Privacy Policy
Last updated: June 2026
This policy describes how Passos Consultoria collects, uses and protects your personal data, in compliance with the Brazilian General Data Protection Law (LGPD).
Last updated: June 22, 2026
This Privacy Policy (the "Policy") describes, in a transparent manner, how our Organization collects, stores, uses, shares and protects the personal data of its clients, employees, partners and website users, in strict compliance with the Brazilian General Data Protection Law (Law No. 13.709/2018 - LGPD) and other applicable legislation.
1. Scope and Information Collected
Section 1.1 - Data Provided Directly by the Data Subject
We collect information that is essential to providing our services and enhancing your professional experience with us. Such data includes, but is not limited to:
- Identification Data: full name, national ID numbers (CPF, RG), date of birth.
- Contact Information: e-mail address, telephone number and residential/business address.
- Financial Data: payment information, banking details and transaction history required for corporate billing.
Section 1.2 - Data Collected Automatically
For purposes of information security, internal auditing and compliance with legal obligations, our servers record technical browsing data:
- IP address, browser type, operating system, approximate geolocation and history of interactions with our digital platform through cookies and equivalent identifiers.
2. Purpose and Legal Bases for Processing
Section 2.1 - Institutional and Commercial Purpose
In accordance with Article 6 of the LGPD (Purpose Principle), the processing of data is intended for:
- Performance of service agreements or terms of use accepted by the user;
- Management of customer service, technical support and processing of financial requests;
- Communication of security updates, important corporate notices and personalized marketing (subject to the right to opt out).
Section 2.2 - Legal Grounds (Legal Bases)
We ensure that all processing of personal data is supported by a legitimate legal basis, such as:
- Performance of a Contract: necessary to fulfill the established relationship.
- Legitimate Interest: for the development and protection of our operational activities, provided they do not override the fundamental rights of the data subject.
- Compliance with a Legal/Regulatory Obligation: storage of digital records required by regulatory bodies or tax legislation.
- Consent: collected in an express and prominent manner for specific ancillary purposes.
3. Sharing and International Transfer of Data
Section 3.1 - Sharing with Third Parties
The Organization restricts access to personal data to business partners and service providers strictly necessary for operations (e.g., cloud infrastructure providers, payment gateways and external audits). All third parties are contractually bound to maintain strict levels of confidentiality and security equivalent to our standards.
Section 3.2 - International Transfer
Should data be stored on servers located outside the national territory, we ensure that the receiving country or international entity provides an adequate level of protection, using contractual safeguards such as Standard Contractual Clauses.
4. Information Security and Data Retention
Section 4.1 - Technical and Administrative Protection Measures
We adopt strict information security and governance measures to shield data against unauthorized access, leaks or accidental destruction. Among the corporate safeguards in use are encryption of data at rest and in transit, strict control of employee access, and periodic vulnerability audits.
Section 4.2 - Retention Periods
Personal data will be retained only for the period necessary to fulfill the purposes described in this policy, or as required by applicable statutory limitation periods for the corporation's legal defense.
5. Data Subject Rights and DPO Contact
Section 5.1 - Exercise of Rights Guaranteed by the LGPD
Any data subject may, at any time and free of charge, request through our official channel:
- Confirmation of the existence of processing and access to stored data;
- Correction of incomplete, inaccurate or outdated information;
- Anonymization, blocking or deletion of unnecessary data or data processed in non-compliance;
- Withdrawal of previously granted consent.
Section 5.2 - Official Communication Channel (Data Protection Officer / DPO)
For legal questions or requests relating to privacy, please contact our Data Protection Officer (DPO) directly through the standard service address on the privacy portal.
If you prefer, you may consult the regulatory guidelines and the legal source file directly in our repository of original documents or on the government website.
Access the Original Source Text (LGPD Regulatory Source)