Privacy Policy

Mps Promotora LTDA ("Company," "we," "us," or "our") operates the website promomps.com and provides the Neuro Elite nootropic supplement and related services. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website, subscribe to our SMS messaging program, make a purchase, or otherwise interact with our services.

By accessing or using our website and services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please discontinue use of our website and services immediately.

1. SMS Messaging & TCPA Compliance

When you provide your phone number and opt in to receive text messages from us, you expressly consent to receive recurring automated marketing and informational text messages from Mps Promotora LTDA, including messages sent using an automatic telephone dialing system or prerecorded/artificial voice technology, at the mobile number you provided. You understand and agree that your consent is not a condition of any purchase.

1.1 Message Frequency

You may receive up to 4 messages per week. Message frequency may vary depending on your interaction with our services, ongoing promotions, order status updates, and other informational or marketing communications. We will not exceed the stated maximum frequency without obtaining additional consent from you.

1.2 Message and Data Rates

Standard message and data rates may apply to any messages sent to or received from us as determined by your wireless carrier. Please contact your wireless carrier for details regarding your specific text messaging plan and any charges that may apply. You are solely responsible for any charges related to text messages you send or receive.

1.3 Opting Out of SMS

You may opt out of receiving SMS messages at any time by replying STOP to any text message you receive from us. After sending STOP, you will receive a single confirmation message verifying that you have been unsubscribed. After that, you will no longer receive text messages from us unless you re-subscribe. You may also opt out by visiting our Opt-Out page or by contacting us directly at support@promomps.com.

1.4 Getting Help

For assistance at any time, reply HELP to any text message from us. You may also contact us at support@promomps.com for further information about our messaging program.

1.5 Carrier Compatibility

Our SMS program may not be available on all wireless carriers. Carriers are not liable for delayed or undelivered messages. We do not guarantee message delivery. Service availability may depend on your carrier's coverage area and technical capabilities.

1.6 SMS Data Collection

When you opt in to our SMS program, we collect your mobile phone number and consent status. We may also collect your first and last name if provided. We use this information solely for the purpose of sending you the messages you have consented to receive. We do not sell, rent, loan, trade, lease, or otherwise transfer for profit any phone numbers or personal information collected through our SMS program to any third party.

1.7 Third-Party SMS Service Providers

We use third-party SMS service providers to deliver messages on our behalf. These providers may have access to your phone number for the sole purpose of delivering our messages. They are contractually obligated to handle your data in accordance with applicable privacy laws and our instructions. They are prohibited from using your information for any purpose other than delivering our messages.

1.8 TCPA Rights

Under the Telephone Consumer Protection Act (TCPA), you have the right to:

• Provide or revoke consent to receive automated text messages at any time
• Not be charged for opting out of our messaging program
• Receive clear and conspicuous disclosure about our messaging program before providing consent
• Know that your consent is not a condition of purchasing any goods or services
• File a complaint with the Federal Communications Commission (FCC) if you believe your rights have been violated
• Pursue legal action for violations of the TCPA, including statutory damages

2. Information We Collect

2.1 Personal Information You Provide

We collect personal information that you voluntarily provide to us when you make a purchase, create an account, subscribe to our SMS program, fill out a contact form, participate in a promotion, or otherwise communicate with us. This information may include:

• Identity information: First name, last name, date of birth
• Contact information: Email address, phone number, mailing address, billing address, shipping address
• Account information: Username, password, account preferences
• Payment information: Credit card number, debit card number, billing address (processed securely through our payment processor)
• Communication information: Content of messages, emails, or other communications you send to us
• SMS consent information: Mobile phone number, opt-in timestamp, consent status, opt-in method
• Survey and feedback data: Responses to surveys, product reviews, testimonials

2.2 Information Collected Automatically

When you visit our website, we automatically collect certain information about your device and browsing activity. This information may include:

