Cookie Policy – Trilha CuboPlus

Last updated: 2026-10-22

Trilha CuboPlus uses cookies and similar technologies across its platforms (including public domains, the admin dashboard, and dedicated tenant portals) to optimize system performance, ensure secure logins for students and managers, and deliver a smooth, personalized browsing experience.

This policy transparently explains what cookies are, which types we use, what they are for, and how users can accept, refuse or change their choices, on the site itself or in the browser.

1. What Are Cookies?

Cookies are small text fragments sent by the website and stored in the user's device browser (computer, tablet, mobile). They record specific information that helps the system remember the user's actions and preferences (such as active logins, video player display settings, and learning path progress) over time.

2. Why Do We Use Cookies?

The use of cookies is vital in modern LMS platforms:

• Security & Login: Ensure the student stays securely logged in throughout their study session on their isolated portal, preventing unauthorized access.
• Pedagogical Adjustment: Remember the user's preferred language, video player speed settings, and overall lesson progress.
• Telemetry & Performance: Collect aggregated telemetry metrics about learning path load times and most-used features to guide continuous platform improvement.
• Ad Measurement (only with consent): Know whether a click on a Trilha CuboPlus ad on Google Ads led to a sign-up, contact request or subscription, to assess our ad spend. We do not use cookies for remarketing or to personalize ads.

3. Types of Cookies We Use

On the Trilha CuboPlus public site (such as trilha.cubo.plus and its topic pages), the cookie banner groups these technologies into three categories: Necessary (always on), Statistics and Advertising. Statistics and Advertising are only turned on with your consent, and each one can be accepted or refused separately. Before you choose, no statistics or advertising tool (Google Analytics, Microsoft Clarity or Google Ads) is loaded on these pages.

3.1 Strictly Necessary Cookies (Essential):

• Purpose: Essential for tenant-exclusive portals to function. They enable secure user authentication in the exclusive data vault (dedicated database), maintain session state, and allow free, protected navigation through internal learning path areas.
• On the Public Site: This category includes the record of your choice in the cookie banner and of your preferred language, kept in the browser itself (local storage), and, only while the tab is open, where the visit came from (utm campaign parameters and the landing page), so that a sign-up or contact request records where the visit came from. These records do not identify the person on their own.
• Anti-Bot Protection (CAPTCHA): We use the Cloudflare Turnstile service (cloudflare.com/products/turnstile) as a human verification mechanism in the login and user registration process. Turnstile silently and non-intrusively analyzes browser behavioral signals without displaying visual challenges in most cases, and does not use persistent tracking cookies. Data collected by Turnstile (such as interaction signals and IP address) is processed by Cloudflare, Inc. solely for security purposes, in accordance with Cloudflare's Privacy Policy (https://www.cloudflare.com/privacypolicy/).
• Control: Cannot be disabled in the system, as doing so would completely prevent login and LMS use.

3.2 Functionality Cookies (Preferences):

• Purpose: Store user choices to customize their experience. They remember, for example, the volume level selected in the video player, the selected language, and whether the user chose dark or light mode in the dashboard.

