Privacy Policy
Last updated: [DATE — pending legal review]
Draft: this document is an initial template, framed by the Brazilian General Data Protection Law (LGPD, Law no. 13,709/2018), and has not undergone legal review. Bracketed fields must be filled in before official publication.
1. Controller
[VASTA LEGAL ENTITY NAME], CNPJ [CNPJ], with registered offices at [ADDRESS], is the controller of personal data processed on tryproa.com and the Proa platform. Data Protection Officer (DPO): [DPO NAME AND CONTACT].
2. What data we process
- Contact data: name, email, and the messages you send when reaching out to us;
- Account data: credentials and usage records of the platform by subscribing customers;
- Data from customers' stores: when operating the platform on our customers' stores, we process aggregate browsing and purchase events (visits, orders, and amounts), without building individual visitor profiles and without third-party tracking cookies. In this case we act as a processor, under the instructions of the customer that owns the store.
3. Why we use it
- To answer inquiries and schedule demos (LGPD art. 7, V — pre-contractual procedures);
- To provide, maintain, and improve the Service (art. 7, V — performance of contract);
- To comply with legal and regulatory obligations (art. 7, II);
- To exercise rights in legal proceedings (art. 7, VI).
4. Sharing
We do not sell personal data. We share data only with processors necessary to provide the Service (for example, hosting and infrastructure providers), under contract and with adequate safeguards, or when required by law. International transfers, when they occur, follow the requirements of LGPD art. 33.
5. Cookies
The tryproa.com website uses no advertising cookies and no third-party tracking cookies. We may use cookies strictly necessary for the website to function.
6. Retention
We keep data for as long as necessary for the purposes in this Policy or for periods required by law. When processing ends, data is deleted or anonymized, except in the cases provided for in LGPD art. 16.
7. Your rights
Under LGPD art. 18, you may request: confirmation of processing, access, correction, anonymization, portability, deletion, information about sharing, and review of automated decisions. To exercise your rights, write to [DPO EMAIL]. We will respond within the timeframes set by law.
8. Security
We adopt technical and organizational measures proportional to the risk of processing, including access control, encryption in transit, and operation logging. No system is infallible; relevant incidents will be communicated to the Brazilian authority (ANPD) and to data subjects under LGPD art. 48.
9. Changes to this Policy
We may update this Policy. The current version will always be available on this page, with its last-updated date.
10. Contact
Privacy questions: hello@tryproa.com.