Privacy Policy and Data Protection

Last updated: 2026-10-31 · v2.4

1. Data Controller Identification

2. Personal Data Collected

3. Purpose and Legal Basis for Processing

The table below details each processing purpose, the data involved, and the legal basis under the LGPD (Art. 7).

PurposeDataLegal Basis (LGPD Art. 7)
Collaborative research project managementRegistration, participation, productionLegitimate interest (Art. 7, IX)
Communication with collaboratorsEmail, name, phoneConsent (Art. 7, I)
New member selection processApplication, scores, feedbackPre-contractual procedures (Art. 7, V)
Gamification and recognitionScores, badges, leaderboardLegitimate interest (Art. 7, IX)
Platform usage analytics (anonymized)Pageviews, events (PostHog — no PII)Legitimate interest (Art. 7, IX)
Platform adoption monitoringSessions, pages visited, last access (identified)Legitimate interest (Art. 7, IX)
Email campaign effectivenessDeliveries, opens, clicksLegitimate interest (Art. 7, IX)
Reports for sponsoring chaptersAggregated data per chapter (no PII)Legitimate interest (Art. 7, IX)
Audit and governanceAdministrative actions, audit logLegitimate interest (Art. 7, IX)
PMI certification verificationCredly badges (public API)Legitimate interest (Art. 7, IX)
Monitoring by partner chapter boardsAggregate KPIs, publications, impact hours, top 3 by XP (already public data). No individual attendance or personal information.Legitimate interest (Art. 7, IX) — co-sponsoring chapters monitor project outcomes. Access restricted to institutional email (@pmiXX.org.br).
Delivery and custody of the signed Volunteer AgreementSigned agreement (name, address, phone, date of birth, PMI ID, signatures and timestamps)Contract performance (Art. 7, V): each party receives the copy of the instrument it signed. For the institutional archive of the contracting chapter, also Legitimate interest (Art. 7, IX)
Contact with people who are not members (guest speaker at a meeting, individual message from management)Name and e-mail provided by a member or by management; delivery, open and click metrics; the guest's name on the meeting's public agendaLegitimate interest (Art. 7, IX). The person is informed in the e-mail itself, can ask to stop receiving messages and can object (Art. 18, §2)

3.1. Public display of your location on the geographic map

The homepage shows a map of the geographic distribution of Núcleo IA & GP members. Including your location in an identifiable way on this map is optional and based on your consent, with two levels:

Both levels are based on your consent (LGPD Art. 7, I) and can be enabled, changed, or revoked at any time under Settings → My Profile. With no active opt-in, you receive no individual state or country pin; your location may still be included in aggregate counts by country or continent, based on legitimate institutional interest (Art. 7, IX), always without individual identification. Named pins (countries and continents) have a minimum floor of 3 members. The "Internacional" (ZZ) chip has no floor of its own: it groups countries with fewer than 3 members and countries not mapped by the platform — it does not identify any country or individual.

4. Data Sharing

5. International Data Transfer

The platform uses infrastructure providers headquartered outside Brazil. Personal data may be transferred to the following countries/regions, pursuant to LGPD Art. 33:

The infrastructure transfers above are based on legitimate interest for the execution of the research initiative (LGPD Art. 33, IX) and the data processing agreements (DPA) of the respective providers. Transfers to the artificial intelligence providers (Google, Anthropic and OpenAI) are based instead on the data subject's specific and highlighted consent, with prior information about the international nature of the operation (LGPD Art. 33, VIII), and do not occur without it.

6. Data Retention

The periods below apply from the indicated event. After the period, data is anonymized or deleted. Upon volunteer offboarding, access to organizational tools (including the Núcleo Google Drive folders) is revoked — for permanent exits (alumni), revocation is automatic and takes place within 1 hour of offboarding; we recommend retrieving any personal files before departure.

CategoryRetention PeriodAfter Period
Active member dataWhile active in the initiativeAnonymization
Inactive member data3 years after deactivationAnonymization
Activity sessionsWhile member is activeDeleted with account
Email events (webhooks)12 months after eventDeletion
Administrative audit log5 yearsActor anonymization
Applications2 years after the decision on the application, or after the application when no decision was recorded (1 year if the person withdrew)Anonymization
Notifications6 months after readDeletion
Anomaly logs1 yearDeletion
Credly badge cacheWhile member is activeDeleted with account
E-mail and name of a person who is not a member (guest, individual message)1 year after the meeting or the messageAnonymization; the guest's name on the agenda becomes "External guest"
Partner contacts1 year after end of relationshipDeletion
Volunteers and study group leaders5 years after offboardingAnonymization
Signed agreement copy in restricted Drive folder5 years after offboardingFile deletion
Unsubscribe list (e-mail only)For as long as the request stands, only to make sure the person receives no more messagesDeleted at the data subject's request

7. Your Rights (LGPD Art. 18)

8. Automated Decisions (LGPD Art. 20)

The platform performs the following automated processing:

You have the right to request a review of any automated decision that affects your interests, including your gamification score. To request a review, contact nucleoia@pmigo.org.br.

9. Security

9.1. Security Incidents

In case of a security incident that may pose relevant risk or harm to data subjects, the organization commits to:

10. Cookies, Analytics and Tracking

We do not use advertising, remarketing, or third-party tracking cookies for commercial purposes.

11. Target Audience and Minors

The platform is intended for project management and artificial intelligence professionals, all over 18 years of age. We do not intentionally collect data from minors (LGPD Art. 14). If we identify data from minors, it will be deleted.

12. Changes to This Policy

Changes will be communicated on the platform and by email. Last update date is visible at the top of this page.

13. Contact and National Authority

To exercise your rights or clarify questions about this policy:

If you are not satisfied with the response, you may file a complaint with the National Data Protection Authority (ANPD):

https://www.gov.br/anpd/pt-br