• Device information: Device type, operating system, unique device identifiers, browser type and version, screen resolution, device language settings
• Usage information: Pages visited, time spent on pages, links clicked, referring and exit pages, search queries used to find our site
• Network information: IP address, internet service provider, approximate geographic location derived from IP address
• Timing information: Date and time of visits, time zone settings, session duration
• Performance information: Page load times, error logs, interaction patterns

2.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Payment processors: Transaction confirmation, partial payment details for fraud prevention
• Shipping providers: Delivery status, delivery confirmation information
• Analytics providers: Aggregated website usage data, demographic insights
• Advertising partners: Ad click data, conversion data, interest-based audience information
• Public databases: Publicly available information for verification purposes

2.4 Tracking Technologies

We and our third-party partners use cookies, web beacons, pixels, and similar tracking technologies to collect information about your interactions with our website. For more details on how we use cookies and similar technologies, please see Section 9 of this Privacy Policy.

3. How We Use Your Information

We use the personal information we collect for various purposes, including but not limited to:

3.1 Order Processing and Fulfillment

• Process and fulfill your orders for Neuro Elite
• Send order confirmation and shipping notifications
• Process returns, refunds, and exchanges under our 180-Day Money-Back Guarantee
• Manage and update your account information
• Process payments through our secure payment processors
• Verify your identity and prevent fraud

3.2 Communications

• Send you SMS messages (with your express consent) regarding promotions, product updates, and informational content
• Respond to your inquiries, comments, feedback, and support requests
• Send you transactional emails regarding your orders, account, and billing
• Notify you about changes to our services, policies, or terms
• Send you marketing communications (where permitted by law and with your consent where required)

3.3 Service Improvement

• Analyze website usage patterns to improve our website design and functionality
• Conduct research and analysis to better understand our customers and improve our products
• Develop new products, services, features, and functionality
• Monitor and analyze trends, usage, and activities on our website
• Test and evaluate new features or product offerings

3.4 Security and Legal

• Detect, investigate, and prevent fraudulent transactions and other illegal activities
• Protect the rights, property, or safety of our company, our users, or the public
• Comply with applicable legal requirements, industry standards, and our policies
• Enforce our Terms and Conditions and other agreements
• Respond to lawful requests from public authorities, including law enforcement

3.5 Personalization

• Personalize your website experience based on your browsing history and preferences
• Deliver targeted advertising and promotional content relevant to your interests
• Recommend products and services that may be of interest to you
• Customize the content and layout of our website for your device

4. How We Share Your Information

We may share your personal information with third parties in the following circumstances and for the following purposes:

4.1 Service Providers

We share your information with third-party service providers who perform services on our behalf. These service providers are contractually obligated to use your information only for the purposes of providing services to us and in accordance with this Privacy Policy. Service providers include:

• Payment processors: To securely process your payments
• Shipping and fulfillment companies: To deliver your orders
• SMS delivery platforms: To send text messages you have consented to receive
• Email service providers: To send transactional and marketing emails
• Customer support platforms: To manage and respond to your inquiries
• Analytics providers: To analyze website usage and improve our services
• Cloud hosting providers: To host our website and store data securely
• Fraud prevention services: To detect and prevent fraudulent activity

4.2 Advertising Partners

We may share certain information with advertising partners to deliver targeted advertisements, measure ad performance, and conduct retargeting campaigns. This information may include device identifiers, browsing data, and interaction data. We do not share your name, email address, phone number, or payment information with advertising partners for their own marketing purposes.

4.3 Legal Requirements

We may disclose your personal information if required to do so by law, regulation, legal process, or governmental request, including:

• To comply with a subpoena, court order, or other legal obligation
• To respond to requests from law enforcement or other government agencies
• To protect and defend the rights, property, or safety of Mps Promotora LTDA, our users, or the public
• To investigate potential violations of our Terms and Conditions
• To detect, prevent, or address fraud, security issues, or technical problems

4.4 Business Transfers

In the event that Mps Promotora LTDA is involved in a merger, acquisition, reorganization, bankruptcy, dissolution, sale of assets, or similar transaction, your personal information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

4.5 With Your Consent

We may share your information with third parties when you have given us your explicit consent to do so. We will always inform you of the purpose and scope of any such sharing before obtaining your consent.

