COUTO & SILVA Intelligence · ARGUS™ ← Terms of Service
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Privacy Policy

This Privacy Policy explains what personal data Couto & Silva Intelligence collects, how it is used, and the rights available to subscribers regarding their data.

Last updated: September 9, 2026  ·  Effective date: September 9, 2026  ·  CNPJ 65.389.772/0001-02  ·  RTD 1215516
01

Data Controller

The data controller responsible for your personal data is:

Couto & Silva Intelligence
CNPJ: 65.389.772/0001-02
Rio de Janeiro, Brazil
Contact: desk@coutosilva.com

02

What Data We Collect

We collect only the minimum data necessary to deliver our services. Where the Subscriber is an institution, the licensed content is used by a single Named Recipient designated by the Subscriber, as defined in our Terms of Service (Section 01).

DataSourcePurpose
Email addressProvided by subscriber at purchaseDelivery of Intelligence Briefs and service notifications
Named Recipient's name and email addressProvided by the SubscriberDelivery of licensed content
Professional contact and role informationReferral partnerAssessment of professional relevance prior to commercial approach
Payment dataProcessed by Stripe, Inc.Billing and subscription management — not stored by us
Purchase historyStripe dashboardAccess verification and invoice records
Usage dataWeb server logsSite security and performance — anonymized, not linked to identity

We do not collect: phone numbers, company names, IP addresses linked to identity, or any data beyond what is listed above.

03

How We Use Your Data

Your email address is used exclusively to:

— Deliver ARGUS Intelligence Briefs upon payment confirmation
— Send service notifications (amendments to Terms, access suspension, renewal reminders)
— Respond to direct inquiries sent to desk@coutosilva.com

We do not use your data for marketing, profiling, behavioral analysis, or any purpose beyond direct service delivery.

04

Data Sharing and Third Parties

We do not sell, rent, or share your personal data with third parties, with the following strictly necessary exceptions:

Stripe, Inc. — Our designated Payment Processor. Stripe processes all payment transactions under its own Privacy Policy and PCI-DSS compliance standards. Couto & Silva Intelligence does not store or access payment card data at any point.

No other third-party processors, advertising networks, analytics platforms, or data brokers receive your personal information.

05

Data Retention

Your email address is retained for the duration of the active subscription or purchase relationship, plus a maximum of 24 months thereafter for legal and tax compliance purposes, in accordance with Brazilian Law No. 13,709/2018 (LGPD) and applicable fiscal regulations.

Upon written request to desk@coutosilva.com, your data will be deleted within 30 days, except where retention is required by law.

06

Your Rights

Under Brazilian Law No. 13,709/2018 (LGPD) and, where applicable, the European General Data Protection Regulation (GDPR), you have the following rights:

Access
Request confirmation of what personal data we hold about you.
Correction
Request correction of inaccurate or incomplete data.
Deletion
Request erasure of your personal data, subject to legal retention requirements.
Portability
Request your data in a structured, machine-readable format.
Objection
Object to processing of your data for any purpose beyond service delivery.
Withdrawal
Withdraw consent at any time — without affecting prior lawful processing.

To exercise any of these rights, contact: desk@coutosilva.com. We will respond within 15 business days.

07

International Data Transfers

Payment data is processed by Stripe, Inc., headquartered in the United States, under Stripe's own Standard Contractual Clauses and compliance framework; Couto & Silva Intelligence does not store or access payment card data at any point.

Data is treated in compliance with Brazilian Law No. 13,709/2018 (LGPD — General Data Protection Law).

Couto & Silva Intelligence is established in Brazil. Personal data is collected directly from the Subscriber and, where a prospective Subscriber has been introduced through the referral programme, from the referral partner, limited to professional contact and role information. Where personal data is received from a referral partner, Couto & Silva Intelligence informs the data subject in accordance with Article 14 of the GDPR at the first communication with that person. Where Regulation (EU) 2016/679 (GDPR) applies to this processing, the legal basis is Article 6(1)(b) where the contract is entered into by the data subject, and Article 6(1)(f) where the Subscriber is an institution and the Named Recipient is one of its personnel, or where professional contact information is received through the referral programme, the legitimate interest being the delivery of the contracted intelligence service, the administration of the licence and the assessment of professional relevance prior to any commercial approach.

Where a Subscriber established in the European Economic Area transfers personal data to Couto & Silva Intelligence and requires a transfer mechanism under Chapter V of the GDPR, Couto & Silva Intelligence will enter into the Standard Contractual Clauses adopted by the European Commission, or another lawful mechanism agreed between the parties, before such data is transmitted.

08

Cookies and Tracking

This website does not use advertising cookies, tracking pixels, or behavioral analytics tools. Basic session data (web server logs) is collected for security and performance purposes only and is not linked to individual identities.

No third-party cookies are set by Couto & Silva Intelligence. Stripe may set cookies during the checkout process, governed by Stripe's own cookie policy.

09

Security

All communications between your browser and this website are encrypted via HTTPS/TLS. Email delivery uses industry-standard secure mail protocols. We do not store payment card data at any point — all payment security is managed by Stripe, Inc. under PCI-DSS Level 1 compliance.

10

Amendments to This Policy

We may update this Privacy Policy from time to time. When we do, we will notify active subscribers via email at least 15 calendar days before changes take effect, in accordance with our Terms of Service. The current version is always available at coutosilva.com/privacy/.

11

Contact and Data Protection Inquiries

For any questions, requests, or concerns regarding this Privacy Policy or the handling of your personal data:

Data Controller
desk@coutosilva.com
Couto & Silva Intelligence · CNPJ 65.389.772/0001-02 · Rio de Janeiro, Brazil