Privacy and Personal Data Protection Policy

Last updated: 7 May 2026  ·  Version 1.0

As SixTree is a Brazilian company, this Policy is governed by Brazilian law; the original Portuguese version prevails in case of interpretive doubt.

1. Introduction

Having your personal data properly looked after is a right protected by Law No. 13,709 of 14 August 2018, known as the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais, LGPD), and an obligation of SixTree to you.

This Privacy Policy adopts a privacy by design approach and is intended to make transparent how SixTree processes your personal data, in compliance with:

2. To Whom This Policy Applies

This Policy applies to all personal data processed by SixTree in the context of its strategic advisory and product studio services, encompassing:

This Policy does not apply to third-party services, sites or products eventually accessed via links present in our channels. We recommend consulting the respective privacy policies of those third parties.

3. Identification of the Controller

For the purposes of this Policy, the Controller of the personal data collected is the legal entity identified below:

SIXTREE CONSULTORIA EM DESENVOLVIMENTO SUSTENTÁVEL LTDA
CNPJ (Brazilian company registration number): 62.144.984/0001-31
Quadra ARNO 12, Alameda das Aroeiras, H.M. 02, Lote 03 — Palmas/TO, Brazil — Postcode 77.001-048

Institutional email for privacy matters: office@sixtree.co

4. Terms and Definitions

For the better understanding of this document, we adopt the terms defined in Article 5 of the LGPD, summarised below:

Personal data
information related to an identified or identifiable natural person.
Sensitive personal data
personal data concerning racial or ethnic origin, religious belief, political opinion, trade union membership or membership in religious, philosophical or political organisations, data referring to health or sexual life, genetic or biometric data, when linked to a natural person.
Anonymised data
data relating to a data subject who cannot be identified, considering the use of reasonable technical means available at the time of processing.
Data subject
the natural person to whom the personal data being processed refers.
Processing
any operation performed with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
Controller
the natural or legal person, of public or private law, to whom the decisions concerning the processing of personal data are attributed.
Processor
the natural or legal person, of public or private law, who carries out the processing of personal data on behalf of the Controller.
Data Protection Officer (DPO)
the person appointed by the Controller to act as the channel of communication between the Controller, the data subjects and the Brazilian National Data Protection Authority (ANPD).
Consent
the free, informed and unequivocal expression by which the data subject agrees to the processing of their personal data for a specified purpose.
Anonymisation
use of reasonable technical means available at the time of processing through which a piece of data loses the possibility of association, directly or indirectly, with an individual.
ANPD
Brazilian National Data Protection Authority, the federal public administration body responsible for ensuring, implementing and supervising compliance with the LGPD throughout the national territory.

5. How We Collect Your Data

We collect your personal data through different means, as detailed below. In accordance with the principle of necessity (Article 6, III, of the LGPD), we collect only the data strictly necessary to fulfil the purposes set out in this Policy.

How we collectWhat that means
Through your inputWe collect data you voluntarily provide when filling in the Diagnostic Brief form, contact forms, commercial proposals or registrations on our official channels.
Through your interaction with the siteWe collect data automatically generated when you browse sixtree.co, such as IP address, approximate geolocation (city or region), device type, operating system, browser, and pages visited, in compliance with Article 7, I, of the Internet Civil Framework.
Through cookiesSmall text files sent by the site to your device, stored either temporarily or permanently. Information stored in cookies is also considered personal data and follows all the rules of this Policy.
Through technology providersWe collect data processed by our Processors (Google Workspace, Vercel, Google Analytics and Google reCAPTCHA), as detailed in Section 8.

5.1. Data collected in the Diagnostic Brief form

When you respond to the Diagnostic Brief, we collect:

SixTree does not collect sensitive personal data through the Diagnostic Brief form or at any other point of commercial interaction.

5.2. Cookies used

The sixtree.co site uses only two categories of cookies, described below. We do not use marketing cookies, behavioural advertising cookies or cross-site tracking cookies.

CategoryPurpose
Strictly necessary cookiesEnsure the technical functioning of the site, such as session, security and language preference. They cannot be disabled without affecting navigation.
Analytics cookies (Google Analytics)Allow us to understand the aggregate use of the site for statistical and content improvement purposes. They can be disabled in your browser settings without affecting page functionality.

The detailed list of cookies, with the name, purpose and duration of each, is available on request to the DPO at office@sixtree.co.

5.3. Managing your consent

When you visit sixtree.co for the first time, we display a banner so you can decide about the use of analytics cookies (Google Analytics). By default, these cookies are disabled until you accept — in compliance with LGPD/GDPR and Google Consent Mode v2.

