Privacy Policy
Last updated: 16 September 2026
1. Who is responsible
This policy explains how W VERTEX LTDA, a limited liability company (sociedade limitada) organised under the laws of Brazil, registered under CNPJ 13.796.310/0001-06, with its registered office at Av. João Paulino Vieira Filho, 625, Sala 1504, Zona 01, Maringá, Paraná, 87020-015, Brazil ("W Vertex", "we", "us"), handles personal data connected with holdingos-uk.wvertex.com.br and with Holding OS. W Vertex is the controller of that data.
For any privacy question or request, write to support@wvertex.com.br. This address is also our channel for requests under Brazil's data protection law (LGPD).
2. The short version
- We collect little.
- We never see what you enter into your copy of the template in Notion.
- We do not sell your personal data.
- Advertising and analytics cookies load only if you accept them.
3. What we collect and why
When you visit holdingos-uk.wvertex.com.br. With your consent, given through the cookie banner, Google Analytics, Google Ads and Meta (Facebook and Instagram) set cookies and similar technologies on this page. They collect:
- device and browser information;
- your approximate location, based on your IP address;
- the pages you view and the buttons you click;
- the site that referred you.
We use this to understand how the page performs, to measure our advertising on Google and Meta, and to show our ads to people who have visited the page (remarketing). If you decline, none of these tags load and the page works exactly the same.
When you buy Holding OS or download the free version. Checkout runs on Gumroad, Inc., which collects your payment details and VAT. We do not receive your card number. Gumroad shares with us:
- your name and email address;
- your country;
- the details of your order.
We use this information to deliver the product, send you updates, provide support, process refunds and keep the records required by tax and accounting law.
When you email us. We receive your email address and your message, and use them to answer you.
Emails about Holding OS. If you buy Holding OS or download the free version, we may email you about updates to your edition, new editions and offers. Every such email includes an unsubscribe link, and we act on unsubscribe requests promptly. We send marketing emails to UK customers on the basis of the soft opt-in under the Privacy and Electronic Communications Regulations 2003, which applies to similar products of ours, and you can opt out at any time.
4. What we do not collect
The information you enter into the template stays in your own Notion workspace. W Vertex has no access to it. That data is governed by Notion's terms, privacy policy and security practices.
5. Lawful bases
Under the UK GDPR and the Data Protection Act 2018 (and, where they apply, Brazil's LGPD and the EU GDPR), we rely on:
- Performance of a contract: to deliver what you bought and support you.
- Legal obligation: to keep tax and accounting records.
- Legitimate interests: to send service emails about your edition, to protect against fraud, and to improve the page. We have balanced these interests against your rights.
- Consent: for analytics and advertising cookies, and for marketing emails where the soft opt-in does not apply. You can withdraw consent at any time.
6. Who we share data with
We share personal data only with the service providers we use to run Holding OS:
- Gumroad (checkout, merchant of record and delivery);
- Google (analytics and advertising);
- Meta Platforms (advertising measurement and remarketing on Facebook and Instagram);
- our email delivery provider;
- our website host and our domain and DNS provider.
We may also share data with professional advisers and with public authorities when the law requires it.
We do not sell personal data.
7. Cookies and your choices
Analytics and advertising cookies load only after you accept them in the banner. You can change your choice at any time by clearing the site's cookies in your browser, which brings the banner back.
You can also:
- control or delete cookies in your browser settings;
- turn off personalised Google ads at adssettings.google.com;
- adjust your ad preferences in your Facebook and Instagram settings;
- block Google Analytics with Google's opt-out browser add-on.
We also honour Global Privacy Control (GPC) signals: when your browser sends one, this page does not load advertising tags from Google or Meta, whatever you chose in the banner. Our site does not respond to "Do Not Track" signals.
8. How long we keep data
- Purchase records: for as long as tax and accounting law requires.
- Marketing email list: until you unsubscribe.
- Analytics data: for the retention period set in Google Analytics, currently 14 months.
- Support emails: for as long as needed to handle your request and any follow-up.
9. International transfers
W Vertex is based in Brazil, and some of our providers are based in the United States and other countries. Your data may be processed in any of these places. Where UK data protection law requires it, we rely on the safeguards it allows, including the UK's adequacy regulations and the International Data Transfer Agreement or Addendum published by the Information Commissioner.
10. Security
We use reasonable technical and organisational measures to protect personal data. No method of transmission or storage is completely secure.
11. Your rights
Under the UK GDPR you have the right to:
- access the personal data we hold about you and receive a copy;
- have it corrected;
- have it erased;
- restrict or object to certain uses, including direct marketing;
- receive your data in a portable format;
- withdraw consent at any time, without affecting what was done before.
To exercise any right, write to support@wvertex.com.br. We will answer within one month, and we will not treat you differently for exercising your rights.
You also have the right to complain to the Information Commissioner's Office (ico.org.uk), the UK supervisory authority. We would appreciate the chance to deal with your concern first.
Residents of Brazil and the European Union have similar rights under their local laws.
12. Children
Holding OS and holdingos-uk.wvertex.com.br are not directed to children under 13, and we do not knowingly collect their personal data.
13. Changes to this policy
We may update this policy. When we do, we change the date at the top. Significant changes will be highlighted on the page.