3.3 Statistics Cookies (Telemetry & Performance):

• Purpose: Collect aggregated and 100% anonymized information about how students and managers interact with system features. They help assess Google API stability, identify speed bottlenecks in exclusive portal loading, and refine lesson progress.
• Google Analytics: We use the Google Analytics service (analytics.google.com), provided by Google LLC, to collect and analyze statistical traffic and navigation data on our public domains (such as trilha.cubo.plus), only when the Statistics category is accepted in the cookie banner. Data collected includes information about pages visited, time spent, traffic source, and device type, linked to a random browser identifier (_ga and _ga_* cookies), without directly identifying visitors. IP addresses are anonymized before storage. Use of Google Analytics is subject to Google's Privacy Policy (https://policies.google.com/privacy).
• Sign-up and Contact Request: When the Statistics category is accepted and the visitor signs up or requests contact from the site, this browser's Google Analytics identifier (the client_id and the session start) goes along with the sign-up or request. With it, our server tells Google Analytics that the visit resulted in a sign-up, trial, contact request or subscription, without sending name, email or phone number.
• Microsoft Clarity: On our public domains (such as trilha.cubo.plus), we also use Microsoft Clarity (clarity.microsoft.com), an experience-analytics tool provided by Microsoft Corporation. Clarity generates heatmaps and anonymized session recordings (capturing cursor movement, clicks, and scrolling) to understand how visitors navigate and improve page usability. The tool uses its own cookies (_clck and _clsk), automatically masks sensitive fields and content, and is not used to personally identify visitors. Its activation depends on acceptance of the Statistics category in the cookie banner and may be revoked at any time. Use is subject to Microsoft's Privacy Statement (https://privacy.microsoft.com/privacystatement).
• International Transfer: Google and Microsoft may process this data on servers outside Brazil, which is an international data transfer (art. 33 of LGPD).

3.4 Advertising Cookies (Google Ads Conversion Measurement):

• Purpose: Measure whether Trilha CuboPlus ads on Google Ads, a service of Google LLC, bring results. When a visit comes from an ad, the page address carries a click identifier created by Google (gclid, gbraid or wbraid).
• What We Keep: When the Advertising category is accepted, the click identifier is kept in your browser (local storage) for up to 90 days and goes along when you sign up, ask to talk to a specialist or subscribe to a plan, being recorded with the sign-up or request in our customer relationship management system (CRM). If the Statistics category is also accepted, the Google tag may set its own ad measurement cookies on the site's domain (with names starting with _gcl_). Without Advertising consent, the click identifier is neither kept nor passed on, and Google Analytics receives the page address without it.
• What We Tell Google: When a visitor who gave this consent signs up, asks to talk to a specialist or subscribes to a plan after clicking an ad, we may tell Google which click generated that conversion. Today this only includes the click identifier and the event type (for example, sign-up, contact request or subscription), with the date it happened and, for a subscription, the amount, without name, email or phone number. If this changes, this policy will be updated.
• No Remarketing and No Personalization: We do not use this data for remarketing (advertising again to people who visited the site) or to personalize ads. The ad personalization signal sent to Google is always denied.
• Legal Basis: Consent (art. 7, I, of LGPD), which can be refused or withdrawn at any time, without affecting the use of the site.
• International Transfer: Google processes this data on servers outside Brazil, which is an international data transfer (art. 33 of LGPD). Processing by Google is subject to Google's Privacy Policy (https://policies.google.com/privacy) and to its rules on how Google uses information from sites that use its services (https://policies.google.com/technologies/partner-sites).

4. Cookie Management

• Site Settings: On the first visit to the public site, the cookie banner offers, with the same prominence, "Accept all" and "Essential only", plus "Customize", which lets you accept or refuse Statistics and Advertising separately. The choice is kept in the browser itself.
• Changing or Withdrawing Consent: At any time, the "Cookie preferences" link in the site footer reopens the banner with your current choices. Withdrawing consent is as simple as giving it: when you uncheck a category, we stop loading its tools and delete from the browser the cookies they set on the site domain (_ga, _ga_*, _gcl_*, _clck and _clsk) and, for Advertising, the stored click identifier. Withdrawal applies from that moment on.
• Earlier Choices: Anyone who accepted cookies before October 22, 2026 will see the banner again, because the Advertising category is a new purpose. Until the new choice, only the Statistics category applies.
• Google Consent Mode: We use Google Consent Mode (Consent Mode v2) in its basic version: the Google tag is only loaded after the choice, and the choice is passed on to it.
• Browser Settings: Users can configure or disable cookies at any time by directly changing the privacy settings of their browser (Google Chrome, Firefox, Safari, Microsoft Edge).

Note: Disabling preference or telemetry cookies may limit the functioning of interactive features and integrated platform support. On the public site, refusing Statistics and Advertising does not prevent the use of any feature.