1. Identity of the data controller and the website
This privacy policy governs the processing of personal data by PAD PARTICIPACOES LTDA in connection with the website published under the domain padparticipacoes.online. The holding is the sole owner of the domain and the only entity that publishes content on it. No franchisee, licensee, agent, or third-party operator is authorised to use this brand or this domain.
- Data controller
- PAD PARTICIPACOES LTDA
- CNPJ
- 65.449.535/0001-90
- Registered office
- Q CLN 206 Bloco A, Loja 9, Asa Norte, Brasilia, Federal District, postal code 70.844-510, Brazil
- Domain
- padparticipacoes.online
- Contact email
- padpimenta@gmail.com
- Telephone
- +55 61 8261 2777
2. Scope
This policy covers visitors of padparticipacoes.online who send a message through the contact form, contact the holding by email or telephone, or otherwise send personal information to the holding in connection with this website. The holding is a private non-financial participation company and does not offer regulated financial services, consumer products, or brokerage of any kind through this website.
3. Personal data collected
The holding collects only the personal data that visitors voluntarily provide, namely:
- Full name, email address, and subject line submitted through the contact form on the home page.
- The content of the message written by the visitor.
- Any additional identification data the visitor chooses to add to that message.
The website does not use behavioural profiling, does not run advertising trackers, and does not collect biometric data, health data, financial account data, or data concerning children or adolescents.
4. Purposes of processing
Personal data received through this website is processed solely for the following purposes:
- Reply to the visitor's message.
- Keep an internal record of correspondence received by the holding.
- Comply with legal or regulatory duties applicable to the holding.
Personal data is not used for direct marketing, is not sold, and is not shared with third parties for commercial purposes.
5. Legal basis
Processing is based on the legitimate interest of the holding in operating an official website and in replying to correspondence, on the execution of pre-contractual steps when the visitor initiates them, and on the consent of the visitor as expressed by the act of sending a message. This is in line with the Brazilian General Data Protection Law (Lei nr. 13.709, of August 14, 2018).
6. Sharing with third parties
Personal data received through this website may be shared with the professional advisors engaged by the holding (accountants, legal counsel), only to the extent strictly necessary. Data may also be shared with public authorities when required by law or by a valid order. Data is not shared with commercial partners of the holding, with participated companies, or with any external marketing entity.
7. Retention
Correspondence received through this website is retained for the period reasonably necessary to reply, to keep a record of the exchange, and to comply with legal retention duties applicable to the holding. After that period, the data is either deleted or archived under restricted access.
8. Security
The holding applies reasonable technical and organisational measures to protect the personal data it holds: restricted internal access, use of updated systems, and monitoring of email accounts used for statutory correspondence. No system connected to the internet is fully immune to incidents, and the holding notifies the visitor and the competent authority in cases required by law.
9. Data subject rights
Under the Brazilian General Data Protection Law, the visitor has the right to confirm processing, access data, correct data, anonymise or delete data, request portability, be informed about sharing, revoke consent, and file a complaint with the National Data Protection Authority. Requests are handled by the contact channels listed in section 1.
10. Cookies and analytics
The website uses only strictly necessary technical cookies, required for basic navigation. It does not use advertising cookies, does not use cross-site tracking, and does not embed third-party marketing pixels.
11. Changes to this policy
The holding may update this policy to reflect changes in its practices or in the applicable law. The updated version is published on this same page with a new "in force from" date.
12. Governing law and jurisdiction
This policy is governed by the laws of the Federative Republic of Brazil. The courts of the district of Brasilia, Federal District, are elected as the sole competent forum.