This Privacy Policy describes how Nun Tecnologia Sustentável Ltda ("we," "our" or "the Company") collects, uses, stores and protects the personal data of our research partners, clients, collaborators, website visitors and all others whose data is processed in connection with our research and experimental development activities in physical and natural sciences in Campo Bom, Rio Grande do Sul.
As a registered limited company (Ltda) conducting scientific research and experimental development, we are committed to compliance with the LGPD (Lei nº 13.709/2018), the CDC (Lei nº 8.078/1990) and applicable tax legislation in Rio Grande do Sul. Research and development activities involve processing partner data and, depending on the nature of the research, potentially sensitive environmental, biological or technical data — we apply high standards of data governance throughout.
Introduction and Scope
This Policy applies to all personal data processed in connection with our R&D activities — including industry partners and clients who commission research, academic and institutional collaborators, individual researchers or consultants who work with us, website visitors who submit partnership enquiries, and research participants whose data may be collected as part of experimental studies. The nature of scientific research means that the categories and sensitivity of data processed vary significantly by project — this Policy describes our general framework, which is supplemented by specific data governance documentation for individual research engagements.
Identity of the Controller
Entity type: Sociedade Limitada (Ltda)
CNPJ: 48.278.955/0001-31
Activity (CNAE): Pesquisa e Desenvolvimento Experimental em Ciências Físicas e Naturais
Address: Av. Edgar Hoffmeister, 600, Bairro Paulista, Campo Bom — RS, CEP 93716-508, Brasil
Email: privacidade@nuntecnologia.com.br
Personal Data We Collect
- Partner and client identification data: Company name, CNPJ, address, and the name, role, phone and email of the research or project contact at the partner organisation — collected when organisations engage our R&D services or sign research partnership agreements.
- Research collaboration data: Where research involves collaboration with academic institutions, government bodies or other research entities — names, institutional affiliations and contact data of the researchers or representatives involved.
- NFS-e and fiscal data: CNPJ or CPF and billing address for NFS-e issuance on every research service contract, in compliance with SEFAZ-RS and ISS/Campo Bom requirements.
- Research project data (partner-specific): Project briefs, technical specifications, data provided by partners as input to research, and all commercially confidential research information shared under research or NDA agreements. This is not personal data in the LGPD sense but is treated with equivalent confidentiality.
- Research participant data (where applicable): In research projects that involve human participants — identification, contact and any study-specific data collected in the research protocol. In all such cases, a specific informed consent and data governance framework is established for the project, consistent with LGPD and applicable ethical research standards.
- Contact and partnership enquiry data: Name, organisation and message when submitting partnership enquiries via our website form, WhatsApp or email.
- Technical website data: IP address, browser type, pages visited and access times.
Purpose and Legal Basis
| Purpose | Legal Basis (LGPD) |
|---|---|
| Delivery of R&D research and experimental development services | Performance of contract (Art. 7º, V) |
| Research partnership management and collaboration | Performance of contract; Legitimate interest |
| Research involving human participants | Consent (Art. 7º, I); Research by public body or research body (Art. 7º, IV where applicable) |
| Issuing NFS-e; SEFAZ-RS tax compliance | Legal obligation (Art. 7º, II) |
| ISS — Prefeitura de Campo Bom | Legal obligation (Art. 7º, II) |
| Scientific publication and research dissemination (anonymised) | Legitimate interest; Consent where required |
| Website analysis and improvement | Legitimate interest; Consent (cookies) |
Data Sharing
- Research collaborators (with partner agreement): Where research involves academic institutions, government agencies or co-research partners — only the minimum data necessary for the specific research collaboration is shared, under appropriate data governance agreements.
- SEFAZ-RS / Receita Federal: NFS-e data for research service contracts — fiscal compliance.
- Prefeitura de Campo Bom (ISS): For ISS obligations on research and development service activities.
- FAPERGS / CNPq / FINEP (where applicable): Where research is conducted under public research funding, minimum necessary reporting data is submitted to the relevant funding body as required by the grant terms.
- PROCON-RS: When required in a consumer dispute.
- Legal authorities: When required by a competent judicial or administrative order.
International Transfers
Our research activities are based in Campo Bom, RS. Where research collaborations involve international institutions or where scientific publications are submitted to international journals, partner identification data may be transmitted internationally as required by the collaboration or publication process — always under the guarantees of Art. 33 of the LGPD or recognised adequacy mechanisms. Research participant personal data is never transmitted internationally without explicit consent and a specific data governance framework.
Retention Periods
- NFS-e and fiscal records: Minimum 5 years under Receita Federal and SEFAZ-RS requirements.
- Research service contracts and partner data: Duration of the research relationship plus 5 years for contractual and dispute documentation.
- Research data and scientific records: In accordance with applicable scientific data retention standards and the specific terms of each research agreement — typically a minimum of 5 years from project completion, and longer where required by the funding body or the nature of the research.
- Research participant data (where collected): Defined in the specific data governance framework for each study, consistent with ethical research standards and LGPD — participants are informed of retention periods before participation.
- Partnership enquiry data (no engagement commenced): Up to 1 year from last contact.
- Website analytics: Aggregated and anonymised after 12 months.
Security Measures
- Partner research data stored in access-controlled systems — accessible only to researchers working on that specific project;
- Strict separation between different research partnerships — proprietary data from one partner not accessible to researchers working on a different partner's project;
- Unpublished research findings treated as confidential until publication is agreed with the partner;
- Website and digital communications encrypted in transit (HTTPS/TLS);
- NFS-e and fiscal records in compliance with SEFAZ-RS requirements;
- As a Ltda, formal internal data handling protocols maintained;
- Incident response procedures and breach notification per LGPD Art. 48.
Your Rights under the LGPD
- Confirmation and Access (Art. 18, I–II): Confirm whether we hold your data and receive a copy.
- Correction (Art. 18, III): Request correction of inaccurate data.
- Anonymisation / Blocking / Deletion (Art. 18, IV): Request deletion — subject to fiscal and research data retention obligations.
- Portability (Art. 18, V): Receive your data in a structured format.
- Withdrawal of Consent (Art. 8º, §5º): Withdraw consent at any time — for research participants this is described in the specific study consent form.
- Complaint to the ANPD (Art. 18, §1º): Lodge a complaint at www.gov.br/anpd.
We respond within 15 business days.
Cookies and Tracking
Our website uses cookies for essential functionality and aggregated performance analysis only. We do not use behavioural tracking or advertising cookies. Preferences can be managed through browser settings.
Protection of Minors
Research partnerships are engaged by organisations and adult professionals. Where any research study involves minor participants, a specific ethical review process, parental consent framework and additional data governance measures are applied in accordance with LGPD Art. 14 and applicable ethical research standards before any data collection begins. We do not collect personal data from children under 13 via our website.
Research Data Governance
Scientific R&D activities involve specific data governance considerations beyond standard LGPD requirements. We apply the following principles across all research engagements:
Updates to this Policy
This Policy may be updated to reflect changes in our research activities, the LGPD, ANPD guidance or applicable Rio Grande do Sul tax legislation. Material changes will be communicated to active research partners by email and via our website.
Contact & Data Protection Officer
All privacy requests, questions and complaints — including from research participants — should be directed to our Data Protection Officer (Encarregado — LGPD Art. 41):
Privacy Contact — Nun Tecnologia Sustentável Ltda
ANPD — Autoridade Nacional de Proteção de Dados
www.gov.br/anpd