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HomePrivacy Policy
Legal document

Privacy Policy

How Torian Market collects, uses, protects and shares the personal data of those who read, subscribe and trust our curation.

Last updatedMay 13, 2026
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10 min read
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Current versionv.1
Table of contents

TORIAN MARKET LTDA

Brazilian Tax ID (CNPJ) 66.518.480/0001-95 · Av. Brigadeiro Faria Lima, 1572, Suite 1022, Jardim Paulistano, São Paulo/SP, ZIP 01.451-917 — Brazil

Table of contents

  1. 01Introduction
  2. 02About Torian Market and our services
  3. 03Definitions
  4. 04Personal data we collect
  5. 05Purposes and legal bases for processing
  6. 06Sharing data with third parties
  7. 07International data transfers
  8. 08Storage and retention period
  9. 09Data subject rights
  10. 10Information security
  11. 11Cookies and similar technologies
  12. 12Children and adolescents' data
  13. 13Data Protection Officer (DPO) and contact channels
  14. 14Informational nature of the services and User responsibility
  15. 15Automated data processing
  16. 16Changes to this Policy
  17. 17Governing law and venue
  18. 18Final provisions
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This Policy describes — clearly and in detail — how Torian Market collects, uses, stores, shares and protects the personal data of users, subscribers and visitors, in strict compliance with Brazil's LGPD and other applicable laws.

01

Introduction

TORIAN MARKET LTDA, a Brazilian private legal entity, registered under CNPJ 66.518.480/0001-95, headquartered at Av. Brigadeiro Faria Lima, 1572, Suite 1022, Jardim Paulistano, São Paulo/SP, ZIP 01.451-917 (hereinafter “Torian”, “Torian Market”, “we” or “Controller”), is committed to the privacy, transparency and protection of personal data of its users, subscribers, visitors and customers (“User” or “Data Subject”).

The purpose of this Privacy Policy is to inform — clearly, objectively and in detail — how personal data is collected, used, stored, processed, shared and protected across the platforms, services, websites, apps and channels operated by Torian, in strict compliance with Law nº 13.709/2018 (LGPD), the Brazilian Internet Civil Framework (Law nº 12.965/2014), Decree nº 8.771/2016, the Consumer Defense Code (Law nº 8.078/1990) and other applicable regulations.

By accessing, registering, contracting, subscribing or using any of Torian's services, the User declares to have read, understood and fully accepted the terms of this Policy. Users who do not agree with any provision should refrain from using the services.

02

About Torian Market and our services

Torian Market is a content, intelligence and market-prediction platform dedicated to producing, curating and distributing information that helps Users understand and interpret diverse markets. Our services are mainly organised into the following fronts:

Premium newsletter
Periodic production and delivery of bulletins, reports and analyses on financial markets, prediction markets, politics, economy, geopolitics, technology, crypto and related topics.
News portal
Continuous web publication of news, articles, columns, interviews and journalistic content on the same topics.
Predictions & market intelligence platform
Digital product through which Torian provides forecasts, projections, probabilities, scenarios, quantitative and qualitative analysis, informational signals and alerts — to support the User's own decision-making.
Communications, alerts and notifications
Transactional messages, alerts and notifications via email, push, SMS, WhatsApp or other channels authorised by the User.

Important: Torian is exclusively a provider of information, analysis and content. It is not a financial institution, broker, crypto exchange, payment institution, does not manage third-party portfolios, does not custody funds and does not execute orders on behalf of the User. Any financial, investment or betting decision made based on our content is the User's sole responsibility.

