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 an audience measurement tool to understand how the website is used. It only loads after you accept the cookie notice: until you accept, or if you decline, no measurement takes place. You can change your mind at any time in Cookie preferences, in the footer of every page; when you decline, measurement cookies already stored are deleted. We do not load advertising tracking scripts. Pages with embedded video connect to the video platform when the video loads, and from then on processing is also governed by that platform's policy.

Cookies

We use two functional cookies: one is created when you fill in the Inclusion Observatory form, so we do not ask for your details again on every visit, and the other stores your answer to the cookie notice. Both last six months. If you accept measurement, the measurement tool stores its own cookies, used to tell visitors and sessions apart, which are deleted when you decline in 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.

Who is responsible for the data

On the platform, the school, network or city government that hired Vínculoo® decides about the data. Vínculoo® only uses this data to provide the service, as the institution instructs. This also applies to sensitive data, such as health information, and to data about children and adolescents, which is used only to support the student's education.

Who the data is shared with

We do not sell or pass on platform data. It only goes through the suppliers the service needs in order to work, such as cloud hosting and artificial intelligence, which are bound by confidentiality and security obligations. Some of these suppliers are located outside Brazil.

How we protect the data

Each person only sees the data of their own institution and access role. Information travels encrypted, changes are recorded and there are automatic backups. If an incident affects the data, we notify the institution quickly so it can take the necessary steps.

Requests about the data and end of contract

Anyone who wants to see, correct or delete platform data should ask the responsible institution, and Vínculoo® helps the institution respond. When the contract or agreement ends, the data is returned to the institution or deleted, as that document sets out.

Artificial intelligence

Vínculoo® does not use platform data to train artificial intelligence.

Technical documents on the platform's security and privacy are sent to institutions that request them, during contracting or when a partnership is formalized.