Privacy Policy

1. Who we are

Próximo Passo is a B2B SEO agency headquartered in Sorocaba, São Paulo, Brazil, registered under CNPJ 49.670.135/0001-53. We operate the website agenciaproximopasso.com and are the entity responsible for the personal information collected through this site.

For any privacy-related matter, contact us at site@agenciaproximopasso.com.br.

2. Scope and applicable law

This Privacy Policy applies to visitors of the English-language, U.S.-facing version of our site (agenciaproximopasso.com). It is designed with reference to the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), and follows similar principles found in other U.S. state privacy laws (for example Virginia, Colorado, Connecticut and Utah). Próximo Passo is a Brazilian company and is primarily subject to Brazil's General Data Protection Law (LGPD); we extend comparable transparency and control to visitors from the United States as a matter of policy, regardless of whether every statutory threshold of a given state law applies to our business.

3. Information we collect

3.1. Information you provide directly

When you contact us (WhatsApp, forms, scheduling a call), we collect:

• Full name
• Work or personal email address
• Phone number (when provided)
• Company name, job title and industry
• Messages and information you share with our team

3.2. Information collected automatically

When you browse the site, we automatically collect:

• IP address (anonymized where applicable)
• Browser type and version, operating system, language settings
• Pages visited, time on page, browsing flow
• Referral source (site, search engine or campaign that brought you here)
• Device identifiers and cookies (with your consent, where optional)

3.3. Information we do not collect

We do not collect sensitive personal information (racial or ethnic origin, religious beliefs, political opinions, health data, sexual orientation, biometric data) and we never request financial or banking information through the site.

4. How we use your information

• Sales support: respond to inquiries, schedule diagnostics, prepare proposals, keep a record of our relationship.
• Contract performance: deliver contracted services and maintain business records.
• Communication: send replies, requested materials and relevant updates about ongoing projects.
• Marketing (with consent): occasional educational content, news and event invitations. You can unsubscribe at any time.
• Site improvement: analyze aggregated visitor behavior to improve usability, content and speed.
• Targeted advertising (with consent): remarketing on platforms such as Google Ads and Meta Ads to show Próximo Passo content to people who showed interest.
• Legal compliance: respond to lawful requests from authorities, and exercise or defend legal claims.
• Security: prevent fraud, detect and mitigate security incidents, keep the site safe.

5. Sources of information

We collect personal information directly from you (forms, WhatsApp, email), automatically through your use of the site (cookies and similar technologies), and, occasionally, from advertising and analytics partners (Google, Meta) who provide aggregated insights about how ads and campaigns perform.

6. Sale or sharing of personal information

Próximo Passo does not sell personal information in exchange for money. However, under the CCPA/CPRA's broad definition, our use of advertising cookies and pixels (Google Ads, Meta Ads) for interest-based advertising may be considered a "share" of personal information, even though no money changes hands.

You can opt out of this sharing at any time through our cookie preferences panel (declining "Marketing and remarketing" cookies) or by contacting us at site@agenciaproximopasso.com.br. See also section 14 regarding automated opt-out signals.

7. Who we disclose information to

We only share personal information with service providers necessary to operate the site and our business, under confidentiality and data-processing agreements:

• Hosting and infrastructure: Hostinger International Ltd. (site hosting).
• Communication: WhatsApp (Meta Platforms, Inc.) for direct customer contact.
• Analytics: Google LLC (Google Analytics 4), only with your consent.
• Advertising: Google LLC (Google Ads), Meta Platforms, Inc. (Facebook/Instagram Ads), only with your consent.
• Internal CRM: Próximo Passo's own tools, with access restricted to staff involved in your inquiry.
• Public authorities: when required by law, court order, or lawful request from a competent authority.

8. Cookies and tracking technologies

We use first-party and third-party cookies to make the site work, remember your preferences, measure traffic and personalize communication. You control which categories you accept through the consent banner or the floating preferences button, available on every page.

For full details on every cookie we use, see our Cookie Policy.

9. Data retention

Your data is stored on servers located in Brazil (Hostinger) and may be processed on servers of our service providers in other countries (see section 13).

Retention periods:

• Sales contact data: up to 5 years after our last interaction, for relationship history.
• Contractual and financial records: as required by applicable law.
• Browsing data (analytics cookies): up to 14 months (Google Analytics 4 default).
• Remarketing data: up to 540 days (Google Ads default).
• Access and security logs: 6 months.

After these periods, data is anonymized or deleted, unless a longer retention period is legally required.

10. Data security

We apply technical and administrative safeguards to protect your data, including:

• HTTPS encryption (TLS 1.3) across the entire site
• Role-based access control (only authorized staff access specific data)
• Multi-factor authentication on critical systems
• Access logs and periodic audits
• Regular backups with encryption at rest
• Contracts with service providers establishing minimum security standards

In the event of a security incident that could pose a meaningful risk to affected individuals, we will notify affected individuals and, where legally required, applicable authorities within a reasonable timeframe.

11. Your privacy rights

Depending on your state of residence, you may have the right to:

• Know / Access the personal information we hold about you and how it is used and shared
• Correct inaccurate personal information
• Delete personal information we hold about you, subject to certain exceptions
• Portability: receive your data in a portable, readily usable format
• Opt out of the sale or sharing of personal information, including for targeted advertising
• Limit use and disclosure of sensitive personal information (not applicable, as we do not collect sensitive personal information)
• Non-discrimination for exercising any of these rights
• Appeal a decision we make regarding your request

12. Children's privacy

Próximo Passo's site and services are intended for business professionals aged 18 and over, in a B2B context. We do not knowingly collect personal information from children under 13 (as defined by the Children's Online Privacy Protection Act, COPPA). If we become aware that we have inadvertently collected such information, we will delete it promptly.

13. International data transfers

Because Próximo Passo is based in Brazil, personal information collected through this site is processed in Brazil and may also be processed by service providers (Google LLC, Meta Platforms, Inc., Hostinger International Ltd.) on servers located outside the United States. We require our service providers to maintain safeguards consistent with applicable data protection standards.

14. Do Not Track & Global Privacy Control

Our site does not currently respond to browser "Do Not Track" signals. We also do not yet automatically detect Global Privacy Control (GPC) signals; we are working toward supporting automated opt-out preference signals. Until then, you can opt out of analytics and advertising cookies at any time through our cookie preferences panel, described in our Cookie Policy, or by emailing site@agenciaproximopasso.com.br.

15. Changes to this policy

We may update this policy periodically to reflect changes in our practices, the technologies we use, or legal requirements. The "last updated" date at the top of this page always reflects the most recent revision.

For material changes (that reduce your rights or expand the information we collect), we will post a notice on the site and, where applicable, notify you by email.

16. Contact us

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