AVODAH DYNAMICS LGPD PRIVACY POLICY

Effective Date: October 26, 2025
Last Updated: October 26, 2025

1. INTRODUCTION

At Avodah Dynamics, we believe that your personal data deserves the same respect and protection we give to our mission of helping you walk boldly into your calling. This Privacy Policy explains how we collect, use, and protect your personal data in compliance with Brazil's Lei Geral de Proteção de Dados (LGPD - Law No. 13,709/2018).

2. DATA CONTROLLER AND CONTACT INFORMATION

Data Controller:
Avodah Dynamics
Website: https://avodahdynamics.com
Email: privacy@avodahdynamics.com

Data Protection Officer (DPO):
Email: dpo@avodahdynamics.com

3. LEGAL BASIS FOR PROCESSING

We process your personal data based on the following legal grounds under LGPD:

• Consent: When you explicitly agree to our processing activities
• Contract Performance: To fulfill our coaching, consulting, and product services
• Legitimate Interest: For improving our services and community engagement
• Legal Obligation: To comply with applicable laws and regulations
• Vital Interest Protection: When necessary to protect your essential interests

4. PERSONAL DATA WE COLLECT

4.1 Information You Provide Directly

• Identity Data: Name, age, profession, contact information
• Registration Data: Account credentials, profile information
• Payment Data: Billing information, transaction records (processed through secure third-party providers)
• Communication Data: Emails, coaching session notes, community interactions
• Faith and Purpose Data: Spiritual preferences, goals, values alignment information

4.2 Information Collected Automatically

• Usage Data: Website interactions, service usage patterns
• Technical Data: IP address, browser type, device information
• Location Data: General geographic location (when applicable)
• Marketing Data: Email engagement, content preferences

5. PURPOSE OF DATA PROCESSING

We use your personal data to:

• Service Delivery: Provide coaching, consulting, and educational services
• Community Building: Connect you with like-minded individuals in our faith-based community
• Product Fulfillment: Process orders for apparel and digital products
• Communication: Send program updates, inspirational content, and service notifications
• Improvement: Enhance our services and develop new offerings
• Legal Compliance: Meet regulatory and contractual obligations
• Marketing: Share relevant content and opportunities (with your consent)

6. DATA SHARING AND TRANSFERS

6.1 Authorized Sharing

We may share your data with:

• Service Providers: Payment processors, email platforms, hosting services
• Partners: Authorized coaches and consultants within our network
• Legal Authorities: When required by law or to protect legal rights

6.2 International Transfers

Some service providers may be located outside Brazil. We ensure adequate protection through:

• Adequacy decisions by Brazilian authorities
• Standard contractual clauses
• Binding corporate rules
• Explicit consent when required

7. DATA RETENTION

We retain your personal data for:

• Active Accounts: Duration of service relationship plus 5 years
• Marketing Data: Until you withdraw consent or request deletion
• Financial Records: 5 years for tax and accounting purposes
• Legal Requirements: As mandated by applicable laws

8. YOUR RIGHTS UNDER LGPD

You have the right to:

• Access: Request information about your data processing
• Correction: Update or correct inaccurate information
• Deletion: Request removal of your data (subject to legal obligations)
• Portability: Receive your data in a structured, machine-readable format
• Consent Withdrawal: Revoke previously given consent
• Objection: Object to processing based on legitimate interest
• Restriction: Request limitation of processing activities
• Information: Understand who we share your data with
• Anonymization: Request anonymization when legally possible

To exercise these rights, contact us at privacy@avodahdynamics.com.

9. DATA SECURITY

We implement comprehensive security measures including:

• Technical Safeguards: Encryption, secure servers, access controls
• Administrative Controls: Staff training, data handling procedures
• Physical Security: Secure facilities and equipment protection
• Regular Audits: Ongoing assessment of security practices

10. COOKIES AND TRACKING

Our website uses cookies and similar technologies to:

• Ensure proper website functionality
• Analyze website performance
• Provide personalized content
• Support marketing efforts

You can manage cookie preferences through your browser settings. Essential cookies cannot be disabled without affecting website functionality.

11. CHILDREN'S PRIVACY

Our services are designed for adults aged 18 and older. We do not knowingly collect personal data from children under 18. If we become aware of such collection, we will promptly delete the information and notify appropriate authorities as required.

12. AUTOMATED DECISION MAKING

We may use automated processing for:

• Content personalization
• Service recommendations
• Marketing communications

You have the right to request human review of automated decisions that significantly affect you.

13. DATA BREACH NOTIFICATION

In case of data breaches that may pose risks to your rights and freedoms, we will:

• Notify the Brazilian National Data Protection Authority (ANPD) within 72 hours
• Inform affected individuals when high risk is involved
• Implement immediate containment and remediation measures

14. THIRD-PARTY LINKS

Our website may contain links to external sites. This Privacy Policy applies only to Avodah Dynamics. We encourage you to review the privacy policies of any third-party sites you visit.

15. POLICY UPDATES

We may update this Privacy Policy to reflect:

• Changes in our services
• New legal requirements
• Enhanced security measures
• Improved data practices

Significant changes will be communicated through email or website notifications.

16. COMPLAINTS AND REGULATORY AUTHORITY

If you have concerns about our data processing practices, you may:

• Contact our DPO at dpo@avodahdynamics.com
• File a complaint with the Brazilian National Data Protection Authority (ANPD)
• Seek judicial remedies through Brazilian courts

ANPD Contact Information:
Website: https://www.gov.br/anpd/pt-br
Email: comunicacao@anpd.gov.br

17. CONTACT US

For questions, requests, or concerns regarding this Privacy Policy or our data practices:

Email: privacy@avodahdynamics.com
Website: https://avodahdynamics.com
DPO: dpo@avodahdynamics.com

At Avodah Dynamics, we're committed to protecting your privacy while helping you discover your purpose. Your trust enables us to build a community where faith, ambition, and integrity align perfectly.