4.6 Information We Do Not Sell

We do not sell, rent, loan, trade, lease, or otherwise transfer for profit any phone numbers or personal information collected through our SMS program to any unaffiliated third party for their own marketing purposes. We value your privacy and are committed to safeguarding your personal data.

5. Your Rights Under the CCPA (California Residents)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) regarding your personal information. This section describes those rights and how to exercise them.

5.1 Right to Know

You have the right to request that we disclose the following information about our collection and use of your personal information over the past 12 months:

• The categories of personal information we have collected about you
• The categories of sources from which we collected your personal information
• Our business or commercial purpose for collecting or selling your personal information
• The categories of third parties with whom we shared your personal information
• The specific pieces of personal information we have collected about you
• Whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information each category of recipient received

5.2 Right to Delete

You have the right to request that we delete personal information we have collected from you, subject to certain exceptions. Upon receiving and verifying your request, we will delete your personal information from our records and direct our service providers to delete your personal information from their records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete a transaction for which the personal information was collected or provide a good or service you requested
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible
• Debug to identify and repair errors that impair existing intended functionality
• Exercise free speech or ensure another consumer's right to exercise their free speech rights
• Comply with the California Electronic Communications Privacy Act
• Comply with a legal obligation or exercise rights under the law
• Make other internal and lawful uses of the information that are compatible with the context in which you provided it

5.3 Right to Opt Out of Sale or Sharing

You have the right to opt out of the sale or sharing of your personal information. While we do not sell personal information in the traditional sense, some of our advertising activities (such as sharing data with advertising partners for targeted advertising) may constitute a "sale" or "sharing" under the CCPA/CPRA. You may opt out of these activities by contacting us at support@promomps.com.

5.4 Right to Correct

You have the right to request that we correct inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the processing. Upon receiving your verified request, we will use commercially reasonable efforts to correct the inaccurate personal information.

5.5 Right to Limit Use of Sensitive Personal Information

If we collect sensitive personal information (such as Social Security numbers, financial account information, precise geolocation, racial or ethnic origin, or health information), you have the right to request that we limit the use and disclosure of that information to what is necessary to perform our services or provide our goods.

5.6 Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA/CPRA rights. We will not:

• Deny you goods or services
• Charge you different prices or rates for goods or services
• Provide you a different level or quality of goods or services
• Suggest that you will receive a different price, rate, level, or quality of goods or services

5.7 How to Submit a Request

To exercise any of the rights described above, you may submit a verifiable consumer request to us by:

• Emailing us at support@promomps.com
• Writing to us at: Mps Promotora LTDA, Rua Conselheiro Dantas, 312, Shopping Luciana, Centro - 01 BA, Serrinha, 48700-000, Brazil

We will verify your identity before processing your request. You may also designate an authorized agent to make a request on your behalf by providing the agent with written permission signed by you. We may require the authorized agent to submit proof of your authorization before processing the request.

5.8 Categories of Personal Information Collected

In the preceding 12 months, we have collected the following categories of personal information as defined by the CCPA:

6. Data Security

We implement a combination of administrative, technical, and physical security measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

6.1 Technical Safeguards

• Encryption: We use industry-standard SSL/TLS encryption (256-bit) to protect data transmitted between your browser and our servers
• Secure storage: Personal information is stored on secure servers with restricted access controls
• Payment security: Credit card information is processed by PCI DSS-compliant payment processors and is never stored on our servers
• Firewalls: We utilize firewalls and intrusion detection systems to prevent unauthorized access
• Monitoring: We continuously monitor our systems for potential vulnerabilities and attacks
• Access controls: We implement role-based access controls to limit access to personal information to authorized personnel only

