Privacy Policy

Introduction

Comp9 is committed to protecting your privacy and ensuring transparency in our data practices. This Privacy Policy explains how we collect, use, share, and protect your personal information in compliance with applicable U.S. data protection laws.

This Policy is supplemented by additional internal policies, processes, and best practices. If you have any questions or concerns about how we handle personal data, please contact us through the designated Privacy Channels listed below.

Scope of This Policy

This Policy applies to Comp9 Consultoria Empresarial e Treinamento Ltda and governs the processing of personal data related to the use of our services in the United States. It describes our practices in relation to personal data collected from customers, employees, suppliers, and website visitors.

Information We Collect

We may collect personal data from you or about you in the following ways:

Directly from you (e.g., when you register, submit information, or interact with our services).
From third parties (e.g., hiring companies that use our services for business purposes).
Automatically (e.g., through website analytics, cookies, and tracking technologies).

Types of Personal Data Collected

Individuals: Name, email, phone number, job role, and any data provided during interactions.
Legal entities: Business name, legal representative, tax identification (EIN), address, contact details.
Job applicants: Resumes and professional background for recruitment purposes.
Website visitors: IP address (anonymized where applicable), browser type, and interaction history.

How We Use Your Information

We collect and process personal data for purposes including:

Delivering and managing services.
Complying with legal and regulatory obligations.
Improving the security and functionality of our website.
Sending updates, promotional content, or relevant notifications.
Enforcing company policies and protecting our legitimate interests.

Legal Basis for Processing Personal Data

Comp9 processes personal data in accordance with U.S. data protection laws, including:

Performance of contractual obligations (e.g., service agreements).
Legitimate business interests (e.g., improving our offerings, defending legal claims).
Legal compliance (e.g., responding to governmental requests).
Consent (where required, particularly for marketing or sensitive data processing).

Cookies and Website Analytics

Comp9 uses cookies and Google Analytics to enhance user experience and optimize our services. You may adjust browser settings to disable cookies or limit tracking.

Sharing and Disclosure of Personal Data

We may share your personal data under the following circumstances:

Service Providers: Trusted partners who assist in operations, such as IT security and data storage.
Legal Requirements: To comply with subpoenas, law enforcement requests, or regulatory mandates.
Business Interests: In case of mergers, acquisitions, or corporate restructuring.

We do not sell personal data.

International Transfers

Your data may be transferred to international entities, including our headquarters in Brazil. We ensure that all transfers comply with relevant U.S. privacy safeguards, including standard contractual clauses and secure data storage practices.

Data Retention & Security

Personal data will be stored securely for as long as necessary to fulfill its intended purposes, comply with legal obligations, or support business operations. Once retention is no longer required, we securely dispose or anonymize data.

Your Rights Under U.S. Law

Depending on your jurisdiction, you may have rights under CCPA, Virginia CDPA, or other state privacy laws, including:

Right to Know: Request details on what personal data we collect.
Right to Access: Obtain a copy of your personal data.
Right to Correct: Update inaccurate or incomplete information.
Right to Delete: Request deletion of personal data, subject to legal obligations.
Right to Opt-Out: Prevent the sale or sharing of personal data (Comp9 does not sell data).
Right to Non-Discrimination: We will not deny services or impose penalties for exercising privacy rights.

To exercise your rights, contact us using the Privacy Channels below.

Contact Information

For privacy inquiries, data requests, or complaints, contact our Data Protection Officer (DPO):

Juan Musso
📩 Email: contact@comp9us.com
📍 Address: Rua Itapaiuna 1800, apto 232, Edifício Anthurium, Jardim Morumbi, CEP 05705-901, São Paulo/SP, Brazil

Changes to This Privacy Policy

Comp9 may update this Privacy Policy to reflect changes in regulations, technology, or business practices. Any modifications will be posted on our website with the latest revision date.

Last Updated: May 12, 2025