This Privacy Policy describes how Jessica Barreto Representações Ltda ("we," "our" or "the Company") collects, uses, stores and protects the personal data of our manufacturer clients, retail and wholesale trade contacts, website visitors and all others whose data is processed in connection with our commercial representation activities in Conceição do Jacuípe, Bahia.
As a registered limited company (Ltda), we are fully committed to compliance with the Brazilian General Data Protection Law — LGPD (Lei nº 13.709/2018), the Brazilian Consumer Protection Code — CDC (Lei nº 8.078/1990), applicable ANVISA regulations for the commercialisation of pharmaceuticals and cosmetics, and applicable tax legislation in the State of Bahia.
Introduction and Scope
This Policy applies to all personal data processed by our commercial representation company — including manufacturer clients who engage our representation services, retail and wholesale trade contacts whose data we manage to develop commercial accounts in Bahia, website visitors and anyone whose data is processed in connection with our activities. We operate in two main data relationships: with manufacturers (our principals) and with trade buyers (our commercial targets).
Identity of the Controller
Entity type: Sociedade Limitada (Ltda)
CNPJ: 48.280.140/0001-97
Activity (CNAE): Representantes Comerciais e Agentes do Comércio de Medicamentos, Cosméticos e Produtos de Perfumaria
Address: Praça Manoel Teixeira de Freitas, 30, Centro, Conceição do Jacuípe — BA, CEP 44245-000, Brasil
Email: privacidade@jessicabarreto.com.br
Personal Data We Collect
We process data across two principal groups:
A. Manufacturer clients (principals):
- Company name, CNPJ and the name, role, phone and email of the responsible commercial or sales contact at the manufacturer — collected when companies engage our representation services or request proposals.
- Product and commercial data: product portfolio, pricing, promotional materials and commercial terms — provided for use in our representation activities in Bahia.
- Billing data for NFS-e issuance (CNPJ and contact).
B. Trade buyers and retail contacts (commercial targets):
- Business name, CNPJ and the name, role and contact details of pharmacists, drugstore buyers, beauty retail purchasers and wholesale distributors in Conceição do Jacuípe, Feira de Santana and across Bahia.
- Purchase history, sales data and account development records associated with each trade client — maintained to manage the commercial relationship on behalf of manufacturer principals.
- For pharmaceutical channel contacts: CRF-BA registration number where applicable for compliant pharmaceutical commercial representation.
C. Website visitors: IP address, browser type, pages visited and access times; name, phone and message when submitting an enquiry form.
Purpose and Legal Basis
| Purpose | Legal Basis (LGPD) |
|---|---|
| Commercial representation and account development for manufacturers | Performance of contract (Art. 7º, V) |
| Management of trade buyer relationships on behalf of manufacturer principals | Performance of contract; Legitimate interest (Art. 7º, IX) |
| ANVISA-compliant pharmaceutical representation to licensed trade buyers | Legal obligation; Performance of contract (Art. 7º, II, V) |
| Issuing NFS-e; SEFAZ-BA tax compliance | Legal obligation (Art. 7º, II) |
| ISS — Prefeitura de Conceição do Jacuípe | Legal obligation (Art. 7º, II) |
| Commercial results reporting to manufacturer principals | Performance of contract; Legitimate interest |
| Website analysis and improvement | Legitimate interest; Consent (cookies) |
Data Sharing
- Manufacturer principals (sales reports): Trade buyer account information, sales data and commercial results are shared with the manufacturer whose products we represent — this is the core deliverable of our representation service and is the basis on which the engagement is commissioned.
- SEFAZ-BA / Receita Federal: Tax data for NFS-e issuance and applicable federal and state tax compliance.
- Prefeitura de Conceição do Jacuípe (ISS): For ISS/ISSQN obligations on commercial representation service activities.
- ANVISA / CRF-BA (pharmaceutical sector): Where required by pharmaceutical commercial representation regulations — identification of licensed pharmaceutical trade buyers to verify compliant commercialisation.
