Privacy Policy

1. Who we are

UNDERNEATH — Search Intelligence is the search visibility brand (technical SEO, website architecture and AI discovery) of MOMENTVM OPVS PRESTADORA DE SERVICOS - SOCIEDADE UNIPESSOAL LTDA, a company registered in Brazil under CNPJ 52.090.660/0001-04, based in São Paulo, Brazil (“UNDERNEATH”, “we”).

This policy covers underneathsi.com in all of its language versions, the contact form and any conversations that follow from it. For any privacy matter, write to contact@underneathsi.com.

2. Our role

When we run the website and respond to inquiries, the company named above decides why and how the data is used and acts as the controller under the Brazilian General Data Protection Law (Law 13,709/2018, “LGPD”).

In client projects, controller and processor roles depend on each engagement’s contract and instructions. This policy does not replace a specific data processing agreement where one is required.

As a small-scale processing agent under Brazilian data protection authority (ANPD) Resolution CD/ANPD 2/2022, the company has not appointed a data protection officer. contact@underneathsi.com is the contact channel for individuals and for the ANPD.

3. Information we handle

• Information you submit: name, email address, website address, the issue you select, your message and anything else you choose to include, plus what comes in later conversations.
• Technical access data: when you open any page, your browser sends your IP address, date and time, browser and device type and referring page to the hosting service that delivers the site (see section 7). Fonts are served by the site itself, without calling external services. We use no audience analytics and build no browsing profiles.
• Engagement records: if you become a client, identification and contact details, proposals, contracts and tax documents.

The form does not ask for sensitive information (such as health, religion, racial origin or biometrics) or passwords. Please do not include them in your message.

4. How the data reaches us

Through the contact form, by email or on WhatsApp, when you choose to contact us. The form sends its content to the Web3Forms service, which delivers it to our inbox. If automatic sending is not available in your browser, the site opens your email app with the message ready, and nothing is sent unless you confirm.

Technical access data is generated automatically by the communication between your browser and the servers that deliver the site.

5. Why we use the data and on what legal basis

• Replying to your inquiry and reviewing your website: reading your message, analysing the URL you provide, clarifying scope and preparing a proposal. Legal basis: pre-contractual steps taken at your request (LGPD art. 7, V).
• Providing contracted services: performance of a contract (art. 7, V).
• Keeping track of our conversations: legitimate interests (art. 7, IX), limited to what is needed to follow up on your request.
• Meeting legal and tax obligations: compliance with a legal or regulatory obligation (art. 7, II).
• Protecting the site, preventing abuse and defending rights: legitimate interests (art. 7, IX) or the regular exercise of rights (art. 7, VI), as applicable.

Submitting the form does not subscribe you to a newsletter or promotional emails. If we ever offer that kind of content, signing up will be separate, voluntary and easy to cancel.

6. What we do with the URL you submit

We may review publicly available information about the website you name to understand crawling, indexing, content, performance and structure issues. Submitting a URL does not authorise us to access private areas, admin panels or third-party data, or to run security tests. Deeper reviews require an agreed scope and specific permissions.

7. Who we share data with

Data is accessed only by authorised UNDERNEATH staff and by the providers the site needs to work:

• Web3Forms (Web3Creative, India): receives the form content and delivers it by email, acting as our processor. According to the Web3Forms privacy policy, its infrastructure runs on Amazon Web Services, Cloudflare and Hetzner, and submissions are kept for up to 3 years. We delete them earlier, as described in section 10.
• Email provider: where we receive and answer messages.
• Website hosting: receives the technical access data needed to deliver the pages.
• WhatsApp (Meta): only if you choose to contact us there, under Meta’s own policies.
• Public authorities: when required by law or court order.

We do not sell, rent or trade personal information, and we do not share contact lists.

8. International transfers

Some of these providers process data outside Brazil: Web3Forms operates from India with infrastructure in several regions. When you submit the form, the transfer is necessary to answer your request (LGPD art. 33, IX, together with art. 7, V). If we adopt other providers abroad, we will follow the conditions of LGPD art. 33 and the ANPD’s international transfer rules.

9. Cookies and similar technologies

The site sets no cookies and uses no analytics, advertising or tracking tools. It only uses 2 temporary entries in the browser tab’s memory, deleted right after use, to control animations. See the Cookie Policy for details.

10. How long we keep data

• Inquiries that do not lead to an engagement: up to 1 year after the last message exchanged. After that, messages are deleted from our inbox and from the Web3Forms dashboard.
• Clients: for the duration of the contract and then for the periods required by tax, accounting and civil law, or while needed to defend legal rights.
• Technical access data: for the log retention period of our hosting and content delivery providers.
• Privacy requests: a record of the request and our reply, for as long as needed to show it was handled.

When the period ends, data is deleted or anonymised.

11. Security

We apply technical and organisational measures proportionate to the risk, such as limiting access to people who need the data, encrypted transmission (HTTPS) and keeping systems up to date. No online environment is risk-free. If a relevant security incident occurs, we will assess, record, notify and mitigate it as the law requires.

12. Your rights

Under LGPD art. 18, you may request:

• confirmation that we process your data, and access to it;
• correction of incomplete, inaccurate or outdated data;
• anonymisation, blocking or deletion of unnecessary or excessive data, or data processed unlawfully;
• portability, under ANPD regulations;
• information about who we share your data with;
• deletion of data processed on the basis of consent, withdrawal of consent and information about the consequences of not consenting;
• objection to processing based on other legal grounds where the law is not being followed.

To exercise any of these rights, write to contact@underneathsi.com. We may ask for minimal information to confirm your identity so that one person’s data is not given to another. Full confirmation and access requests are answered within 15 days (LGPD art. 19, II). Deletion may be limited where the law requires us to keep certain data.

You may also file a complaint with Brazil’s National Data Protection Authority (ANPD).

13. Visitors outside Brazil

Depending on where you are, laws such as the GDPR (European Union and United Kingdom), PIPEDA and provincial laws (Canada) or US state privacy laws may give you additional rights, depending also on our activities and the processing involved. We do not claim that every foreign privacy law automatically applies to our operation. Where one does, we will provide the notices, channels and choices it requires. We do not sell personal information or share it for cross-context behavioural advertising.

14. Children

Our services are aimed at businesses and professionals and are not directed to children. If we receive a child’s or teenager’s data without a proper basis, we will take appropriate action as soon as we become aware of it.

15. Analysis tools and artificial intelligence

We may use technical tools, including artificial intelligence, to analyse public website information and help prepare reports. We do not make solely automated decisions that affect the interests of people who submit the form. If that changes, this policy will be updated first.

16. Changes and contact

This policy may change for legal, technical or operational reasons. The date of the current version appears at the top of the page, and relevant changes will be highlighted here. Questions and requests: contact@underneathsi.com.