Privacy Policy

1. Identification of the Controller

The Controller of the personal data processed within this ecosystem is Palatine Academy. All decisions regarding data processing are guided by ethical governance, information security and strict compliance with the law.

For any clarification, request to exercise rights or communication with the institution, our Data Protection Officer (DPO) can be reached directly through the official channel: faleconosco@pltn.com.br.

2. Information We Collect

In strict observance of the principles of necessity and data minimisation (Art. 6, III of the LGPD), we collect only the data that is essential for each legitimate purpose:

• Registration and Academic Enrolment Data: Full name, email address, telephone/WhatsApp number for essential academic communications and access credentials to access courses and download materials in Palatine Academy's own environments.
• Interaction Data in the Curated Athenaeum (Second Brain): Name and email voluntarily provided when interacting, suggesting articles or recording academic discussions on the knowledge pages and research notes.
• Contact Forms and Waiting Lists: Information provided spontaneously (name, institutional email, job title and message) when requesting information about the courses, the Athenaeum or institutional partnerships.
• Technical Browsing Data and Cookies: IP address, date and time of access, browser type, operating system and pages viewed, collected to comply with a legal obligation (Art. 15 of the Brazilian Civil Rights Framework for the Internet) and to ensure the stability of the infrastructure and the integrity of the secure session across subdomains (*.pltn.com.br).

3. Legal Bases and Purposes of Processing

The entire cycle of personal data processing at Palatine Academy is supported by the exhaustive legal grounds set out in Article 7 of the LGPD:

• Performance of a Contract or Preliminary Procedures (Art. 7, V): To enable student enrolment, provide access to teaching content in our own learning environments, academic monitoring, student support and the issue of executive certificates.
• Free and Unambiguous Consent (Art. 7, I): To send executive newsletters, scientific articles from the Athenaeum and notices of new course launches, and to reply to general contact forms. Consent may be withdrawn by the data subject at any time.
• Compliance with a Legal or Regulatory Obligation (Art. 7, II): To retain connection records as required by the Brazilian Civil Rights Framework for the Internet and to issue the tax notes and records relating to educational transactions.
• Legitimate Interest of the Controller (Art. 7, IX): To improve cybersecurity against fraud and malicious attacks, for technical auditing of server stability and for performance support.

4. Data Sharing

Palatine Academy does not sell, rent or share personal data with third parties for unauthorised advertising or economic purposes. Sharing takes place exclusively in the following scenarios:

• Infrastructure and Essential Service Providers: Technology partners engaged for encrypted payment processing, the sending of transactional emails and high-security cloud hosting (such as the Vercel platform and Edge distribution networks), all bound by strict confidentiality and information security clauses.
• Legal or Judicial Order: In the event of an express order issued by a competent judicial or regulatory authority in the exercise of its legal powers.

5. Information Security and Retention

We adopt technical, organisational and administrative security measures capable of protecting personal data against unauthorised access, accidental incidents or unlawful destruction:

• All communication within the ecosystem travels exclusively over the encrypted HTTPS (TLS) protocol with advanced HTTP protection headers (HSTS, Content Security Policy, X-Content-Type-Options).
• Passwords and access credentials are stored under robust cryptographic hashes, inaccessible to staff or third parties.
• Personal data is retained for the time strictly necessary to fulfil the contracted purposes or to meet statutory retention periods (such as 6 months for connection records under the Brazilian Civil Rights Framework for the Internet and civil limitation periods). Once the legal period has ended, the data is securely deleted or anonymised.

6. Your Rights (Article 18 of the LGPD)

As a data subject, you may exercise the following rights at any time, free of charge and in a simplified manner, by contacting our official channel:

7. Contact and Data Protection Officer (DPO)

To exercise any of your rights under Article 18 of the LGPD, to request clarification about how your data is processed or to submit any privacy request, please contact our Data Protection Officer:

Data Protection Officer (DPO) email: faleconosco@pltn.com.br
Registered Office: Brasília, Federal District · Brazil