Consigo — Creator Terms of Service and Data Processing Agreement (DPA)

Version 1.0 — June 2026

This document regulates the legal relationship between Jeff Monteiro (developer and operator of Consigo) and the Creator (user of the ULTRA and/or CREATOR plans who publishes, shares routines, or uses the "Lead Machine" feature).

By activating the CREATOR plan, sharing a routine, or configuring a lead capture webhook in the Consigo application, you accept this Agreement in its entirety.

1. Purpose and Definitions

1.1. Creator (or Publisher): Natural or legal person registered under the ULTRA or CREATOR plan who creates, exports, and makes habit routines available to other app users.

1.2. Follower: App user of Consigo who imports and executes a routine shared by a Creator.

1.3. Lead Machine: Integration technology provided by Consigo that allows the Creator to request and receive contact data (Name, Email, Phone number) and progress events of the Follower, subject to the Follower's consent, triggered directly to the Creator's webhook.

1.4. Webhook: Secure HTTPS address configured by the Creator to receive the data generated by the Lead Machine.

2. Intellectual Property and Routine Licensing

2.1. By exporting and sharing a routine in Consigo, the Creator grants Consigo a worldwide, non-exclusive, royalty-free, sublicensable, and transferable license to host, display, distribute, and reproduce said routine within the platform.

2.2. The Creator grants Followers who import the routine a personal, non-exclusive, non-transferable, and free license to view, edit (locally), and practice the activities proposed in the routine.

2.3. The Creator declares to be the author or legitimate owner of the copyright of all content inserted in their routines (texts, images, links). It is prohibited to include content that violates the intellectual property of third parties, or is defamatory, pornographic, or illegal.

3. Data Processing Agreement (DPA) — Lead Machine

3.1. Relationship and Roles under LGPD

The Creator acts as an Independent Data Controller (Art. 5, VI of the LGPD) for all Follower information received through the Lead Machine. The purpose and how this data will be used post-collection are at the sole discretion of the Creator.

Consigo acts as a Data Processor (Art. 5, VII of the LGPD) or a mere technical transmission channel, providing the infrastructure to capture consent and forward the data securely to the Creator. Consigo does not store information received by webhook beyond the technical transit period.

3.2. Obligations of the Creator (Controller)

The Creator commits to:

1. Legal Basis: Use Follower data exclusively under a valid legal basis of the LGPD. If the Follower revokes consent, the Creator must immediately cease processing.

2. Transparency: Provide a clear and accessible Privacy Policy to Followers in the external link of their routine, detailing how the collected leads will be processed by their organization.

3. Data Subject Rights: Respond directly and in a timely manner to Followers' requests for access, correction, deletion, or portability of their personal data.

4. Appropriate Purpose: Do not use the received data for purposes other than those informed to the Follower at the moment of consent (e.g., sending spam, selling the lead database, or using it for advertising purposes unrelated to the imported routine).

5. Security and Incident Notification: Maintain strict information security measures on the webhook receiving server. In case of security incidents or data leaks in their systems, the Creator must notify the ANPD and the affected data subjects, assuming full responsibility and exempting Consigo from any burden.

3.3. Webhook Configuration

1. The Creator is obliged to provide a Webhook URL with mandatory support for encrypted connections (HTTPS).

2. The Creator assumes sole responsibility for attacks, inoperability, or slowness on their own receiving servers.

4. Disclaimer and Indemnity

4.1. Consigo does not audit or control the Creator's activities outside the application environment. We are not responsible for the content of communications sent by the Creator to the Follower outside the application.

4.2. Indemnity Clause: The Creator agrees to defend, indemnify, and hold Consigo (and Jeff Monteiro) harmless from any claim, lawsuit, administrative proceeding, ANPD fine, loss, or expense (including attorney fees) arising from:

Leak or misuse of personal data collected by the Lead Machine under the Creator's responsibility;

Violation of copyrights or third-party intellectual property in the content of the published routine;

Breach of any term of this Agreement or applicable legislation (LGPD and the Consumer Defense Code).

5. Suspension and Termination of Service

5.1. Consigo reserves the right to remove routines, disable webhook integrations, or ban Creator accounts immediately, without refund and without prior notice, if:

Abuse of the Lead Machine is identified (such as collecting data for phishing, spam, or scams);

The Creator's webhook is generating excessive errors or being flagged as an attack vector against third parties (DDoS);

There are substantiated reports from Followers about harassment, fraud, or copyright violation in the shared routine.

5.2. In case of cancellation of the CREATOR plan subscription by the creator, the Webhook (Lead Machine) functionality will be automatically suspended. The data transmission will cease on the subscription expiration date.

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