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🥛 Colméia · TO · BrazilPrivacy · LGPD · Dairy · MAPA · Traceability · Tocantins

Privacy Policy.

Ltda Débora Silva de Souza Ltda · CNPJ 48.278.621/0001-68

Company

Débora Silva de Souza Ltda

CNPJ

48.278.621/0001-68

Last updated

January 2025

Legislation

LGPD · MAPA · SEFAZ-TO · ADAPTO · SIE-TO

This Privacy Policy describes how Débora Silva de Souza Ltda ("we," "our" or "the Producer") collects, uses, stores and protects personal data of our clients, website visitors and all persons whose data we process in connection with our milk preparation and dairy activities at Sítio Recanto Feliz, Zona Rural, Colméia, Tocantins, Brazil.

As a registered limited liability company (Ltda) operating in the milk preparation sector (CNAE: Preparação do Leite), we are committed to full compliance with the LGPD (Lei nº 13.709/2018), the regulations of the MAPA (Ministério da Agricultura, Pecuária e Abastecimento) for dairy inspection and traceability, the ADAPTO (Agência de Defesa Agropecuária do Tocantins) requirements, SIE-TO (Serviço de Inspeção Estadual do Tocantins) inspection obligations, and the tax obligations of SEFAZ-TO and ICMS-TO. As a rural agroindustrial operation, our activity is subject to ICMS — not ISS, which applies to services rather than goods production.

01

Introduction and Scope

This Policy applies to all personal data processed in connection with our milk preparation and dairy activities — direct consumer clients, commercial buyers (markets, cooperatives, food businesses), institutional buyers (schools, government agencies, PNAE programmes), website visitors and any person whose data we process. Our operation is based on a rural property (Sítio Recanto Feliz) in the Zona Rural of Colméia, TO. Most of our commercial clients are legal entities (CNPJs); however, individual consumers who purchase dairy directly and individual rural producers from whom we may source raw milk are natural persons whose data is directly protected by the LGPD.

02

Identity of the Controller

Company name: Débora Silva de Souza Ltda
Type: Sociedade Limitada (Ltda)
CNPJ: 48.278.621/0001-68
Activity (CNAE): Preparação do Leite (Milk Preparation)
Address: Sítio Recanto Feliz, SN, Zona Rural, Colméia — TO, CEP 77725-000, Brazil
Email: privacy@deborasilvasouza.com.br
03

Personal Data We Collect

A. Commercial client data (buyers of milk and dairy):

  • Institutional and commercial clients (CNPJ): Company name, CNPJ, delivery address, contact name and WhatsApp — for order management, delivery scheduling and NF-e issuance. The company itself is not a data subject under the LGPD, but the natural person who is the ordering contact is.
  • Individual direct consumers (CPF): Name, CPF, address and WhatsApp for direct consumer orders. These individuals are natural persons directly protected by the LGPD.
  • Purchase and delivery history: Products ordered, quantities, delivery dates and delivery addresses — retained as part of the commercial relationship and for NF-e traceability.

B. Mandatory dairy traceability data (regulatory — not personal data in most cases):

  • Lot numbers and production records: Each batch of pasteurised milk is assigned a lot number with production date, quantity, processing temperature records and quality test results. This data relates to the product, not to individual people.
  • Herd health records: Brucellosis and tuberculosis testing results, vaccination records and animal health documentation required by ADAPTO and MAPA — these relate to the cattle herd, not to any natural person, and are not personal data under the LGPD.
  • Delivery traceability: If a delivery is associated with a named buyer (for PNAE or institutional supply), the lot number is linked to that buyer's order — connecting product traceability data with buyer identification data.

C. Website and contact data:

  • Name, WhatsApp and order description when submitting an order or enquiry via the website.
  • IP address, browser type and pages visited.
04

Purpose and Legal Basis

PurposeLegal Basis (LGPD)
Milk and dairy order management and deliveryContract performance (Art. 7º, V)
Dairy traceability (lot tracking — mandatory under MAPA)Legal obligation (Art. 7º, II)
PNAE / institutional supply documentationContract performance; Legal obligation
Issuing NF-e per delivery / batchContract performance; Legal obligation (Art. 7º, II)
ICMS-TO — fiscal bookkeeping (SEFAZ-TO)Legal obligation (Art. 7º, II)
SIE-TO and ADAPTO inspection complianceLegal obligation (Art. 7º, II)
Website analytics and improvementLegitimate interest; Consent (cookies)
05

