This is a courtesy translation. In case of any discrepancy, the Portuguese version of this Policy prevails.
DACH DIGITAL
Dach Digital Consultoria e Soluções Digitais
CNPJ (Brazilian company registry) no. 19.748.647/0001-24
Avenida Paulista, 302 — Bela Vista — São Paulo/SP, Brazil. Zip code: 01.310-000
Privacy contact: web@dachdigital.com.br
1. About this Policy
1.1. This Privacy Policy explains how DACH DIGITAL handles the personal data of anyone who visits dachdigital.com.br, fills in our forms or contacts us through the channels listed here.
1.2. It was written to comply with Law no. 13,709/2018 (the Brazilian General Data Protection Law, or LGPD) and with the Brazilian Internet Civil Framework (Law no. 12,965/2014).
1.3. This Policy covers our website. The data processing we perform while running campaigns and tools for clients is governed by the service agreement signed with each client, in which DACH DIGITAL acts as processor, following the instructions of the client as controller.
1.4. By continuing to browse, you confirm that you have read this Policy. The use of non-essential cookies depends on your consent, collected through the notice shown on your first visit.
2. What data we collect
2.1. Data you provide. When you fill in the contact form we collect your name, e-mail, company, the address of your website or store, and the message you write. Those are the only fields we ask for: we do not request identity documents, financial data or sensitive personal data.
2.2. Data collected automatically. While you browse, the following may be recorded: IP address, browser type and version, operating system, language, pages visited, time spent, traffic source (an ad or a search, for example) and cookie identifiers.
2.3. Communication data. If you write to us by e-mail, WhatsApp or social media, we keep the content of the conversation and the contact details you provide.
2.4. We do not intentionally collect data from children or adolescents. If we identify a record in that situation, it will be deleted.
3. Why we process this data, and on what legal basis
3.1. To respond to an enquiry and prepare a proposal. Legal basis: preliminary procedures related to a contract, at the request of the data subject (art. 7, V, LGPD).
3.2. To send communications about our services and content to people who have shown interest. Legal basis: legitimate interest (art. 7, IX), always with an unsubscribe option in every message.
3.3. To measure the performance of the site and of campaigns, understand where visits come from and improve the pages. Legal basis: consent for non-essential cookies (art. 7, I) and legitimate interest for aggregated metrics.
3.4. To keep the site secure and maintain access logs. Legal basis: compliance with a legal obligation (art. 7, II, together with art. 15 of the Internet Civil Framework).
3.5. To exercise rights in judicial, administrative or arbitration proceedings where necessary. Legal basis: art. 7, VI, LGPD.
3.6. We do not use your data for automated decisions producing legal effects on you.
4. Cookies and measurement technologies
4.1. Cookies are small files stored in your browser. We use three groups:
- Essential: they make the site work, storing for example your language choice, the light or dark theme and your cookie decision itself. They do not require consent.
- Measurement: they help us understand, in aggregate, how the pages are used. They may include Google Analytics 4 and Google Tag Manager.
- Advertising: they allow us to measure ad effectiveness and present more relevant campaigns. They may include Google Ads and Meta Pixel.
4.2. Measurement and advertising cookies are only activated after you accept them in the cookie notice. Until then we apply the platforms' consent mode, which restricts the use of identifiers.
4.3. You can change your mind at any time: clear the site data in your browser so the notice appears again, or block cookies in your browser settings. Blocking essential cookies may impair how the pages work.
5. Who we share data with
5.1. We do not sell personal data.
5.2. We share only what is necessary with suppliers that operate on our behalf, under contract and a duty of confidentiality:
- Hosting and infrastructure providers, which store the website and the database;
- Measurement and advertising platforms such as Google and Meta, when you consent to the corresponding cookies;
- E-mail and customer relationship management tools, used to answer your enquiry and organise the commercial follow-up.
5.3. We may also share data in response to a court order, a request from a competent authority or a legal obligation.
6. International data transfers
6.1. Some of the tools mentioned above are operated by companies based outside Brazil, which may involve international data transfers, particularly to the United States.
6.2. In those cases we require contractual protection guarantees from suppliers that are compatible with the LGPD, under its art. 33.
7. How long we keep data
7.1. Commercial contact data: for the duration of the conversation and for up to 5 (five) years after the last contact, in line with the limitation period for commercial claims.
7.2. Website access logs: 6 (six) months, as required by art. 15 of the Internet Civil Framework.
7.3. Measurement data in third-party tools: for the retention period configured in each platform, typically 2 (two) to 14 (fourteen) months.
7.4. Once the period ends, data is deleted or anonymised, unless the law requires longer retention.
8. Security
8.1. We apply technical and administrative measures to protect your data, including encrypted connections (HTTPS) across the site, access control to the administration panel, separation between environments and periodic backups.
8.2. No system is completely immune. If a security incident occurs with relevant risk to your rights, we will notify you and the Brazilian National Data Protection Authority (ANPD), as required by art. 48 of the LGPD.
9. Your rights
9.1. The LGPD grants you the right, at any time and free of charge, to:
- Confirm that we process your data and access it;
- Correct incomplete, inaccurate or outdated data;
- Request the anonymisation, blocking or deletion of unnecessary data or data processed unlawfully;
- Request the portability of your data to another supplier;
- Delete data processed on the basis of your consent;
- Know which entities we share your data with;
- Be informed about the option not to consent and the consequences of refusing;
- Withdraw consent;
- Object to processing carried out on the basis of legitimate interest.
9.2. To exercise any of these rights, write to web@dachdigital.com.br. We will reply within 15 (fifteen) days. We may ask for additional information to confirm your identity before acting on the request, a safeguard that exists in your favour.
9.3. You may also file a complaint with the ANPD through the channels listed at gov.br/anpd.
10. Changes to this Policy
10.1. This Policy may be updated to reflect changes in our practices or in the law. The date of the last update is shown at the top of this page.
10.2. Material changes will be announced on the site before they take effect.
11. Governing law and jurisdiction
11.1. This Policy is governed by Brazilian law.
11.2. The courts of the Judicial District of São Paulo/SP, Brazil, are elected to settle any disputes arising from it, without prejudice to a consumer data subject's right to bring proceedings in their own place of residence.