Privacy
Policy

1. Who we are

PLEXOR is a technology brand operated by the CEREBRA/CLUSTERTEC ecosystem, headquartered in São Carlos, SP, Brazil. We are the controller of the personal data collected on this website.

2. What data we collect

When you fill in the contact form, we collect:

• Full name
• Email address
• Phone / WhatsApp number (when provided)
• Company name
• Industry / sector
• Product of interest
• Description of the operational challenge (free-text message)
• Date and time of submission
• Record of LGPD consent

As you browse the site, technical data such as IP address, browser type, pages visited and time on page may be collected automatically, solely for aggregate traffic analysis via Google Analytics, in anonymized form.

We do not collect sensitive data as defined in Art. 5, II of the LGPD (health, biometrics, racial origin, religious, political or philosophical beliefs, trade-union membership, genetic data or sexual orientation).

3. How we use your data

Your data is used exclusively to:

• Respond to the commercial contact initiated by you (reply by email or phone/WhatsApp, when provided)
• Send the acknowledgment email confirming receipt of your request
• Send commercial communications related to PLEXOR products and services, subject to your express consent
• Continuously improve our products and services, based on aggregated and anonymized information
• Comply with legal and regulatory obligations, where applicable

Your data is not traded, transferred, sold or shared with third parties for marketing, advertising or any other purpose not stated in this policy.

4. Legal basis for processing

The processing of your data is based on the following grounds set out in the LGPD (Art. 7):

• Consent (item I), to send the confirmation email, marketing communications and to use your phone/WhatsApp number for commercial follow-up
• Legitimate interest (item IX), to respond to the commercial contact you voluntarily initiated
• Compliance with a legal obligation (item II), where required by applicable law

Consent may be withdrawn at any time, without prejudice to processing previously carried out on that basis (Art. 8, §5, LGPD).

5. Data sharing

The data collected is processed internally and is not shared with third parties for commercial purposes. The only situations in which data may be accessed by third parties are:

• Locaweb, our hosting and email provider, with servers located in Brazil, which processes the data as a processor under our instructions
• Google LLC, via Google Analytics, for anonymized traffic analysis. The data is processed under Google's privacy policy and may involve international transfer; Google is a signatory of the EU Standard Contractual Clauses as a safeguard
• Public authorities, when required by law, court order or applicable regulation

Under no circumstances is your data sold, rented or transferred to third parties for marketing or advertising purposes.

6. How long we store data

Data is retained for the following periods:

• Commercial contact data, for as long as necessary to fulfill its purpose and for up to 5 years after the end of the commercial relationship, in line with the limitation periods of the Brazilian Civil Code (Art. 206)
• LGPD consent records, for 5 years, for legal evidence purposes (Art. 7, §5, LGPD)
• Browsing data (Analytics), according to Google Analytics' retention policy, generally up to 14 months

After these periods expire, data is securely deleted or anonymized so that the data subject can no longer be identified.

7. Your rights as a data subject

Under Arts. 17 to 22 of the LGPD, you have the right to:

• Confirmation and access, to confirm the existence of processing and access your data
• Correction, to request the correction of incomplete, inaccurate or outdated data
• Anonymization, blocking or deletion, of unnecessary or excessive data, or data processed in non-compliance with the LGPD
• Portability, to receive your data in a structured, interoperable format
• Deletion, to request the deletion of data processed on the basis of consent
• Withdrawal of consent, at any time, without prejudice to prior processing
• Objection, to processing based on legitimate interest
• Information on sharing, to know which public and private entities your data is shared with
• Petition to the ANPD, to file a complaint with Brazil's National Data Protection Authority

To exercise any of these rights, send a request to the email below with the subject [LGPD]. We will respond within 15 business days, as per Art. 19 of the LGPD.

8. Data security

We adopt appropriate technical and organizational measures to protect your data against unauthorized access, loss, alteration or improper disclosure, including:

• Data transmission via HTTPS/TLS in all site communications
• SMTP authentication with SSL encryption when sending emails
• Access credentials stored in environment variables, not exposed in the source code
• Physical and logical access restriction to the systems that store the information
• Validation and sanitization of all data received through the form

In the event of a security incident that may pose relevant risk or harm to data subjects, we will notify the ANPD and the affected data subjects within the legal timeframe, as per Art. 48 of the LGPD.

9. Cookies

This site uses Google Analytics for anonymous traffic analysis. Analytics may use session cookies to track visits in aggregate. We do not use individual tracking cookies for personalized advertising.

10. Data Protection Officer (DPO)

11. Changes to this policy

This policy may be updated periodically. The last-updated date is always shown at the top of this page. Relevant changes will be communicated by email to affected data subjects, where applicable.

12. Applicable law

This policy is governed by Brazilian law, in particular the General Data Protection Law (Law No. 13,709/2018) and the Brazilian Civil Rights Framework for the Internet (Law No. 12,965/2014). The courts of the district of São Carlos, SP, Brazil, are elected to settle any disputes.