Privacy and data transparency

Privacy Policy

Learn what personal information we collect, why we use it, which service providers may receive it, and how to exercise your privacy rights.

Last updated: October 29, 2026.

This Privacy Policy describes how George Eich Institute LLC, a company based in Florida, United States, and Vinners LTDA, a company based in Brazil, handle personal information in connection with georgeeich.com, campaign pages, business inquiry forms, diagnostic conversations, content subscriptions and related communications. It applies to website visitors, prospective clients, business contacts and representatives of organizations interacting with us. We follow privacy laws applicable to each processing activity, including Brazil's General Data Protection Law (LGPD) where it applies and relevant United States laws.

1. Organizations responsible for processing

George Eich Institute LLC (the “Institute”), based in the State of Florida, United States, and Vinners LTDA (“Vinners”), based in Brazil, participate in the activities described in this policy. Each organization may determine the purposes and methods of certain processing activities, and both may make decisions together where their business and operational activities overlap. Their respective responsibilities depend on the specific processing activity.

Website: georgeeich.com.

Data Protection Officer (DPO) and privacy contact: George Eich.

Email for privacy requests: dpo@georgeeich.com.

Current operating arrangement: During this initial phase, information submitted through Institute forms is routed to the Bubble-based lead intake infrastructure operated by Vinners and is also handled through RD Station for lead management, business communications and, where separately authorized, marketing automation and subscriptions. This arrangement may involve access to the data by both organizations.

2. Personal information we may collect

Information you provide

Technical and website information

Depending on the page, configuration and your privacy choices, we may collect pages visited, interaction and conversion events, dates and times of access, IP address, browser and device information, traffic source, campaign parameters (such as UTM values), and advertising click identifiers (such as gclid, fbclid and li_fat_id). Attribution information may be associated with a form you voluntarily submit.

Please do not include sensitive personal information, unnecessary confidential documents or third-party personal information in free-text form fields.

3. Why we use information

We process information for the following purposes. Where Brazil's LGPD applies, the table indicates the potential legal bases, depending on the circumstances. In the United States and other locations, the processing is also subject to the privacy and marketing rules applicable to the individual and the activity.

PurposeHow information is usedPotential LGPD legal basis (when applicable)
Respond to a business inquiryReceive requests, contact you, arrange and hold a diagnostic conversation, and send information or proposals you requested.Steps requested before a contract and/or consent, as appropriate.
Business qualification and CRMUnderstand your company's context, evaluate service fit, organize follow-up and maintain relevant lead history, including through Vinners' Bubble-based workflows and RD Station.Pre-contractual steps and, where appropriate, legitimate interests subject to the required assessment.
Requested newsletters and contentManage an active subscription to Priority and send the content you separately requested, including subscription preferences and unsubscribe handling.Consent where required; it can be withdrawn.
Website analytics and improvementAssess website performance, understand navigation, identify errors and analyze engagement.Consent for nonessential analytics technologies where required.
Advertising and conversion measurementMeasure campaign effectiveness, attribute conversions and, where permitted, support advertising audiences or remarketing.Consent for nonessential advertising technologies and related processing where required.
Security, legal obligations and recordkeepingProtect systems, prevent misuse or fraud, retain required records and respond to valid legal requests.Legal obligation and/or legitimate interests, as appropriate.

Some form information may be used for preliminary business qualification, for example based on a stated role, company revenue range or decision timeline. You can ask about this processing using the contact details below.

Submitting a diagnostic request does not automatically subscribe you to the Priority newsletter. A request for a business conversation is separate from agreeing to recurring marketing emails, and consenting to contact about that request is also separate from consenting to analytics or advertising cookies.

4. Cookies, pixels and campaign measurement

Cookies and related technologies, including browser storage, pixels, server-side conversion integrations and tags, may be used to support basic website features, measure visits and evaluate advertising campaigns. Technologies in use or planned for Institute pages may include:

TechnologyPurposeImportant detail
Strictly necessary featuresSite operation, form integrity and security.Not intended for behavioral advertising.
Google Tag ManagerManage deployment of third-party tags.The tag manager is not, by itself, a grant of permission for optional tags.
Google Analytics 4Analytics, page visits, events and website performance.Nonessential analytics tracking must be assessed under applicable consent requirements.
Google AdsConversion reporting, attribution and advertising measurement.Depending on setup, the service may process campaign identifiers and conversion data.
Meta Pixel / Conversions APIMeasure events and attribute campaigns on Meta services.Events may be sent from the browser and, if configured, server-side.
LinkedIn Insight TagMeasure LinkedIn campaigns and conversions.Associated identifiers depend on the page configuration.
ChatGPT Ads (OpenAI)Measure interactions and advertising conversions on selected pages.The advertising SDK loads only after permission for advertising on updated website pages.

Cookie choices

We distinguish strictly necessary technologies from optional analytics and advertising technologies. Nonessential tracking should be enabled only where there is a valid legal basis and the visitor's applicable choices have been respected. Declining analytics or advertising tracking must not prevent you from submitting a business inquiry.

On updated pages, you may reject, accept or separately configure analytics and advertising through the cookie notice. You can change your choices using the “Cookie preferences” link in the footer. Other pages may differ during deployment. This policy alone does not technically block tags or cookies.

Cookie lifetimes depend on the provider, tool configuration and user choices. Relevant details should be available through the cookie preference interface when installed. If applicable laws give you a right to opt out of targeted advertising or particular disclosures, you may contact us at dpo@georgeeich.com while the corresponding controls are being deployed.

