Privacy Policy – Contcore Consulting

1. Controller Identification

Name: CONTCORE IT CONSULTING LTDA ("Contcore Consulting"), a Brazilian company headquartered at Avenida Paulista, 1106 - Suite 01, 16th Floor, Bela Vista, São Paulo - SP, 01310-914, registered under CNPJ 60.001.835/0001-98, providing remote services to clients in Brazil, Portugal, and the European Union. Contact Form: available here

2. Personal Data Processing Information

Contcore operates exclusively as a remote service provider, without physical presence in European territory. Data processing is conducted in compliance with: - Brazilian Law No. 13,709/2018 (LGPD) for clients in Brazil - GDPR principles for EU/Portugal clients

3. Processing Purposes

Data will be used exclusively for:

• Provision of contracted remote services
• Technical and operational communication
• Compliance with applicable legal obligations

As a remote service provider, Contcore acts as a Data Processor when operating under instructions from European clients (GDPR Article 28).

4. International Transfers

Being a remote service provider: - European client data remains stored in their region - Any transfers use compliance mechanisms such as: • Standard Contractual Clauses • Binding Corporate Rules (where applicable)

5. Data Subject Rights

Under applicable regulations:

• Access and rectification (via contracting client)
• Portability upon formal request
• Erasure according to retention policies

European clients should primarily exercise rights through their local data controller.

6. Security Measures

As a remote provider, we implement: - Data encryption in transit and at rest - Restricted access based on functional need - Strict confidentiality policies - Regular security audits

7. Final Provisions

This policy reflects our exclusive remote service model: - Does not constitute establishment in the EU under GDPR - Clients maintain primary control over their data - Brazilian laws apply as primary jurisdiction