Privacy Policy

Last updated: November 2026

This Privacy Policy describes how Steady Ledger collects, uses, stores, and protects personal data in connection with its website and digital publications. Steady Ledger is committed to handling personal information in compliance with Brazil's Lei Geral de Proteção de Dados (LGPD, Law 13.709/2018) and the European Union's General Data Protection Regulation (GDPR, Regulation 2016/679).

1. Data Controller

The data controller is Steady Ledger, reachable at support@steadyledger.online. All data-related inquiries, requests, and complaints should be directed to this email address.

2. Data Collected

2.1 Data provided directly

When a reader contacts Steady Ledger by email or completes a purchase, the following data may be collected: name, email address, payment information (processed by a third-party payment provider — Steady Ledger does not store full payment card details), and the content of any communication.

2.2 Data collected automatically

When visiting the website, the following data may be collected automatically: IP address (anonymized where technically feasible), browser type and version, operating system, referring URL, pages visited, time and date of visit, and approximate geographic location derived from IP address.

2.3 Cookies and tracking technologies

The site may use first-party cookies for essential site functionality (session management, preference storage) and third-party cookies or pixels for analytics and advertising measurement. Advertising pixels, where used, collect anonymized interaction data to measure the effectiveness of advertising campaigns. No cookie or pixel collects data that personally identifies a visitor unless the visitor has separately provided that information through a purchase or contact form.

3. Legal Bases for Processing

Under LGPD and GDPR, Steady Ledger processes personal data on the following legal bases:

  • Contract performance — processing necessary to deliver purchased digital content, process refunds, and provide customer support (LGPD Art. 7, V; GDPR Art. 6(1)(b))
  • Legitimate interest — processing necessary for website analytics, fraud prevention, and advertising measurement, where such processing does not override the data subject's rights (LGPD Art. 7, IX; GDPR Art. 6(1)(f))
  • Legal obligation — processing required by applicable law, including tax and accounting obligations (LGPD Art. 7, II; GDPR Art. 6(1)(c))
  • Consent — where required, consent is obtained before processing; consent can be withdrawn at any time by contacting support@steadyledger.online (LGPD Art. 7, I; GDPR Art. 6(1)(a))

4. Data Retention

Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected:

  • Transaction records: retained for up to 5 years from the date of transaction, as required by Brazilian tax and commercial law
  • Support correspondence: retained for up to 2 years from the date of last communication
  • Analytics data: retained in anonymized form; raw data purged within 14 months
  • Email address for communication purposes: retained until the individual requests deletion

5. Data Sharing

Steady Ledger does not sell personal data to third parties. Data may be shared with:

  • Payment processors — to complete transactions and process refunds
  • Hosting and infrastructure providers — to deliver the website and digital content
  • Analytics and advertising platforms — in anonymized or aggregated form for campaign measurement
  • Legal authorities — when required by law or valid legal process

6. International Data Transfers

Data may be transferred to and processed in countries outside of Brazil and the European Economic Area, including the United States, where service providers such as hosting, analytics, and payment platforms operate. Such transfers are conducted in compliance with applicable data protection laws, using standard contractual clauses or other approved transfer mechanisms where required.

7. Data Subject Rights

Under LGPD and GDPR, individuals have the following rights regarding their personal data:

  • Right of access — to obtain confirmation of whether personal data is being processed and to access that data
  • Right of correction — to request correction of incomplete, inaccurate, or outdated data
  • Right of deletion — to request deletion of personal data, subject to legal retention requirements
  • Right of portability — to receive personal data in a structured, commonly used, and machine-readable format
  • Right to withdraw consent — where processing is based on consent, to withdraw that consent at any time
  • Right to object — to object to processing based on legitimate interest
  • Right to information — to be informed about third parties with whom data has been shared

To exercise any of these rights, contact support@steadyledger.online. Requests will be responded to within 15 days under LGPD or 30 days under GDPR.

8. Data Security

Steady Ledger implements technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or destruction. These include encrypted data transmission (TLS/SSL), access controls, and regular review of data handling practices.

9. ANPD and Supervisory Authorities

Under LGPD, data subjects may file complaints with Brazil's Autoridade Nacional de Proteção de Dados (ANPD). Under GDPR, data subjects in the European Economic Area may file complaints with their local supervisory authority.

10. Changes to This Policy

This policy may be updated periodically. Changes are effective upon publication on this page. The "last updated" date at the top of this page reflects the most recent revision.

11. Contact

For any questions about this privacy policy or Steady Ledger's data practices, contact: support@steadyledger.online