Privacy Notice

The Privacy Policy of W2M COMERCIO E PUBLICIDADE DIGITAL LTDA (“SPARTANAS”), registered with the CNPJ/MF under no. 21.586.178/0001-36, is a formal statement of our commitment to the General Data Protection Law (Law no. 13.709/2018 – “LGPD”) and has been prepared in accordance with applicable legislation.

We at SPARTANAS are constantly committed to safeguarding the security of the Personal Data we process. To achieve this goal, we act with commitment, ethics, assertiveness, transparency and respect, seeking to maintain and strengthen a relationship of trust.

We have written this document to explain how your personal data is handled within our website https://porno.spartanas.com, but if you still have any questions, you can contact us at [email protected] and we will be happy to answer your questions.

PLEASE NOTE THAT OUR WEBSITE IS INTENDED EXCLUSIVELY FOR PEOPLE OVER 18 (EIGHTEEN) YEARS OF AGE. IF YOU ARE UNDER 18 (EIGHTEEN) YEARS OF AGE, WE ADVISE YOU NOT TO CONTINUE ACCESSING OUR WEBSITE.

It is very important that you read everything carefully.

By accessing the website, you accept this Privacy Notice and acceptance by the User generates a contractual relationship with SPARTANAS. You acknowledge that you are and will always be free to use the services or not.

The Privacy Notice was originally written in Brazilian Portuguese (PT-BR). If this Privacy Notice is offered in any language other than PT-BR it shall be for information purposes only and, in the event of a conflict between the PT-BR language version and the translated language version, the PT-BR version shall prevail.

First of all, we will show you the definitions of some of the terms that will appear throughout this document.

• PERSONAL DATA: information relating to a natural person that makes them directly identified or identifiable;
• SENSITIVE PERSONAL DATA: personal data concerning racial or ethnic origin, religious conviction, political opinion, membership of a trade union or religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data, when linked to a natural person;
• DATA SUBJECT: the natural person to whom the personal data being processed refer;
• PROCESSING: any operation carried out with personal data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction;
• ANONYMIZATION: use of reasonable technical means available at the time of processing, by means of which a piece of data loses the possibility of association, directly or indirectly, with an individual;

CONSENT: a free, informed and unequivocal statement by which the data subject agrees to the processing of their personal data for a specific purpose.

In accordance with Data Protection Laws, we collect only the Personal Data that is necessary and relevant for conducting our activities and we only use this data for the purposes for which it was collected.

3.1 – Data Provided by the User:

• Platform Registration Data: email address;

• Data required by the payment processing company to make a purchase on the platform: full name, CPF, full address, date of birth, e-mail, telephone, debit or credit card details, boleto or pix key – other than Safe2Pay, in our case, the data is are passed on to acquiring companies such as banks, card operators and other financial institutions responsible for processing your payment;

• Public comments (optional) in the section for each movie: free text written and published by the user;
• Anonymized votes (optional) to understand what the user wants to see on the platform: selections in voting format.

3.2 – Data Collected by the Platform:

• Location Data: Approximate access location data is collected via IP address in order to improve your user experience. The billing address is collected if you make a purchase on the website.
• Transaction Data: Data is collected for the transaction: CPF, full name, full address, date of birth, e-mail address, telephone number. Credit or debit card, boleto or pix and individual financial transaction data are only collected by the payment company Safe2Pay and are not stored with Spartanas. Payment transactions are processed by Safe2Pay and Spartanas a has no responsibility for the transaction with the card acquirers and/or issuing bank.
• Electronic Device Data: When using the site porno.spartanas.com.br, minimum data will be collected, in accordance with Brazilian law, such as IP address, date and time of access. This information will be collected for the purpose of complying with Law no. 12.965/2014, known as the Brazilian Civil Rights Framework for the Internet.
• Contact details: If you would like to talk to us or find out about our services, you can send us a message in the “Contact” field on our website. We will collect your name, e-mail address and telephone number. You can also send us an e-mail at [email protected] or a WhatsApp message at +55 (11) 94050-8967. In the message, simply let us know what you need from us and how we can help you.
• Google Analytics: Our Platform uses Google Analytics to collect and process Data, in accordance with Google’s policies. Google is solely and exclusively responsible for the use of the data made by it or its partners, and SPARTANAS has no liability arising from such use.
• Cookies: When you access porno.spartanas.com, cookies are used. Cookies are pieces of information stored directly on the computer and/or device you are using, allowing us to collect information such as browser type, time spent on our site, pages visited, language preferences and other anonymous traffic data.

