Last updated: 16 June 2026
Controller: TiMo Midia Ltda
Contact: [email protected]
This Policy was structured for international application, respecting the privacy, data protection, consumer protection, electronic communications and digital advertising rules applicable in the jurisdictions where TiMo Mídia operates or where users are located.
TiMo Mídia adopts an international data governance standard and seeks to keep its practices aligned with applicable privacy and data protection laws, observing the technical and operational characteristics of each digital environment and applicable mandatory rules.
TiMo Mídia Identification and Service Channel
The digital environments and technology solutions described in this Policy are operated, managed or monetized by:
Legal name: TiMo Midia Ltda
Trade name: TiMo Mídia
CNPJ: 62.179.475/0001-44
Address: Rua Ana de Carvalho Silveira, nº 287, Silveira, Belo Horizonte/MG, CEP 31.140-440 , Brazil
Compliance, Privacy and DPO email: [email protected]
Scope of the Policy
This Policy applies to websites, portals, pages, digital properties, advertising inventory, advertising technologies, email marketing platforms, newsletters, integrations, scripts, online environments and solutions operated, managed, optimized or monetized by TiMo Mídia that refer to this Policy.
This Policy does not apply to third-party websites, third-party ads, third-party products, external platforms, services with their own policies or environments that expressly identify another company as the primary controller, even when accessed through links or integrations displayed on properties managed by TiMo Mídia.
Local Addenda
When a Local Addendum applies to the user’s country, the country of operation of the website or the relevant jurisdiction, that Addendum supplements this Policy. In the event of conflict, the Local Addendum prevails only to the extent necessary to comply with mandatory local law.
Nature of the Operation (AdTech)
TiMo Mídia operates as an AdTech specialized in technical infrastructure, digital advertising inventory management, optimization and monetization of advertising spaces for publishers and media companies. Activities include programmatic advertising delivery, audience measurement, fraud, bot and technical-abuse prevention, and email marketing and newsletter solutions for retention of publishers’ own audiences.
Privacy Principles
We adopt technical and administrative controls compatible with the nature of the operation, guided by the following principles:
- Transparency: provide clear information about data processing purposes.
- Purpose limitation: process data only for legitimate and informed purposes.
- Minimization: collect data that is necessary and proportionate for the operation.
- Security and prevention: adopt reasonable measures to protect data and mitigate incident risks.
- Accountability: maintain measures capable of demonstrating compliance with applicable rules.
- Respect for user choices: provide viable consent and opt-out management mechanisms when applicable.
- Limited retention: retain data only for the time necessary for legitimate purposes.
Definitions
- Personal Data: information that identifies or makes a natural person identifiable, including online identifiers.
- Technical Data: records generated by devices during access, such as logs, network metadata and software characteristics.
- Aggregated or Anonymized Data: information processed to prevent reasonable association with an individual.
- Cookies: small files stored in the user’s browser to record preferences and technical parameters.
- Pixels, Tags and Web Beacons: elements used to monitor events such as ad delivery or email openings.
- Programmatic Advertising: automated purchase and sale of advertising spaces.
- Online Identifiers: technical codes such as cookie or advertising IDs associated with browsers or devices.
- Invalid Traffic (IVT): impressions, clicks or events artificially generated or produced by bots that distort real metrics.
- Email Marketing / Newsletters: distribution of communications by electronic mail.
- Controller: agent that determines the main purposes and means of processing.
- Processor: agent that processes data on behalf of and under the instructions of the Controller.
- Independent Controller: third-party agent that determines its own processing purposes when interacting with the ecosystem.
TiMo Mídia Roles in Data Processing
Depending on the technical context, TiMo Mídia may act in different roles:
- As Controller, when it determines processing purposes and means, such as campaign security, infrastructure protection or direct user support.
- As Processor, when it provides technology or processes data on behalf of publishers, clients or partners, following their instructions, such as managing a partner email list.
- As a technical monetization partner, operating infrastructure that connects publishers to demand networks.
