Privacy Policy

Our commitment to privacy

Embaixada da Família® recognizes that privacy, data protection and respect for people's dignity are part of responsible institutional conduct.

This Privacy Policy explains, clearly and in proportion to how this website currently works, how matters related to personal data and digital technologies are handled in this environment.

Our principle is simple:

personal data should not be collected or used without necessity, a legitimate purpose and transparency.

The technological structure and features of this website may evolve. When that happens and there is a relevant impact on the processing of personal data, this Policy should be updated according to the features actually in use.

1. Party responsible for the website

The institutional digital environment is the responsibility of:

Embaixada da Família
CNPJ: 07.733.443/0001-30

For the purposes of this Policy, Embaixada da Família may also be referred to simply as the Embaixada.

Channel for privacy and data protection matters: in preparation. The institutional channel will be listed in this Policy once it is active.

We will not present as active a channel that is not yet actually available.

2. Who this Policy applies to

This Policy applies to the institutional website of Embaixada da Família® and to browsing on its public pages.

It should be understood in light of the features actually available in the digital environment.

Other services, programs, platforms, research, professional relationships, franchise processes or digital resources that may come to process personal data may require their own specific information, instruments and policies.

3. Current state of data collection by the website

In the version of the website submitted to technical review before this publication, no active mechanisms were identified for the direct collection of personal data through:

• contact forms;
• user registration;
• account creation;
• login;
• newsletter;
• chat;
• franchise interest forms;
• résumé submission;
• scheduling;
• active location collection;
• analytics tools;
• advertising pixels;
• remarketing mechanisms.

Resources or paths visually presented as unavailable or in preparation should not be understood as active data collection mechanisms.

If new features are activated, this Policy should be reviewed according to the nature of the data and operations involved.

4. Cookies

In the technical configuration reviewed before this publication, the website does not use its own application cookies for tracking, advertising, analytics or persistent personalization.

For this reason, a merely cosmetic cookie consent banner has not been implemented.

If technologies that use cookies or equivalent mechanisms and require information, preference management or consent are incorporated in the future, the corresponding structure should be assessed and implemented before or together with their activation.

5. Temporary session storage

The reviewed technical configuration uses the browser's temporary session storage, called sessionStorage, for a functional purpose: restoring the scroll position when a person returns to certain pages during the same browsing session.

This resource:

• serves a functional purpose;
• was not implemented for advertising;
• was not implemented for profiling;
• was not implemented to directly identify the person;
• does not remain as persistent storage after the corresponding browser session ends.

In the reviewed configuration, no use of localStorage by the application was identified.

6. Language preference

The website offers versions in Brazilian Portuguese, Spanish and English.

The current architecture uses the page address itself to determine the language being accessed.

As a result, the language preference does not depend on persistent browser storage to work.

7. Fonts and external resources

The typefaces used by the website, including Lora and Inter, have been configured to be served locally by the application itself.

During normal browsing submitted to technical review, no requests to Google Fonts or other third-party requests arising from the currently implemented features were identified.

This finding refers to the reviewed application and should not be interpreted as a definitive description of the future hosting, security, content delivery or technical service infrastructure that may be used.

8. Technical data from the production infrastructure

Even when a website has no forms or analytics tools, the infrastructure needed to make it available on the internet may process technical information related to the operation, security and delivery of its pages.

Depending on the production infrastructure actually used, this may include, for example:

• IP address;
• date and time of requests;
• technical information about the browser or device;
• pages or resources requested;
• security logs;
• error logs;
• information needed to prevent abuse and maintain the service.

The scope, purpose, retention periods and parties responsible for these records depend on the production infrastructure actually adopted.

This information should be confirmed, and this Policy updated, once the definitive hosting and other production services configuration is established.

9. Sensitive personal data

The fact that the website presents content on topics such as health, wellbeing, relationships, family, emotions, development, spirituality or faith does not, in itself, mean that the website is collecting sensitive personal data about its visitors.

In the currently reviewed configuration, there is no active field intended for visitors to provide such information.

If future features involve the processing of sensitive personal data, measures and information compatible with the nature, purpose and risks of that processing should be adopted.

10. Children and adolescents

Some institutional content and initiatives may address development, family, childhood or adolescence.

This does not mean that the website currently maintains mechanisms for the direct collection of personal data from children or adolescents.

Future features that directly involve children or adolescents should undergo a specific assessment of privacy, security, responsibilities, authorizations and other applicable requirements before being implemented.

11. Spirituality, faith and freedom of conscience

Embaixada da Família® recognizes spirituality as a dimension that may relate to meaning, purpose, transcendence, values, hope, connection, belonging and relationships.

For people who have faith, their convictions and traditions may be meaningful resources in their life experience.

Information related to religious convictions deserves special protection and should not be used for:

• discrimination;
• improper profiling;
• coercive proselytism;
• manipulation;
• commercial exploitation of vulnerability;
• improper restriction of freedom of conscience.

The presence of content about spirituality or faith on the website does not mean the automatic collection of information about visitors' religion, beliefs or absence of belief.