- PROCON-BA: When required in a consumer dispute mediation under the CDC.
- Legal authorities: When required by a competent judicial or administrative order.
International Transfers
Our commercial representation activities operate within Brazil and Bahia. All client and trade contact data is stored in Brazil. Any technology platforms for communication or data management that operate on international servers do so only under the guarantees of Art. 33 of the LGPD or recognised adequacy mechanisms.
Retention Periods
- NFS-e and fiscal records: Minimum 5 years under federal and state tax legislation (CTN, Art. 174; SEFAZ-BA).
- Manufacturer representation contracts and commercial records: Duration of the representation relationship plus 5 years for contractual, fiscal and commission dispute documentation.
- Trade buyer account records (retail and wholesale contacts): Duration of active commercial engagement with that buyer plus 2 years — to support account dispute resolution and commission calculation records.
- Pharmaceutical channel contact records (CRF-BA): Retained in accordance with ANVISA pharmaceutical commercialisation record requirements.
- Contact and enquiry data (no engagement): Up to 1 year from last interaction.
- Website analytics: Aggregated and anonymised after 12 months.
Security Measures
- Trade buyer account data and commercial results accessible only to the representative and authorised support staff — never shared between different manufacturer principals;
- Manufacturer commercial data (pricing, promotional terms) treated as confidential and not shared with trade buyers beyond what is required for the commercial presentation;
- WhatsApp and email communications handled with discretion;
- Encryption in transit (HTTPS) for website and digital communications;
- As a Ltda, formal internal data handling protocols maintained;
- Incident response procedures and breach notification per LGPD Art. 48.
Your Rights under the LGPD
- Confirmation and Access (Art. 18, I–II): Confirm whether we hold your data and receive a copy.
- Correction (Art. 18, III): Request correction of inaccurate data.
- Anonymisation / Blocking / Deletion (Art. 18, IV): Request restriction or deletion — subject to fiscal and contractual retention obligations.
- Portability (Art. 18, V): Receive your data in a structured format.
- Deletion of consent-based data (Art. 18, VI): Request deletion of data processed by consent.
- Information on sharing (Art. 18, VII): Find out which manufacturer principals or authorities your data has been shared with.
- Withdrawal of Consent (Art. 8º, §5º): Withdraw consent at any time.
- Complaint to the ANPD (Art. 18, §1º): Lodge a complaint at www.gov.br/anpd.
We respond within 15 business days.
Cookies and Tracking
Our website may use cookies for essential functionality and aggregated performance analysis. We do not use behavioural tracking cookies for advertising without prior consent. Preferences can be managed through browser settings.
Protection of Minors
Our commercial representation services engage businesses and trade professionals — adults acting in a professional capacity. We do not intentionally collect personal data from children under 13. The pharmaceutical and cosmetic products we represent may include products intended for children or adolescents; however, commercial representation activities are conducted with adult trade buyers only, not with end consumers or minors directly.
Sensitive Data & Pharmaceutical Compliance
In our own right, we do not collect sensitive personal data as defined in LGPD Art. 5º, II. The pharmaceutical products we represent are not a form of health data — they are commercial products whose commercialisation is regulated by ANVISA. However, we acknowledge the heightened responsibility associated with the pharmaceutical sector:
For cosmetics and perfumery products we represent, we verify that products have the required ANVISA notifications or registrations applicable to the product category before active commercial representation in Bahia.
Updates to this Policy
This Policy may be updated to reflect changes in our activities, the LGPD, ANPD guidance, ANVISA regulations or applicable tax legislation. Material changes will be communicated via our website or directly to active clients by WhatsApp or email.
Contact & Data Protection Officer
All privacy requests, questions and complaints should be directed to our Data Protection Officer (Encarregado — LGPD Art. 41):
Privacy Contact — Jessica Barreto Representações Ltda
ANPD — Autoridade Nacional de Proteção de Dados
www.gov.br/anpd