THEION / PRIVACY NOTICE / SEPTEMBER 2026

Privacy begins by reducing unnecessary collection.

This notice describes the current institutional website. If the site begins using forms, accounts, audience measurement or new providers, the notice must be reviewed before activation.

CONTROLLER AND CHANNEL

A named organization and a direct path for privacy questions.

Declared controller: THEION PROJETOS INTEGRADOS LTDA — CNPJ 62.110.803/0001-56. Privacy channel: vitor@theionintegratedprojects.com.

01

Purpose

Personal data should be used for a legitimate, specific and communicated purpose.

02

Necessity

Processing should be limited to data relevant and proportionate to that purpose.

03

Transparency

The data subject should be able to understand the processing and identify the responsible party.

04

Security

Technical and administrative measures should address unauthorized access, loss, alteration and disclosure.

05

Accountability

The responsible organization should be able to demonstrate that safeguards are effective for the actual processing.

CURRENT OPERATIONAL NOTICE

What happens, what does not happen and where the boundary changes.

The statements below are deliberately scoped to the public website and direct institutional email. They do not silently extend to a future product, client system or professional engagement.

P1Controller and scope

For personal data whose purposes and means are determined by the company, the declared controller is THEION PROJETOS INTEGRADOS LTDA, CNPJ 62.110.803/0001-56. This notice covers the institutional website and messages sent to the channel below. Contracts, professional relationships or future operations may require additional notices.

P2Current website collection

The current public site does not create user accounts, host an embedded contact form or install a THEION-operated behavioral analytics or advertising tool. This statement describes the current configuration and must be reviewed before a new collection mechanism is activated.

P3Local search, briefs and device actions

Search terms and guided-brief choices are processed in the visitor’s browser against public content bundled with the site. Copy and share actions request browser or device capabilities. Opening the external Getnet checkout is also an explicit visitor action. These interactions do not transmit a search, selection, draft or payment data to THEION by themselves.

P4Email contact

Contact links use the mailto protocol to prepare a draft in the visitor’s email application. A message is transmitted only when the visitor chooses to send it, after which the sender’s provider, THEION’s email infrastructure and any necessary service provider may process the message under the applicable purpose and policies.

P5Hosting and technical records

The hosting and network providers may process technical records such as IP address, time, requested resource and browser information for delivery, availability, abuse prevention and infrastructure diagnosis. This notice does not represent those provider records as a THEION visitor-profiling system.

P6Purposes and legal grounds

Data voluntarily sent by email may be used to respond to the request, carry out preliminary procedures requested by the data subject, comply with legal or regulatory obligations, exercise rights and protect the operation. The applicable legal ground depends on the concrete relationship; simple browsing is not treated as consent to advertising.

P7Retention and deletion

Information received directly should remain only for the period compatible with its purpose, the relationship and applicable legal, regulatory, professional or rights-preservation duties. A deletion request must also be evaluated against lawful retention requirements.

P8Data-subject requests

Subject to the Brazilian General Data Protection Law and the circumstances of the processing, a person may request confirmation, access, correction and information about sharing, as well as other applicable rights. Responding may require identity confirmation, locating the data and evaluating retention obligations.

P9Providers and international processing

Hosting, email infrastructure, Getnet checkout and other services selected by the visitor may process data under their own policies and may use infrastructure in other countries. THEION does not receive card data through this website and does not publish a definitive transfer claim without verifying the concrete provider, contract and data flow.

P10Updates and interpretation

This notice must be reviewed before activating a new form, account, metric, vendor or integration. The publication date identifies the public version. This operational disclosure does not replace legal analysis of a specific contract, incident or future processing activity.

MINIMIZE THE FIRST MESSAGE

Do not send secrets or sensitive material before a protected purpose exists.

Avoid passwords, credentials, complete identity documents, health or biometric data, confidential technical files and unnecessary third-party information.

Rights and safeguards depend on the concrete data flow.

The applicable duties may vary with the purpose, people, location, provider, contract and professional context. The current notice does not claim compliance for a future or unexamined system.

Data-subject rights — Brazilian authority

PRIVACY REQUEST

Ask about the data and purpose that matter to your case.

The email draft helps identify the relationship, request and approximate period. THEION may need to confirm identity and locate the relevant data before responding.

Prepare a privacy request