Privacy Policy
This Policy explains what personal data we collect on zerodigital.blackdigital.com.br, why we collect it, who we share it with, how long we keep it and how you exercise your rights. It is written in plain language, as required by the Brazilian General Data Protection Law (Law No. 13,709/2018 — "LGPD").
1. Controller and Data Protection Officer
Controller: Perobeli Design Studio Ltda, CNPJ 54.789.971/0001-91, registered offices at Rua Malvina Ferrara Samarone, 195, Vila Dom Pedro I, São Paulo/SP, 04279-035, Brazil.
Data Protection Officer (Encarregado): Felipe Perobeli — perobeli@doispontozero.digital.
You can reach us about any privacy matter at that address or at comercial@doispontozero.digital.
2. Who this Policy covers
It applies to Site visitors, people who complete our forms, book meetings, write to our email addresses or interact with our professional profiles.
It does not apply to data we process as a processor within client projects — in those cases the client is the controller, and the rules sit in the services agreement and the corresponding data processing agreement.
3. Data we collect
3.1 Data you give us
- Identification and contact: name, business email, phone (when provided), company and role.
- Message content: project description, challenges, timelines, estimated budget and anything else you choose to include.
- Scheduling: when you book a call through our scheduling tool — name, email, time zone and selected slot.
- Applications: if you send us a CV, the professional data it contains.
Please do not include sensitive personal data in our forms (health, biometrics, religious or political beliefs, union membership, sexual orientation) or confidential third-party information. We don't need any of it to reply to you.
3.2 Data collected automatically
- Browsing data: IP address, date and time of access, pages viewed, time on page, traffic source (referrer), search terms that brought you here.
- Technical data: browser type and version, operating system, device type, screen resolution, language settings.
- Cookie identifiers and similar technologies, as described in our Cookie Policy.
Under the Brazilian Internet Civil Framework (Law No. 12,965/2014), application access logs are retained for the statutory period of six months.
3.3 Data from third-party sources
We may enrich information using public and professional sources — such as your company website, professional social networks and public company registries — to qualify the commercial contact and prepare for meetings.
4. Purposes and legal bases
| Purpose | Data involved | Legal basis (LGPD) |
|---|---|---|
| Replying to messages, quotes and meeting requests | Identification, contact, message content | Preliminary steps relating to a contract, at the data subject's request — art. 7, V |
| Preparing proposals and managing the commercial relationship | Identification, contact, project data | Performance of a contract — art. 7, V |
| Operating, maintaining and protecting the Site | IP, access logs, technical data | Legitimate interest — art. 7, IX / legal obligation — art. 7, II |
| Measuring audience and improving content and navigation | Analytics cookies, browsing data | Consent — art. 7, I |
| Marketing, remarketing and campaign measurement | Marketing cookies, advertising identifiers | Consent — art. 7, I |
| Sending content and updates (when requested) | Name and email | Consent — art. 7, I |
| Recruitment processes | CV data | Preliminary steps relating to a contract — art. 7, V |
| Meeting tax, accounting and regulatory obligations | Registration and contractual data | Legal or regulatory obligation — art. 7, II |
| Exercising rights in judicial, administrative or arbitration proceedings | As required by the case | Regular exercise of rights — art. 7, VI |
We do not use personal data for automated decisions producing legal effects or significantly affecting your interests. We do not sell personal data.
5. Who we share data with
We share only what is necessary, with partners acting as processors under our instructions:
- hosting and infrastructure for the Site and corporate email;
- audience analytics and tag management (Google Analytics and Google Tag Manager);
- meeting scheduling tool and video conferencing platform;
- CRM and sales automation, to record and follow up on opportunities;
- legal and accounting advisors, where indispensable;
- public authorities, upon legal request, court order or to defend our rights.
In a corporate reorganisation, merger or acquisition, data may be transferred to the successor, subject to this Policy and with notice to data subjects.
6. International transfers
Some suppliers host data outside Brazil, particularly in the United States and the European Union. Where this happens, we apply safeguards consistent with articles 33 to 36 of the LGPD, such as standard contractual clauses and assessment of the supplier's protection level.
7. How long we keep data
| Category | Retention period |
|---|---|
| Commercial contacts that did not convert | Up to 24 months after the last interaction |
| Client and contract data | For the term of the agreement plus 5 years, per limitation periods |
| Tax and accounting records | 5 years, per applicable law |
| Application access logs | 6 months (art. 15, Internet Civil Framework) |
| Cookies | As stated in the Cookie Policy |
| Unsolicited job applications | Up to 12 months, unless you consent to longer |
Once the period ends, data is deleted or anonymised, except where retention is permitted under art. 16 of the LGPD.
8. Security
We apply technical and administrative measures proportionate to risk, including: encrypted connections (HTTPS/TLS), role-based access control and least-privilege principles, two-factor authentication on critical tools, regular platform and plugin updates, backups, and confidentiality agreements with our team and suppliers.
No system is entirely immune. In the event of a security incident posing relevant risk to data subjects, we will notify the Brazilian Data Protection Authority (ANPD) and affected individuals within the timeframes and formats set by law.
9. Your rights
Article 18 of the LGPD gives you the right to:
- confirm that processing exists and access your data;
- correct incomplete, inaccurate or outdated data;
- request anonymisation, blocking or deletion of unnecessary, excessive or non-compliant data;
- request portability to another provider, subject to trade and industrial secrets;
- delete data processed on the basis of consent, subject to legal retention exceptions;
- obtain information about the public and private entities we share data with;
- be informed that you may withhold consent and what the consequences are;
- withdraw consent at any time;
- object to processing based on legitimate interest;
- lodge a complaint with the ANPD.
How to exercise them: send a request to perobeli@doispontozero.digital stating which right you wish to exercise. We reply within 15 days. We may ask for additional information to verify your identity — that check exists to protect you. Manifestly unfounded or repetitive requests may be refused, always with reasons given.
10. Cookies
Our use of cookies and similar technologies, the categories involved and how to manage your preferences are described in the Cookie Policy.
11. Children
The Site is aimed at professionals and companies and is not directed at anyone under 18. We do not knowingly collect data from children or adolescents. If we identify inadvertent collection, we delete the data. Guardians who suspect such a submission can contact us through the channels above.
12. Users outside Brazil
If you are in the European Economic Area or the United Kingdom, you may have additional rights under the GDPR — including restriction of processing and the right to lodge a complaint with your national data protection authority. We handle those requests through the same channels described in this Policy.
13. Changes to this Policy
This Policy may be revised to reflect legal, technological or business changes. The update date at the top of the page indicates the version in force; substantial changes will be highlighted on the Site.
14. Contact
Data Protection Officer: perobeli@doispontozero.digital
General contact: comercial@doispontozero.digital
Address: Rua Malvina Ferrara Samarone, 195, Vila Dom Pedro I, São Paulo/SP, 04279-035, Brazil
Brazilian Data Protection Authority (ANPD): gov.br/anpd