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) |
Health and physical risk. Surfing carries real risk, and before any lesson or surf guide trip there should be a signed liability waiver and medical-condition disclosure. Those documents process health data, which the LGPD classifies as sensitive (art. 11): they need their own legal basis, restricted access and a defined retention period. [CONFIRM whether the form exists and how it is stored] This site collects no health data through any form.
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.
Cloudbeds and accommodation booking
Booking for all three units is processed by Cloudbeds, a third-party processor. Clicking "Book direct" takes you off this site and into Cloudbeds' privacy policy, over which we have no control. Booking, ID and payment data are collected there, not here. International transfer basis, retention period and sub-processors [CONFIRM].
Google Tag Manager
The live site loads Google Tag Manager. In this architecture it is injected only after analytics consent; without consent no tag loads. In this mockup the consented branch is deliberately empty: nothing is measured and nothing is sent. [CONFIRM which tags run inside the container]
Guest registration
Accommodation carries its own guest-registration obligations. Which data is required by law, how long it is kept and who has access [CONFIRM].