Who we are
This website is run by Pragma Decision Intelligence Ltda., CNPJ 69.625.835/0001-33, São Paulo, Brazil (“Pragma”, “we”). We are the controller of the personal data described here under Brazil’s General Data Protection Law (Law No. 13,709/2018, “LGPD”).
For anything about your personal data, write to privacidade@pragma.do.
What this policy covers
This policy covers pragma.do, including the Value Tree diagnostics, and the e-mails you send us through it. Data our clients share with us when they use Signal is governed by the contract with each client, not by this policy.
What we collect
This website has no cookies, no analytics and no advertising pixels. The only thing it stores on your device is the language you choose, in your browser’s local storage. We receive personal data in these ways:
- When you e-mail us. Your name, e-mail address, the content of your message and anything you attach.
- When you use the contact form. Your name, work e-mail address, phone number, company, the subject you choose and your message, which reach us by e-mail.
- When you use a Value Tree diagnostic. Your answers are processed in your browser while you fill it in. When you submit the form, we receive by e-mail your name, e-mail address, company, role, your answers and the estimate. If that sending fails, the form opens an e-mail to us with the same summary instead, and we receive it only if you send it.
- When you visit a page. Our hosting provider records technical data in server logs: your IP address, browser and device type, the page requested, the referring page, and the date and time.
- When a page loads its fonts. Our typefaces are served by Google Fonts, so your browser connects to Google’s servers, which receive your IP address and browser details. Google processes that data under its own privacy policy.
Why we use it
- To answer your message and, if you ask, to discuss a pilot, a partnership, an investment or a role. Legal basis: steps prior to a contract at your request, and our legitimate interest in replying (LGPD art. 7, V and IX).
- To deliver the website and keep it secure. Legal basis: our legitimate interest in running a working, secure site (art. 7, IX), and our legal obligation to keep access logs under the Brazilian Internet Act (Law No. 12,965/2014, art. 15; LGPD art. 7, II).
We do not sell personal data, use it for advertising, or make automated decisions about you based on it.
Who we share it with
- Service providers who process data on our behalf: our e-mail provider, Google Workspace, which also delivers the site’s forms to our inbox, and our hosting provider, Vercel.
- Authorities, when the law or a court order requires it.
International transfers
Some of our providers, including Google and Vercel, store data outside Brazil, for example in the United States. When that happens we rely on the safeguards the LGPD allows for international transfers (art. 33), such as contractual clauses with the provider.
How long we keep it
- E-mails, including the site’s forms: for as long as the conversation, or any relationship that comes out of it, is active. After that we delete them, unless a law requires us to keep them longer.
- Access logs: six months, as the Brazilian Internet Act requires, unless an authority asks us to keep them longer.
Your rights
Under the LGPD (art. 18) you can ask us to:
- confirm whether we hold personal data about you, and give you access to it;
- correct data that is incomplete, inaccurate or out of date;
- anonymize, block or delete data that is unnecessary, excessive or processed unlawfully;
- move your data to another provider;
- tell you who we have shared it with;
- delete data processed on the basis of your consent, or withdraw that consent;
- stop processing that does not comply with the law.
Write to privacidade@pragma.do. We answer within 15 days. You can also complain to Brazil’s data protection authority, the ANPD.
If you are in the European Union or the United Kingdom, you have similar rights under the GDPR or the UK GDPR, including the right to complain to your local supervisory authority.
Security
We protect personal data with technical and organizational measures suited to the risk, and we limit access to our e-mail and hosting accounts to the people who need it. If a security incident could cause you relevant harm, we will notify you and the ANPD as the LGPD requires.
Children
This website is meant for businesses and is not directed at anyone under 18. We do not knowingly collect data about children.
Changes to this policy
When we change this policy we update the date at the top of this page. If a change affects how we use data you have already given us, we will tell you by e-mail.