Privacy Policy

Privacy Policy

1. Who we are and who controls your data

Your personal data is controlled by LYBEL TECNOLOGIA LTDA, registered under Brazilian company registry (CNPJ) no. 68.121.174/0001-46, which operates Lybel.

For any matter related to your personal data, write to privacidade@lybel.com.br.

2. Data Protection Officer (DPO)

The data protection officer (controlador), as defined by Article 41 of Brazil's LGPD (General Data Protection Law), is Diego Clair. You may contact him directly at privacidade@lybel.com.br to exercise your rights as a data subject or ask questions about this policy.

3. What data we collect

We collect only the data you voluntarily provide when joining the waitlist:

We also automatically record at the time of registration:

We do not collect sensitive data (racial origin, religion, health, biometrics, etc.) or data from minors.

• Name
• Email address
• Optional feedback about your needs as a service provider
• The source of your visit (UTM parameter present in the URL, when available)
• The date and time of registration

4. How we use your data (purposes)

We use your data exclusively to:

• Keep you informed about the development and launch of Lybel.
• Invite you to participate in beta tests.
• Conduct, with your prior consent, research and interviews to help shape the product.
• Comply with applicable legal and regulatory obligations.

5. Legal basis for processing (Article 7 of Brazil's LGPD)

Processing of your data is based on your free, informed and unambiguous consent, provided when you join the waitlist (Article 7, item I, of the LGPD).

You may revoke this consent at any time, as described in the "Your rights" section.

6. Who we share your data with

We do not sell, rent or commercialize your personal data. We share data only with operators strictly necessary for the service to function:

These operators process your data only according to our instructions and are subject to contractual confidentiality and security obligations. This list may be updated as the service evolves; always consult the current version of this policy.

• Cloudflare, Inc. — landing page hosting, CDN and abuse protection.
• Railway Corp. — database infrastructure where registrations are stored.
• Resend — delivery of the emails you receive from us (password resets, account notices and communications).

7. International data transfers

Cloudflare, Railway and Resend operate servers in the United States. By registering, you acknowledge that your data may be processed outside Brazil. We adopt appropriate contractual safeguards with these operators, as required by Article 33 of the LGPD.

8. How long we retain your data

We retain your data for as long as you remain on the waitlist or have an interest in receiving communications from us. If you request deletion, we remove your data within 15 days, except where legal retention obligations apply (e.g. maintaining the minimum record of your consent, as required by Article 16 of the LGPD).

If the Lybel project is discontinued, we will notify registered users and delete the database within 90 days, except for minimum records required by law.

9. Your rights as a data subject (Article 18 of Brazil's LGPD)

At any time, you may request:

To exercise any of these rights, write to privacidade@lybel.com.br. We respond within 15 days.

• Confirmation of whether your data is being processed.
• Access to your data.
• Correction of incomplete, inaccurate or outdated data.
• Anonymization, blocking or deletion of unnecessary, excessive or non-compliant data.
• Portability of your data to another service provider, upon express request.
• Deletion of data processed on the basis of your consent.
• Information about public and private entities with which we share your data.
• Information about the possibility of withholding consent and the consequences of doing so.
• Revocation of consent.

10. How we protect your data

We adopt reasonable technical and administrative measures to protect your data: encrypted traffic in transit (HTTPS/TLS), database in a protected environment, access limited to the project operator and the operators listed in section 6.

No system is 100% secure. In the event of a security incident that may pose risk or relevant harm to data subjects, we will notify you and Brazil's National Data Protection Authority (ANPD) within the timeframes required by the LGPD.

11. Cookies and similar technologies

This page does not use tracking cookies, third-party pixels or analytics tools. The only data that may be stored in your browser are strictly necessary cookies for the website to function.

If we adopt analytics or marketing tools in the future, we will update this policy and, where applicable, request your consent via a dedicated banner before activation.

In the emails we send, we record whether the message was delivered, whether it was opened, and whether the receiving server rejected it. We use these records for two purposes: to know whether our communications are arriving, and to stop writing to addresses that reject our messages — which protects delivery of essential emails such as password resets. Open measurement relies on an invisible image in the message and is imprecise by nature: some providers load images automatically, recording opens that never happened. You can prevent this by setting your email program not to load images automatically.

12. Children and minors

Lybel is not intended for persons under 18 years of age and does not intentionally collect data from children or minors. If you identify a registration in that condition, contact us so we can remove it.

13. Complaints to the ANPD

If you believe your rights have not been adequately respected, you may file a complaint with Brazil's National Data Protection Authority (ANPD) at gov.br/anpd.

14. Changes to this policy

This policy may be updated as the project evolves. For material changes, we will notify registered users by email, where applicable. The date of the last update is at the top of the document.

15. Contact

Questions, requests or complaints: privacidade@lybel.com.br.