- Alongside Independent Controllers, including Google, SSPs, DSPs, ad exchanges, ad servers, anti-fraud tools and measurement providers, which may operate under their own policies, legal bases and responsibilities.
Allocation of Responsibilities in Digital Environments of Publishers, Operators and Third Parties
When a digital environment is operated, managed, optimized, monetized, integrated or technically supported by TiMo Mídia, this Policy applies to activities related to the advertising technology layer, programmatic monetization, advertising platform integrations, ad infrastructure, Google advertising stack, management of advertising-related consent signals, advertising cookies, fraud prevention, invalid traffic (IVT) mitigation, advertising measurement, technical security, traffic quality, email marketing, newsletters and other technical solutions connected to TiMo Mídia's role, as applicable.
TiMo Mídia will not automatically be considered responsible for every aspect of the website, domain, editorial content, hosting, imprint/legal notice, proprietary forms, editorial support, local commercial management, products, services, offers, commercial promises or general operation of the digital environment when those activities remain under the control of an operator, publisher, domain holder, advertiser, commercial partner or responsible third party.
In these situations, the operator, publisher, domain holder or local party responsible for the digital environment may act as an independent controller or as the party independently responsible for the activities it directly determines, without prejudice to TiMo Mídia's role as controller, processor, technical monetization partner, independent controller or, where legally configured, joint controller in relation to specific processing activities.
The exact legal qualification of each party will depend on the processing purposes, the means effectively determined by each participant, the technical configuration of the digital environment, applicable contracts, documented instructions, relationships with third-party platforms and mandatory rules of the applicable jurisdiction.
When legally or contractually necessary, TiMo Mídia and the respective operator, publisher, client or partner may establish specific instruments to govern their roles and responsibilities, including data processing agreements, processor clauses, joint-controller arrangements, rules for responding to data-subject rights, consent management, opt-out records, information security, retention, incident response and cooperation with competent authorities.
Data That May Be Collected
Technical and Browsing Data
We may collect:
- IP address and approximate geolocation derived from IP;
- Access date and time, pages accessed, referrer and exit URLs;
- Browser, operating system, device type, language, screen resolution and User Agent;
- Cookie identifiers and advertising identifiers;
- Logs, click events, impressions, ad interactions, security signals and traffic patterns.
Cookie and Consent Data
We may collect:
- Registered preferences and consents granted, refused or revoked;
- Consent date, time and version;
- Opt-out choices and recognized privacy preference signals, when required and technically supported.
Advertising and Monetization Data
We may collect:
- Ad requests and frequency, viewability and brand-safety metrics;
- Inventory information, aggregated reports and aggregated performance and revenue data;
- Anti-fraud signals and traffic audit data.
Voluntarily Provided Data
We may collect:
- Name, email, phone number when provided, and company when provided;
- Content of messages, documents or attachments sent through support channels;
- Data needed to validate data-subject requests.
Email Marketing and Newsletter Data
We may collect:
- Email, name when provided, subscription source, date and time of subscription;
- Proof of opt-in or consent when applicable, and communication preferences;
- Sending, delivery, opening, click, rejection, bounce and spam-complaint history;
- Unsubscribe records and data kept in suppression lists.
Sensitive Data and Minors
TiMo Mídia does not seek to collect sensitive data or children’s data. Our digital environments are not directed to children. If inadvertent collection of minors’ data without an adequate legal basis is identified, we will adopt reasonable and proportionate measures for deletion, anonymization or restriction of processing, as applicable.
Purposes of Processing
Collected data is processed for the following purposes, according to the needs of each environment:
- Technical operation, stability and performance of websites;
- Security, fraud prevention, bot and abusive scraping mitigation and invalid traffic (IVT) prevention;
- Audience measurement and performance analysis;
- Advertising monetization, ad delivery, measurement, frequency and optimization;
- Contextual advertising and brand-safety maintenance;
- Personalized advertising when there is a valid legal basis;
- Consent management and reporting to publishers and partners;
- User support and defense of rights in proceedings or internal audits;
- Compliance with legal obligations;
- Sending newsletters and email communications;
- Unsubscribe management and suppression-list administration.