We collect the following cookies:

• Essential cookies: necessary for the platform to function correctly and perfectly provide the services that are available to our Users. Otherwise the platform will not function properly and the website will not be able to efficiently provide all the tools or resources associated with it.
• Performance cookies: responsible for collecting anonymous information on how Users use and interact with the platform and the tools provided.
• Functionality cookies: associated with the memory of the data provided, these cookies allow the platform to remember any choices made by Users, directing you to the functions you may choose. It is responsible for providing better experiences and ensuring convenience for Users. This information may also be associated with anonymized data, which will not track User activity outside the platform space.
• Analytical cookies: we use these cookies to monitor and analyse how our Users use the platform’s tools and functionalities, allowing us to check for any flaws in the site and provide convenience and customization for Users. In addition, based on these cookies, we can highlight the main services that we think are of most interest to our Users.
• Security cookies: to prevent our Users’ data from being vulnerable to malicious attacks by third parties, these cookies store information in encrypted form.

To disable cookies directly in your browser, simply click on the corresponding link and follow the step-by-step instructions – if your browser is not included in this list, you will need to look for a reliable tutorial on the internet:

• INTERNET EXPLORER: https://support.microsoft.com/pt-br/topic/descri%C3%A7%C3%A3o-de-cookies-ad01aa7e-66c9-8ab2-7898-6652c100999d#:~:text=Clique%20no%20bot%C3%A3o%20Ferramentas%20e,cookies%20e%20clique%20em%20OK.
• FIREFOX: https://support.mozilla.org/pt-BR/kb/impeca-que-sites-armazenem-cookies-e-dados-no-fire
• CHROME: https://support.google.com/accounts/answer/61416?hl=pt-BR&co=GENIE.Platform%3DAndroid
• SAFARI and IOS: https://www.apple.com/br/legal/privacy/br/cookies/#:~:text=Mas%20se%20voc%C3%AA%20quiser%20desabilitar,para%20saber%20como%20bloque%C3%A1%2Dlos.

SPARTANAS processes Personal Data in accordance with the provisions of the law. In general, we process the Personal Data mentioned above to conduct our activities, using it to:

• Allow you to make purchases of our streaming plans on our website;

• Allow you to use and access our website;

• Promote our products and notify you of new features, services and promotions;

• To perform our obligations or exercise our rights under our contract with you;

• To comply with legal or regulatory obligations to which we are subject;

• Evaluate the effectiveness of the advertising we provide;

• Ensure the security of our environments, manage risks and detect, prevent and/or remedy fraud or other potentially illegal or prohibited activities, as well as violations of applicable policies, contracts or terms of use;
• Regularly exercise our rights in judicial, administrative or arbitration proceedings.

SPARTANAS only shares the Personal Data of its Users with third parties when it is necessary for the purposes provided for in our contracts, in the legislation and regulations pertinent to the activities carried out by SPARTANAS.

In addition, SPARTANAS only shares data with companies that demonstrate the same degree of zeal and commitment to data protection, so we will not share your data with third parties, except in the following cases.

Hypotheses of data sharing:

• Sharing with the consent of the data subject: your data will be shared whenever you expressly request and/or authorize us to do so;

• Sharing with public bodies and public entities: we may share your data with public bodies and public entities in order to comply with any legal and/or regulatory obligations that may be imposed on the services we provide, as well as to comply with any judicial and administrative orders that may be imposed;

• Sharing with law enforcement authorities: we may share your personal data and other information that we deem necessary if, at the discretion of SPARTANAS, there is suspicion of the commission of any act considered a crime or misdemeanor, under the terms of the legislation. In this case, the existence of a legal and/or regulatory obligation, as well as a court order, will be expressly waived;
• Sharing with service providers and business partners: we may share your personal data with service providers and business partners, such as companies that provide hosting and data storage services, information security services, fraud management services, IT services and means of payment, i.e. our strategic partners that support our activities. The data shared with each partner is only that which is necessary for their respective activities.

