Privacy Policy

Who handles your data

The controller of the personal data collected on this site is Vínculoo Tecnologia Ltda, registered under Brazilian company number (CNPJ) 34.787.197/0001-72, with registered offices at Av. Paulista, 1471, Conj. 1110, Caixa Postal 16314, Bela Vista, São Paulo/SP, CEP 01311-927, operating under the Vínculoo® brand. Controller means it decides the purposes and the means of processing, under art. 5, VI of Brazilian Law 13.709/2018. The data protection officer required by art. 41 of the LGPD is Rafael Anselmo, reachable at dpo@vinculoo.com.br — that is the address for privacy questions and for the requests under art. 18.

What we collect

We collect only what you type into a form. Nothing is collected without you entering it.

• In the contact and materials forms: name, e-mail, phone and role.
• In the Inclusion Diagnostic: the above, plus the name of the institution, the municipality, the state and the answers you gave about the school's or network's processes.
• In the Inclusion Observatory: the same contact data, to unlock the query.

The Diagnostic answers are about institutional process. No question asks for a name, a medical report or any student information, and no student data travels through this site.

What we use it for, and on what legal basis

• To answer your contact and send the material or report you asked for. Legal basis: preliminary procedures at your request, art. 7, V of the LGPD.
• Commercial contact about Vínculoo® solutions. Legal basis: your consent, art. 7, I, given in the form.
• To improve the tools and content of the site, from aggregated data that identifies no one. Legal basis: legitimate interest, art. 7, IX.

You can withdraw consent at any time, and that does not affect processing carried out before the withdrawal.

Who we share it with

Form data is sent to Vínculoo®'s commercial management system, hosted on infrastructure it contracts. We do not sell, rent or transfer personal data to third parties for marketing purposes.

We use Google Tag Manager to measure how the site is used. It is only loaded after you accept the cookie notice: until you accept — or if you decline — no Google script runs and no connection to Google is made. You can change your mind at any time under Cookie preferences, in the footer of any page; declining also erases the measurement cookies already stored. We do not load advertising tracking scripts. Pages with an embedded YouTube video connect to Google's servers when the video loads, and from that moment the processing is also governed by Google's privacy policy.

Cookies

We use one functional cookie, called vinculoo_lead, created when you fill in the Inclusion Observatory form. It exists so we don't ask for your details again on every visit, and it lasts six months. We also use the vinculoo_consentimento cookie, which stores your answer to the cookie notice for the same period. If you accept measurement, Google Analytics writes its own cookies (_ga and related ones), used to distinguish visitors and sessions, and erased when you decline under Cookie preferences. We do not use advertising or cross-site tracking cookies.

How long we keep it

Contact data is kept while the commercial relationship or the interest shown lasts, and is deleted when you ask or when it is no longer needed for the purpose that motivated it. Access logs are kept for the period set by art. 15 of the Brazilian Internet Civil Framework.

Your rights

Art. 18 of the LGPD grants you, at any time and free of charge, the right to:

• confirm whether we process your data, and access it;
• correct incomplete, inaccurate or outdated data;
• request anonymisation, blocking or deletion of unnecessary or excessive data;
• request portability to another provider;
• request deletion of data processed under your consent;
• know who we share your data with;
• withdraw consent.

To exercise any of them, write to dpo@vinculoo.com.br. We answer within fifteen days.

Security

We adopt technical and administrative measures to protect data from unauthorised access and from accidental or unlawful situations, under art. 46 of the LGPD. No system is immune, which is why we keep an incident response process: if something happens that could pose a relevant risk to you, we notify you and the Brazilian Data Protection Authority.

Changes to this policy

When this policy changes, the update date at the top changes with it. Changes affecting the purpose of processing or the sharing of data will be communicated prominently.