Privacy Policy

Who We Are

Wisdom Beyond Technology, LLC ("Wisdom", "we", "our", or "us") is the data controller responsible for your personal data collected through our website at wisdombtech.com and our associated ventures — INO-OS (intelligencenative.ai), Thinkers.pro (thinkers.pro), Wortya (wortya.com), and Refactoring the Firm (refactoringthefirm.com).

We are a US-based company operating globally, including in the European Economic Area (EEA) and Brazil, and we are committed to protecting your personal data in accordance with applicable privacy laws, including the EU General Data Protection Regulation (GDPR), the Brazilian Lei Geral de Proteção de Dados (LGPD), and the California Consumer Privacy Act (CCPA).

Data We Collect

We collect the following categories of personal data, only to the extent necessary for the purposes described in this policy:

• Contact information: name, email address, phone number — when you fill out a contact form, subscribe to our newsletter, or reach out to us directly.
• Professional information: company name, job title, industry — when provided voluntarily in communications or forms.
• Usage data: IP address, browser type, pages visited, time spent, referring URLs — collected automatically via cookies and analytics tools.
• Communications: content of emails or messages you send us.
• Book purchase data: if you purchase Refactoring the Firm via Amazon, we receive only the data Amazon chooses to share with publishers; Amazon's own privacy policy governs that transaction.

We do not collect sensitive personal data (health, biometric, racial or ethnic origin, political opinions, religious beliefs, financial account numbers) through this website.

How We Use Your Data

We use personal data for the following purposes:

• Responding to inquiries — to reply to messages submitted through our contact form or email.
• Newsletter and updates — to send you information about our products, ventures, book, and events, when you have opted in.
• Service delivery — to provide access to INO-OS, Thinkers.pro, Wortya, or other services you have engaged with.
• Analytics and improvement — to understand how visitors use our website and improve the experience.
• Legal compliance — to meet our obligations under applicable law.
• Security — to detect and prevent fraud, abuse, or unauthorized access.

Legal Basis for Processing — GDPR

If you are located in the EEA or UK, we rely on the following legal bases under Article 6 of the GDPR:

• Consent (Art. 6(1)(a)): for newsletter subscriptions and marketing communications. You may withdraw consent at any time.
• Contract (Art. 6(1)(b)): when processing is necessary to perform a contract with you or to take pre-contractual steps at your request.
• Legitimate interests (Art. 6(1)(f)): for analytics, security, and fraud prevention, where our interests are not overridden by your rights.
• Legal obligation (Art. 6(1)(c)): when required by EU or member-state law.

Legal Basis for Processing — LGPD

If you are located in Brazil, we rely on the following legal bases under Article 7 of the LGPD:

• Consent (Art. 7, I): for marketing communications and newsletter subscriptions. Consent is freely given, informed, and revocable.
• Contract execution (Art. 7, V): when processing is necessary to perform a contract or pre-contractual procedures.
• Legitimate interest (Art. 7, IX): for analytics, security, and service improvement, in accordance with Art. 10 of the LGPD.
• Legal or regulatory compliance (Art. 7, II): when required by Brazilian law.

You may exercise your rights as a data subject under the LGPD at any time by contacting us at privacy@wisdommkt.com.

Data Sharing

We share personal data only in the following circumstances:

• Service providers: trusted third-party vendors who help us operate our website and services (email platforms, analytics, hosting). They act as data processors under our instructions and are bound by data processing agreements.
• Legal requirements: when required by law, court order, or government authority.
• Business transfers: in connection with a merger, acquisition, or sale of assets, in which case we will notify you before your data is transferred.
• With your consent: in any other circumstance where you have given explicit prior consent.

Current key service providers include: website hosting (cloud infrastructure), email delivery, and web analytics. A full and current list is available upon request.

International Data Transfers

Wisdom Beyond Technology is headquartered in the United States. If you are located in the EEA, UK, or Brazil, your data may be transferred to and processed in the US or other countries that may not offer the same level of data protection as your jurisdiction.

When we transfer data internationally, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission for transfers to the EEA/UK;
• Data Processing Agreements with all processors compliant with LGPD requirements for transfers from Brazil;
• Adequacy decisions where applicable.

Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law:

• Contact form inquiries: up to 24 months from last interaction.
• Newsletter subscribers: until you unsubscribe or withdraw consent.
• Analytics data: aggregated and anonymized after 14 months.
• Legal and compliance records: as required by applicable law (typically 5–10 years).

When data is no longer needed, it is securely deleted or anonymized.

Your Rights

Depending on your location, you have the following rights regarding your personal data:

To exercise any of these rights, contact us at privacy@wisdommkt.com. We will respond within 30 days (GDPR/LGPD require responses within 15 days for LGPD and one month for GDPR, extendable by two months for complex requests).

Cookies & Tracking

Our website uses cookies and similar technologies. We use:

• Essential cookies: required for the website to function. No consent required.
• Analytics cookies: to understand website traffic and behavior. Requires your consent.
• Marketing cookies: currently not used. We will notify you before introducing any.

You can manage or withdraw your cookie consent at any time via your browser settings or our cookie preference center. Note that disabling certain cookies may affect website functionality.

We do not use cross-site tracking, fingerprinting, or third-party advertising networks.

Children's Privacy

Our website and services are not directed to individuals under the age of 16. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected data from a child under 16, we will delete it promptly. If you believe we have collected data from a minor, please contact us immediately.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law. When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, notify you by email or a prominent notice on our website.

We encourage you to review this policy periodically. Your continued use of our website after changes are posted constitutes acceptance of the updated policy.

Contact & Data Protection Officer