Privacy policy

1. Controller

The controller of personal data collected through pairwise.online is Pairwise, an editorial imprint established in Brazil, contactable at support@pairwise.online. Pairwise maintains no public premises and receives correspondence by email only. Data protection enquiries sent to that address reach the person responsible for them.

2. Data collected

2.1 Data provided directly

Where a message is sent to the support address, the email address, the content of the message, and any attachment are received and retained. Where a paid publication is bought, the payment provider transmits the buyer's name, email address, country, transaction identifier, amount, and the last four digits of the payment instrument. Full card numbers are never received or stored by Pairwise.

2.2 Data collected automatically

Server logs record IP address, user agent, requested URL, referring URL, and timestamp. Aggregate analytics record pages viewed, approximate region derived from IP address, device category, and session duration. Where advertising measurement is in use, an advertising platform may set identifiers permitting it to attribute a visit to a campaign.

2.3 Data not collected

Pairwise does not request or knowingly collect health data, biometric data, data revealing racial or ethnic origin, political opinions, religious belief, trade union membership, sex life, or sexual orientation. It does not ask visitors to describe their relationships or personal circumstances, and does not build profiles of individuals from any information a visitor volunteers.

3. Purposes and legal bases

• Operating the website and keeping it available — legitimate interests (GDPR Art. 6(1)(f)); legitimate interests of the controller (LGPD Art. 7, X).
• Answering support messages — performance of a contract or steps taken before it (GDPR Art. 6(1)(b)); LGPD Art. 7, V.
• Processing purchases, refunds, and payment disputes — performance of a contract (GDPR Art. 6(1)(b)); LGPD Art. 7, V.
• Meeting tax, accounting, and consumer-law obligations — legal obligation (GDPR Art. 6(1)(c)); LGPD Art. 7, II.
• Aggregate analytics and advertising measurement — consent where the applicable law requires it, otherwise legitimate interests (GDPR Art. 6(1)(a) or (f)); LGPD Art. 7, I or IX.
• Detecting fraud and abuse — legitimate interests (GDPR Art. 6(1)(f)); LGPD Art. 7, X.

Where processing rests on legitimate interests, a balancing assessment has been carried out and can be requested at the support address. Where it rests on consent, that consent can be withdrawn at any time without affecting processing already carried out.

4. Cookies and similar technologies

Strictly necessary cookies support delivery of pages and are not optional. Analytics and advertising identifiers, where present, are used to measure aggregate traffic and campaign performance, and are subject to consent in jurisdictions that require it. Browsers can block or delete cookies through their own settings; blocking strictly necessary cookies may prevent parts of the site from loading.

5. Sharing

Personal data is shared only with processors acting on documented instructions: the hosting and content-delivery provider that serves this website, the payment provider that processes transactions, the email provider that carries support correspondence, and the analytics or advertising platforms described above. Data is also disclosed where a competent authority requires it under applicable law, or where disclosure is necessary to establish or defend a legal claim. Personal data is never sold, rented, or exchanged.

6. International transfers

Because processors operate outside Brazil and outside the European Economic Area, personal data may be transferred internationally. Such transfers rely on adequacy decisions where they exist, and otherwise on Standard Contractual Clauses or the equivalent safeguards recognised under LGPD Art. 33. A description of the safeguards applying to a specific transfer can be requested at the support address.

7. Retention

• Support correspondence: 24 months from the last message in the thread.
• Transaction records: retained for the period required by Brazilian tax and accounting law, currently five years.
• Server logs: 12 months.
• Aggregate analytics: 14 months, in aggregated form.

At the end of a retention period, data is deleted or irreversibly anonymised, except where a longer period is required by law or by an active legal claim.

8. Rights of data subjects

Under the LGPD (Art. 18) and the GDPR (Arts. 15–22), a data subject may request confirmation of processing, access to their data, correction of incomplete or inaccurate data, anonymisation, blocking or deletion of unnecessary data, portability, information about entities with which data has been shared, information about the consequences of refusing consent, withdrawal of consent, objection to processing, and restriction of processing.

Requests are sent to support@pairwise.online and are answered within 15 days under the LGPD and within one month under the GDPR, extendable where the request is complex, with notice given. Identity is verified before data is disclosed. No charge is made unless a request is manifestly unfounded or repetitive.

9. Security

Transport encryption is applied to the whole website. Access to support correspondence and transaction records is restricted to those who need it. Payment credentials are handled entirely by the payment provider and are not transmitted to Pairwise. No system is immune to compromise; where a breach is likely to result in risk to data subjects, notification is made to the ANPD, to the competent supervisory authority, and to affected individuals in accordance with LGPD Art. 48 and GDPR Arts. 33–34.

10. Children

This website is directed at adults and is not intended for anyone under 18. Pairwise does not knowingly collect data from children. Where such data is identified, it is deleted.

11. Complaints

A complaint may be made to the Brazilian National Data Protection Authority (ANPD) at gov.br/anpd, or, for data subjects in the European Economic Area or the United Kingdom, to the supervisory authority of the relevant country. Raising the matter at the support address first is welcome but not required.

12. Changes

Material changes to this policy are published on this page with a revised version number and effective date. The version in force at the time of a visit governs that visit.