Privacy and Confidentiality Policy

Summary

  • Experience in working with subjects ranging from “sensitive” to “secret”.
  • Clients’ names are not disclosed without prior consent in writing.
  • Double physical backup plus cloud backup (the latter may be suppressed upon request). Robust password policy and its rotation in place.
  • Sensitive work and above is moved to, stored in and performed in isolated (not connected to the internet) equipment.
  • The default procedure is to keep your documents in electronic format for 60 days, then to delete/erase them using FBI standards. Immediate erasing upon request. Paper documents are not kept; immediately upon processing paper documents are either returned to the client or shredded.

We abide to:

Information Collection & Use

Registration

http://www.truste.org/docs/Model_Privacy_Policy_Disclosures.doc

Based upon model from www.TRUSTe.org

No online registration is required. Only actual clients and suppliers are required to use login data (username/password), the conditions for being granted these credentials being subject to specific contracts. The registration data (name and valid email) used for those who comment on the blog and/or opt to receive our newsletter is not disclosed publicly in any manner, nor sold or by any other means made available to third parties. We shall NOT use this information to send emails – other than the newsletter, if subscribed to – of any kind, including offers from ourselves or business associates.

Orders, Application Forms etc.

We do not sell nor accept applications for employment online as well as do not collect personal, business or financial information (such as credit card number, expiration date).

Surveys or Contests

From time-to-time we may provide you the opportunity to participate in contests or surveys on our site. If you participate, we will request certain personally identifiable information from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes contact information (such as name and email) and demographic information (such as zip code). We use this information solely to notify contest winners and award prizes.

We may use a third party service provider to conduct these surveys or contests; that company will be prohibited from using our users’ personally identifiable information for any other purpose. We will not share the personally identifiable information you provide through a contest or survey with other third parties unless we give you prior notice and choice.

Tell-A-Friend

From time to time we may request you to refer our services. If you choose to tell a friend about our site, we will ask you for your friend’s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the site. Guilherme Basilio & Consultores Ltda. stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program.

Your friend may contact us at <remove@transconsult.com.br> to request that we remove this information from our database.

Newsletters

If you wish to subscribe to our newsletter, we will use your name and email address to send the newsletter to you. Out of respect for your privacy, we provide you a way to unsubscribe. Please see the “Choice and Opt-out” section.

Profile

We store information that we collect through cookies, log files, clear gifs, and/or third party sources to monitor site traffic and access. We do not tie any personally identifiable information to provide tailored promotions and marketing offers nor to improve the content of the site.

We do not share your profile with other third parties.

Supplementation of Information

Email Verification:

To prevent unwanted subscriptions to the newsletter, we send a one-time confirmation email.

Enhancement of Profile Information:

We DO NOT purchase marketing data from (nor sell to) third parties to enhance our/their existing user database.

Information Sharing and Disclosure

Aggregate Information (non-personally identifiable):

We SHARE aggregated demographic information about our user base with our partners and advertisers. This information does not identify individual users. We do not link aggregate user data with personally identifiable information.

Personally identifiable information:

We DO NOT Share Personally Identifiable Information with Third Parties.

Log Files

As is true of most Web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the site, to track users’ movements around the site and to gather demographic information about our user base as a whole.

Except when legally mandatory, we do not link this automatically-collected data to personally identifiable information.

We use a third-party tracking service [called Google Analytics] that uses cookies and log files to track non-personally identifiable information about visitors to our site in the aggregate.

Cookies & Clear GIFs

A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We use cookies on this site. We do not link the information we store in cookies to any personally identifiable information you submit while on our site. We use session ID cookies to make it easier for you to navigate our site. A session ID cookie expires when you close you browser.

If you reject cookies, you may still use our site, but your ability to use some areas of our site, such as contests or surveys, will be limited.

Clear Gifs (Web Beacons/Web Bugs)

We employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), that help us better manage content on our site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personally identifiable information.

We do not use clear gifs in our HTML-based emails.

Third Party Advertisers

The ads appearing on this Web site are delivered to users by our direct advertising partners. We do not share web site usage information about users with third parties. We do not use services of third parties advertising services.

Links to Other Sites

This Web site contains links to other sites that are not owned or controlled by Guilherme Basilio & Consultores Ltda. Please be aware that we, Guilherme Basilio & Consultores Ltda., are not responsible for the privacy practices of such other sites. We encourage you to be aware, when you leave our site, and read the privacy statements of these sites. are not responsible for the privacy practices of such other sites.

This privacy statement applies only to information collected by this website. We encourage you to be aware, when you leave our site, and read the privacy statements of these sites.

Bulletin Boards/Chat Rooms

If you use a bulletin board or chat room on this site, you should be aware that any personally identifiable information you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these forums.

We reserve the right to terminate the accounts of visitors who use these services in a manner inconsistent with our Terms of Use.

Security

The security of your personal information is important to us. When you enter sensitive information (such as credit card number) this is done (a) on encrypted form using secure socket layer technology (SSL) and (b) outside our website, directly at the financial institution (bank, credit card, PayPal etc.) website, under the security and privacy policies of said institutions.

We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

If you have any questions about security on our website, you can email us at <datasecurity@transconsult.com.br>.

Business Transitions

In the event Guilherme Basilio & Consultores Ltda. goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified via email and prominent notice on our website for 30 days of any such change in ownership or control of your personal information.

Changes in this Privacy Statement

If we decide to change our privacy policy, we will post those changes to this privacy statement at the homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you by email and by means of a notice on our home page.

Choice/Opt-out

If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included in each newsletter or communication or by emailing us at <remove@transconsult.com.br>

Legal Disclaimer

This privacy statement applies only to information collected by this website.

We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order or legal process served on our Web site.

Contact Us

If you have any questions or suggestions regarding our privacy policy, please contact us at: <datasecurity@transconsult.com.br> or by phone, fax or postal address.