Please be advised that any external links on our site, as they are not our property, we have no control over the content and practices of these sites and cannot be held responsible for their respective Privacy Policies. It is the User’s choice to click on external links and provide personal data to these third parties.

International transfer of Personal Data: SPARTANAS transfers Personal Data to entities located outside Brazil, always for the purposes described in this Policy, for storage on physical or cloud servers in other countries.

Some of these countries may not have the degree of Data protection equivalent to Brazil and, if we need to transfer your Personal Data outside Brazil, we will take steps to ensure that your information is protected and safeguarded as soon as it leaves Brazil. In particular, we will use, where available, the standard contractual clauses approved by the National Data Protection Authority and permitted under articles 33, item II, letter “b”, and 35 of the LGPD.

We use the most modern information security systems in all our systems and devices, which includes the use of technological tools such as access controls, firewalls, account creation and access logs, among others.

Internally, your data is only accessed by professionals duly authorized by SPARTANAS, who are committed to confidentiality, having signed a Confidentiality Agreement.

It is important to remember that we only apply these layers of security from the moment your information is received by SPARTANAS and for as long as it is kept with us. Therefore, we cannot guarantee the security of the electronic device or networks you are using to access our website.

Although we use our best efforts to protect the Personal Data we have access to, we know that incidents can happen, precisely because no security system is infallible. Therefore, should any of your Personal Data be exposed in any way, we will take the necessary actions to mitigate risks and will notify you of the incident, as well as the relevant authorities.

As the owner of your own personal data, you have a number of rights that can be exercised at any time and upon direct request to SPARTANAS. Below we will explain each of these rights, demonstrating our commitment to transparency:

• Confirmation of the existence of Processing;

• Access to Personal Data;

• Correction of incomplete, inaccurate or outdated Personal Data;

• Anonymization, blocking or deletion of Personal Data that is unnecessary, excessive or processed in breach of the LGPD;

• Portability of Personal Data to another service or product provider, respecting the commercial and industrial secrets of SPARTANAS;

• Deletion of Personal Data processed with consent, where applicable;

• Information on entities with which SPARTANAS has shared your Personal Data;

• Information on the possibility of not providing consent and the consequences of such refusal;

• Revocation of any consent provided; and
• Opposition to Processing carried out on the basis of one of the hypotheses for waiving consent, in the event of non-compliance with the LGPD.

If SPARTANAS is the Controller of your Personal Data, you can exercise your rights by simply sending an e-mail to: [email protected].

Upon receiving a request from the Data Subject, we may ask for proof of identity, in order to ensure that Personal Data is only shared with the true Data Subject, avoiding improper sharing and fraud.

Finally, we remind you that these rights are not absolute, but SPARTANAS is committed to complying with your requests regarding the rights provided for in the LGPD whenever possible.

We will keep your information with us for as long as you maintain your account on our site. If you choose to close your account, you can request the deletion of your personal data directly through our communication channels, remembering that deleting the account is not enough to cancel the subscription to any contracted service.

We would also like to remind you that, even if you request that your data be deleted, we may keep some of your information with us for a period of 2 (two) years, in accordance with current legislation. In this case, we will inform you. In addition, we may keep your data with us in an anonymized form and for the exclusive use of SPARTANAS.

It is very important that Data Subjects protect themselves against unauthorized access to their devices, account or any password when they are in our environments.

Furthermore, please be aware that we will never send requests for data or attachments that can be executed or downloaded (extensions: .exe, .com, among others) by e-mail.

Our e-mails are always sent with domains ending in “@spartanas.com.br”.  Remember: you are responsible for the accuracy, veracity and updating of the data you provide us with. It is your responsibility to keep them secure and up to date.

This Policy shall be governed by and construed in accordance with the laws of the Federative Republic of Brazil, principally the General Personal Data Protection Act (LGPD).

If you have any further questions about this Policy, please contact us at [email protected].

We will publish the updated version on our Website whenever we make any kind of update and/or change to these Privacy Policies and, if your consent is required, we will request it immediately via your e-mail address registered with us.

 

History of updates to this Policy
Date	Version	Responsible
January/2023	1st	Board of Directors
Mar/2025	2nd and Current	Board of Directors