Políticas

Privacy Policy

PT/BREN/US

1. Introduction

This Privacy Policy (or simply “Policy”) applies to all data in which CPD Consultoria, Planejamento e Desenvolvimento de Sistemas Ltda. (hereinafter referred to as CPD) acts as the data controller, regardless of how the data was collected (website, business cards, social media, phone calls, etc.).

We are committed to protecting the personal data to which we have access during our operations.

We declare that we will process personal data in accordance with applicable laws.

We inform you that we use cookies on our website. For more information, please refer to our Cookie Policy.

2. How CPD Uses Personal Data

  • Website access data, such as your IP address, browsing information, and physical location, may be used for statistical purposes related to website access and navigation.
    Legal Basis (Brazilian LGPD - Law 13.709/2018): Art. 7, I - "upon the data subject's consent" (requested prior to browsing).
  • Navigation data collected by third-party services embedded in our website (Google, YouTube, Facebook), which may be used to deliver personalized ads during your navigation.
    Legal Basis: Art. 7, I - "upon the data subject's consent".
  • Data collected through website forms, which may include full name, email, phone number, company, and job title. These may be used for email or phone contact, limited to offers from our product/service portfolio.
    Legal Basis: Art. 7, I - "upon the data subject's consent".
  • Data collected in person at events, client visits (or potential clients), and business meetings, including full name, email, phone, company, and job title, for contact purposes limited to offering our products/services.
    Legal Basis: Art. 7, I - "upon the data subject's consent".
  • Data provided for product/service delivery, including name, ID documents (CPF, RG), address, email, phone, company, and role. Used for contract maintenance and communication related to contracted services.
    Legal Basis: Art. 7, V - "necessary for performance of a contract or preliminary procedures requested by the data subject".
  • Data provided through blogs or social media, such as name, email, phone, company, and job title, may be used for contact regarding product/service offerings.
    Legal Basis: Art. 7, I - "upon the data subject's consent".
  • Note: Publicly disclosed data may be used without consent as per Art. 7, §4 - “Consent is waived for data manifestly made public by the data subject.”
  • Data for employee hiring, including personal identification documents, address, email, phone, bank information, spouse and children data, health data, and others required by law, for employment contract management.
    Legal Basis: Art. 7, V - "necessary for performance of a contract".
  • Data for recruitment and selection, including personal and academic background, address, email, and phone, used to evaluate candidates.
    Legal Basis: Art. 7, V - "necessary for preliminary steps related to a contract".
  • All personal data may be used to exercise or defend legal claims in judicial, administrative, or extrajudicial proceedings.
    Legal Basis: Art. 7, VI - "for regular exercise of rights in legal, administrative, or arbitration proceedings".
  • All personal data may be used for risk management, obtaining/maintaining insurance coverage, or professional advice.
    Legal Basis: Art. 7, IX - "necessary to serve the legitimate interests of the controller or third party".
  • All personal data may be used to comply with legal obligations to which CPD or the data subject is subject.
    Legal Basis: Art. 7, II - "to comply with a legal or regulatory obligation".
  • All personal data may be used for credit protection activities.
    Legal Basis: Art. 7, X - "for credit protection, including under relevant legislation".

3. Data Sharing

  • We may share your personal data with suppliers and/or business partners for contract preparation and product/service delivery.
  • We may share your data with insurers or professional consultants for risk management, insurance coverage, or legal/administrative purposes.
  • We may share your data with financial institutions for product/service billing.
  • We may share your data with digital marketing service providers, including email platforms. In such cases, data will only be shared if explicit consent has been obtained.
  • We may share data when legally required or necessary to protect the vital interests of the data subject or third parties.

4. International Data Transfers

International data transfer refers to any processing of personal data outside Brazil.
Indirect personal data collected via cookies may be processed by entities located outside Brazil (e.g., Google, YouTube, LinkedIn, Facebook, Instagram).
Data collected via forms is processed by Zoho Corporation's CRM, based in India.
Data related to signed contracts is processed using Microsoft Office 365, headquartered in the U.S.
All international data transfers are protected through encrypted connections, and service providers comply with applicable data protection laws.

5. Data Retention and Termination of Processing

Data collected with consent will be used as long as the data subject remains interested. The subject may revoke consent at any time, and the data will be deleted within 7 business days.
Data processed under contracts will be retained until the end of the contractual term.
All data may be retained to fulfill legal obligations.

6. Data Subject Rights

Data subjects whose personal data is processed by CPD are entitled to the following rights:

  • a) Confirmation of data processing;
  • b) Access to personal data;
  • c) Correction of incomplete, inaccurate, or outdated data;
  • d) Anonymization, blocking, or deletion of unnecessary or non-compliant data;
  • e) Data portability to another provider;
  • f) Deletion of data processed with consent;
  • g) Information about public and private entities with whom data has been shared;
  • h) Information about the possibility and consequences of not providing consent;
  • i) Revocation of consent.

You may exercise your rights by contacting lgpd@cpd.com.br.
To protect your privacy, CPD reserves the right to verify your identity before fulfilling requests related to your data.

7. Data Subject Responsibilities

  • Review this Privacy Policy;
  • Provide accurate and truthful information;
  • Notify us of any changes to your data through official channels;
  • Do not provide third-party data without authorization;
  • Be liable for any false, excessive, or inaccurate data provided and for any damage caused to CPD or third parties.

8. Data Security and Protection

  • CPD stores personal data in secure repositories and performs regular backups to ensure availability.
  • All personal data transmissions occur over encrypted channels.
  • Devices used to access personal data are protected by security software.
  • Processors selected for data handling follow strict data protection and security policies.

9. Changes to This Policy

This policy may be updated at any time and will remain available at: Privacy Policy.
Updates will not be individually notified, so we recommend checking this page periodically.

10. Our Company Information

  • Legal Name: CPD Consultoria, Planejamento e Desenvolvimento de Sistemas LTDA.
  • Trade Name: CPD
  • CNPJ: 00.395.228/0001-28
  • Address: SAUS Quadra 5, Bloco N, Ed. OAB, Rooms 1113, 1115, 1117, 1119, 1121, and 1122, Asa Sul - Brasília/DF
  • ZIP Code: 70070-913
  • Phone: +55 (61) 2104-3200
  • Email: lgpd@cpd.com.br

11. Data Protection Officer (DPO)

Last updated on July 9, 2024.