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PRIVACY POLICY

A Peça-Chave™ –  The Missing  Key™ Executive  Communication  System

Operated by Alexandra Hurley
Worcester, Massachusetts, United States

Last Updated: January 14, 2026

 

1. Introduction

A Peça-Chave™ (“Company,” “we,” “us,” or “our”) is an online educational platform operated by Alexandra Hurley and based in Worcester, Massachusetts, United States.

This Privacy Policy explains how we collect, use, process, store, and protect personal information when you access our website, membership portal, digital courses, mentorship programs, and related services (collectively, the “Services”).

This Policy is intended to comply with applicable privacy and data protection laws, including:

  • United States federal and applicable state laws
  • Brazil’s Lei Geral de Proteção de Dados (LGPD – Law No. 13.709/2018)
  • European Union General Data Protection Regulation (GDPR)

By using our Services, you acknowledge and agree to the practices described in this Privacy Policy.

 

2. Data Controller

The data controller responsible for your personal information is:

A Peça-Chave™
Operated by Alexandra Hurley
Worcester, Massachusetts, United States
alexhurley02@gmail.com

 

3. Personal Information We Collect

A. Information You Provide

  • Full name
  • Email address
  • Billing information
  • Country of residence
  • Company name and job title (optional)
  • Account login credentials
  • Communications sent to us

B. Payment Information

Payments are processed securely by third-party providers such as Stripe and PayPal.

We do not store full credit card numbers.

C. Automatically Collected Information

  • IP address
  • Browser and device type
  • Operating system
  • Pages visited
  • Time spent on pages
  • Course enrollment and progress
  • Referral source

D. Cookies and Tracking Technologies

We use cookies and similar technologies to:

  • Maintain login sessions
  • Track course progress
  • Improve user experience
  • Analyze website performance

You may manage cookie preferences through your browser settings.

 

4. Legal Basis for Processing

We process personal information based on:

  • Performance of a contract
  • Legitimate business interests
  • User consent
  • Legal obligations

 

5. How We Use Your Information

We use personal information to:

  • Create and manage user accounts
  • Provide access to digital courses and materials
  • Process payments
  • Send transactional communications
  • Improve platform functionality
  • Protect intellectual property
  • Enforce our Terms of Use
  • Comply with legal requirements

We do not sell personal information.

 

6. International Data Transfers

Because we are based in the United States, personal data may be transferred to and processed in the United States.

By using our Services, users outside the United States consent to this transfer.

We apply reasonable safeguards for cross-border transfers.

 

7. Data Sharing

We may share limited personal information with:

  • Payment processors
  • Email service providers
  • Hosting and cloud providers
  • Learning management system providers
  • Analytics providers
  • Legal authorities when required

All third parties are required to protect personal data.

 

8. Data Retention

We retain personal information only as long as necessary to:

  • Provide Services
  • Maintain financial and tax records
  • Resolve disputes
  • Enforce agreements
  • Comply with legal obligations

Deletion requests are subject to applicable legal retention requirements.

 

9. Data Security

We use commercially reasonable administrative, technical, and physical safeguards, including:

  • SSL encryption
  • Secure hosting
  • Limited access controls
  • Password-protected accounts

No system is completely secure. Users acknowledge this risk.

 

10. Your Rights

Depending on your location, you may have the right to:

  • Request access to your data
  • Request correction
  • Request deletion
  • Restrict or object to processing
  • Withdraw consent
  • Request data portability (where applicable)

Requests may be submitted to:
alexhurley02@gmail.com

Identity verification may be required.

 

11. Children’s Privacy

Our Services are intended for individuals 18 years of age or older.

We do not knowingly collect data from minors.

 

12. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of the Commonwealth of Massachusetts, United States.

Any disputes shall be resolved exclusively in the state or federal courts located in Massachusetts.

International users consent to this jurisdiction.

 

13. Monitoring & Intellectual Property Protection

We may monitor accounts to prevent:

  • Unauthorized access
  • Credential sharing
  • Distribution of proprietary content

Violations may result in suspension or termination.

All A Peça-Chave™ content is protected by U.S. and international intellectual property laws.

 

14. Changes to This Policy

We may update this Privacy Policy at any time. Continued use of Services constitutes acceptance of updates.

 

15. Contact Information

A Peça-Chave™
Operated by Alexandra Hurley
Worcester, Massachusetts, United States
alexhurley02@gmail.com