03

Definitions

For the purposes of this Policy, the following definitions apply, in line with art. 5 of the LGPD and other relevant technical concepts:

Personal Data
Information related to an identified or identifiable natural person.
Sensitive Personal Data
Data on racial or ethnic origin, religious belief, political opinion, union affiliation, health, sex life, genetic or biometric data.
Data Subject
The natural person to whom the personal data being processed refers.
Controller
Torian Market Ltda., which makes the decisions regarding the processing of personal data.
Processor
Natural or legal person who processes personal data on behalf of the Controller.
Data Protection Officer (DPO)
Communication channel with data subjects and with the Brazilian Data Protection Authority (ANPD).
Processing
Any operation carried out with personal data — collection, use, access, storage, deletion, transfer and so on.
Analytical Content
Any forecast, projection, probability, analysis, report, informational signal, alert, chart, model or study produced by Torian.
Prediction Markets
Environments where participants trade contracts whose value depends on the occurrence (or not) of future events.
04

Personal data we collect

4.1. Data provided directly by the User

  • Account data: full name, email, phone/WhatsApp, date of birth, Brazilian CPF (when legally required), nationality, profession and location.
  • Authentication data: login, password (stored with irreversible hash), MFA tokens, security questions and answers.
  • Subscription data: contracted plan, subscription history, payment status, preferences and topics of interest.
  • Payment data: payment methods tokenised by the provider (card, PIX, bank slip). Torian does not store sensitive payment credentials.
  • Contact and support data: messages, emails, tickets, conversations, audio and recordings (when applicable and with prior notice).
  • User-generated content: comments, ratings, surveys, votes on predictions and other voluntary contributions.
  • Analytical preferences: markets, themes, regions, assets and alert/notification settings defined by the User.

4.2. Data collected automatically

  • Technical data: IP, browser, OS, device identifier, language and time zone.
  • Usage data: pages visited, time on site, clicks, scrolls, traffic source, email opens.
  • Cookies and similar technologies (see Section 11).
  • Approximate geolocation via IP (we do not collect precise GPS without explicit consent).

4.3. Data obtained from third parties

  • Social authentication providers (Google, Apple, X, Discord) — only data authorised by the User.
  • Payment providers and PSPs — transaction confirmations, antifraud, billing identifiers.
  • Media, referral and affiliate partners — signup origin, campaigns and coupons.
  • Public sources and bureaus — only when strictly necessary for fraud prevention or legal compliance.

4.4. Data Torian does NOT collect

By design, Torian does not collect: private keys, seed phrases, passwords to third-party platforms, orders or positions held at brokers, financial balances at other institutions, or sensitive data (except with specific, highlighted consent).

05

Purposes and legal bases for processing

Torian only processes personal data under legitimate legal bases, in line with art. 7 and art. 11 of the LGPD. The main purposes and bases are:

5.1. Contract performance (art. 7, V)

  • Creating and maintaining the User's account; processing subscriptions, charges and renewals.
  • Providing access to the newsletter, news portal and the predictions & market-intelligence platform.
  • Personalising the delivery of analytical content, forecasts and alerts according to User preferences.
  • Customer service, technical support and handling requests.

5.2. Compliance with legal obligations (art. 7, II)

  • Meeting tax, accounting and anti-money-laundering requirements.
  • Complying with requests from competent authorities (tax authority, ANPD, courts, prosecutors, police).
  • Keeping access logs for 6 months (art. 15 of the Brazilian Internet Civil Framework).

5.3. Legitimate interest (art. 7, IX)

  • Platform security, fraud prevention, bots and abusive scraping.
  • Improving products, analytical models and the quality of forecasts.
  • Statistical analysis and model calibration, preferably with anonymised or aggregated data.
  • Defending Torian's rights in judicial, administrative or arbitration proceedings.

5.4. Consent (art. 7, I)

  • Sending marketing and commercial content not tied to an active subscription.
  • Use of non-essential cookies (analytics and advertising).
  • Collection of precise geolocation, when applicable.
  • Processing of sensitive data in the rare cases where it may occur.

Consent can be revoked at any time, free of charge, through the channels in Section 13 — without prejudice to processing previously carried out under the then-current consent.

5.5. Regular exercise of rights (art. 7, VI)

  • Defence in judicial, administrative and arbitration proceedings.
  • Preservation of evidence for the applicable statute of limitations.

