Privacy Policy - Intragroup

1. WHO WE ARE

INTRAGROUP INFORMATION TECHNOLOGY LTD., registered under CNPJ No. 11.275.941/0001-54, operator of the website https://intragroup.com.br/en, respects the privacy of its clients, partners, suppliers, candidates, and visitors, and is committed to protecting the personal data processed during the use of its website and digital channels.

This Privacy and Cookies Policy aims to explain, in a clear, transparent, and accessible way, how Intragroup collects, uses, stores, shares, and protects the personal data it processes, in accordance with Law No. 13.709/2018 (Brazilian General Data Protection Law – LGPD), as well as other applicable rules issued by the National Data Protection Authority (ANPD).

By accessing the website or using any of its electronic forms, the user acknowledges this Privacy Policy.

When processing depends on consent, such consent will be requested freely, informed, unequivocally, and specifically, as provided for in the LGPD.

Data Controller

Legal Name: INTRAGROUP INFORMATION TECHNOLOGY LTD.

CNPJ: 11.275.941/0001-54

Website: https://intragroup.com.br/en

2. WHAT DATA WE COLLECT

Intragroup collects only the personal data necessary to provide its services, support users, maintain business relationships, conduct recruitment activities, and continuously improve its digital channels.

Data provided by the user

When filling out forms available on the website, the following may be collected, depending on the type of request:

Full name;
Email address;
Phone number;
WhatsApp number;
Company name;
Job title (when provided);
Subject;
How the user learned about Intragroup;
Message;
Professional résumé and other information provided by the candidate during recruitment processes;
Other information voluntarily entered by the user.

The information provided will be processed exclusively for purposes related to handling the submitted request.

Purposes

The data may be used to:

respond to contact requests;
provide information about products, solutions, and services;
prepare commercial proposals;
carry out technology solution demonstrations;
maintain business relationships with clients and partners;
perform preliminary procedures related to service contracting;
conduct recruitment and selection processes;
answer questions and requests sent by users;
comply with legal and regulatory obligations.

Data collected automatically

During browsing on the website, technical information related to access may be collected automatically, such as:

IP address;
access date and time;
browser type and version;
operating system;
screen resolution;
device used;
pages visited;
traffic source;
time spent on the website;
cookie-generated identifiers;
navigation statistics.

These data are collected through proprietary and third-party technologies used by Intragroup to ensure proper website operation and improve the user experience.

Purposes

The automatically collected data may be used to:

ensure the security of the digital environment;
prevent fraud and unauthorized access;
identify technical failures;
improve browsing experience;
optimize website performance;
produce usage statistics;
measure marketing campaigns;
analyze conversions and commercial performance;
support strategic decisions related to the services offered.

3. LEGAL BASES FOR PROCESSING

The processing of personal data carried out by Intragroup strictly follows the legal bases provided for under the General Data Protection Law.

Depending on the purpose of processing, the following legal bases may be used:

performance of a contract or preliminary procedures related to the contracting of services requested by the data subject;
compliance with a legal or regulatory obligation;
exercise of rights in administrative, judicial, or arbitration proceedings;
credit protection, when applicable;
legitimate interest of Intragroup, balancing the company’s interests and the fundamental rights of the data subject;
data subject consent, whenever required by law, especially for non-essential cookies, marketing communications, and other situations where the LGPD so determines.

Whenever processing is based on consent, the data subject may revoke it at any time, without affecting the lawfulness of processing performed previously.

4. DATA SHARING

Intragroup does not sell, commercialize, or disclose personal data to third parties for economic purposes.

Data may be shared exclusively when necessary for the execution of the company’s activities, observing the principles of necessity, purpose, and security set forth in the LGPD.

Data may be shared with:

companies responsible for website hosting;
cloud infrastructure providers;
the RD Station platform for customer relationship management (CRM), marketing automation, and lead management;
providers responsible for sending electronic communications;
information technology service providers;
companies responsible for browsing and website performance analytics solutions;
providers of user behavior monitoring and digital experience improvement solutions;
companies belonging to Intragroup’s economic group, when necessary for customer support or service execution;
public authorities, regulatory bodies, or the Judiciary, when required by law or court order.

