1. Who we are and who controls your data
This policy applies to the site praedictor.com and to all of its subdomains and pages.
The controller of personal data, under art. 5, VI of the LGPD (Brazil's General Data Protection Law), is:
PRAEDICTOR CONSULTORIA E TREINAMENTO LTDA
CNPJ: 68.174.930/0001-03
E-mail for privacy matters: [email protected]
Officer in charge of personal data processing (DPO), under art. 41 of the LGPD:
José Lourenço Travassos Miranda — [email protected]
To exercise any right set out in this policy, or to ask questions about the processing of your data, write to the e-mail address above. We answer within 15 days.
2. What data we collect
We collect only what is necessary, and only in two situations:
a) When you fill in a form (Contact and Mentoring pages), you provide us with:
| Data | Required |
|---|---|
| Name | Yes |
| Yes | |
| Phone / WhatsApp | Depends on the form |
| Role and professional background | No |
| Current challenge, urgency, and contact preference | No |
| Free-text message | No |
b) When you browse the site, we automatically collect usage data: IP address, browser and device type, pages visited, time spent, source of the visit, and screen resolution. This data is collected through Google Analytics 4 and used in aggregate form.
We do not collect sensitive data (racial origin, religious conviction, political opinion, health, biometric, or genetic data), nor data of children and adolescents. The site is not directed at anyone under 18.
We do not process payments. E-book purchases take place entirely on the Hotmart platform, which is the controller of payment data. We never have access to your credit card or banking details.
3. Why we process this data, and on what legal basis
The LGPD requires a legal basis for each purpose. Ours are:
| Purpose | Legal basis (LGPD) |
|---|---|
| Replying to your enquiry and following up on the conversation | Art. 7, V — preliminary procedures related to a contract, at the request of the data subject |
| Sending information about programs, content, and openings | Art. 7, I — consent |
| Understanding how the site is used and improving it | Art. 7, IX — legitimate interest |
| Meeting legal, tax, and regulatory obligations | Art. 7, II — legal obligation |
| Exercising or defending rights in legal proceedings | Art. 7, VI — regular exercise of rights |
Where the basis is legitimate interest, we assess the processing to be proportionate, limited to what is necessary, and not overriding your fundamental rights and freedoms. You may object to this processing at any time.
4. Who we share it with
We do not sell, rent, or assign your personal data. We share it only with the service providers necessary to the operation:
| Service | What for | Where the data sits |
|---|---|---|
| Google Analytics (Google LLC) | Site usage metrics | United States |
| Formspree (Formspree Inc.) | Receiving form messages | United States |
| Cloudflare | Site hosting and delivery | Global network |
| Hotmart | E-book sales and delivery | Brazil |
| Zoho Mail | Professional email | International |
International transfer: some of these providers are located outside Brazil. This transfer takes place under art. 33 of the LGPD, on the basis of performance of the contract and of your consent, and we require providers to adopt clauses and protection standards compatible with Brazilian legislation.
We may also share data upon a court order or a request from a competent authority.
5. Cookies
The site uses Google Analytics cookies to measure audience and understand browsing behaviour in aggregate form. We do not use advertising cookies or social network pixels.
You choose. On your first visit, we display a notice at the bottom of the screen with two options: accept or decline analytics cookies. Until you accept, Google Analytics is not loaded — no browsing data is sent. If you decline, the site keeps working normally, simply without audience measurement.
Your choice is recorded in your own browser and can be changed at any time: just clear the site data in your browser settings and the notice will appear again.
You can also block or delete cookies directly in your browser settings.
6. How long we keep it
| Data | Period |
|---|---|
| Messages and form data | For the duration of the commercial relationship and for up to 5 years after the last contact |
| Event data (Analytics) | 2 months |
| User data (Analytics) | 14 months |
| Records required by law | For the applicable statutory period |
Once the period ends, the data is deleted or anonymized.
7. Your rights
Under art. 18 of the LGPD, you may at any time request:
- Confirmation that we process your data and access to it
- Correction of incomplete, inaccurate, or outdated data
- Anonymization, blocking, or deletion of unnecessary data or data processed in non-compliance
- Portability to another provider
- Deletion of data processed on the basis of consent
- Information about who we share your data with
- Withdrawal of consent, at any time and free of charge
- Objection to processing based on legitimate interest
Just write to [email protected]. We may ask for identity confirmation before responding, for your own protection.
You also have the right to petition the ANPD — Autoridade Nacional de Proteção de Dados, Brazil's national data protection authority (gov.br/anpd).
8. Security
We adopt technical and administrative measures to protect your data: an encrypted connection (HTTPS) across the whole site, restricted access to the information, and a choice of providers with recognized security standards.
No system is entirely immune. In the event of a security incident that may bring relevant risk to you, we will notify you and the ANPD, in accordance with art. 48 of the LGPD.
9. Changes to this policy
We may update this policy to reflect changes in the law or in the operation of the site. The date of the last update is at the top. Relevant changes will be communicated prominently.
10. Jurisdiction
The courts of the judicial district of São José dos Campos, State of São Paulo, Brazil, are elected to settle matters arising from this policy, with waiver of any other.