This Privacy Policy describes how RSC Impulse Representações Ltda ("we," "our" or "the Company") collects, uses, stores and protects the personal data of our principals (represented manufacturers and suppliers), buyers, their commercial representatives, website visitors and all others whose data is processed in connection with our commercial representation and trade agent activities in Ananindeua, Pará.
As a registered limited company (Ltda) engaged in commercial representation under Lei 4.886/65 and Lei 8.420/92, we are committed to compliance with the LGPD (Lei nº 13.709/2018), the CDC (Lei nº 8.078/1990), applicable SEFAZ-PA tax requirements and applicable legislation in Pará. Commercial representation involves accessing confidential commercial information from both principals and buyers — we treat all such data with the discretion the profession requires.
Introduction and Scope
This Policy applies to all personal data processed in connection with our commercial representation activities — including manufacturer and supplier principals who appoint us as their representative, buyers and their purchasing contacts in the Região Norte, website visitors who submit enquiries, and any individual whose data appears in commercial documentation. As an intermediary, we handle data from two distinct groups — principals and buyers — with distinct confidentiality obligations to each.
Identity of the Controller
Entity type: Sociedade Limitada (Ltda)
CNPJ: 48.278.735/0001-08
Activity (CNAE): Representantes Comerciais e Agentes do Comércio de Mercadorias em Geral Não Especializado
Professional registration: CORE-PA — Conselho Regional dos Representantes Comerciais do Pará
Address: Cond. Ilhas do Marajó, Passagem São Paulo, 18, Distrito Industrial, Ananindeua — PA, CEP 67035-440, Brasil
Email: privacidade@rscimpulse.com.br
Personal Data We Collect
As a commercial intermediary, we process data from two distinct groups of data subjects:
A. Principals — manufacturers and suppliers we represent:
- Company name, CNPJ, address and the name, role, phone and email of the commercial or sales contact at the principal — collected when establishing a representation mandate.
- Commercial terms, product catalogues, pricing tables and commission structures provided under the representation agreement — treated as commercially confidential.
- NFS-e billing data for commission settlement documentation.
B. Buyers — clients and prospects in the Região Norte:
- Company name, CNPJ, address and the name, role, phone and email of the purchasing or commercial contact — collected during prospecting and order facilitation.
- Purchase history, order volumes, payment history and account status — maintained for account management and principal reporting.
- Credit standing information (where provided voluntarily by the buyer or obtained from publicly available commercial sources such as SERASA) — used solely to support principal decision-making on credit terms.
C. Website and general contact:
- Name, company and message when submitting enquiries via our website form or WhatsApp.
- IP address, browser type, pages visited and access times.
Purpose and Legal Basis
| Purpose | Legal Basis (LGPD) |
|---|---|
| Commercial representation services for principals | Performance of contract (Art. 7º, V) |
| Buyer prospecting and account development | Legitimate interest (Art. 7º, IX) |
| Order facilitation and transaction intermediation | Performance of contract (Art. 7º, V) |
| Commercial reporting to principals | Performance of contract |
| Commission settlement and NFS-e issuance | Performance of contract; Legal obligation (Art. 7º, II) |
| ISS — Prefeitura de Ananindeua | Legal obligation (Art. 7º, II) |
| SEFAZ-PA tax compliance | Legal obligation (Art. 7º, II) |
| CORE-PA regulatory compliance | Legal obligation (Art. 7º, II) |
| Website analysis and improvement | Legitimate interest; Consent (cookies) |
Data Sharing
- Principals (represented manufacturers/suppliers): Buyer name, contact, order data and account status shared with the specific principal whose products are the subject of the transaction — as an inherent part of the representation mandate under Lei 4.886/65.
- Buyers: Minimum principal identification data shared to facilitate the commercial transaction — product origin, manufacturer identification and terms necessary for the buyer to make an informed purchasing decision.
- SEFAZ-PA / Receita Federal: NFS-e data for commission service contracts — fiscal compliance.
- Prefeitura de Ananindeua (ISS): For ISS obligations on commercial representation service activities.
- CORE-PA: Professional registration compliance data as required by the Conselho Regional dos Representantes Comerciais do Pará.
- PROCON-PA / Senacon: When required in a consumer or commercial dispute.
- Legal authorities: When required by a competent judicial or administrative order.
International Transfers
Our commercial representation activities are based in Ananindeua, PA. Where we represent manufacturers or suppliers based outside Brazil — or where buyer data is reported to principals in other countries — such transfers occur under the guarantees of Art. 33 of the LGPD or recognised adequacy mechanisms. International principals are informed of LGPD requirements as part of the representation mandate. No Brazilian buyer data is transferred internationally beyond what the specific transaction with an international principal requires.
Retention Periods
- NFS-e and commission records (SEFAZ-PA): Minimum 5 years under federal and state tax legislation.
- Representation contracts and mandate records: Duration of the mandate plus 5 years — the applicable commercial dispute period under Lei 4.886/65 and the Código Civil.
- Buyer account records and purchase history: Duration of the active commercial relationship plus 3 years after last transaction — sufficient for commercial dispute and warranty purposes.
- Prospecting and contact data (no transaction concluded): Up to 2 years from last contact — commercial relationships in the Norte market often develop over longer prospecting cycles.
- CORE-PA registration records: For the duration of our professional registration and as required by CORE-PA.
- Website enquiry data (no engagement): Up to 1 year from last contact.
- Website analytics: Aggregated and anonymised after 12 months.
Security Measures
- Principal pricing tables, commission structures and commercial terms stored in access-controlled systems — not shared across our portfolio of represented manufacturers;
- Buyer purchase data and account information segregated by principal mandate — buyers of manufacturer A's products are not visible to manufacturer B;
- Commercial communications handled with discretion — pricing and strategy data shared only through appropriate channels;
- NFS-e and fiscal records in compliance with SEFAZ-PA digital certificate requirements;
- Website encrypted in transit (HTTPS);
- 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 commercial contact or identification data.
- Anonymisation / Blocking / Deletion (Art. 18, IV): Request deletion — subject to mandatory fiscal and contractual retention obligations under Lei 4.886/65.
- Portability (Art. 18, V): Receive your data in a structured format.
- Opposition (Art. 18, §2º): Object to processing based on legitimate interest — particularly relevant for buyers who object to prospecting contact.
- Information on sharing (Art. 18, VII): Find out which principals or entities your data has been shared with.
- Withdrawal of Consent (Art. 8º, §5º): Withdraw consent at any time for consent-based processing.
- 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 may use 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
Commercial representation contracts are entered into by adults acting in a professional capacity on behalf of legal entities. We do not intentionally collect personal data from children under 13. All commercial mandates and buyer engagements are handled by adults legally authorised to represent their organisations.
Commercial Representation Law & CORE-PA
Commercial representation in Brazil is governed by specific legislation that affects how we process and retain commercial data:
Updates to this Policy
This Policy may be updated to reflect changes in our activities, the LGPD, ANPD guidance, CORE-PA requirements or applicable Pará tax legislation. Material changes will be communicated to active principals and buyers by WhatsApp or email and via our website.
Contact & Data Protection Officer
All privacy requests — from principals and buyers alike — should be directed to our Data Protection Officer (Encarregado — LGPD Art. 41):
PRIVACY CONTACT — RSC IMPULSE REPRESENTAÇÕES LTDA
ANPD — Autoridade Nacional de Proteção de Dados
www.gov.br/anpd