Legal
Privacy Notice
This notice explains what personal data Pay Census processes, why, on what legal basis, for how long, and what rights are available. It is written to satisfy the Brazilian General Data Protection Law (Lei nº 13.709/2018, the LGPD) and the EU General Data Protection Regulation (Regulation 2016/679, the GDPR). Pay Census acts as controller of the data described below and can be reached at [email protected].
What is collected
- Correspondence
- An email address, a name where one is given, and the content of the message, for any correspondence sent to the address above.
- Delivery records
- Standard records generated when a page is served: IP address, timestamp, page requested, referring address, user agent and approximate region derived from the IP address. These are produced by the hosting and content delivery infrastructure.
- Audience measurement
- Aggregate measurement of page views and traffic sources, where such measurement is in use. It is not used to build a profile of an identified individual by this publication.
- Order records
- Where a paid item is purchased, the payment processor collects and holds the payment details. Pay Census receives a record of the transaction — the address used, the item and the date — and never receives or stores full card numbers.
There is no reader account, no comment form and no newsletter sign-up on this site. Data relating to children is not knowingly collected; the site is intended for readers aged 18 or over.
Why it is processed, and on what basis
- To answer correspondence
- LGPD Art. 7, X (procedures preliminary to a contract) and Art. 7, IX (legitimate interests) as applicable; GDPR Art. 6(1)(b) and Art. 6(1)(f). Without an address, a reply cannot be sent.
- To deliver and protect the site
- Legitimate interests in operating the publication, keeping the service available and preventing abuse: LGPD Art. 7, IX; GDPR Art. 6(1)(f).
- To measure audience in aggregate
- Legitimate interests in understanding which notes are read, applied so that it does not override the rights of readers: LGPD Art. 7, IX; GDPR Art. 6(1)(f). Where consent is required for a given technology in a given jurisdiction, it is requested before that technology is used.
- To fulfil an order and meet accounting duties
- Performance of a contract and compliance with a legal obligation: LGPD Art. 7, V and Art. 7, II; GDPR Art. 6(1)(b) and Art. 6(1)(c).
How long it is kept
- Correspondence: up to 24 months from the last message in the exchange, then deleted.
- Delivery records: up to 12 months, then deleted or aggregated beyond identification.
- Aggregate measurement: retained in aggregate form, which does not identify individuals.
- Order and accounting records: for the period required by Brazilian tax and commercial law, which may exceed five years.
Who else processes it
Data is shared only with processors acting on documented instructions: the hosting and content delivery provider that serves these pages, the email provider that carries correspondence, the audience measurement provider where one is in use, and the payment processor for any paid item. Personal data is not sold, rented or exchanged, and it is not disclosed to advertisers for their own purposes.
International transfers
These providers may process data outside Brazil and outside the European Economic Area. Transfers rely on the mechanisms available under LGPD Arts. 33–36 and GDPR Chapter V, including standard contractual clauses and adequacy decisions where applicable, together with contractual commitments from each processor.
Cookies and similar technologies
No advertising cookie is set by this site of its own accord. Where a cookie or similar identifier is used for audience measurement or for an advertising platform's own measurement, it is disclosed and, where the applicable law requires consent, requested before use. Browser controls can block or delete cookies; blocking them does not restrict access to any note on this site.
Protective measures
Traffic is served over TLS. Administrative access is limited to the people who operate the publication and is protected by multi-factor authentication. No method of transmission or storage is perfect, and no assurance to the contrary is offered here.
Rights
Under the LGPD (Art. 18) and the GDPR (Arts. 15–22), readers may request confirmation of processing, access, correction of incomplete or inaccurate data, anonymisation, blocking or deletion of unnecessary or excessive data, portability, information about shared parties, and may withdraw consent or object to processing based on legitimate interests. Requests go to [email protected] and are answered within 15 days under the LGPD and within one month under the GDPR.
Complaints may be made to the Brazilian National Data Protection Authority (ANPD) or, in the European Economic Area, to the competent national supervisory authority.
Changes
Material changes to this notice are published on this page with a new date at the head of the document. The version in force is the one shown here.