6.2 Administrative Safeguards

• Regular security training for employees who handle personal information
• Strict data handling policies and procedures
• Regular security audits and vulnerability assessments
• Incident response plans for potential data breaches
• Data minimization practices to limit collection to what is necessary

6.3 Data Breach Notification

In the event of a data breach that compromises the security, confidentiality, or integrity of your personal information, we will notify you and applicable regulatory authorities as required by law. Notification will be provided without unreasonable delay, consistent with the legitimate needs of law enforcement and any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

6.4 Limitations

While we strive to use commercially acceptable means to protect your personal information, no method of transmission over the Internet or method of electronic storage is 100% secure. We cannot guarantee the absolute security of your information. You are responsible for maintaining the confidentiality of your account credentials and for any activities that occur under your account.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. The retention period may vary depending on the context of the processing and our legal obligations.

7.1 Retention Periods

• Account information: Retained for the duration of your account and for up to 3 years after account closure
• Order and transaction data: Retained for 7 years for accounting and tax compliance purposes
• SMS consent records: Retained for 5 years from the date of consent, or as required by the TCPA
• SMS opt-out records: Retained indefinitely to ensure we honor your opt-out request
• Marketing data: Retained until you opt out or for up to 3 years of inactivity
• Website usage data: Retained for up to 26 months
• Customer support records: Retained for up to 3 years after the last interaction

7.2 Deletion

When personal information is no longer needed for the purposes for which it was collected or when the retention period has expired, we will securely delete or anonymize the information. Anonymized data, which cannot be linked back to an identifiable individual, may be retained and used for analytical purposes indefinitely.

8. Children's Privacy

Our website and services, including the Neuro Elite product, are not intended for individuals under the age of 18. We do not knowingly collect, solicit, or maintain personal information from anyone under the age of 18. If you are under 18, please do not attempt to register for our services, make any purchases, or send any personal information to us.

If we become aware that we have collected personal information from a child under the age of 18 without verification of parental consent, we will take steps to delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us immediately at support@promomps.com.

We also comply with the Children's Online Privacy Protection Act (COPPA) to the extent applicable, and we do not knowingly collect personal information from children under the age of 13. Our marketing, including our SMS messaging program, is directed solely to adults who are 18 years of age or older.

9. Cookies & Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website, analyze site traffic, and personalize content and advertisements. This section explains the types of cookies we use and how you can manage your cookie preferences.

9.1 What Are Cookies?

Cookies are small text files that are placed on your device when you visit a website. They are widely used to make websites work more efficiently, provide a better user experience, and supply information to the owners of the site. Cookies can be "session" cookies (which are deleted when you close your browser) or "persistent" cookies (which remain on your device for a set period of time or until you delete them).

9.2 Types of Cookies We Use

• Essential cookies: These cookies are necessary for the website to function properly. They enable basic functions such as page navigation, access to secure areas, and shopping cart functionality. The website cannot function properly without these cookies.
• Performance cookies: These cookies collect information about how visitors use our website, such as which pages are visited most often, how long visitors spend on each page, and whether any error messages are received. This data helps us improve the performance and usability of our website.
• Functionality cookies: These cookies allow the website to remember choices you make (such as your language preference or the region you are in) and provide enhanced, personalized features. They may be set by us or by third-party providers whose services we have added to our pages.
• Advertising cookies: These cookies are used to deliver advertisements that are relevant to your interests. They are also used to limit the number of times you see an advertisement and to measure the effectiveness of advertising campaigns. They remember that you have visited a website and this information is shared with advertising partners.
• Analytics cookies: We use analytics services such as Google Analytics that use cookies to help us analyze how visitors interact with our website. This information is used to compile statistical reports on website activity.

