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 | Tour / proposal form | Identify the enquiry | Pre-contractual steps (item V) |
| Phone / WhatsApp and email | Form | Reply to the enquiry | Pre-contractual steps (item V) |
| Company and headcount | Form | Size the proposal | Pre-contractual steps (item V) |
| Plan of interest and start date | Form | Prepare the proposal | Pre-contractual steps (item V) |
| Contract details | At contracting, 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) |
| Plan of interest | Contact form | To reply already knowing which plan family is of interest | Preliminary steps to a contract (item V) |
| Biometric access data | Joining a plan with 24/7 access | To open the door. Biometric data is sensitive personal data (LGPD art. 5, II) with its own regime — see the dedicated section below | Specific, highlighted consent (art. 11, I) |
| Company incorporation documents | Taking a fiscal address | To support registering the company at the address and to receive its mail | Performance of a contract (item V) and compliance with a legal obligation (item II) |
| Browsing identifiers (Google Analytics G-MEN03LDY6T) | Only after analytics consent | Audience measurement | Consent (item I) — never legitimate interest |
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.
Biometrics: sensitive data, its own regime
Tarrafa’s 24/7 access works by biometric reading. Under the LGPD, biometric data is sensitive personal data (art. 5, II) and may only be processed with specific, highlighted consent (art. 11, I) — never buried in the plan contract or in a general clause.
In practice that means a separate authorisation stating what is collected, where it is stored, who has access, how long it is kept and what happens when the plan ends. [CONFIRM the access-system vendor, whether what is stored is the fingerprint image or only a mathematical template, where the data is hosted, and the deletion period after the contract ends]
Anyone who does not want to register biometrics needs an alternative way in. [CONFIRM what it is]
Fiscal address and mail
Taking a fiscal address means Tarrafa holds your company incorporation documents and receives your company’s mail — including mail from public bodies, which usually carries a deadline. The contract has to state exactly how mail is received, notified, held and returned, and what happens to it on termination. [CONFIRM the terms]
Tarrafa does not open third-party mail. [CONFIRM — if envelopes or contents are scanned, that is additional processing and has to be written down]
Cookies and Google Analytics
This site uses Google Analytics, property G-MEN03LDY6T, loaded through MonsterInsights. It is an analytics cookie, it is off by default, and it only loads after you tick “Analytics” in the cookie bar. Legal basis: consent (art. 7, item I). [CONFIRM the retention configured on the property and whether IP anonymisation is on]
An honest note about the current banner. The cookie notice on Tarrafa’s live site presents its entire privacy text and every category description in English, to Brazilian visitors, on a Portuguese-language site. Consent read in a language the person was not addressed in is not informed consent. On top of that, the primary action is a plain “Accept”, with the granular controls hidden behind “Settings”. Here, rejecting sits beside accepting at the same size, and nothing is pre-ticked.
Retention
Enquiries that did not become a plan [CONFIRM]. Active and closed contracts follow the applicable tax and civil periods [CONFIRM]. Biometric data [CONFIRM — and it should be the shortest of the three].
Plan terms
Minimum term, cancellation notice, renewal and refund conditions for each plan family — hot desk, dedicated desk, private office and virtual office — [CONFIRM all of them]. None has been written here, because an invented cancellation clause is worse than a missing one.
Map
No third-party map is embedded. The location block is a drawing of our own and, on the published site, becomes a link out to the visitor’s own maps app.