted consent of the individual portrayed, formalized through a dedicated term that informs the purposes of the processing. The USER who submits images of third parties is responsible for obtaining and keeping this term and for ensuring that they have all the necessary authorizations, including with regard to image rights. Submitting images of individuals under 18 (eighteen) years of age is not permitted.
Images and any biometric data will be processed exclusively to enable the execution of the PUPILA activities requested on the Platform, and will not be used to identify or authenticate people, nor shared for purposes other than those described in this Notice.
The individual portrayed may withdraw their consent at any time by emailing privacy@pupila.ai, in which case their images and biometric data will be deleted, except where retention is required by law.
The Personal Data we collect may be used as described in the table below:
Personal data category
Purposes
Registration data; Contact information
To enable a service you have contracted
Images and biometric data
Image generation on the Platform
We will process the images submitted by USERS, which may contain biometric data, exclusively to enable the execution of the requested activities, based on the specific and highlighted consent of the individual portrayed and, where applicable, the explicit consent required by foreign legislation.
Registration data; Attributes associated with your electronic devices
Communication, management and improvement
All categories of personal data
Compliance with our legal or regulatory obligations
Your personal data may be used to meet our obligations under the law and/or regulations of government bodies and orders or requests from tax authorities, the Judiciary and/or other competent authorities. For example, we may process personal data to issue invoices.
All categories of personal data
Allowing the regular exercise of our rights
Even after your relationship with us ends, we may process some of your personal data to exercise our rights guaranteed by law, including as evidence in judicial, administrative or arbitration proceedings.
All categories of personal data
Enabling activities necessary for our Organization
Based on our legitimate interest, we may also process your personal data in activities such as: improvements to our products and services, relationships with our clients and partners, company performance analysis and reports, and internal consultations. In activities supporting PUPILA’s interests, we will always respect the limits of your expectations, and the processing of personal data will not harm your fundamental interests, rights or freedoms.
Registration data
Preventing fraud and safeguarding your security
We may process your personal data to safeguard your security (and that of third parties) and prevent identity fraud, especially during your access to our institutional website and internal systems, or when entering or visiting our premises.
Contact information; Attributes associated with your electronic devices
Advertising
We may use your Personal Data to create target audience segments and thus promote more suitable content for PUPILA’s marketing campaigns. In this case, the option to unsubscribe from our database will always be available at the end of each communication we send, with the possibility of choosing to receive information such as offers and news about PUPILA’s latest trends.
Cookies are files or pieces of information that may be stored on your devices when you access PUPILA’s Website/Platform. We use cookies to make use easier and to adapt our pages to the interests and needs of data subjects, as well as to compile information about the use of the Website, helping to improve its structure and content. Below you can see the types of cookies and their respective purposes, which justify the use of the information we collect, in accordance with the LGPD:
Type of cookie
What do they do?
Necessary/Essential
These are essential cookies to enable the proper functioning of our Platform/Website and to allow you to use all available features.
Performance/Analytics
These are cookies that help us understand how visitors interact with our Platform/Website, providing information about the areas visited, the time spent on the Platform/Website and any problems encountered.
Functional
These are cookies that allow us to remember your previous choices, such as browsing language. They provide a personalized experience.
Marketing/Advertising
These are cookies used to deliver content that is more relevant and specific to your interests. They may also be used to present more targeted advertising or to limit the number of times it is displayed. They also allow the effectiveness of a launched campaign to be measured.
PUPILA may share your personal data, in which case sharing will be restricted to the minimum necessary and required to fulfill specific purposes previously informed to you in this Notice. Thus, we may share your data with third parties in the following situations:
Some of these operations may involve the transfer of personal data to other countries, as detailed in Section 10.
In any of the cases above, PUPILA will use its best efforts to establish responsibilities with the companies receiving personal data, through appropriate contractual instruments containing provisions on legal bases, purposes, forms of processing and security measures, among other safeguards granted to data subjects, in accordance with the LGPD and other applicable laws.
As PUPILA serves clients and data subjects located in different countries, it may transfer and/or store Personal Data in the United States and/or in other countries where it has facilities, business activities or service providers. Thus, your Personal Data may be transferred to other countries or regions, including to other entities of its group or to contracted operators, such as cloud data storage providers.
When transferring your Personal Data outside your country of residence, we do so in accordance with applicable law and adopt appropriate measures to ensure the protection of your data, ensuring that any processing occurs lawfully, only under our instructions and for the purposes informed, under the terms of the data processing agreement signed with the respective recipient.
For transfers from Brazil, we will observe the mechanisms provided for in Article 33 of the LGPD and in the regulations of the ANPD (Brazilian National Data Protection Authority). For transfers from the European Union, the European Economic Area or the United Kingdom to countries that are not recognized as having an adequate level of protection, we will use appropriate and necessary safeguards.
Please be aware that, outside the jurisdiction of your residence, your Personal Data will be subject to local laws, which may not offer the same level of protection as the legislation of your country and may provide for disclosure to governments, courts, law enforcement authorities or regulatory bodies of that jurisdiction. Images and biometric data will only be transferred when necessary to generate the requested images and with the same safeguards described herein.
To protect the privacy of data subjects, the personal data processed by PUPILA will be automatically deleted when it is no longer useful for the purposes for which it was collected, or when the data subject requests its deletion, unless its retention is expressly authorized by applicable law or regulation.
Images and biometric data submitted to the Platform will be kept only for the period necessary to generate the requested images or until the data subject withdraws consent, whichever occurs first, except where retention is required by law.