12. Principles for data processing

Whenever personal data is processed in connection with the Embaixada's digital activities, its design should take into account principles such as:

• purpose;
• adequacy;
• necessity;
• transparency;
• security;
• prevention;
• respect for people's rights.

The amount of information processed should be proportionate to the corresponding purpose.

Collecting less is also a way of protecting.

13. Data sharing

In the currently reviewed configuration, there is no active collection of personal data through website forms intended for sharing with third parties.

Embaixada da Família should not sell personal data as a product.

If future technological, professional or institutional services require suppliers or other parties to take part in data processing, that relationship should have a legitimate purpose, a compatible need and measures appropriate to the context.

This Policy should be updated when such relationships become relevant to the transparency owed to people.

14. Analytics, advertising and profiling

In the reviewed version of the website, no active mechanisms were identified such as:

• Google Analytics;
• Google Tag Manager;
• Meta Pixel;
• TikTok Pixel;
• LinkedIn Insight Tag;
• Hotjar;
• Microsoft Clarity;
• remarketing tools;
• mechanisms intended to build advertising profiles of visitors.

Any future adoption of technology of this kind should be assessed before activation, including the need to update this Policy and any applicable information, preference or consent mechanisms.

15. Automated decisions and artificial intelligence

In the configuration currently available to the public, the website does not use mechanisms intended to make automated decisions about visitors based on their personal data.

Future resources involving artificial intelligence, apps, digital agents, personalization or automated analysis should not be considered active merely because they are mentioned in institutional planning.

Before features of this kind are made available, the following should be assessed, as applicable:

• purpose;
• data used;
• security;
• privacy;
• transparency;
• oversight;
• limits of use;
• responsibilities;
• people's rights.

16. Security

Embaixada da Família® seeks to structure its digital environment responsibly and in a way that is compatible with the features in use.

No internet-connected environment, however, should be presented as absolutely invulnerable.

Security measures should be assessed and improved as the infrastructure, features, data processed and corresponding risks evolve.

17. Rights related to personal data

Whenever personal data is processed in connection with the Embaixada's activities, people may exercise the rights granted to them by applicable law, subject to the conditions that apply to each situation.

These rights may include, as applicable:

• confirmation that processing takes place;
• access;
• correction;
• information about use and sharing;
• deletion, blocking or anonymization where applicable;
• portability where appropriate;
• withdrawal of consent where consent is the basis used;
• objection or other rights provided for in applicable rules.

The exercise of a right will be assessed considering the nature of the processing, the identity of the person making the request, existing legal and professional obligations and legitimately applicable limits.

18. Channel for privacy matters

The Embaixada is setting up its institutional channel for privacy and data protection matters.

Once this channel is actually active, its details will be published in this Policy.

Until then, no fictitious email address, phone number, data protection officer name or other channel will be presented merely to formally complete this document.

Any appointment of a data protection officer or equivalent role will be made when applicable and institutionally defined.

19. Links and external environments

The website may in the future include links to external environments.

When accessing a service or page belonging to a third party, that environment's privacy practices may differ from those adopted by Embaixada da Família®.

The existence of a link does not imply full control over the technologies, policies or practices of the external environment.

Whenever an integration or specific relationship is relevant to data processing, the corresponding information should be presented appropriately.

20. New features

Before activating features that could significantly change the processing of personal data, the need to update this Policy should be assessed.

This includes, for example, the future implementation of:

• forms;
• registrations;
• user accounts;
• newsletter;
• scheduling;
• payments;
• restricted areas;
• apps;
• artificial intelligence resources;
• analytics;
• digital advertising;
• geolocation;
• integrations with external platforms;
• digital franchise processes;
• accreditation processes;
• other resources involving personal data.

Presenting a feature as “in preparation” does not mean that its data processing is already active.

21. Instituto I.M.A.G.E.M.® and research

Instituto I.M.A.G.E.M.® is a distinct institution within the ecosystem.

Browsing the institutional website of Embaixada da Família® does not mean automatic participation in research.

Research activities involving people or data should have their own procedures and comply with the corresponding ethical, institutional and regulatory requirements.

Consent to take part in research should not be presumed from simply browsing, taking part in programs or using public content.

22. Relationship with other documents

This Policy should be read together with other applicable institutional documents.

The Terms of Use set out conditions and limits related to the use of the digital environment.

The Ethical and Protection Standard presents principles of dignity, safety, freedom of conscience, responsibility and protection that guide institutional conduct.

Specific services, programs, professional relationships, research, franchises, accreditations or platforms may have their own instruments.

23. Updates to this Policy

This Policy may be updated due to changes that are:

• technological;
• institutional;
• operational;
• regulatory;
• in the infrastructure;
• in the website's features;
• or in the ways personal data is processed.

When a change is relevant to people, transparency measures compatible with its nature should be adopted.

The current version should state its update date when officially published.

24. Transparency is also care

A Privacy Policy should not serve merely to fulfill a formality.

It should help people understand what happens to their information.

That is why we seek to present the real state of the available features, without attributing to the website mechanisms it does not have and without hiding technologies that actually come to process data.

As the digital environment evolves, this Policy should evolve too.

Caring for data is also a way of caring for people.

Base text subject to legal validation and confirmation of the definitive production infrastructure before its definitive publication.