Privacy policy

Version 1 · Effective 2026-10-29

This policy explains how AKM DDBG LLC processes the personal data it receives through the contact form on this website: what data it collects, for what purposes and on what legal bases, where the data is processed, how long it is retained, and how you can exercise your rights. In this policy, “GDPR” means Regulation (EU) 2016/679, the General Data Protection Regulation, and “LGPD” means Brazilian Law No. 13,709/2018, the Lei Geral de Proteção de Dados Pessoais.

1. Controller

Controller: AKM DDBG LLC, which operates the website dbngadvisory.com under the name DBNG Advisory.
Contact for personal data inquiries: privacy@dbngadvisory.com.
Channel for data subjects in Brazil: privacy@dbngadvisory.com. You can write to us in Portuguese and we will reply in Portuguese.

2. Data we collect

Data you provide in the form: name, email address and message (required) and company (optional). Without the required data, we cannot respond to your inquiry.
Technical data relating to the submission: IP address, date and time, used to prevent automated submissions and misuse of the form.

We do not request sensitive data. Please do not send financial information through this channel.

3. Purposes and legal bases

Purpose	European Union and EEA (GDPR, Article 6(1))	Brazil (LGPD, Article 7)
Responding to your inquiry and, if you request it, preparing a proposal	Steps taken at your request prior to entering into a contract, point (b)	Preliminary procedures relating to a contract, at your request, item V
Preventing misuse and protecting the website (IP address and anti-spam measures)	Legitimate interest in the security of the website, point (f)	Legitimate interest, item IX
Sending INSIGHTS, only if you checked the subscription box	Consent, point (a)	Consent, item I

The “I have read the privacy policy” box on the form only records that this policy was made available to you; it is not consent and it is not the legal basis for any processing.

Your data is not used for any other purpose, is not sold, and is not subject to automated decision-making or profiling.

4. Recipients of the data

Service providers, which process the data solely on our behalf and under contract:
- website and email hosting: Hostinger, with servers in the United States (Massachusetts);
- sending INSIGHTS, if you checked the subscription box: this is done with phpList, software installed on the same Hostinger hosting, with no other provider involved.
Competent authorities, where required by law or by court order.

5. Place of processing and international transfers

Servers. The servers are provided by Hostinger and located in the United States (Massachusetts). Hostinger processes the data on our behalf, as a processor, under its data processing agreement.
Team. Our team accesses the data from a country recognized by the European Commission as providing an adequate level of data protection, always under confidentiality obligations.
Safeguards for the European Union and the European Economic Area. Hostinger’s data processing agreement incorporates the standard contractual clauses adopted by the European Commission (Commission Implementing Decision (EU) 2021/914).
Safeguards for Brazil and other countries. We apply the instrument required by each applicable law, including the LGPD for data of data subjects in Brazil.

You can ask us for more information about these safeguards, and for a copy of them, at privacy@dbngadvisory.com.

6. Retention periods

Form data: 24 months from the date of the inquiry.
IP address: 90 days.
INSIGHTS subscription: your email address and the record of your consent are retained for as long as the subscription remains active.
Unsubscribing from INSIGHTS: only your email address is retained, on a suppression list, so that no further communications are sent to you.

7. Your rights

In all cases, you may request access to, rectification of, or erasure of your data, and unsubscribe from our emails. Please send your requests to privacy@dbngadvisory.com. As a general rule, we will respond within one month; the specific time limit for Brazil is set out below.

If you are in the European Union or the European Economic Area, under Articles 15 to 22 GDPR you may also:
- request restriction of processing and portability of your data;
- object at any time, on grounds relating to your particular situation, to processing based on our legitimate interest;
- not be subject to a decision based solely on automated processing (we do not take decisions of that kind);
- withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
- lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work, or place of the alleged infringement: for example, in Italy, the Garante per la protezione dei dati personali (www.garanteprivacy.it); in Spain, the Agencia Española de Protección de Datos (www.aepd.es).
If you are in Brazil, you may also:
- request confirmation of the existence of processing;
- request the anonymization, blocking, or deletion of data that is unnecessary, excessive, or processed in breach of the LGPD;
- request the portability of your data;
- request the deletion of data processed on the basis of your consent;
- request information about the entities with which we share your data;
- request information about the possibility of not giving your consent and about the consequences of refusing;
- revoke your consent;
- lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD).

For data subjects in Brazil, confirmation of the existence of processing and access to the data are provided immediately, in simplified form, or within 15 days of the request, by means of a clear and complete statement (Article 19 LGPD).

Requests from Brazil can be sent in Portuguese to the same channel: privacy@dbngadvisory.com. Versão em português desta política: dbngadvisory.com/pt/privacidade/.

8. Security measures

To protect your data, we apply the following measures:

access restricted to the people who need the data to perform their duties;
two-factor authentication on the hosting control panel;
files containing form data that are not accessible from the web;
service providers bound by confidentiality obligations;
notification without delay of any incident that may affect you.

9. Cookies and browser storage

Cookies and third-party tools. This website does not use cookies or any third-party analytics, advertising, or tracking tools.
Language preference. If you choose a language, that preference is stored in your browser’s local storage (localStorage), under the key dbng.lang, so that the website is displayed in that language. It does not leave your device, and you can delete it in your browser settings.
Changes. If this changes, we will update this policy before the change takes effect.

10. Confidential information about your company

Any information about your company that you provide at a later stage for an engagement will be governed by the confidentiality agreement that will be signed before we receive it.

11. Changes to this policy

Each new version of this policy is published with its effective date. If a change affects the processing of data we already hold, we will notify you by email.