Your Privacy Rights

1. Your privacy rights

1. Right to know / access

Request confirmation of whether we process your personal information, and receive a clear copy of the specific pieces of information we hold about you.

2. Right to correct

Ask us to correct inaccurate personal information (changed your email, job title or company? Let us know).

3. Right to delete

Request deletion of personal information we've collected from you, subject to certain legal exceptions (for example, records we must keep for accounting purposes).

4. Right to data portability

Receive your data in a structured, commonly used, machine-readable format so you can take it to another provider, where applicable.

5. Right to opt out of sale or sharing

Opt out of the sale or sharing of your personal information, including for cross-context behavioral (targeted) advertising. See our Privacy Policy, section 6.

6. Right to limit use of sensitive personal information

Not currently applicable, as we do not collect sensitive personal information through this site.

7. Right to non-discrimination

We will not deny you goods or services, charge you a different price, or provide a different level of service because you exercised any of these rights.

8. Right to appeal

If we deny your request in whole or in part, you have the right to appeal our decision. See section 7 below.

2. How to submit a request

The process is free and straightforward:

1. Email us at site@agenciaproximopasso.com.br with the subject:
   Privacy Request – [type of request]
2. In the body, include:
   • Your full name
   • The email address you used to contact Próximo Passo (if different from the sender's address)
   • Your company, if applicable
   • Which right you're exercising (access, correction, deletion, opt-out, etc.)
   • Any additional details needed (specific data to correct, reason for deletion)
3. We will acknowledge receipt within a reasonable time.
4. We will respond within 45 calendar days of receiving your request (see section 3 for details on possible extensions).

3. Response time

We aim to respond to verified requests within 45 calendar days of receipt. When reasonably necessary, we may take up to an additional 45 days to respond (up to 90 days total); if so, we will notify you of the extension and the reason for it within the initial 45-day period.

4. Identity verification

To prevent someone else from accessing information that isn't theirs, we may ask you to confirm your identity before fulfilling certain requests (especially access, portability and deletion). This may include:

• Confirming the request was sent from the email address originally on file
• Confirming details only you would know (date of your last contact with us, topic discussed, company name)
• In exceptional cases, an identification document (deleted once verification is complete)

This process protects you, it isn't meant as a barrier.

5. Authorized agents

You may designate an authorized agent to submit a request on your behalf. We may require the agent to provide proof of your written authorization and may still require you to directly verify your own identity or confirm the authorization with us.

6. When we may deny a request

Applicable law allows us to deny a request, in whole or in part, in certain situations, including:

• Legal retention obligations: we cannot delete records we are required to keep (for example, accounting or tax records).
• Exercise of legal claims: data needed to defend against or pursue a legal claim.
• Compliance and security: data needed to detect security incidents or comply with a legal obligation.
• Manifestly unfounded or excessive requests: for example, repetitive identical requests submitted in a short period without new grounds.

Whenever we deny a request, in whole or in part, we will explain the specific reason and inform you of your right to appeal.

7. Appealing a decision

If we deny your request, you may appeal our decision by replying to our response email or writing to site@agenciaproximopasso.com.br with the subject "Privacy Appeal", explaining why you believe the decision should be reconsidered. We will review your appeal and respond within the time required by applicable law. If your appeal is denied, we will explain why and, where required, inform you of your right to file a complaint with a state regulator.

8. Filing a complaint

If you believe your rights were not properly addressed, California residents may file a complaint with:

• California Privacy Protection Agency (CPPA): cppa.ca.gov
• California Attorney General's Office: oag.ca.gov/privacy/ccpa

Residents of other U.S. states may contact their respective state Attorney General's office or consumer protection authority.

9. Direct contact

Privacy contact: Fabio Orlando (Co-Founder, Próximo Passo).

Email

site@agenciaproximopasso.com.br

Mailing address

Sorocaba, São Paulo, Brazil · CNPJ 49.670.135/0001-53