You can review or change your decision at any time by clicking Cookie settings (also available in the footer of every page). Your choice is stored locally on this device and is not shared with third parties.

6. How We Use Your Data

According to the LGPD, personal data may only be processed for legitimate, specific, explicit purposes that have been informed to the data subject (Article 6, I). Therefore, we collect your data, and only that which is necessary, for the following purposes:

PurposeDetail
To return the preliminary diagnosisTo send you, by email, a reading of your company's current moment based on the responses provided in the Diagnostic Brief.
To conduct the commercial relationshipTo get in touch with you to schedule conversations, send proposals, execute contracts and manage the relationship with leads, prospects and clients.
To maintain history of your interactionsTo preserve the history of your responses and prior contacts in order to support subsequent conversations, sparing you from repeating information.
To improve SixTree's methodologyTo calibrate and improve SixTree's proprietary methodology through analysis of anonymised data, without the possibility of individual identification, under Article 12 of the LGPD.
To communicate institutional updatesTo send communications about SixTree's services, content and updates, exclusively when you express explicit interest (specific opt-in). Withdrawal of consent is free and made easy.
To comply with legal obligationsTo comply with legal, regulatory, accounting and tax obligations applicable to SixTree, as well as requests from competent authorities.
To defend SixTree's rightsTo regularly exercise rights in judicial, administrative or arbitral proceedings (Article 7, VI, of the LGPD).

7. Legal Bases for Processing

In compliance with Article 7 of the LGPD, the processing of your personal data takes place under the following legal bases, depending on the purpose:

8. With Whom We Share Your Data

SixTree does not sell, lease or trade your personal data with third parties for marketing purposes. To carry out the purposes set out in this Policy, we rely on Processors and partners that may take part in the processing cycle of your data, always under contractual obligations of confidentiality and data protection.

8.1. Technology Processors

The Processors listed below process your personal data on behalf of SixTree, under contract and exclusively for the authorised purposes:

ProcessorPurpose of processing
Google Workspace (Google LLC)Email infrastructure, file storage (Drive), spreadsheets (Sheets) and automation (Apps Script). Google's policy: policies.google.com/privacy.
Vercel (Vercel, Inc.)Hosting of sixtree.co and the Diagnostic Brief form. Policy: vercel.com/legal/privacy-policy.
Google Analytics (Google LLC)Aggregate statistical analysis of site usage, as described in Section 5.2. Google's policy: policies.google.com/privacy.
Google reCAPTCHA (Google LLC)Anti-spam service that protects the Diagnostic Brief form. When submitting the form, behavioural data (interaction with the page) is processed by Google. Policy: policies.google.com/privacy.

8.2. Professionals and partners bound by confidentiality

When strictly necessary for the execution of the contracted services, personal data may be shared with solicitors, accountants, auditors and associated consultants, all bound by contractual obligations of confidentiality and data protection.

8.3. In investigations or compliance with legal obligation

SixTree may share personal data with competent authorities in compliance with judicial orders, legitimate administrative requisitions, or in investigations related to illegal activities, fraud or threats to the security of persons or systems. Whenever possible and legally authorised, we will inform you of such sharing.

9. International Data Transfer

The Processors listed in Section 8.1 maintain technological infrastructure on servers located outside Brazilian territory, mainly in the United States of America. As a result, some of your data may be transferred internationally.

Such transfers take place in compliance with Chapter V of the LGPD (Articles 33 to 36) and with the applicable infralegal regulations issued by ANPD, by adopting specific safeguards provided in contracts with each Processor, including standard contractual clauses, confidentiality commitments and protection standards equivalent to or higher than those of Brazilian law.

10. How Long We Keep Your Data

SixTree keeps your personal data only for the time necessary to fulfil the purposes set out in this Policy, observing the following maximum periods:

Data categoryRetention period
Active leads and clientsFor the duration of the relationship and for a further 5 (five) years after closure, to comply with tax and fiscal obligations, also observing the applicable limitation periods for defence in any judicial proceedings.
Non-engaged leads12 (twelve) months from last contact, at the end of which we send a re-engagement communication. Without response within 30 (thirty) additional days, the data is deleted or anonymised.
Site access logs12 (twelve) months, in compliance with Article 15 of Law No. 12,965/2014 (Internet Civil Framework) and Decree No. 8,771/2016.
BackupsKept in sync with the primary database, with a daily copy and rotation every 90 (ninety) days.

Once the retention period has ended, the data is securely deleted or anonymised, except for the legal hypotheses for retention provided in Article 16 of the LGPD.

