LGPD · Law 13.709/2018
Privacy Policy
Last updated: [CONFIRM date]
[CONFIRM — this document is a structural template within the mockup. It must be reviewed by a lawyer and completed with the company's real details before launch. No company name, CNPJ, address, email or period below is real.]
1. Data controller
The controller of personal data processed through this site is [CONFIRM registered company name], CNPJ [CONFIRM], registered office at [CONFIRM full address], Florianópolis — Santa Catarina, Brazil.
Privacy contact: [CONFIRM DPO email]. Data Protection Officer: [CONFIRM name or “not applicable”].
2. What we collect and why
| Data | When | Purpose | Legal basis (LGPD art. 7) |
|---|---|---|---|
| Name | Booking form | Identify the booking | Pre-contractual steps (item V) |
| Phone / WhatsApp and email | Booking form | Confirm the booking | Pre-contractual steps (item V) |
| Date and number of participants | Booking form | Check availability | Pre-contractual steps (item V) |
| Prior experience / certification | Booking form | Match the activity to the level | Pre-contractual steps (item V) |
| Health declaration | Before the activity, where required | Activity safety — sensitive health data | Consent (item I) |
| Emergency contact | Before the activity | Activity safety | Consent (item I) |
| Analytics cookies | Browsing, if permitted | Measure site usage | Consent (item I) |
| Marketing cookies | Browsing, if permitted | Measure campaigns | Consent (item I) |
⚠ Medical questionnaire — sensitive health data
A diving operation collects a medical questionnaire and health declaration. That is sensitive personal data under art. 11 of the LGPD and requires specific, highlighted consent, restricted access and its own retention period.
So this website collects no health information at all. There is no medical form on any page, and the message field expressly asks you not to write health information there. The questionnaire is completed and signed at the school, on paper or in a dedicated system — never in a web field that lands in an inbox. Who has access, where it is held and for how long: [CONFIRM — legal review].
3. Cookies
Essential cookies keep the site working and remember your consent choice; they cannot be switched off. Analytics and marketing cookies are off by default and are only enabled if you tick the matching option in the banner. You can revisit your choice at any time by clearing site data in your browser.
| Category | Default | Examples | Retention |
|---|---|---|---|
| Essential | Always on | Consent record (stored in your browser) | [CONFIRM] |
| Analytics | Off | [CONFIRM tool — e.g. Google Analytics 4] | [CONFIRM] |
| Marketing | Off | [CONFIRM tool — e.g. Meta Pixel] | [CONFIRM] |
4. WhatsApp
The buttons on this site open a WhatsApp conversation with a pre-filled message. From the moment you send that message, the processing of your data in that app is also governed by Meta Platforms' privacy policy, over which we have no control.
5. Sharing
We do not sell personal data. We share it only with processors necessary to deliver the service:
- Website hosting — [CONFIRM]
- Analytics tool, if permitted — [CONFIRM]
- WhatsApp / Meta Platforms, when you start the conversation
- Public authorities, where legally required
International transfers: [CONFIRM — likely, if hosting or analytics sit outside Brazil. State the countries and safeguards.]
6. How long we keep it
Contact data and enquiries: [CONFIRM period]. Consent records: [CONFIRM period]. After that, data is deleted or anonymised, unless a legal retention duty applies.
7. Your rights (LGPD art. 18)
At any time, free of charge, you may request:
- confirmation that processing exists;
- access to your data;
- correction of incomplete, inaccurate or out-of-date data;
- anonymisation, blocking or deletion of unnecessary or non-compliant data;
- portability to another provider;
- deletion of data processed on the basis of consent;
- information about who we share your data with;
- information about your right to refuse consent and the consequences;
- withdrawal of consent.
To exercise any of these, write to [CONFIRM email]. We will reply within the statutory period. You may also petition the ANPD, Brazil's data protection authority.
8. Security
We apply technical and administrative measures to protect personal data. [CONFIRM measures — e.g. HTTPS, access control, backups]. In the event of a significant security incident we will notify you and the ANPD under art. 48.
9. Minors
This site is not directed at people under 18 and does not knowingly collect children's data. No image on this site depicts children or minors.
10. Changes
We may update this policy. The date at the top shows the last revision. Material changes will be flagged on the site.
Cookies: what exists today
⚠ Floripa Dive’s current site has no cookie consent mechanism at all — mandatory and missing. This mockup implements a granular banner, with analytics and marketing off by default, nothing pre-ticked, and rejecting exactly as easy and as visible as accepting.
The pages /privacy-policy-2/ and /termos-de-uso/ already exist and need review to confirm that they name the controller, the legal basis, the retention period, the art. 18 rights and every processor — including the WooCommerce payment path and the newsletter signup on the homepage. [CONFIRM — legal review]
Booking and payment
The R$ 60.00 per-person deposit is paid by Pix, bank deposit or transfer, and the balance at the school. This site processes no payment and stores no banking data: the form composes a message sent over WhatsApp, and any online purchase happens in your WooCommerce [CONFIRM processor and retention].