Legal Bases for Processing
The legal bases adopted by TiMo Mídia vary according to applicable law, purpose and company role. They may include:
- Consent, when required by local law for non-essential cookies, personalized advertising and certain marketing communications.
- Legitimate Interest, when permitted, for technical operation, security, fraud prevention, purely contextual advertising and aggregated metrics, respecting user rights.
- Performance of Contract or pre-contractual procedures, to process services requested by partners or respond to user contacts.
- Compliance with legal or regulatory obligations, including retention of logs required by applicable frameworks.
- Regular exercise of rights, for legal protection of the company.
- Fraud protection and security, to ensure operational integrity.
Cookies and Similar Technologies
The operation may use cookies, pixels, tags, local storage and session identifiers, generally organized as:
- Necessary Cookies: essential for stability, security and consent management.
- Functional Cookies: save basic user choices.
- Measurement Cookies: collect technical traffic data in aggregate form.
- Advertising Cookies: used for ad delivery, frequency capping, ecosystem protection and targeted advertising.
- Security Cookies: focused on preventing anomalous activity and fraud.
Preference Management
Users may manage preferences through the banner or Consent Management Platform (CMP), when available and required by applicable law, through the privacy center or through native browser settings.
Programmatic Advertising and Relationship with Google and Partners
TiMo Mídia works with international partners, including Google Ad Manager, Google Ad Exchange, AdSense, MCM and equivalent technologies when applicable.
These partners may process technical data, online identifiers and browsing information to select ads, measure performance, prevent fraud, limit frequency, protect advertisers, generate reports and comply with platform policies.
When Google products or services are used, TiMo Mídia may provide a notice or link to Google’s official information about data use on partner sites and apps, including: https://policies.google.com/technologies/partner-sites
Consent Mode and Technical Signal Management
When applicable and according to the configuration of each digital environment, the operation may integrate Consent Mode, governing technical signals such as ad_storage, analytics_storage, ad_user_data and ad_personalization.
If the user refuses or revokes consent, tags operate with restrictions. Depending on technical configuration and applicable law, systems may send cookieless signals, perform aggregate modeling or stop using information for personalized advertising.
Email Marketing, Newsletters and Electronic Communications
TiMo Mídia sends its own communications and also provides technology and support for partner publishers. Newsletter and commercial email sending depends on an adequate legal basis, such as consent or legitimate interest, according to the jurisdiction.
- Right to unsubscribe: when required by applicable law, every email will include a clear and functional opt-out mechanism, respected within a reasonable or legally required period.
- Tracking: when permitted, emails may contain pixels, web beacons or tracking links to measure delivery, openings, clicks, security and engagement.
- Suppression list: after unsubscribe, the address will be included in a technical suppression list for the time necessary to prevent unwanted sending, comply with obligations, prove compliance and protect the operation against improper list reimports.
- Complaints about unsolicited communications may be sent to [email protected].
Data Sharing
TiMo Mídia may share data with third-party categories needed for the operation, including hosting providers, CDNs, cybersecurity services, analytics tools, CMP and tag-management providers, programmatic advertising platforms, SSPs, DSPs, ad exchanges and ad servers, email marketing providers, anti-fraud tools, consultants, auditors, business partners when necessary, and competent public authorities under legal obligation.
International Data Transfers
Collected data may be transferred, stored or processed in other countries due to the international nature of the internet, cloud computing and programmatic advertising.
TiMo Mídia adopts safeguards for these transfers, seeking to apply contracts, standard contractual clauses when applicable, technical measures such as access control and encryption in transit, supplier assessments, adequacy decisions when available and other mechanisms recognized by applicable law.
