Privacy Policy

01Who is responsible for your data

NORTHGATE LTDA, Tax ID (CNPJ) 65.834.600/0001-09, with offices at Rua Aluisio de Azevedo, 751, Alto Alegre, Cascavel/PR, ZIP 85.805-100, Brazil, is the controller of the personal data described in this policy.

This policy covers northgatee.com and the commercial relationship that starts from it. It does not cover the systems we build and operate for clients: in those, the client is the controller and we act as processor, under the terms of the service agreement signed between us.

02What we collect

We keep collection deliberately small. In practice, that means:

• Data you give us. Name, company, work e-mail, phone, segment and the description of your problem, sent through the contact form or by e-mail.
• Data from the relationship. Messages exchanged, meeting notes, proposals, contracts and billing information, once a commercial conversation is under way.
• Technical data. Anonymous access logs kept by our hosting provider (IP address, browser, pages visited, timestamps) for security and stability.

We do not collect sensitive personal data through this site, and we ask you not to send it through the form. We do not knowingly collect data from children or adolescents.

03Why we use it, and on what legal basis

Under the Brazilian General Data Protection Law (LGPD, Law 13.709/2018), each use has a basis:

• Replying to your request and preparing a proposal — pre-contractual steps taken at your request (art. 7, V).
• Running a signed contract, including support, invoicing and delivery — performance of a contract (art. 7, V).
• Security, fraud prevention and keeping the site working — legitimate interest (art. 7, IX).
• Legal and tax obligations, such as keeping invoices and contracts — compliance with a legal obligation (art. 7, II).
• Occasional messages about our work, when you have opted in — consent (art. 7, I), which you can withdraw at any time.

We do not sell personal data, we do not rent mailing lists and we do not run behavioural advertising on this site.

04Who else sees it

Your data is shared only with parties that make the service work, and only to the extent each one needs:

• Infrastructure and tooling providers — hosting, e-mail, document storage and project management, bound by contract to process data on our instruction only.
• Accounting, legal and audit advisers, when a legal obligation or the defence of a right requires it.
• Public authorities, when there is a legal duty or a valid judicial order.

Our own team accesses data on a need-to-know basis. No part of a project is handed to hidden subcontractors — the same commitment we put in our client contracts.

05International transfers

Some providers we rely on host data outside Brazil. When that happens, the transfer is made under safeguards accepted by the LGPD — standard contractual clauses or an equivalent instrument — and limited to what the service requires. We can tell you which providers are involved in your case if you ask.

06How long we keep it

We keep data only as long as the purpose that justified collecting it is alive:

• Contact requests that do not become a project — up to 24 months, then deleted.
• Contracts, invoices and fiscal records — for the period required by Brazilian law, typically five years after the relationship ends.
• Access logs — six months, as set out in the Brazilian Internet Civil Framework.

After the applicable period, data is deleted or irreversibly anonymised.

07How we protect it

Security is a delivery discipline for us, not a page in a policy. Applied to your data, that means encryption in transit, access control by role, tested backups, active monitoring and review of every provider that touches personal data.

No system is immune. If an incident occurs with a relevant risk to your rights, we notify you and the Brazilian data protection authority (ANPD) within the legal deadline, describing what happened and what we did about it.

08Your rights under the LGPD

At any time, and free of charge, you can ask us to:

• confirm that we process data about you, and access it;
• correct incomplete, inaccurate or outdated data;
• anonymise, block or delete data that is unnecessary, excessive or processed unlawfully;
• port your data to another provider, as regulated by the ANPD;
• delete data processed on the basis of consent;
• know with whom we have shared your data;
• withdraw consent, and be told what happens if you do;
• object to processing carried out on the basis of legitimate interest.

09Cookies

This site does not use advertising or cross-site tracking cookies. We use only what is strictly necessary to serve the pages and keep them secure, plus, where enabled, aggregated audience measurement that does not identify you individually.

Your browser lets you block or delete cookies at any time. Blocking strictly necessary cookies may break parts of the site.

10Changes to this policy

When this policy changes we update the date at the top of the page. If a change materially affects how we treat your data, we say so directly to the people concerned rather than relying on you noticing a new date.

11Talk to a human

Questions about this document, or about data we hold on you, go to NORTHGATE LTDA — Rua Aluisio de Azevedo, 751, Alto Alegre, Cascavel/PR, ZIP 85.805-100, Brazil. Tax ID (CNPJ) 65.834.600/0001-09.

Contact NORTHGATE