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 | Enrolment / contact form | Identify the enquirer | Pre-contractual steps (item V) |
| Phone / WhatsApp and email | Form | Reply to the enquiry | Pre-contractual steps (item V) |
| Level / study goal | Form | Recommend the right class | Pre-contractual steps (item V) |
| Placement test result | If taken | Place in the correct class | Consent (item I) |
| Enrolment details | At enrolment, off the website | Formalise the contract | Legal obligation (item II) |
| Analytics cookies | Browsing, if permitted | Measure site usage | Consent (item I) |
| Marketing cookies | Browsing, if permitted | Measure campaigns | Consent (item I) |
WhatsApp is the only published contact channel. Enrolment and the trial class happen there, so your number, your name and the content of the conversation sit in the school's WhatsApp Business account and under Meta Platforms' policy, over which we have no control. This site collects no health form, injury, pregnancy or any health data through a form - that information is handled in person with the teacher. [CONFIRM whether a pre-practice health form exists and how it is stored]
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.
Third parties this site uses
The school's live site loads three third-party services that have to be named here, each with its transfer basis, purpose and retention period:
- Google Tag Manager (GTM-WB4LPM3) - site usage measurement. Loads only with analytics consent. [CONFIRM which tags run inside the container]
- Mailchimp - newsletter delivery. Newsletter consent is separate from and independent of enrolment, and can be withdrawn at any time.
- Instagram feed (Meta) - embedded posts. Loads only with marketing and embeds consent.
In this mockup none of the three is loaded under any circumstances: the consented branch is deliberately empty.
Annual membership and the right of regret
The annual online membership is a distance contract with recurring billing. The full annual price, how it renews, the cancellation route and the 7-day right of regret (CDC art. 49) must be visible before signup. [CONFIRM the real terms]
Policy and terms: two different documents
On the live site, the footer link labelled "Termos de Uso" points at the privacy policy, and there is no separate terms page. They are distinct documents with distinct purposes, and in this build they are separated.