9.3 Web Beacons and Pixels

In addition to cookies, we may use web beacons (also known as tracking pixels or clear GIFs) in our website pages and emails. Web beacons are tiny graphic images with a unique identifier that are used to count visitors to pages, monitor email open rates, and track conversions. They help us understand the effectiveness of our marketing campaigns and website content.

9.4 Managing Cookies

Most web browsers allow you to manage your cookie preferences through the browser settings. You can set your browser to refuse all cookies, accept only certain cookies, or notify you when a cookie is set. Please note that if you choose to block or delete cookies, some features of our website may not function properly.

• Browser settings: Consult your browser's help documentation for instructions on how to manage cookie settings
• Opt-out tools: You can opt out of interest-based advertising by visiting the Digital Advertising Alliance's opt-out page at www.aboutads.info/choices
• Google Analytics: You can opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on
• Do Not Track: Some browsers include a "Do Not Track" feature that signals to websites that you do not wish to be tracked. We currently respond to Do Not Track signals where technically feasible

10. International Data Transfers

Your personal information may be transferred to, and processed in, countries other than the country in which you reside. These countries may have data protection laws that differ from the laws of your country. Our primary operations are based in Brazil, and we use servers and service providers located in various countries to provide our services.

When we transfer personal information across borders, we take appropriate safeguards to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it. These safeguards may include standard contractual clauses, data processing agreements, and other legally recognized transfer mechanisms.

By using our website and services, you consent to the transfer of your information to countries outside of your country of residence, including to countries that may not provide the same level of data protection as your home country.

11. Third-Party Links

Our website may contain links to third-party websites, services, or applications that are not operated or controlled by us. This Privacy Policy does not apply to those third-party websites. We encourage you to review the privacy policies of any third-party websites or services you visit.

We are not responsible for the privacy practices, content, or security of any third-party websites. The inclusion of a link on our website does not imply endorsement of the linked website or any affiliation with its operators.

12. Changes to This Privacy Policy

We reserve the right to update, modify, or change this Privacy Policy at any time. When we make changes, we will update the "Effective Date" at the top of this page and post the revised Privacy Policy on our website. In some cases, we may provide additional notice, such as sending you an email notification or displaying a prominent notice on our website.

Your continued use of our website and services after the posting of any revised Privacy Policy constitutes your acknowledgment and acceptance of the changes. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

For material changes that significantly affect how we handle your personal information, we will provide at least 30 days' advance notice before the changes take effect. If you disagree with any changes, you may close your account and discontinue use of our services.

13. Your Choices and Rights

13.1 Marketing Communications

You can opt out of receiving promotional emails from us by following the "unsubscribe" instructions provided in each email. Even after opting out, you may still receive transactional communications from us regarding your orders, account, and other non-promotional matters.

13.2 SMS Messages

You can opt out of receiving SMS messages at any time by replying STOP to any text message you receive from us. For more information, see Section 1 of this Privacy Policy or visit our Opt-Out page.

13.3 Cookies

You can manage your cookie preferences through your browser settings. See Section 9.4 for more details.

13.4 Access and Correction

You may request access to the personal information we hold about you and request that we correct any inaccurate information. To make such a request, please contact us using the contact information provided below.

13.5 Account Deletion

You may request the deletion of your account and associated personal information by contacting us at support@promomps.com. Please note that we may retain certain information as required by law or for legitimate business purposes.

14. Do Not Track Signals

Some web browsers transmit "Do Not Track" (DNT) signals to websites. Because there is no uniform standard for how DNT signals should be interpreted, our website currently makes reasonable efforts to respond to DNT signals where technically feasible. We will continue to monitor developments in DNT technology and update our practices accordingly.

15. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy, our data practices, or your personal information, please contact us:

We will endeavor to respond to your inquiry within 180 days of receipt. If you are a California resident, we will respond to verifiable consumer requests within 45 days, as required by the CCPA, with the possibility of a 45-day extension when reasonably necessary.

If you are not satisfied with our response, you may have the right to lodge a complaint with a supervisory authority or data protection agency in your jurisdiction.