11. How We Protect Your Data

SixTree adopts good information security practices aligned with the applicable technical and regulatory standards, in compliance with Articles 46 to 49 of the LGPD. The main measures are described below:

MeasureDescription
Logical access controlsAccess restricted to the authorised SixTree team, under contractual obligations of confidentiality. Multi-factor authentication required on all accounts that store personal data.
Cryptographic controlsEncryption in transit (HTTPS/TLS) and at rest, in accordance with the standards of certified providers.
Backup copiesAutomated backups performed periodically, with scheduled rotation, ensuring the recovery of data in case of incident.
Event recording and traceabilityRelevant access and actions are recorded in logs, allowing identification of those responsible and reconstitution of events for audit and security purposes.
Anti-abuse and anti-fraudAutomatic anti-spam and anti-fraud mechanisms in the Diagnostic Brief form, including Google reCAPTCHA.
Contractual accountabilityThe contracts entered into with Processors include clauses on data protection and accountability in case of non-compliance.

Despite the measures adopted, no system is absolutely immune to incidents. If you suspect a security incident involving your data, please contact us immediately at office@sixtree.co. In case of an incident that may entail relevant risk or harm to data subjects, SixTree will notify ANPD and the affected data subjects within the deadlines and in the form provided in Article 48 of the LGPD.

12. Your Rights as a Data Subject

As the holder of your personal data, you have rights clearly defined by the LGPD. Under Article 18, you may, at any time and upon request:

RightWhat it means
Confirmation of the existence of processingTo know whether SixTree processes personal data about you.
Access to dataTo obtain clear and transparent information about which personal data SixTree processes about you.
CorrectionTo request the correction of incomplete, inaccurate or outdated data.
Anonymisation, blocking or deletionTo request the anonymisation, blocking or deletion of unnecessary or excessive data, or data processed in non-compliance with the LGPD.
Data portabilityTo request the portability of your data to another service provider, observing ANPD regulations and commercial and industrial secrets.
Deletion of data processed under consentTo request the deletion of personal data processed on the basis of your consent, except for legal retention obligations under Article 16 of the LGPD.
Information on data sharingTo obtain information about the public and private entities with which SixTree has shared use of your data.
Information on the possibility of not consentingTo obtain information on the possibility of not providing consent and on the consequences of refusal.
ObjectionTo object to processing carried out on the basis of one of the hypotheses dispensing consent, in the event of non-compliance with the LGPD.
Withdrawal of consentTo withdraw consent at any time, by express manifestation through a free and easy procedure, without prejudice to the lawfulness of the processing carried out previously.
Review of automated decisionsTo request the review of decisions taken solely on the basis of automated processing of personal data that affect your interests, under Article 20 of the LGPD. SixTree informs that it does not make fully automated decisions producing legal effects on data subjects.

To exercise any of these rights, write to office@sixtree.co with the subject “Data Subject Rights, LGPD”. The response will be provided within the legal deadline, generally within 15 (fifteen) days from receipt of the request. Complex requests may require an additional period, duly justified and communicated to you.

SixTree may request additional information to confirm your identity before fulfilling the request, as a security measure.

13. Children and Adolescents

SixTree's services are intended exclusively for adults aged 18 or over acting in a professional or business context. We do not knowingly collect personal data from children and adolescents, in accordance with Article 14 of the LGPD.

If inadvertent collection of a minor's data is identified, SixTree will proceed with immediate deletion, except for legal retention obligations. Communications to this effect should be addressed to office@sixtree.co.

14. Complaint to the Brazilian National Data Protection Authority

If you consider that your request has not been adequately addressed by SixTree, or that there has been non-compliance with the LGPD in relation to your data, you may file a complaint directly with the Brazilian National Data Protection Authority (ANPD), through the channels available at www.gov.br/anpd.

15. Changes to This Policy

This Policy may be updated periodically to reflect changes in our practices, in applicable legislation or in the technology infrastructure used. We seek the constant improvement of this document, and you will always be notified when a relevant change occurs here.

Whenever there is a relevant change, we will notify by email the active subjects in our database and update the “Last updated” date at the top of this document. Previous versions are available on request to the DPO, at office@sixtree.co.

16. Data Protection Officer (DPO) and Contact

Data Protection Officer (DPO): Emerson Zotti

Contact email: office@sixtree.co

For any questions, requests or complaints related to this Policy or to the processing of your personal data by SixTree, please contact us at office@sixtree.co. We respond within the legal deadline.

17. Applicable Law and Jurisdiction

This Policy is governed by Brazilian law, in particular:

The forum of the data subject's domicile is elected to settle any disputes related to this Policy, without prejudice to ANPD's competence in matters of its administrative attribution.

SixTree, strategic advisory and product studio.