5.6. Credit protection (art. 7, X)

When applicable, consultations with credit bureaus and prevention of default in subscription plans.

06

Sharing data with third parties

Torian may share personal data with third parties strictly in the cases below, always respecting the principles of purpose, necessity and security under the LGPD:

6.1. Processors and service providers

  • Cloud infrastructure and hosting (AWS, Google Cloud, Cloudflare, Vercel and similar).
  • Email and newsletter delivery (SendGrid, Mailgun, Resend, Amazon SES, Substack, Beehiiv or equivalent).
  • Customer support (Intercom, Zendesk, Crisp or equivalent).
  • Analytics and product (Google Analytics, Mixpanel, PostHog, Amplitude, Hotjar).
  • Payment processors (Stripe, Pagar.me, Asaas, Stark Bank, Pagseguro, Hotmart or equivalent).
  • Antifraud and identity verification partners.
  • SMS, push, WhatsApp Business API and similar providers.

6.2. Public authorities and legal compliance

Torian may share data with administrative, regulatory, tax, police or judicial authorities, upon formal and well-founded request, or to comply with legal obligations or court orders.

6.3. Corporate transactions

In mergers, acquisitions, spin-offs, investment rounds or due diligence, data may be shared with the third parties involved, under strict confidentiality and protection standards equivalent to this Policy.

6.4. Defence of rights

Sharing for defence in proceedings and for investigating fraud, abuse and contractual violations.

Torian does not sell identifiable personal data of Users. Any business involving data respects anonymisation, aggregation or pseudonymisation techniques.

07

International data transfers

Because of the global nature of the technology infrastructure, part of the data may be stored or processed outside Brazil — including in the US, the EU and other countries.

We adopt the safeguards in art. 33 of the LGPD: (i) transfer to countries with an adequate level of protection; (ii) standard contractual clauses; (iii) binding corporate rules; or (iv) other safeguards recognised by the ANPD.

08

Storage and retention period

Data is stored for as long as necessary to fulfil the purposes for which it was collected, according to the criteria below:

Account data
Throughout the contractual relationship and for up to 5 years afterwards, to meet legal obligations.
Access logs
Minimum 6 months (art. 15 of the Brazilian Internet Civil Framework).
Financial and tax records
5 to 10 years, depending on applicable tax legislation.
Subscription history
For the statute-of-limitations period applicable to contractual obligations (typically 5 years).
Marketing and communications
While the consent is in force, or until revocation.
Metrics and analytics
Preferably stored in aggregated or anonymised form after a reasonable retention period.
09

Data subject rights

Under art. 18 of the LGPD, the Data Subject has the following rights, exercisable at any time and free of charge:

  • Confirmation of the existence of processing.
  • Access to the personal data processed.
  • Correction of incomplete, inaccurate or outdated data.
  • Anonymisation, blocking or deletion of unnecessary or excessive data.
  • Data portability to another service provider.
  • Deletion of data processed based on consent.
  • Information about the entities with which Torian shares data.
  • Information about the possibility of not consenting and its consequences.
  • Withdrawal of consent at any time.
  • Objection to processing that does not comply with the LGPD.
  • Review of automated decisions that affect their interests.

Requests can be made through the channels in Section 13. Torian may request additional information to confirm the User's identity before fulfilling a request.

10

Information security

Torian adopts technical, administrative and organisational measures to protect personal data against unauthorised access and accidental or unlawful situations, including:

  • Encryption in transit (TLS 1.2+) and at rest for sensitive data.
  • Passwords stored exclusively as hashes using robust algorithms (bcrypt, Argon2).
  • Role-based access control, least-privilege principle and segregation of duties.
  • Multi-factor authentication (MFA) for administrative access.
  • Continuous monitoring, audit logs and intrusion detection.
  • Periodic backups with restore tests.
  • Vendor assessment and contracts with data-protection clauses.
  • Regular training of staff on privacy and security.
  • Incident response plan.