5. Who receives personal information

We disclose information only for the stated purposes or where lawfully required. Recipients may include:

Form data sent through the Vinners and RD Station workflow may include name, email, phone number, company and professional details, the content of the request, and available campaign attribution information. Access should be limited to personnel and service providers with an operational need to process that information.

Where advertising integrations are configured to use contact details, email addresses or phone numbers may be normalized and cryptographically hashed (for example, using SHA-256) before transmission for ad matching or conversion measurement. Hashing does not necessarily make such information anonymous, and these uses remain subject to applicable privacy rules and consent choices.

We do not sell contact lists for monetary payment. However, certain advertising or cross-context tracking disclosures may be treated as a “sale,” “sharing” or “targeted advertising” under some U.S. state privacy laws. Where such laws apply, we will provide required choices and handle valid requests accordingly.

6. International processing and data transfers

Because the Institute is based in Florida, United States, and Vinners is based in Brazil, personal information may be accessed, disclosed or processed in both countries. In particular, when you submit a form on an Institute page, information may be routed to the Bubble infrastructure used by Vinners and to RD Station for lead management and appropriate communications. Depending on their actual hosting arrangements and subcontractors, these services may also process information in other countries.

Purposes and retention: these cross-border operations support receiving and qualifying inquiries, arranging diagnostic conversations, lead management, requested communications, support and related legal obligations. Lead and CRM data are generally subject to the periods specified in Section 7.

Roles and safeguards: the Institute and Vinners are responsible for their respective decisions about processing, while technology providers may process data as service providers or under their own legally defined roles. We will use the legal transfer mechanisms, contractual provisions, vendor controls and security safeguards required for the actual transfer and applicable jurisdiction. For processing subject to Brazil's LGPD, international transfers must meet the relevant LGPD requirements, including the ANPD rules on international transfers, as applicable.

You may request further information about the destinations, purposes, recipients, applicable safeguards and your rights through dpo@georgeeich.com.

7. How long we keep personal information

We retain personal information only as long as reasonably necessary for the stated purposes and applicable legal obligations, using the following operational retention criteria:

Data categoryRetention criterion
Business inquiries with no contractUp to 24 months after the last relevant interaction, unless an earlier valid deletion request is received or the law permits or requires retention.
CRM and lead qualification history with no contractUp to 24 months after the last relevant interaction; then deleted or de-identified unless continued retention is justified.
Priority newsletter and other requested recurring emailsFor as long as the subscription remains active, until you unsubscribe or withdraw consent. Minimal opt-out or suppression records may be retained as necessary to avoid sending unwanted emails or demonstrate compliance.
Technical access and security logsSix months as a reference period for application access records governed by Brazil's Internet Civil Framework, where applicable. Other security and service logs may be governed by different legal or operational periods; legal holds or incidents may require longer preservation.
Contracts and service documentationThroughout the business relationship and, where justified by applicable law, up to 10 years after termination. Certain categories of documents may have different mandatory or limitation periods.
Cookies and measurement dataAccording to actual provider settings, the applicable technology's lifespan and privacy preferences, with any mandatory retention requirements.

These are upper limits or general criteria, not permission to keep information without a valid purpose. We may delete, de-identify or retain a limited subset of information where permitted or required by law. Deletion may not immediately remove lawful backups, suppression records or materials subject to a legal hold.

8. How we protect information

We seek to apply reasonable technical and organizational safeguards proportionate to the information involved and the relevant risks, including appropriate access controls, restricted operational access and protection of communications and systems. No website, storage platform or transmission method is entirely risk-free. We assess and respond to security incidents in accordance with applicable law.

9. Your privacy rights

Rights under Brazil's LGPD, when applicable

Subject to legal requirements and exceptions, Article 18 of the LGPD may provide rights to:

Where appropriate, Brazilian data subjects may also contact the Brazilian National Data Protection Authority (ANPD).

Rights under applicable U.S. state laws

Depending on your state of residence, the nature of the data processing and whether the relevant law applies to the organization, you may have rights to request access, correction or deletion, to obtain a copy of certain information, or to opt out of qualifying targeted advertising, data sales or certain profiling activities. Some laws also provide an appeal process. We will evaluate and respond to requests under the laws that apply to the specific circumstances. We do not represent that every state privacy statute automatically applies to the Institute solely because it operates in Florida.

You may also opt out of marketing emails through the unsubscribe link in the message. We process valid unsubscribe requests in accordance with applicable rules, including the U.S. CAN-SPAM Act where relevant.

10. How to exercise your rights or contact us

For requests about access, correction, deletion, consent withdrawal, marketing preferences, advertising disclosures, international processing or any other privacy concern, contact George Eich, Data Protection Officer, at dpo@georgeeich.com using the subject “Privacy Request.” This contact covers the Institute and Vinners activities described in this policy.

We may request the minimum information reasonably necessary to verify your identity, locate relevant records and protect your privacy. We will respond within deadlines required by applicable law and explain any lawful limitations or reasons a request cannot be fulfilled.

11. Third-party services and children's information

Our pages may link to services outside our control, including WhatsApp and external platforms. Their own terms and privacy policies may apply when you use them. We encourage you to review those notices.

Our website and business services are intended for adults and professional audiences and are not directed to children under age 13. We do not knowingly request personal information from children under 13 through these business inquiry channels. If you believe such information has been provided, contact the DPO.

12. Updates to this Privacy Policy

We may update this Privacy Policy to reflect changes in our services, providers, processes or legal obligations. We will publish the current version and the date of the most recent update on this page and provide additional notice or seek renewed consent if required by applicable law.

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