Institutional

Privacy policy

Last updated: September 2026 · Version 1.0

This policy describes how the Scaphandre institutional site (scaphandre.com.br) handles personal data. Scaphandre is a solution developed by Nublify Consultoria e Serviços de Tecnologia da Informação Ltda., the controller of the data processed on this site. The contracted operation of the product is governed by its own agreement and data protection addendum.

  1. 01

    Who is the controller

    Nublify Consultoria e Serviços de Tecnologia da Informação Ltda., company registration (CNPJ) 33.795.677/0001-12, headquartered at Av. Yojiro Takaoka, 4384, Sala 701 — Alphaville, Santana de Parnaíba/SP, Brazil, postal code 06541-038.

    Channel for privacy matters and for exercising your rights: contato@nublify.com · +55 (11) 99637-5196.

  2. 02

    What this policy covers

    It covers the institutional site: public pages, product content, institutional materials and the contact form.

    The Scaphandre platform contracted by clients is not governed by this policy: the processing of case, document and user data takes place under a specific agreement and data protection addendum, with clearly defined controller and processor roles.

  3. 03

    Data we process on this site

    As it stands today, the site keeps no visitor registry, requires no identification and builds no first-party browsing profiles.

    • Commercial contact: only the data you choose to send through the form — company, name, corporate email, sector, product of interest, size of the legal operation, approximate number of cases and the challenges you describe.
    • Communications (mailing): with your authorisation, the name and email you provide may be added to our communications list, to send content, news, invitations and product information. Joining is optional, you can leave the list at any time, and we record the date and origin of the authorisation.
    • Email delivery: the form opens your own email application; the message is sent by you to our address and the site does not store its content.
    • Infrastructure records: technical server access logs (IP address, date and time, requested resource and browser agent), kept by the hosting provider for security and availability.
    • Measurement and digital marketing: interaction data with the site and with campaigns (pages visited, traffic source, device type and campaign identifiers), collected by measurement and advertising tools loaded only after your consent — detailed in the cookies, measurement and digital marketing section.
    • We do not process sensitive data or data of children and adolescents on this site, and we do not make automated decisions about visitors.
  4. 04

    Purposes and legal bases

    Processing on the institutional site relies on the following legal bases of the Brazilian General Data Protection Law (Law 13.709/2018, LGPD):

    • Answering contact requests and presenting the product — contract preliminary procedures, at the data subject's request (art. 7, V).
    • Sending content and communications and measuring audience and campaigns — consent (art. 7, I), revocable at any time, and legitimate interest (art. 7, IX) where applicable.
    • Keeping the site secure, preventing abuse and preserving availability — legitimate interest (art. 7, IX) and compliance with a legal obligation (art. 7, II).
    • Complying with legal and regulatory obligations and with orders from competent authorities — art. 7, II.
  5. 05

    Cookies, measurement and digital marketing

    We use cookies and identifiers for two distinct purposes: essential ones, which keep the site, its security and your session working, and non-essential ones, for measurement and marketing, which only take effect after your consent.

    On your first visit, the site shows the cookie notice with the options "Accept all" and "Essential only". Your choice is stored in your browser and can be reviewed at any time through the "Cookie preferences" link in the footer of every page.

    The measurement and marketing tools we use are Google Analytics 4, Google Tag Manager, Google Search Console and Meta (Facebook and Instagram). They record interaction data with pages and campaigns — pages visited, traffic source, device type and campaign identifiers — and are loaded only with your consent.

    If you choose "Essential only", no measurement or marketing tag is loaded and cookies from those tools already stored in your browser are removed. When you review your choice, the site applies the new decision immediately.

    We do not sell personal data. Event data may be shared with advertising platforms (Google and Meta) to measure and optimise campaigns, in the form of metrics and audiences, in line with those platforms' policies.

  6. 06

    Sharing

    We do not sell, rent or trade personal data for commercial purposes. Sharing happens only when necessary:

    • infrastructure, hosting and email providers that support the site and our contact handling;
    • measurement and advertising platforms — Google (Analytics, Tag Manager and Search Console) and Meta (Facebook and Instagram) — to measure audience and campaigns;
    • public authorities, when there is a legal or judicial order;
    • service providers that may support the site, always under contract with confidentiality and data protection obligations.
  7. 07

    International transfers

    The site is hosted on a server contracted from a cloud provider, and email, infrastructure, measurement and advertising services (Google and Meta) process data on servers that may be outside Brazil. In such cases we require contractual safeguards and apply the guarantees provided by the LGPD for international data transfers.

  8. 08

    How long we keep data

    We keep data only for as long as needed for the purposes of this policy:

    • commercial contact messages: 5 years from the last contact, for service and defence in any claim;
    • communications registry: for as long as the data subject does not ask to leave the list or withdraw consent;
    • measurement and campaign data: 14 months in Google Analytics and, on advertising platforms, for the periods configured in those accounts;
    • infrastructure and security records: 6 months.

    Once the periods end or upon the data subject's request, data is deleted or anonymised, except where the law requires it to be retained.

  9. 09

    Your rights as a data subject

    Under art. 18 of the LGPD, you may request:

    • confirmation that processing exists;
    • access to your data;
    • correction of incomplete, inaccurate or outdated data;
    • anonymisation, blocking or deletion of unnecessary, excessive or non-compliant data;
    • portability of your data to another provider;
    • information about the entities with which we share data;
    • information about the possibility of not giving consent and the consequences of refusal;
    • withdrawal of consent and unsubscribing from communications, at any time;

    Requests can be made through contato@nublify.com. We reply within the periods set by the LGPD.

  10. 10

    Security

    We adopt technical and administrative measures to protect the data processed on this site, including access control, environment segregation, event logging and continuous component updates. On the platform, these controls include profiles and permissions, approval limits, audit trail and rule versioning, as described on the security and governance page.

  11. 11

    Changes to this policy

    This policy is reviewed whenever there is a relevant change in the tools, service providers or applicable law. The version in force is the one published on this page, with the update date shown at the top; material changes are announced on this page and, where applicable, through a notice on the site.

  12. 12

    Data protection officer (DPO)

    Nublify's data protection officer (DPO) is available at contato@nublify.com. The same channel receives data subject requests, communications from the Brazilian data protection authority (ANPD) and questions about this policy.