Privacy Policy

1. Introduction

This Privacy Policy explains how PRIMARIS SOFTWARE LTDA (“we”, “our”, “us”) collects, uses, stores, and protects personal data when you use Primaris Course Platform (“Platform”, “Website”).

We are committed to complying with:

• General Data Protection Regulation (GDPR – Europe)
• Lei Geral de Proteção de Dados (LGPD – Brazil)

By accessing or using the Platform, you agree to the collection and use of information in accordance with this Privacy Policy.

2. Basic Website & Business Information

3. Nature of the Service

The Platform is a Software as a Service (SaaS) that enables customers to create and manage their own 100% white-label course platforms.

Using the Platform, customers can:

• Create accounts for their own users
• Manage students and courses
• Create lessons and educational content
• Upload files and videos
• Control access to content

Each customer acts as the Data Controller of their own platform. PRIMARIS SOFTWARE LTDA acts primarily as a Data Processor, providing the technical infrastructure.

4. Personal Data We Collect

5. How Data Is Collected

Personal data is collected mainly through:

• Registration and contact forms
• Platform usage
• Authentication sessions via cookies

6. Purpose of Data Processing

We process personal data only when necessary, including to:

• Enable authentication and session management
• Manage students, courses, and access permissions
• Ensure proper platform functionality
• Provide customer support
• Comply with legal obligations

7. Legal Basis for Processing

Under GDPR and LGPD, data processing is based on one or more of the following legal grounds:

• User consent
• Performance of a contract
• Compliance with legal obligations
• Legitimate interest, when applicable

8. Cookies Policy

The Platform uses strictly necessary cookies to:

• Maintain authenticated user sessions
• Ensure secure access to the Platform

No marketing or tracking cookies are used at this time.

9. Data Storage & Infrastructure

Personal data is processed and stored using the following infrastructure:

• VPS Hosting: Hostinger
• File Storage: AWS S3 (files, videos, logos, styles)
• Email Services: Resend

All services follow industry-standard security practices.

10. Data Sharing

We do not sell or rent personal data.

Data may be shared only with trusted third-party service providers strictly necessary to operate the Platform, under contractual and legal safeguards.

11. Data Retention

Personal data is retained only for as long as necessary to:

• Provide the services
• Fulfill contractual obligations
• Comply with legal requirements

After account termination, data will be deleted or anonymized unless retention is legally required.

12. User Rights

In accordance with GDPR and LGPD, users have the right to:

• Access their personal data
• Correct inaccurate or incomplete data
• Request data deletion
• Restrict or object to processing
• Request data portability
• Withdraw consent at any time

Requests can be made by contacting: primarisoftware@gmail.com

13. International Data Transfers

Personal data may be processed or stored outside the user’s country of residence. When this occurs, appropriate safeguards are applied in compliance with GDPR and LGPD.

14. Data Security

We adopt appropriate technical and organizational measures to protect personal data, including:

• Access control mechanisms
• Secure infrastructure
• Monitoring and backup procedures

Despite our efforts, no system is completely secure.

15. Changes to This Privacy Policy

We may update this Privacy Policy at any time.

Updates will be published on this page, and continued use of the Platform constitutes acceptance of the revised policy.

16. Contact

If you have any questions about this Privacy Policy or your personal data, please contact: