This website is operated by TIHEE LTD, BC Number: TIHEE LTD 2178872, company address: Level 1, Palm Grove House, Wickham’s Cay 1, Road Town, Tortola, British Virgin Islands.
This website is published and operated by TIHEE LTD, Company No. 2178872, with its registered office at Level 1, Palm Grove House, Wickham’s Cay 1, Tortola, British Virgin Islands (“TIHEE”). Ad monetization services are provided by TiMo Midia Ltda (CNPJ No. 62.179.475/0001-44).
Transparency is a fundamental pillar of our operations. This document describes how we collect, use, and protect your personal data.
Regulatory laws and references considered (as applicable): LGPD and the Brazilian Civil Rights Framework for the Internet (Brazil), Law 25,326 (Argentina), Law 1581 (Colombia), LFPDPPP (Mexico), CCPA/CPRA and other state laws (USA), PIPEDA (Canada), and APPI (Japan), among others.
1. DATA CONTROLLER IDENTIFICATION AND CONTACT
This website is a digital property managed, operated, and optimized by:
TIHEE LTD, Company No. 2178872
Registered office: Level 1, Palm Grove House, Wickham’s Cay 1, Tortola, British Virgin Islands (“TIHEE”).
Privacy Officer/DPO (Privacy Channel), operated on behalf of TIHEE LTD
Email: [email protected]
2. WHO THIS POLICY APPLIES TO (SCOPE)
This Policy applies to the processing of personal data:
a) within the context of this domain (website) and the technologies used on it; and
b) where applicable, within the advertising inventory of this website monetized on behalf of TIHEE.
It covers activities such as security, measurement, fraud and invalid traffic prevention, performance improvement, advertising delivery and verification (including programmatic advertising), and user support.
This Policy may be supplemented by specific notices (e.g., cookie banner/preference center). In case of conflict, the specific notice of the website/environment you are visiting shall prevail.
3. IMPORTANT DEFINITIONS
- Personal data: information that identifies or can identify a person directly or indirectly.
- Sensitive personal data: data about racial/ethnic origin, health, biometrics, political opinion, etc. (when applicable).
- Processing: any operation involving data (collection, use, storage, sharing, etc.).
- Cookies/similar technologies: cookies, pixels, web beacons, SDKs, tags, and identifiers used for operation, measurement, security, and advertising.
- Programmatic advertising: automated buying and selling of advertising inventory using technology for delivery, measurement, and control (e.g., fraud prevention, frequency capping, reporting).
4. ROLES AND RESPONSIBILITIES (CONTROLLER/PROCESSOR/INDEPENDENT CONTROLLERS)
4.1. Role of TIHEE LTD
TIHEE acts as the controller especially for purposes related to:
- website operation and maintenance;
- security and stability;
- fraud and invalid traffic prevention;
- measurement and aggregated reporting; and
- advertising monetization (when applicable).
TiMo Midia Ltda (CNPJ No. 62.179.475/0001-44) acts as a service provider for advertising monetization, processing data on behalf of TIHEE for the delivery, measurement and protection of ads on this Website.
4.2. Partners and Suppliers
Certain suppliers and technology partners (including advertising and measurement providers) may act:
- as PROCESSORS (processing data on behalf of TIHEE); and/or
- as INDEPENDENT CONTROLLERS (processing data for their own purposes according to their policies).
Relevant example: Google and advertising/measurement services may process data under their own rules. For transparency about the Google ecosystem on partner sites, see:
https://policies.google.com/technologies/partner-sites
5. WHAT DATA WE COLLECT
5.1 Automatic collection (logs and technical data)
For website operation, security, measurement, and advertising, we automatically collect information such as:
- IP address;
- online and/or cookie identifiers (where applicable and according to your choice);
- browser type and version;
- internet service provider (ISP);
- date and time of access;
- referring and exit pages;
- clicks, events, and navigation information (e.g., ad impressions, interactions, load events);
- technical device information (e.g., operating system, language, resolution, user agent);
- security and integrity indicators (e.g., signals associated with fraud, bots, invalid traffic).
These data are used for system administration, security, fraud prevention, and analytics/reporting (including aggregated). Whenever possible, we seek to use aggregated data and/or minimize identification.
5.2 Data provided by you
When you contact us, we may collect:
- name, email, phone (if provided);
- message content and attachments sent;
- data necessary to validate your request (e.g., identity verification when required).
5.3 Sensitive data and minors
Our services are not directed to individuals under 18 years old and we do not intentionally collect minors’ personal data. If inadvertent collection is identified, we will take reasonable measures to delete it.
We do not request sensitive data as a rule. If exceptionally sent by you (e.g., in contact), it is processed only for service purposes and with applicable safeguards.
