This Privacy Policy describes how PRIOS Consultoria & Estratégia (Brazilian company registration number, CNPJ [to be completed: CNPJ]) (“PRIOS”, “we”) collects, uses, stores and protects the personal data of those who visit this site and use our contact channels.
PRIOS is subject to Brazilian data protection law — Law No. 13,709/2018 (LGPD). Where you are located in the European Economic Area, processing is also governed by the General Data Protection Regulation (EU) 2016/679 (GDPR), and this Policy sets out the rights it gives you.
By browsing this site or sending us your details through our forms and channels, you confirm that you have read this Policy.
1. Who the controller is
PRIOS is the controller of the personal data processed through this site — that is, we decide the purposes and means of the processing. For anything to do with privacy, including exercising your rights, please write to:
- Email: sac@priosestrategia.com
2. What data we collect
2.1. Data you give us
When you complete the contact form or request a business assessment, we collect the details you provide, such as:
- Name;
- Name of the clinic or private practice;
- Phone/WhatsApp number;
- Your message and anything else you choose to share.
2.2. Data collected automatically
This is a static site and it uses no web analytics, no social media pixels and no third-party trackers. What does exist is the hosting server's access log, common to any website: IP address, date and time, page requested and browser identification. Those logs serve the security and operation of the service and are not used to profile visitors.
3. What we use the data for
- Replying to your enquiries and arranging the free business assessment;
- Contacting you about our services when you ask us to;
- Keeping the site available, secure and working properly;
- Meeting legal and regulatory obligations;
- Preventing fraud and safeguarding information security.
4. Legal basis for processing
We process your data on the following bases: the consent you give when you send us a form (Art. 6(1)(a) GDPR; Art. 7, I, LGPD), our legitimate interest in maintaining and improving the site and our communications (Art. 6(1)(f) GDPR; Art. 7, IX, LGPD) and compliance with legal obligations (Art. 6(1)(c) GDPR; Art. 7, II, LGPD).
5. Cookies and tracking technologies
Cookies are small files stored on your device. This site sets no analytics or advertising cookies, which is why you are not asked to consent to any. Should that change — for example, if an audience measurement tool were adopted — this Policy would be updated and your consent would be obtained before any such cookie is set, as required by the GDPR and the ePrivacy rules.
6. Who we share data with
PRIOS does not sell personal data. We share data only with:
- Technology providers supporting the operation of the site and our communications — the hosting company and the messaging services you choose to reach us through, such as WhatsApp — subject to their own privacy policies;
- Authorities, where required by law or court order.
7. International transfers
PRIOS is based in Brazil, a country that currently has no adequacy decision from the European Commission. Where data of users in the European Economic Area is transferred to Brazil or to providers outside the EEA, the transfer relies on the safeguards in Chapter V of the GDPR, in particular the standard contractual clauses adopted by the European Commission. You may request information about these safeguards at the address given in section 1.
8. How long we keep data
We keep personal data only for as long as is necessary for the purposes in this Policy or to meet legal obligations. After that, the data is erased or anonymised.
9. Your rights
Under the GDPR you may exercise the following rights at any time:
- Access to your personal data and to information about how it is processed;
- Rectification of inaccurate or incomplete data;
- Erasure of data that is no longer necessary;
- Restriction of processing;
- Portability of the data you have provided to us;
- Objection to processing based on legitimate interest;
- Withdrawal of consent at any time, without affecting the lawfulness of processing carried out beforehand.
The LGPD additionally gives you the right to request the anonymisation or blocking of unnecessary data and information about the parties with whom your data is shared.
To exercise these rights, write to the address in section 1. If you believe your data has not been handled properly, you may lodge a complaint with the competent supervisory authority: in Ireland, the Data Protection Commission (dataprotection.ie); in Spain, the Agencia Española de Protección de Datos (aepd.es); in Brazil, the ANPD.
10. How we protect your data
We apply technical and organisational measures to protect personal data against unauthorised access, loss or alteration. No system is entirely free of risk, but we work continuously to reduce it.
11. Changes to this Policy
We may update this Policy from time to time. The date of the last update is always shown at the top of this page. We recommend reviewing it occasionally.
12. Contact
Questions about this Policy or about how your data is handled can be sent to sac@priosestrategia.com.