Sharing of Data

Traceability data and buyer identity: For institutional and PNAE supply, lot traceability records linking a batch of milk to a specific buyer order may be requested by MAPA, SIE-TO, ADAPTO or a municipal nutrition officer in the event of a food safety inquiry or audit. In that case, delivery records (buyer name, CNPJ, lot number, delivery date) are shared with the requesting authority. This is a mandatory regulatory disclosure, not a voluntary sharing. We log all such disclosures.
  • SEFAZ-TO / Receita Federal: NF-e data transmitted electronically per delivery — buyer CNPJ or CPF as required.
  • MAPA / SIE-TO / ADAPTO: Product inspection, lot traceability and herd health records — in routine inspection or in the event of a food safety incident. Buyer personal data shared only if formally required and documented.
  • PNAE / Municipal nutrition offices: Delivery records and documentation required for institutional supply accountability — under the formal contractual and regulatory framework of the school meal programme.
  • Refrigerated transport / logistics (where applicable): Delivery address and order reference for cold-chain transport — under a data processing agreement.
  • PROCON-TO / Senacon: When required under the CDC or commercial dispute resolution.
  • Legal authorities: When required by court order or administrative authority.
06

International Transfers

Our operation is based in Colméia, TO. All client data is processed in Brazil. Tax records (NF-e) are processed exclusively in systems certified by the Receita Federal and SEFAZ-TO. Any communication platforms operating on international servers do so under the guarantees of Art. 33 of the LGPD.

07

Retention Periods

  • NF-e and fiscal documentation (SEFAZ-TO): Minimum 5 years as required by Brazilian federal and Tocantins state tax legislation.
  • Mandatory dairy traceability records (MAPA/SIE-TO): Minimum 6 months after the lot expiry date, or as specifically required by MAPA regulations for the product type — typically 1–2 years for pasteurised milk lots.
  • Herd health records (ADAPTO — brucellosis/TB): Minimum 5 years as required by MAPA animal health regulations — these relate to the herd, not to buyer personal data.
  • Active client data (commercial relationship): Retained for the duration of the supply relationship and for 5 years after the last delivery — consistent with tax retention and commercial statute of limitations.
  • Individual consumer contact data without repeat order: Up to 6 months from the date of the last contact.
  • Website analytics: Aggregated and anonymised after 12 months.
08

Security Measures

  • Client purchase data and delivery records stored in access-controlled systems on the rural property — not accessible to third parties;
  • Lot traceability records maintained in a dedicated production log separate from buyer personal data — linked by order number rather than buyer name in operational documentation;
  • NF-e issued using a certified digital certificate (A1/A3) approved by the Receita Federal;
  • WhatsApp order communication handled with discretion;
  • Website encrypted (HTTPS);
  • Incident response procedures in accordance with LGPD Art. 48.
09

Your Rights under the LGPD

  • Confirmation and Access (Art. 18, I–II): Confirm what personal data we hold and receive a copy.
  • Correction (Art. 18, III): Request correction of inaccurate personal data (e.g., address or contact changes).
  • Deletion (Art. 18, IV): Request deletion — subject to mandatory fiscal retention (NF-e: 5 years) and mandatory dairy traceability retention under MAPA.
  • Portability (Art. 18, V): Receive your data in a structured format.
  • Complaint to the ANPD (Art. 18, §1º): Lodge a complaint at www.gov.br/anpd.

We respond within 15 business days.

10

Cookies and Tracking

Our website may use cookies for essential functionality and aggregated performance analytics. We do not use behavioural tracking or advertising cookies. Cookie preferences can be managed through your browser settings.

11

Minors

Our milk and dairy products are food items appropriate for all ages. Direct consumer sales may include family households with children. We process only the data of the adult buyer responsible for the order. School supply through PNAE involves institutional contracts with the municipal government — student personal data is never processed by us; the contracting party is the municipal nutrition office. We do not collect or process data from minors directly.