All vendors contracted by Intragroup undertake confidentiality and data protection obligations consistent with the LGPD and adopt appropriate information security measures.

5. TECHNOLOGIES USED

Intragroup uses technologies that contribute to proper website operation, better user experience, statistical browsing analysis, campaign measurement, and business relationship management.

Depending on the technological structure currently used on the website, the following resources may be employed:

RD Station, for lead management, marketing automation, business relationships, and opportunity tracking;
Google Ads, for conversion and advertising campaign performance measurement;
Google Analytics and/or equivalent Google technologies, for access statistics, browsing behavior analysis, and continuous website improvement;
Hotjar, for browsing experience analysis, heatmaps, visitor behavior, and usability improvement opportunities;
PixelYourSite and compatible technologies for marketing pixel management and event tracking;
Complianz, used to manage cookie consent in compliance with the LGPD.

The purpose of using these technologies is to:

understand how users interact with the website;
identify improvements in the browsing experience;
measure digital marketing campaigns;
evaluate conversions generated by advertising campaigns;
improve content, services, and features offered;
meet legal requirements related to cookie consent.

The use of these tools may involve the processing of online identifiers, IP addresses, browser information, device information, and browsing statistics, always in compliance with the legal bases provided for under the LGPD.

Intragroup may replace, update, or include new equivalent technologies whenever necessary, keeping this Policy updated.

6. INTERNATIONAL DATA TRANSFER

Because of the use of cloud computing services, marketing automation platforms, statistical analysis tools, and technologies provided by global companies, some personal data may be stored or processed on servers located outside Brazilian territory.

Whenever an international transfer of personal data occurs, Intragroup will adopt technical, administrative, and contractual measures intended to ensure an adequate level of protection, observing the requirements set forth in Articles 33 to 36 of the General Data Protection Law.

Contracted vendors must adopt security standards compatible with Brazilian legislation and contractually commit to confidentiality and protection of the information processed.

7. DATA RETENTION PERIOD

Personal data will be stored only for as long as necessary to fulfill the purposes described in this Policy, observing the principles of necessity and minimization set forth in the LGPD.

The retention period may vary according to the nature of the information processed and the applicable legal obligations.

Data may be retained for:

compliance with legal, tax, and regulatory obligations;
performance of contracts;
compliance with requirements from competent authorities;
exercise of rights in administrative, judicial, or arbitration proceedings;
fraud prevention and combat;
preservation of records required by law.

Once the purposes of processing have ended and there is no legal obligation justifying retention, the data will be deleted, anonymized, or securely stored, as permitted by law.

8. DATA SUBJECT RIGHTS

Under Article 18 of the General Data Protection Law, the data subject may exercise the following rights at any time:

confirmation of the existence of processing of their personal data;
access to data processed by Intragroup;
correction of incomplete, inaccurate, or outdated data;
anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;
portability of personal data, when applicable;
deletion of data processed based on consent, subject to legal retention exceptions;
information about the public and private entities with which Intragroup shared data;
information about the possibility of not providing consent and the consequences of such refusal;
revocation of consent, when processing is based on this legal ground;
objection to processing based on legitimate interest, when applicable;
request for review of decisions made solely on the basis of automated processing of personal data, when applicable.

Requests may be sent through the channels indicated in this Policy.

To ensure information security, Intragroup may request additional documents or information to confirm the requester’s identity before handling the request.

Requests will be reviewed and answered within the time limits established by applicable law.

9. DATA PROTECTION OFFICER (DPO)

In accordance with the General Data Protection Law, Intragroup provides a dedicated channel for handling requests related to the processing of personal data.

The Data Protection Officer (DPO) is responsible for acting as the communication channel between Intragroup, data subjects, and the National Data Protection Authority (ANPD).

Contact email:

[email protected]

Through this channel, requests related to the rights provided under the LGPD, questions about this Privacy Policy, requests to update information, revocation of consent, and other matters related to personal data protection may be submitted.

10. COOKIE POLICY

Cookies are small text files stored on the user’s device while browsing the internet. These files allow the website to function properly, improve browsing experience, and enable statistical and performance analysis.

