Courtesy translation. This English version is provided to make the document easier to read. The legally binding document is the original Portuguese version, available at geosite.com.br/privacidade. If the versions diverge, the Portuguese text prevails. Data processing is governed by Brazilian law (LGPD).
1. Introduction and scope
This Privacy Policy explains how Geosite Tecnologia S.A. ("Geosite", "we") processes the personal data of visitors, prospective clients and other data subjects who interact with our corporate websites: geosite.com.br, geositetelecom.com.br and blog.geosite.com.br (the "Websites"). Processing complies with Brazilian Law No. 13,709/2018 (the General Personal Data Protection Law, "LGPD") and the guidance of Brazil's National Data Protection Authority (ANPD).
This Policy does not apply to the environments below, which have their own rules:
- The Geosite Telecom platform (accessed by login at telecom.geosite.com.br): data processing is governed by the contract signed with each client, as set out in section 13.
- The Geosite Telecom mobile app: it has its own specific Privacy Policy, available on the page indicated in the app store.
2. Who the controller is
Geosite Tecnologia S.A., registered under Brazilian company number (CNPJ) 50.086.075/0001-05, with its registered office at Rua Senador Lima Guimarães, 479, Estoril, Belo Horizonte, MG, Brazil. Dedicated privacy channel: contato@geosite.com.br.
3. Key definitions
- Personal data: information relating to an identified or identifiable natural person, such as name, email, phone number and IP address.
- Data subject: the natural person to whom the personal data relates.
- Processing: any operation carried out with personal data, such as collection, use, storage, sharing and deletion.
- Controller: the party that makes decisions about the processing. Processor: the party that processes data on the controller's behalf.
- Cookies: small files stored in the user's browser or device, capable of holding information and identifiers, as described in section 6.
4. What data we collect and where it comes from
4.1. Data you provide
- Contact, trial or proposal forms: name, phone number, email, company, number of subscribers (where applicable) and the content of your message.
- Contact via WhatsApp: phone number and the content of conversations you start.
4.2. Data collected automatically
- Browsing and device data: IP address, date and time of access, browser type, operating system, pages visited, source of the visit and cookie identifiers, according to your consent choices (section 6).
4.3. Sensitive data
The Websites do not request sensitive personal data (such as health, biometric or religious belief data). Please do not include such data in free-text message fields.
5. What we use the data for and on what legal basis
| Purpose | Data used | Legal basis (art. 7 of the LGPD) |
|---|---|---|
| Responding to requests for contact, a demo, a free trial or a commercial proposal | Identification and contact details | Pre-contractual procedures (item V) |
| Sending marketing communications, news and content | Name and contact details | Consent (item I), with specific, revocable opt-in |
| Measuring audience and improving the Websites | Browsing data and analytics cookies | Consent (item I) |
| Running and measuring advertising campaigns | Marketing cookies | Consent (item I) |
| Ensuring the Websites function securely and preventing fraud | IP, logs and necessary cookies | Legitimate interest (item IX) |
| Meeting legal and regulatory obligations and exercising rights in proceedings | As applicable | Legal obligation (item II) and the regular exercise of rights (item VI) |
7. Who we share data with
Geosite does not sell personal data. We share data only where necessary, with:
- Technology suppliers acting on our instructions: hosting and security (Cloudflare), measurement and tags (Google), marketing automation and CRM, and WhatsApp support (Meta and our support platform).
- Companies within our corporate group, for administrative and operational support, within the limits of the purposes set out in this Policy.
- Professional advisers (legal and accounting), under a duty of confidentiality.
- Public authorities, where required by law, regulation or an order from a competent authority.
8. International transfers
Some of the suppliers listed in section 7 may store or process data outside Brazil (for example, Google, Cloudflare and Meta). In those cases we apply the safeguards in art. 33 of the LGPD, such as contractual clauses and mechanisms recognised by the ANPD, to ensure a level of protection consistent with Brazilian law.
9. How long we keep the data
| Category | Retention period |
|---|---|
| Commercial contacts that did not result in a contract | Up to 24 months after the last active interaction |
| Cookie and marketing consent records | 5 years, for evidential purposes |
| Data linked to contracts and tax obligations | Periods required by applicable law |
| Application access logs | Minimum of 6 months (art. 15 of Brazil's Internet Civil Framework) |
Once the period or the purpose ends, the data is securely deleted or anonymised.
10. How we protect the data
We apply technical and organisational measures proportionate to the risk, including encryption in transit (TLS), role-based access control, infrastructure providers with recognised certifications, and security monitoring. No system is infallible: security incidents that may cause significant risk or harm will be reported to the ANPD and to data subjects, as required by art. 48 of the LGPD.
11. Your rights as a data subject
Under art. 18 of the LGPD, you may request:
- Confirmation that processing exists, and access to your data.
- Correction of incomplete, inaccurate or out-of-date data.
- Anonymisation, blocking or deletion of data that is unnecessary, excessive or processed in breach of the law.
- Portability of your data to another provider, subject to regulation.
- Information about the sharing that has taken place and about your option not to consent, along with the consequences.
- Withdrawal of consent and deletion of data processed on that basis.
- Objection to processing carried out on the basis of legitimate interest.
The Websites do not make automated decisions with significant legal effects on data subjects.
How to exercise them: send your request to contato@geosite.com.br. We will respond as quickly as possible, within the statutory deadlines. You may also petition the ANPD directly (gov.br/anpd).
12. Children and young people
The Websites are aimed at a business audience and are not directed at anyone under 18. We do not knowingly collect data from children or young people. If we identify that such data has been collected, it will be deleted.
13. Geosite's roles in processing
On the Websites, Geosite acts as the controller of personal data. On the Geosite Telecom platform, Geosite generally acts as the processor of data entered by its clients (for example, data about internet provider subscribers), processing it in line with the contractual instructions of the client acting as controller and the applicable services agreement.
14. Data Protection Officer (DPO)
Data Protection Officer: Reginaldo Morais.
DPO contact: contato@geosite.com.br.
15. Updates to this Policy
This Policy may be updated to reflect legal, regulatory or operational changes. The version in force, with its date, will always be available at geosite.com.br/privacidade.html. Significant changes will be highlighted on the Websites.
16. Governing law and jurisdiction
This Policy is governed by Brazilian law. The courts of Belo Horizonte, MG, Brazil are designated as the competent forum, save where other statutory jurisdiction applies.