Data Retention and Disposal
Data is retained according to necessity tied to original collection purposes, including legal obligations, consent records, defense of rights, suppression-list administration, technical logs, anti-fraud logs, aggregated reports, support data and email marketing data while a legal basis, active relationship, valid consent or legitimate retention need exists. For email marketing, an active relationship ends upon unsubscribe, consent withdrawal, absence of renewed legal basis or end of the maximum period allowed by law, after which data may remain only in suppression lists as necessary.
Specific periods follow applicable regulatory frameworks, including minimum log-retention periods when required by local law. Once no longer necessary, data is securely deleted or anonymized according to TiMo Mídia processes and reasonable measures.
Data Subject Rights
According to applicable local laws, users may request confirmation and access, correction, deletion, anonymization or blocking, portability when technically feasible, consent withdrawal, objection or restriction, review of automated decisions when applicable, information about data sharing, and complaints to competent authorities.
To exercise rights, contact [email protected]. TiMo Mídia may request information to verify identity. Responses will be provided according to applicable legal deadlines.
Opt-out, Do Not Sell or Share and Privacy Preference Signals
When applicable law recognizes the right to opt out of “sale”, “sharing”, “behavioral advertising”, “personalized advertising” or “targeted advertising”, TiMo Mídia will provide appropriate mechanisms.
This may occur through the preference center, compliance email contact or recognition of privacy preference signals such as Global Privacy Control when required by law and technically supported. After opting out of personalized advertising, users may continue to see contextual non-profiled ads.
Information Security
TiMo Mídia seeks to adopt security measures compatible with risks, including HTTPS connections, encryption in transit when applicable, least-privilege access control, audit logs, firewalls, monitoring, bot prevention, anti-fraud tools and periodic supplier review.
Disclaimer: no internet-connected system is fully immune to risks, external infrastructure failures or incidents caused by third parties.
Security Incident Response Plan
In the event of a confirmed or suspected relevant data-security incident under our responsibility, the technical team will act under a response plan focused on identifying, containing and investigating the threat, adopting mitigation measures. Communications to authorities and data subjects will occur when required by applicable laws, with internal documentation of measures taken.
Automated Decisions and Profiling
The technical operation processes signals automatically mainly for security, invalid traffic (IVT) detection, bot prevention, measurement and advertising segmentation. TiMo Mídia does not seek to make exclusively automated decisions producing relevant legal effects or similarly significant impact on users without legal basis, transparency and respect for applicable rights.
Links, Ads and Third Parties
To the extent permitted by applicable law, properties managed by TiMo Mídia may display ads, scripts, integrations or third-party links. TiMo Mídia does not fully control those external environments, and those third parties have their own privacy policies and data practices.
Digital Accessibility
TiMo Mídia adopts reasonable efforts and seeks, where technically feasible, to align interface development with digital inclusion and web accessibility principles to enable structured navigation. Users may report technical barriers through our compliance channel.
Languages and Versions
This Policy may be made available in other languages. In case of interpretive questions or divergence, the version corresponding to the site’s or applicable operation’s primary language prevails for clarification purposes, unless a mandatory local rule in the user’s residence jurisdiction requires otherwise.
Updates
This Policy may be revised and updated. The current version is identified by the “Last updated” date at the top. Relevant changes may be communicated visibly in digital environments through a notice, banner or other reasonable means, providing an opportunity for review.
Contact
For rights requests, legal questions, compliance notices and matters related to privacy, data protection, cookies, consent, opt-out and data governance, contact [email protected].
Applicable Local Addendum
This addendum supplements the Privacy Policy when South African law applies.
Local Addendum – South Africa
When applicable, processing will observe the Protection of Personal Information Act – POPIA and rules from the Information Regulator.
Users in South Africa may exercise rights of access, correction, deletion, objection to processing, objection to direct marketing and complaint before the competent authority.
Direct marketing by electronic means will observe Section 69 of POPIA. Security incidents involving personal information will be communicated to the Information Regulator and affected data subjects when required by law.
TiMo Midia Ltda – Media Technology and Monetization.