Privacy policy.
This page explains, in plain language, which data is collected when you use the free diagnosis, the application for one-to-one mentoring and the TCMind app, what it is used for, where it is kept and what your rights are, under Brazil's General Data Protection Law (LGPD, Law 13.709/2018).
1. Who is responsible
Controller: BT Serviços de Ensino e Tecnologia Ltda., CNPJ 30.580.414/0001-06, Av. Diário de Notícias, 400, suite 1313-B, Cristal, Porto Alegre/RS, Brazil, 90810-080 (trading as BT Inova), represented by Walmir Bandeira, psychologist (CRP 07/14365, Brazil), creator of TCM, the Theory of Modular Consciousnesses, and responsible for the processing.
Privacy contact: suporte@btinova.com. This is the single channel for requests about your data.
2. Which data is collected
| Where | Data | Purpose |
|---|---|---|
| Free diagnosis (tcmind.help) | Name, e-mail, WhatsApp, your answers to the situations presented, the origin of the link (for example "site"), date, time and response time. | Generate and deliver your personal report; allow contact for the interview; scientific research (see item 4). |
| Mentoring application (wbandeira.com/en/apply) | Name, e-mail, WhatsApp, company, role, size of the operation, the pains you selected, the decision that is stuck, for how long, readiness, and the code of your diagnosis when there is one. | Assess the application; prepare and schedule the 45-minute interview. |
| Interview scheduling | Name, e-mail and chosen time, through Google Calendar. | Book the interview and send reminders. |
| TCMind app (during mentoring) | Everything you fill in: assessments, scores, answers, examples, daily logs, with date, time and time spent. | Run the mentoring, generate your reports and protocols, measure the before and after; scientific research (item 4). |
| Browsing | Basic technical data (IP address, browser, pages visited), logged by the hosting providers. | Security and operation of the sites. We do not use advertising tracking cookies. |
3. Legal bases
- Consent (art. 7, I): by sending the diagnosis or the application, you authorise the use of the data for the purposes described. You can withdraw it at any time through the channel in item 1.
- Performance of a contract (art. 7, V): during the mentoring, the data is necessary to deliver the contracted service.
- Legitimate interest (art. 7, IX): security of the systems and improvement of the method, always with pseudonymised data.
4. Scientific use
TCM is under scientific review. Answers to the diagnosis and to the app may be used in research and in improving the method in pseudonymised form: your name, e-mail and phone are separated from the answers and replaced by a code. Research results are always presented in aggregate, identifying no one. You can ask for your data to be removed from the research at any time, with no effect on your report or your mentoring.
5. Where the data is kept and who has access
- Supabase (database of the diagnosis and the app), Netlify (hosting of the sites and receipt of applications), Google Workspace (e-mail, calendar and storage), Vimeo and YouTube (embedded videos, which may log your viewing under their own policies).
- These providers act as processors, only under our instructions, with servers that may be outside Brazil, under adequate contractual safeguards (art. 33).
- Data is not sold or shared with third parties for advertising.
- Internal access is restricted to Walmir Bandeira and the support team, bound by confidentiality.
6. For how long
- Diagnosis and application: while there is a relationship or an interest in contact, and at most 5 years after the last contact, unless you request deletion earlier.
- Mentoring and app: during the mentoring and for as long as needed for legal obligations and for your access to your own history.
- Research: pseudonymised data may be kept indefinitely, as it does not identify you.
7. Your rights
At any time, by e-mailing suporte@btinova.com, you can: confirm whether we process your data; access it; correct incomplete or outdated data; request anonymisation, blocking or deletion; request portability; know who we share it with; withdraw consent. We reply within 15 days. For your safety, we may ask for identity confirmation before acting.
8. Security
Encrypted connections (HTTPS), individual credentials, backups, and separation between identification and answers in research. No system is infallible; in the event of a relevant incident, you and the Brazilian data protection authority will be notified as required by law.
9. Children and teenagers
The services are intended for adults over 18. We do not knowingly collect data from minors.
10. Changes
This policy may be updated. The date at the top shows the current version. Relevant changes will be communicated by e-mail to anyone with an active relationship.