We emphasize that information may be retained to comply with legal or regulatory obligations, for transfer to third parties – provided that data processing requirements are respected – and for PUPILA’s exclusive use in exercising its rights in judicial or administrative proceedings.
Finally, the data subject should be aware that their request may be lawfully rejected, either for formal reasons (such as their inability to prove their identity) or for legal reasons (such as a request to delete data whose retention is permitted to PUPILA by current legislation).
We use reasonable market means and those required by law to preserve the privacy of the personal data we collect. Thus, we adopt several precautions, in accordance with the guidelines on security standards established in Decree No. 8,771/2016, such as:
In addition to technical efforts, we also adopt institutional best practices aimed at protecting personal data. It is important to note that, although PUPILA makes its best efforts to preserve privacy and protect data subjects’ data, no transmission of information is completely secure, so we cannot fully guarantee that all data received or sent will not be subject to unauthorized access carried out with methods designed to obtain information improperly.
Data protection rights vary according to the data subject’s country of residence. Find the section that applies to you below. If you are not sure which section applies, contact us and we will help you.
If you are in Brazil, the LGPD applies. Regardless of the relationship you choose to establish with PUPILA, you have all the rights related to your personal data provided for by law, including:
You may exercise your rights at any time by contacting us at privacy@pupila.ai. To do so, we ask that you identify yourself and indicate which right you wish to exercise.
PUPILA may request other information and/or documents to confirm your identity or the accuracy of your information. Requests involving personal data and/or documents of other data subjects will not be fulfilled, except by power of attorney, parental authority or another circumstance that authorizes you to exercise the right of another data subject.
Please note that, in specific circumstances, your request may not be fulfilled. In such cases, we will explain the reasons for not fulfilling it.
If you are located in the European Economic Area or the United Kingdom, you have certain rights over your Personal Data. Where we process your Personal Data based on your consent, including the explicit consent required for biometric data, you have the right to withdraw it at any time. Any Personal Data we hold solely on the basis of consent will be deleted after withdrawal. You also have the following rights:
You also have the right to lodge a complaint with the competent data protection supervisory authority.
Access. If you request access to the Personal Data held by PUPILA, we may ask for additional information about the request, including proof of identity and of your right to request access. We will do our best to process the request as quickly as possible and, in any case, within the legal deadline. If this deadline needs to be extended, we will inform you in advance.
Erasure. If you request the erasure of your Personal Data, we may ask for additional information, including proof of identity and of your right to request erasure. We will comply with these requests in the following circumstances:
Rectification. If the Personal Data we hold contains errors or is inaccurate, you have the right to request that it be corrected. In certain circumstances, you may also supplement it with additional information you wish to provide.
Restriction of processing. You have the right to request the restriction of processing in the following circumstances:
Right to object to processing. You may object to the processing of your Personal Data in circumstances where it is processed on the basis of our legitimate interest, when you have specific grounds to do so. Any objection will be assessed taking into account whether there are overriding legitimate grounds for continuing the processing.
To exercise your rights, contact us at privacy@pupila.ai.
If you reside in the United States, your rights depend on the data protection legislation applicable in your state of residence. Subject to that legislation, you may have the right to:
In some states, the collection of biometric identifiers requires prior written notice and consent, which will be obtained through the term mentioned in Section 6.
PUPILA does not sell personal data, including biometric data, for monetary consideration. If, in the future, any activity occurs that applicable law classifies as a sale or sharing, we will provide the corresponding opt-out mechanism.
How to exercise your rights: write to privacy@pupila.ai. We may request information to verify your identity. Depending on the applicable law, you may have the right to appeal a decision of ours; in that case, we will explain how to do so in our response to your request.
In all cases: we may request additional information to confirm your identity. Requests involving the data of other data subjects will only be fulfilled with a power of attorney, parental authority or other legal authorization. In specific circumstances, a request may be refused; in that case, we will explain the reasons.
If you have any questions, you can contact us at privacy@pupila.ai.
Some of the information provided here may be updated or changed. Therefore, we advise you to check this Privacy Notice periodically. Whenever there is a change, we will inform you on our home page. This Privacy Notice was last amended and published on our Website/Platform in: October 2026.
Term/Expression
Meaning
Personal Data
Any information capable of identifying a natural person, directly or indirectly.
Sensitive Personal Data
Any Personal Data concerning racial or ethnic origin, religious belief, political opinion, trade union membership or membership of a religious, philosophical or political organization, as well as data concerning health or sex life, and genetic or biometric data.
Data Protection Officer
Professional responsible for acting as a communication channel between PUPILA, Data Subjects and the ANPD. Their main objective is to ensure that PUPILA complies with the laws and regulations related to privacy and data protection.
LGPD
General Data Protection Law (Federal Law No. 13,709/2018).
GDPR / U.S. legislation
General Data Protection Regulation (European Union and, in its incorporated version, the United Kingdom); U.S. state privacy laws, such as the California Consumer Privacy Act (CCPA).
Third Parties
Any natural or legal person with whom PUPILA has or may have a relationship. This includes: service providers, suppliers, consultants, partners, contracted or subcontracted third parties, lessees and assignees of space, whether or not under a formal contract, including those who use the Company’s name, supply materials, or interact with public officials, the government or other third parties on behalf of PUPILA.
Data Subject
Natural person to whom the personal data refers.
Controller
Natural or legal person, public or private, responsible for decisions regarding the processing of personal data.
Operator
Natural or legal person, public or private, that processes personal data on behalf of the controller.
International Transfer
Transfer of personal data to another country or international organization.
Processing
Any operation carried out with personal data, such as collection, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, disposal, evaluation or control of information, modification, updating, communication, transfer, sharing and extraction.