Privacy, Data Protection, and Cookies Policy

 

Last Updated: October 23, 2025

Welcome to Proceder Marketing!

This policy aims to inform you, as the data subject, about how Proceder Marketing Digital, in its capacity as the Data Controller, collects, uses, and protects your personal data.

By using our services and browsing our website, you agree to the practices described in this policy, in full compliance with the General Data Protection Regulation (GDPR – Regulation (EU) 2016/679) and the Brazilian General Data Protection Law (LGPD – Law No. 13.709/2018).


 

1. Collection, Use, and Legal Basis for Data Processing

 

At Proceder Marketing, we value your privacy. We collect personal data and browsing information for the following purposes, each supported by a specific Legal Basis, as required by GDPR and LGPD:

Purpose of ProcessingData CollectedLegal Basis (GDPR/LGPD)
Website Improvement and Performance AnalysisIP address, location, visited pages, time spent, browsing behavior (via cookies).Legitimate Interest of the Controller and Consent (for non-essential cookies).
Communications and Marketing (newsletters, offers, content)Name, email, phone.Consent of the Data Subject (obtained via clear and specific opt-in).
Contract Performance (contracted services and quotes)Name, email, phone, and financial/payment information.Performance of a Contract or Pre-Contractual Measures.
Advertising Personalization (Targeted Ads)Browsing data and hashed data for advertising tools (Meta ADS, Google Ads, LinkedIn ADS, Bing ADS).Consent of the Data Subject or Legitimate Interest.
Compliance with Legal ObligationsData required for issuing invoices and complying with legal requirements.Compliance with a Legal or Regulatory Obligation.

 

2. Sharing and International Data Transfer

 

 

2.1 Sharing

 

Your personal data will not be shared with third parties without your consent, except in the following situations:

  • Business Partners and Advertising Tools: Google Ads, Meta ADS, LinkedIn ADS, and Bing ADS, for ad targeting and performance analysis purposes.

  • Service Providers (Data Processors): Companies that assist us in website management, hosting, email marketing, and internal systems, who process data on our behalf.

  • Legal Obligation: When required by law, court order, or to protect the rights and security of Proceder Marketing.

 

2.2 International Data Transfer (GDPR Chapter V / LGPD Art. 33)

 

We utilize services from technology partners (such as Google, Meta, etc.) which may have servers located outside the European Union and/or Brazil. In these cases, Proceder Marketing ensures that the transfer is carried out in compliance, using mechanisms that provide an adequate level of personal data protection, such as:

  • Adoption of Standard Contractual Clauses (SCCs).

  • When the transfer is necessary for the Performance of a Contract or due to Legitimate Interest.

 

3. Data Subject Rights (GDPR Chapter III / LGPD Art. 18)

 

You have the right to exercise, at any time, and by formal request to our Data Protection Officer (DPO), the following rights:

  1. Right to Confirmation of processing and Access to the data.

  2. Right to Rectification of inaccurate or incomplete data.

  3. Right to Erasure (right to be forgotten), Restriction of Processing, or Blocking of unnecessary, excessive, or unlawfully processed data.

  4. Right to Data Portability.

  5. Right to Object to processing.

  6. Right to Withdraw Consent at any time.

  7. Right to Review Automated Individual Decisions, including profiling.

 

4. Controller and Data Protection Officer (DPO)

 

 

4.1. Data Controller

 

The identity of the Controller responsible for processing your data is:

  • Proceder Marketing Digital

  • Address in the EU (Spain): Carrer de Càceres, 08028 Barcelona, Spain.

  • Address in Brazil: Tv. Dona Paula, 13, Higienópolis, São Paulo – SP, 01239-050, Brasil.

 

4.2. Data Protection Officer (DPO)

 

The DPO is the communication channel for privacy matters.

  • DPO Department: Marketing & Comunicação

  • Exclusive Email for Privacy Matters: [email protected]

To exercise your rights or for any questions regarding this policy, please contact us via the DPO email address.

Proceder Marketing Digital

October 23, 2025

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