6. PURPOSES OF DATA USE
We use personal and navigation data to:
a) operate, maintain, and improve website functionality;
b) ensure security, stability, and technical integrity;
c) detect, mitigate, and prevent fraud, bots, and invalid traffic;
d) measure audience and performance (including aggregated statistics);
e) deliver, measure, and optimize advertising (including programmatic);
f) limit ad frequency and improve relevance (when applicable and permitted);
g) handle requests, support, and communications;
h) comply with legal/regulatory obligations and protect rights.
7. LEGAL BASES
Processing may occur based on one or more legal grounds, as applicable:
- Consent (e.g., advertising/personalization cookies when required);
- Legal or regulatory obligation;
- Contract execution/preliminary procedures (e.g., requested service);
- Exercise of legal rights;
- Legitimate interest (e.g., security, fraud prevention, service improvement, measurement), with balancing assessment and transparency measures.
In some jurisdictions, advertising and/or cookie use requires prior express authorization. In such cases, appropriate consent/opt-out mechanisms will be used.
8. COOKIES AND SIMILAR TECHNOLOGIES
We use cookies, pixels, tags, and similar technologies for website operation, measurement, security, and advertising.
8.1 Cookie categories
Necessary Cookies – essential for operation, security, and abuse prevention.
Performance/Measurement Cookies – help understand usage and improve performance (preferably aggregated).
Advertising/Marketing Cookies – used to deliver, measure, and optimize ads, including personalization when permitted.
8.2 Managing preferences
- Cookie Banner/Preference Center: accept, refuse, or adjust categories when available.
- Browser/Device: block or delete cookies via browser settings.
Disabling cookies may affect functionality and degrade experience.
9. PROGRAMMATIC ADVERTISING, GOOGLE (AD MANAGER/ADX) AND CONSENT MODE
9.1 Platforms
TIHEE LTD monetizes this Website through TiMo Midia Ltda, which manages programmatic advertising using Google Ad Manager and Google Ad Exchange (AdX) under the Multiple Customer Management (MCM) program.
9.2 Google Consent Mode (v2) signals
- ad_storage
- analytics_storage
- ad_user_data
- ad_personalization
9.3 Operation without consent
If consent is denied, tags may operate with restrictions and send limited signals (“cookieless pings”). Providers may use aggregated data and statistical modeling rather than full identifiers for personalized advertising.
9.4 Google partner transparency
9.5 Third-party technologies
Other partners may use cookies/IDs for campaign measurement, ad verification, security, reporting, frequency control, and (where applicable) personalization. TIHEE does not directly control third-party technologies.
10. DATA SHARING
We may share data, as necessary and according to your choices, with:
- hosting, infrastructure, security, and support providers;
- analytics and measurement tools;
- advertising technology partners (AdTech);
- fraud prevention services;
- consultants and auditors (with safeguards);
- public authorities when legally required.
In some jurisdictions (e.g., California), sharing identifiers for behavioral advertising may be interpreted as “sale” or “sharing.” Opt-out mechanisms are provided when applicable.
11. INTERNATIONAL DATA TRANSFERS
Due to global operations and technology partners, data may be processed outside the user’s country.
Safeguards may include adequacy decisions and contractual clauses recognized by applicable regulations.
12. RETENTION AND DELETION
Data are retained for the time necessary to:
- fulfill policy purposes;
- comply with legal obligations;
- allow audits and security analysis;
- prevent fraud and protect rights.
Afterward, data are deleted or anonymized where technically possible.
13. DATA SUBJECT RIGHTS
You may exercise your rights free of charge via: [email protected]
We may request additional information for identity verification.
Rights may include: confirmation, access, correction, anonymization/deletion, portability, objection, consent withdrawal, information on sharing, and automated decision review (where applicable).
(Response deadlines vary by jurisdiction as described in the original policy context.)
14. USA – OPT-OUT RIGHTS
Where applicable (e.g., California residents), you may opt-out of sale/sharing for behavioral advertising and request access, correction, or deletion via cookie preferences or email.
15. DIGITAL ACCESSIBILITY (BRAZIL)
We aim to follow accessibility best practices and, where applicable, ABNT NBR 17225:2025 and WCAG 2.2 AA guidelines.
16. INFORMATION SECURITY
We adopt reasonable technical and organizational measures aligned with recognized standards (e.g., ISO/IEC 27001 and 27701).
If relevant incidents occur, we will take containment and notification measures as required by law.
17. POLICY UPDATES
This Policy may be updated at any time to reflect operational, regulatory, or technological changes. The “Last Updated” date indicates the current version.
18. CONTACT
To exercise rights or send requests:
Email: [email protected]
Address: TIHEE LTD, Level 1, Palm Grove House, Wickham’s Cay 1, Tortola, British Virgin Islands.