Path2

Privacy Policy

Last updated: August 30, 2026.

1. Purpose

This Privacy Policy ("Policy") is intended to clearly and transparently inform how Path2 Ltda., Brazilian Tax ID / CNPJ 53.787.031/0001-09, headquartered at Av. Paulista, 777, Andar 15, Conjunto 15, Sala 968, Bela Vista, São Paulo/SP, Brazil, CEP 01311-914 ("Path2", "we"), processes the personal data of website visitors and prospective clients ("Data Subject", "you") who interact with the contact form available on our website, in compliance with Brazil's General Data Protection Law (Law No. 13,709/2018, the "LGPD") and other applicable rules.

By filling out and submitting the contact form, you acknowledge and agree to the terms of this Policy.

2. Path2's Role in Data Processing

For the purposes of this Policy, Path2 acts as the data controller of the personal data collected through the contact form, as defined under art. 5, VI, of the LGPD, being responsible for decisions regarding the processing of such data.

3. Personal Data Collected

When you fill out the form available on our website, we collect the following data, provided directly by you on a voluntary basis:

We do not request or process, through this form, sensitive personal data as defined in art. 5, II, of the LGPD (such as racial or ethnic origin, religious belief, political opinion, health or sex-life data, or genetic or biometric data).

4. Purpose and Legal Basis for Processing

The personal data you provide is processed exclusively for the following purposes:

Processing is based on the Data Subject's consent (art. 7, I, of the LGPD), freely given by checking the consent box on the form before the data is submitted. You may withdraw this consent at any time, as described in Section 9 of this Policy, without prejudice to the lawfulness of processing carried out prior to withdrawal.

Path2 does not use the data collected through this form for any purpose other than those described here, nor does it sell such data.

5. Sharing of Data with Third Parties

When you submit the form, you are redirected to the WhatsApp application to start the conversation with Path2. This redirect is carried out through WhatsApp's own infrastructure, a service owned by Meta Platforms, Inc. ("Meta"), which receives the message content in order to display it in the chat. Accordingly, the personal data entered in the form is shared with Meta, acting as a data processor, solely for the purpose of enabling initial contact. We recommend reading WhatsApp's privacy policy.

We also use Google Analytics, a tool provided by Google LLC ("Google"), for statistical purposes related to website usage, as detailed in Section 7 below.

Outside of these cases, Path2 does not share, disclose, or sell the personal data it collects to any other third party, except when required by legal or regulatory obligation, or upon order from a competent authority.

6. International Data Transfer

Meta and Google are companies whose infrastructure and servers are located, in whole or in part, outside Brazilian territory. As such, the processing described in Section 5 may involve the international transfer of personal data, as set out in art. 33 of the LGPD. Such transfer is based on the Data Subject's specific and highlighted consent (art. 33, VIII, of the LGPD), given at the moment you choose to fill out and submit the contact form, being aware of the international nature of this operation.

7. Cookies and Analytics Tools

We use Google Analytics, with IP address anonymization enabled, to collect statistical and aggregated information about visitor navigation on our website (such as pages visited and time spent). This information is not used to identify you individually and is not cross-referenced with the data provided through the contact form.

8. Storage, Retention, and Deletion of Data

Personal data collected through the form is manually recorded by the Path2 team in an internal system for managing relationships with prospective clients, with access restricted to authorized partners and staff. Path2 may, at its discretion, migrate this system to other customer relationship management (CRM) tools, while always keeping access restricted to its team.

Data is retained for the period necessary to fulfill the purposes described in Section 4, in accordance with arts. 15 and 16 of the LGPD. Path2 commits to periodically reviewing the records it maintains and selectively deleting data of leads that remain inactive or that did not move forward into a business relationship, except where retention is necessary to comply with a legal or regulatory obligation, or for the regular exercise of rights in judicial, administrative, or arbitration proceedings.

9. Data Subject Rights

Under art. 18 of the LGPD, you are entitled, upon request, to:

  1. Confirmation of the existence of processing of your personal data;
  2. Access to your personal data;
  3. Correction of incomplete, inaccurate, or outdated data;
  4. Anonymization, blocking, or deletion of unnecessary or excessive data, or data processed in noncompliance with the LGPD;
  5. Portability of your data to another service or product provider, upon express request;
  6. Deletion of personal data processed based on your consent, except as provided in art. 16 of the LGPD;
  7. Information about the public and private entities with which Path2 has shared your data;
  8. Information about the possibility of not giving consent and the consequences of refusal; and
  9. Withdrawal of consent, as provided in art. 8, §5, of the LGPD.

You may exercise any of these rights by contacting us at the email address indicated in Section 11 of this Policy. Path2 will respond to requests within the timeframes established by the LGPD, and may request additional information to confirm the identity of the requester before proceeding.

10. Security Measures

Path2 adopts reasonable technical and administrative measures, compatible with the size and nature of its operation, aimed at protecting the personal data it processes from unauthorized access and from accidental or unlawful destruction, loss, alteration, communication, or dissemination, in accordance with art. 46 of the LGPD. This includes, among other measures, restricting access to the internal lead-management system exclusively to authorized partners and staff.

In the event of a security incident that could pose a relevant risk or harm to Data Subjects, Path2 will notify Brazil's National Data Protection Authority (ANPD) and, where applicable, affected Data Subjects, as provided in art. 48 of the LGPD.

11. Contact Channel

For general questions about our services, you can reach us via WhatsApp at +55 11 94324-8115. To exercise the rights described in Section 9, or for any other questions related to the processing of your personal data, use the email privacidade@path2.fi.

As a small-sized data processing agent, Path2 is exempt, under ANPD Resolution CD/ANPD No. 2/2022, from formally appointing a Data Protection Officer (DPO), while still maintaining the communication channel above for handling Data Subject requests.

12. Changes to this Policy

This Policy may be updated periodically to reflect changes in our data processing practices or in applicable law. The current version will always be available on this page, indicating the date it was last updated. We recommend reviewing this document periodically.

13. Governing Law and Jurisdiction

This Policy is governed by the laws of the Federative Republic of Brazil, in particular Law No. 13,709/2018 (LGPD). The courts of the Judicial District of São Paulo/SP, Brazil, are hereby elected to settle any disputes arising from this Policy, to the exclusion of any other, however privileged it may be.

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