Torian will under no circumstances ask for the User's password via email, phone, message or any other means.

11

Cookies and similar technologies

Torian uses cookies and similar technologies (pixels, local storage) to enable platform functionality, measure audience, personalise content and offer a better experience. Categories are:

Strictly necessary
Essential to platform functioning (authentication, security, load balancing). No consent required.
Performance / analytics
Collect aggregated information on how Users interact with the service.
Functionality
Remember preferences (language, theme, time zone, favourite markets).
Advertising & marketing
Enable measuring campaigns and serving relevant content.
12

Children and adolescents' data

Torian's services are exclusively for people 18 or older. We do not intentionally collect data from children (under 12) or adolescents (12–18).

Should inadvertent processing of minors' data be identified, Torian will take immediate steps to delete it, except in the cases of art. 14 of the LGPD. Parents or guardians should contact us through the channels in Section 13.

13

Data Protection Officer (DPO) and contact channels

To exercise rights, request clarifications or report incidents, the Data Subject can reach us through the following channels:

Controller
Torian Market Ltda. — CNPJ 66.518.480/0001-95.
Address
Av. Brigadeiro Faria Lima, 1572, Suite 1022, Jardim Paulistano, São Paulo/SP, ZIP 01.451-917 — Brazil.
General email
murilo@torianmarket.com
Privacy / DPO
privacidade@torianmarket.com
Phone
+55 (11) 4216-1365

The Data Subject also has the right to petition the Brazilian Data Protection Authority (ANPD) directly at www.gov.br/anpd.

14

Informational nature of the services and User responsibility

As Torian is a platform for information, content, intelligence and market predictions, the User acknowledges and agrees that:

  • All content is exclusively informational, educational and analytical.
  • Forecasts reflect probabilistic estimates subject to uncertainty, error and revision. Past results do not guarantee future results.
  • Content does not constitute personalised investment advice, financial consulting or securities analysis subject to CVM or the Brazilian Central Bank.
  • Torian does not know each User's individual financial situation and does not offer personalised advice.
  • Any financial, investment or betting decision based on the content is the User's sole responsibility.
  • The User must critically evaluate the content, consider their own profile and, if appropriate, consult a qualified professional.
  • Torian is not liable for losses, damages or lost profits arising from decisions made by the User based on the platform's content.
15

Automated data processing

Torian uses automated processing — including statistical techniques, quantitative models and AI — mainly to: (i) personalise content delivery; (ii) calibrate forecasts and models; (iii) detect fraud and abuse; (iv) measure engagement and editorial quality.

The User has the right to request review of automated decisions that affect their interests, under art. 20 of the LGPD, by contacting us through Section 13.

16

Changes to this Policy

Torian may update this Policy periodically to reflect changes in services, partnerships, applicable laws or privacy best practices. The current version is always available at www.torianmarket.com.

Material changes will be communicated by registered email or by a highlighted notice on the platform, with reasonable advance notice. Continued use of the services after the new version takes effect constitutes acceptance of the updated terms.

17

Governing law and venue

This Policy is governed by the laws of the Federative Republic of Brazil. The courts of São Paulo/SP are elected as competent to resolve any disputes, except for special venues provided by consumer law.

18

Final provisions

  • Any invalidity of any provision will not affect the others, which remain in force.
  • Torian's tolerance of any non-compliance does not imply novation, waiver or forgiveness.
  • This Policy must be read together with the Terms of Use and the Cookie Policy.
  • This Policy does not create rights other than those expressly provided by applicable law.

Privacy questions?

Reach out to our Data Protection Officer (DPO) — we'll respond as quickly as possible, in line with the Brazilian LGPD.

DPO email
privacidade@torianmarket.com
General email
murilo@torianmarket.com
Phone
+55 (11) 4216-1365
Address
Av. Brigadeiro Faria Lima, 1572, Suite 1022, Jardim Paulistano, São Paulo/SP, ZIP 01.451-917 — Brazil
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