12

Dairy Inspection, Traceability, and ICMS-TO

MAPA / SIE-TO / ADAPTO — dairy inspection in Tocantins: Milk preparation and dairy commercialisation in Brazil are regulated by MAPA (Ministério da Agricultura, Pecuária e Abastecimento) and the state agricultural inspection services. In Tocantins, the competent authorities are ADAPTO (Agência de Defesa Agropecuária e Florestal do Tocantins) and SIE-TO (Serviço de Inspeção Estadual do Tocantins). Operations that sell only within Tocantins require SIE-TO registration; interstate commercial operations would require SIF (Serviço de Inspeção Federal). The Sítio Recanto Feliz operation is registered for intrastate sale within Tocantins. ADAPTO obligations include: mandatory brucellosis and tuberculosis testing of the cattle herd (Programa Nacional de Controle e Erradicação da Brucelose e Tuberculose — PNCEBT), vaccination records, herd registration and periodic inspection visits. These requirements generate institutional records about the herd and property — not personal data about buyers. However, an ADAPTO or SIE-TO inspection may result in access to delivery records, which may contain buyer identification data — this is shared only under formal inspection authority and is logged.
Dairy lot traceability — mandatory under MAPA and the intersection with buyer data: MAPA regulations for pasteurised milk require full lot traceability — each batch must be identified with a lot number, production date, processing parameters and origin of the raw milk. This traceability system is designed to enable rapid product recall in the event of a food safety incident. For most purposes, traceability records relate to the product (lot number, quantity, date) and not to individual buyers. However, for institutional supply (PNAE, schools, government agencies), delivery records link a specific lot to a named institutional buyer — creating a connection between product traceability data and buyer identification. We maintain traceability and buyer records in separate systems, linked by order number — so that traceability lookups identify lots without unnecessarily exposing buyer personal data, and buyer records can be corrected or deleted (where legally permitted) without compromising mandatory traceability documentation.
ICMS-TO and NF-e for milk preparation — no ISS: Milk preparation (CNAE: Preparação do Leite) is an agroindustrial production activity — the preparation and sale of a physical food product. This activity is subject to ICMS-TO (Imposto sobre Circulação de Mercadorias e Serviços — Tocantins), not to ISS (which applies to services). The NF-e for each delivery of milk or dairy products is issued with the applicable ICMS-TO rate for food products and the correct CFOP code for agroindustrial product sales. For institutional buyers (schools, PNAE, government agencies), the NF-e serves as the mandatory fiscal document for public accounting and programme reimbursement. For resellers (markets, cooperatives, laticínios that process milk further), the NF-e from Débora Silva de Souza Ltda is their input cost document. The buyer's CNPJ or CPF on the NF-e is retained for the mandatory 5-year period. Rural producers in Brazil may also be subject to ITR (Imposto Territorial Rural) on the rural property itself — this is a federal property tax on rural land and generates no personal data of buyers.

PNAE (Programa Nacional de Alimentação Escolar): Supply to the school meal programme requires the rural producer to hold a valid DAP (Declaração de Aptidão ao PRONAF) or CAF (Cadastro Nacional da Agricultura Familiar), SIE-TO inspection registration and CNPJ. The PNAE contracting process involves documentation of the rural producer (including CNPJ and rural producer registration) — this is institutional documentation about Débora Silva de Souza Ltda, not personal data about individual students or families in the school meal programme. Student and family data is never processed by us; the municipal nutrition office is responsible for that data under its own LGPD obligations.

13

Updates to this Policy

This Policy may be updated to reflect changes in our activities, in the LGPD, in ANPD guidance, in MAPA dairy inspection or traceability regulations, in ADAPTO or SIE-TO requirements, or in the tax legislation of the State of Tocantins. Material changes will be communicated via our website and by WhatsApp to regular commercial clients.

14

Contact and Data Protection Officer

All privacy requests should be directed to our Data Protection Officer (LGPD Art. 41):

🥛

Privacy — Débora Silva de Souza Ltda

CompanyDébora Silva de Souza Ltda
CNPJ48.278.621/0001-68
AddressSítio Recanto Feliz, SN, Zona Rural, Colméia — TO, CEP 77725-000, Brazil
WhatsApp+55 (63) 9 0000-0000
HoursMon–Sat: 06:00–18:00
ResponseWithin 15 business days of receipt.
You also have the right to lodge a complaint with the Brazilian national data protection authority:
ANPD — Autoridade Nacional de Proteção de Dados
www.gov.br/anpd