Privacy Policy

1. Information we collect

1.1 Personal information

We may collect personal information, including but not limited to your name, telephone number, email address, company name and other contact details, through forms on our website and landing pages and integrations with CRM and lead capture platforms.

1.2 Browsing information

We collect information about your interaction with our website and landing pages, including your IP address, browser type, pages visited, browsing time and other statistical data.

1.3 Audience metrics (first-party analytics)

To understand how our website is used in aggregate, we maintain our own audience measurement system that is cookie-free. We anonymously record pages visited, reading time and scroll depth, device type (mobile, tablet or computer), browser language, country of access, visit source (referring website and campaign parameters) and clicks on actions such as WhatsApp, opening a course or downloading an e-book.

To distinguish one visit from another, we use a random session identifier stored only in your browser's temporary memory (sessionStorage), which expires when you close the tab, is not a cookie, does not persist between visits and does not identify you. We do not create profiles, use the data for advertising or store your IP address (the country is derived on the server and the IP address is discarded), and we do not share these metrics with third parties.

The legal basis for this measurement is legitimate interest (Articles 7, IX and 10 of the LGPD), limited to aggregate statistical analysis. We respect your right to object: if your browser has Do Not Track or Global Privacy Control enabled, we do not perform any measurement; you may also object through our contact channels.

This data is used exclusively for audience measurement(to understand which content attracts most interest and improve the website), and is always treated as aggregate statistics, never to identify individuals. For questions, access requests or objections relating to these metrics, contact us through our contact channels.

2. Use of information

2.1 Communication

We use your personal information to contact you, answer your questions, provide support and send relevant information about our services.

2.2 Improving our services

We analyse browsing information to better understand how users interact with our website and landing pages, in order to improve the user experience and our services.

2.3 Marketing

We may use your information to send marketing materials, promotions or other information we believe may interest you. You may opt out of these emails at any time by following the unsubscribe instructions provided in each email.

3. Sharing information

3.1 Trusted third parties

We may share your information with trusted third parties who help us operate our website, conduct our business or provide services to you, provided those parties agree to keep the information confidential.

3.2 Legal requirements

We may disclose your information when we believe disclosure is necessary to comply with applicable laws, regulations, legal proceedings or government requests.

3.3 Processors and international transfers

To operate the platform, we use two suppliers that process data on our behalf as processors and maintain servers outside Brazil. We disclose this in accordance with Articles 33 and 39 of the LGPD.

• Microsoft - we store a daily backup of our database on HSC's corporate SharePoint and use Microsoft Teams for meetings and online classes, which includes participants' names.
• Anthropic - our internal proposal-writing assistant uses Claude technology. When a proposal is generated, the client identification data it contains is processed by this service.

In both cases, the transfer relies on Article 33, IX of the LGPD (performance of a contract to which the data subject is a party) and the contractual data protection clauses agreed with each supplier. Neither is authorised to use the data for its own purposes, and we do not sell or transfer the database to third parties.

4. Information security

We implement appropriate security measures to protect your personal information against unauthorised access, alteration, disclosure or destruction. However, no method of Internet transmission or electronic storage is 100% secure, so we cannot guarantee absolute security.

5. Data retention

We retain your personal data only for as long as necessary for the purposes of this policy. In practice:

• Contact records without a commercial relationship - if you provided your details and there has been no interaction for 24 months, we automatically remove your name, email address, telephone number and identification document details, retaining only non-identifying information (registration source and dates), which is not personal data.
• Purchases and tax records - these are retained for the legally required period (Article 16, I of the LGPD), without data identifying you.
• Course certificates - retained for as long as necessary to demonstrate training, and removed at your request.

You do not need to wait for these periods: you may request erasure at any time through the contact in section 6.

6. Your rights

6.1 Access, rectification and erasure

You may contact us by email at contato@hscglobalgroup.com:

• Confirmation and access: a complete list of the information we hold about you, in a file you can keep or transfer elsewhere.
• Rectification: correction of any inaccurate or outdated data.
• Erasure: deletion of your personal data. When fulfilling this request, we remove your name, email address, telephone number and identification document details from our records, proposals and certificates.
• Objection to marketing: stop receiving offers while retaining the services you have already purchased.

There is an exception to erasure provided by law: financial and tax records of completed purchases must be retained for the statutory period (Article 16, I of the LGPD). In these records, we retain only the amount and date, without data identifying you.

We respond to requests within 15 days.

6.2 The legal basis for each use

Not every use depends on your consent. It is important to know the basis for each use because this affects your rights:

• Consent (Article 7, I) - when you complete a form to receive material, enrol on a course or request contact. You may withdraw it at any time.
• Performance of a contract (Article 7, V) - providing, delivering and supporting the services you have purchased.
• Legal obligation (Article 16, I) - retaining tax and accounting records of completed purchases.

7. Compliance with LGPD, GDPR and CCPA

7.1 LGPD

We comply with Brazil's General Data Protection Law (LGPD), ensuring your personal information is processed in accordance with the principles and rights established by law.

7.2 GDPR

We comply with the European Union's General Data Protection Regulation (GDPR), ensuring your personal information is processed in accordance with the principles and rights established by law.

7.3 US regulations

We comply with United States privacy regulations, including the California Consumer Privacy Act (CCPA), where applicable.

8. Changes to this policy

We may update this Privacy Policy periodically. We will notify you of changes by publishing the new Privacy Policy on our website. We recommend reviewing this page periodically to stay informed about how we protect your information.

9. Contact

If you have questions about this Privacy Policy, please contact us by email at contato@hscglobalgroup.com.