Intragroup uses a cookie consent management platform, allowing the user to choose which cookie categories they wish to authorize, in compliance with the General Data Protection Law (LGPD).

Cookie Categories

Necessary Cookies

These are essential for the functioning of the website and the use of its core features.

These cookies allow, for example:

proper page operation;
browsing security;
user session management;
recording consent preferences;
protection against unauthorized access.

These cookies cannot be disabled by the website systems, as their use stems from legitimate interest and the technical need for the platform to operate.

Preference Cookies

These are used to store choices made by the user during browsing, providing a personalized experience.

These cookies may record information such as:

preferred language;
browsing preferences;
previously selected settings.

Their use depends on the settings defined by the user.

Statistical (Analytical) Cookies

These are used to understand how visitors use the website, allowing the generation of aggregated statistics that support continuous platform improvement.

These cookies may collect information such as:

most visited pages;
average time spent;
traffic sources;
browsing flow;
page performance;
conversion events.

Whenever possible, this information is processed in aggregated or pseudonymized form.

According to the technologies currently used by the website, the following services may be employed:

Google Analytics or equivalent Google technologies;
Hotjar;
other statistical analysis tools that may be implemented in the future.

Marketing Cookies

These are used to measure the effectiveness of advertising campaigns, track conversions, and personalize promotional content.

Depending on the website’s technological structure, the following may be used:

Google Ads;
PixelYourSite;
compatible campaign measurement technologies;
other digital advertising platforms that may be implemented in the future.

These cookies may record information related to the user’s interactions with advertising campaigns, allowing results to be evaluated and marketing actions optimized.

Consent for Cookie Use

Strictly necessary cookies are used regardless of user consent, as they are essential for website operation.

Analytical, preference, and marketing cookies will only be used when the user has given consent, whenever required by applicable law.

Consent may be granted, refused, or changed at any time through the cookie banner or management panel available on the website.

Revoking consent does not affect the lawfulness of processing performed previously.

How to Manage or Disable Cookies

In addition to the management panel provided by Intragroup, the user may configure their browser to block or delete cookies.

Disabling certain cookies may limit functionality, affect the browsing experience, or prevent some areas of the website from working properly.

11. INFORMATION SECURITY

Intragroup adopts technical, administrative, and organizational measures consistent with best information security and data governance practices, seeking to protect personal data against:

unauthorized access;
accidental loss;
destruction;
improper alteration;
unauthorized disclosure;
unlawful use;
any form of processing incompatible with applicable law.

Measures adopted may include:

information access control;
use of secure connections (HTTPS);
monitoring of technological environments;
internal information security policies;
authentication controls;
permission management;
periodic updates of the systems used.

Although Intragroup adopts high security standards, no technological environment is completely immune to incidents. Therefore, it is not possible to guarantee absolute security against events resulting from third-party actions, infrastructure failures, or other circumstances beyond the company’s control.

If a security incident involving personal data is identified and may cause relevant risk or harm to data subjects, Intragroup will adopt the measures provided for in applicable law, including, when necessary, notification to the National Data Protection Authority (ANPD) and to the affected data subjects.

12. INFORMATION PROVIDED BY THE USER

By filling out any form available on the Intragroup website, the user declares that:

the information provided is true, complete, and up to date;
they are authorized to represent the company indicated, when applicable;
they are aware that the provided data will be used to handle the submitted request;
they have read and understood this Privacy Policy;
when required, they have provided consent freely, informedly, and unequivocally.

The user agrees to inform Intragroup of any relevant changes to their personal data whenever necessary to keep the information up to date.

13. CHANGES TO THIS POLICY

This Privacy and Cookies Policy may be changed at any time to reflect:

changes in applicable law;
new guidance from the National Data Protection Authority (ANPD);
changes in the services offered by Intragroup;
implementation of new technologies;
updates to personal data processing practices.

Whenever relevant changes occur, the new version will be published on this page, including the corresponding update date.

It is recommended that this Policy be reviewed periodically so that the user remains informed about how their personal data is processed.

CONTACT

If you have questions about this Privacy Policy, about the processing of your personal data, or if you wish to exercise any of the rights provided for under the General Data Protection Law, please contact us through the channels below: