Privacy Policy
Draft subject to legal review before publication
Last updated: [insert date]
1. Who the controller is
[Insert legal name], registered under Brazilian company ID (CNPJ) no. [insert], headquartered at [insert address] (“DxCA”), is the controller of the personal data processed on this website, under Law No. 13,709/2018 (Brazilian General Data Protection Law, LGPD).
Data Protection Officer: [insert name or channel of the DPO], by email at [insert DPO email].
2. Data we collect
When you talk to Dax, our AI agent, or contact us on WhatsApp, we may receive:
- The messages you send, including the description of your challenge
- Your name and company, if you provide them
- Your email and phone number, if you provide them
Dax is an artificial intelligence: her answers do not replace a technical assessment by our team. [Describe where conversations with Dax are stored and for how long.]
While you browse, technical data such as IP address, browser type and pages visited may be recorded. [Describe the analytics tool, if any, and whether it uses cookies.]
3. How we use the data
- To respond to your request and contact you through the channels you provided
- To assess the challenge described and prepare an initial conversation
- To keep the website secure and running
We do not ask for secrets, credentials or sensitive data. Please do not include them in your conversations.
4. Legal bases
We process the data you share in conversations to carry out preliminary procedures related to a contract, at the data subject's request (LGPD, art. 7, V), and, where applicable, based on your consent (art. 7, I). Technical browsing data is processed based on legitimate interest (art. 7, IX), for the security and improvement of the website. [Validate the legal bases with the legal team.]
5. Sharing
We do not sell personal data. Data may be processed by service providers such as website hosting, email delivery and customer relationship management, always on our behalf and under confidentiality obligations. [List the approved providers and any international data transfer.]
6. How long we keep data
We keep data for as long as needed to handle your request and meet legal obligations. [Define the retention period for contacts received through the website.]
7. Cookies
[State whether the website uses only essential cookies or also analytics cookies, and how visitors can manage these choices. If applicable, publish a separate Cookie Policy.]
8. Your rights
Under article 18 of the LGPD, you may at any time request:
- Confirmation that processing exists and access to the data
- Correction of incomplete, inaccurate or outdated data
- Anonymization, blocking or deletion of unnecessary data
- Portability of the data to another provider
- Information about who the data has been shared with
- Withdrawal of consent, when consent is the basis for processing
- To lodge a complaint with the National Data Protection Authority (ANPD)
9. Security
We adopt technical and administrative measures to protect personal data against unauthorized access and accidental or unlawful destruction, loss, alteration or disclosure.
10. Contact
To exercise your rights or ask questions about this policy, contact the DPO: [insert DPO email].