Privacy Policies

These Privacy Policies apply to the services provided by the legal entity EMB Empreendimentos Digitais, hereinafter referred to as Retrato da Alma Gêmea.

When deciding to use the services offered by Imagem da Alma Gêmea, the user automatically AGREES AND ACCEPTS these Privacy Policies and is aware of all the clauses listed here.

It is important that you frequently check for updates to the Privacy Policy. We may update this Privacy Policy from time to time to reflect changes in our service-related personal data practices or changes in applicable laws.

We will post a notice on our website to alert you in advance of material changes to our privacy policy and will indicate at the top of the Privacy Policy when it was last modified.


1.1 This Privacy Policy (“Policy”) aims to inform you, user of the website of the Portrait of the Soul Gêmea, about what information is collected, in addition to how it is treated, in what situations it is shared and when it is deleted, in compliance with LGPD (General Data Protection Law), Law No. 13,709, of August 14, 2018, whose new wording came into force through Law No. 13,853/19, in addition to Federal Law No. 12,965 of August 23 April 2014 (Marco Civil da Internet) and EU Regulation No. 2016/679 of April 27, 2016 (European General Regulation for the Protection of Personal Data – GDPR).

1.2 The acceptance of this Privacy Policy will occur when you use the site offered by the site of the Portrait of the Soul Gêmea, expressing free, express and informed consent. Do not use the site if you do not agree with this Privacy Policy or any other agreement that governs your use of the site. If you have any questions, please contact us through the communication channels on the website.


2.1 Those responsible for the website undertake to comply with the rules set out in the LGPD, in compliance with the following principles:

Lawfulness, loyalty and transparency: the user's personal data will be processed in a lawful, loyal and transparent manner.
Limitation of purposes: the user's personal data will only be collected for specific, explicit and legitimate purposes, and cannot be further processed in a way that is incompatible with those purposes.
Minimization of data: the user's personal data will be collected in an adequate, relevant and limited manner to the needs of the purpose for which they are processed.
Accuracy: the user's personal data will be exact and updated whenever necessary, so that those considered inaccurate are erased or rectified whenever possible.
Conservation limitation: The user's personal data will be kept in a way that allows the identification of their holders only during the period necessary according to the purposes for which they are processed.
Integrity and confidentiality: the user's personal data will be treated securely, protected from unauthorized or unlawful interventions and against accidental loss, destruction or damage, adopting the appropriate technical or organizational measures.

2.2 The website user has the following rights, conferred by the Personal Data Protection Law and the RGPD:

1. Right of confirmation and access: it is the user's right to obtain confirmation from the website that the personal data concerning him/her are being processed or not and, if that is the case, the right to access his/her personal data;

2. Right of rectification: is the user's right to obtain from the website, without undue delay, the rectification of inaccurate personal data concerning him;

3. Right to delete data (right to be forgotten): it is the user's right to have their data erased;

4. Right to limit the processing of data: it is the user's right to limit the processing of their personal data, being able to obtain it when contesting the accuracy of the information, when the treatment is unlawful, when the website no longer needs the data for the purposes proposals, when you have objected to the processing of data and in case of unnecessary data processing;

5. Right of opposition: it is the right of the user to, at any time, object to the processing of personal data concerning him for reasons related to his particular situation, and may also oppose the use of his personal data to define a marketing profile (profiling);

6. Right to data portability: is the right of the user to receive personal data concerning him and that he has provided to the company, in a structured, commonly used and machine-readable format, and the right to transmit this data to other companies;

7. Right not to be subjected to automated decisions: it is the user's right not to be subject to any decision taken exclusively based on automated processing, including profiling, which has effects in its legal sphere or which significantly affects it. in a similar way.

3. The user may exercise their rights by means of written communication sent through the company's communication channels with the subject “LGPD – EMAIL”, specifying:

1. Full name or corporate name and e-mail address of the user and, if applicable, of his representative;

2. Right you wish to exercise with the company;

3. Order date and user signature;

4. Any document that can demonstrate or justify the exercise of your right;

5. The user will be informed in case of rectification or deletion of his data.


3.1 While using the website, in order to safeguard and protect the rights of third parties, the user must only provide his/her personal data, and not those of third parties.


4.1 The collection of user data will take place in accordance with the provisions of this Privacy Policy and will depend on the user's consent, which is expendable only in the cases provided for in article 11, item II, of the Personal Data Protection Law.

4.1.1 Types of data collected; User identification data for registration;

The use of some services on the site by the user will depend on registration, and in these cases, the following data may, as the case may be, be collected and stored: Name, date of birth, country in which you were born, gender, sexual orientation, racial preference and email. In addition, credit card data may still be collected, when this is the means used for payment.

The collection of said data serves to carry out the service, not being used for any other purpose than this. In addition, if desired, the user may choose to receive e-mails about promotions that may be launched or news about the services offered. The user can opt out of receiving emails at any time. Data informed in the contact form

The data eventually informed by the user who uses the website's contract forms, including the content of the message sent, will be collected and stored only for the execution of the service. Data related to the execution of contracts signed with the user

For the execution of the service present on the website, other data related or necessary for its execution may be collected and stored, including the content of any communications with the user. Access records

In compliance with the provisions of art. 15, caput and paragraphs, of Federal Law No. 12.965/2014 (Marco Civil da Internet), user access records will be collected and stored for at least six months. sensitive data

Sensitive data from users will not be collected, thus understood those defined in arts. 9 and 10 of the GDPR and in arts. 11 and following of the Personal Data Protection Act. Thus, among others, the following information will not be collected:

Data revealing the user's racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data to uniquely identify a person, data relating to the user's health, data relating to life sexual intercourse, data relating to criminal convictions or offenses or related security measures. Collection of data not expressly provided for;

Eventually, other types of data not expressly provided for in this Privacy Policy may be collected, provided that they are provided with the user's consent, or that the collection is permitted or imposed by law.

4.1.2 Legal basis for the processing of personal data;

By using the website, the user is consenting to this Privacy Policy. The user has the right to withdraw his consent at any time, not compromising the lawfulness of the processing of his personal data before the withdrawal. The withdrawal of consent can be done through the contact channels on the website. The consent of the relatively or absolutely incapable, especially of children under 16 (sixteen) years old, can only be given, respectively, if duly assisted or represented.

Personal data necessary for the execution and fulfillment of the services contracted by the user may also be collected. The processing of personal data without the user's consent will only be carried out on grounds of legitimate interest or for the cases provided for by law, that is, among others, the following:

For compliance with a legal or regulatory obligation by the controller;

For carrying out studies by research body, ensuring, whenever possible, the anonymization of personal data;

When necessary for the execution of a contract or preliminary procedures related to a contract to which the user is a party, at the request of the data subject;

For the regular exercise of rights in judicial, administrative or arbitration proceedings, the latter pursuant to Law No. 9,307, of September 23, 1996 (Arbitration Law);

For the protection of the life or physical safety of the data subject or third parties;

For the protection of health, in a procedure carried out by health professionals or health entities;

When necessary to meet the legitimate interests of the controller or third parties, except in the event that the holder's fundamental rights and freedoms prevail that require the protection of personal data;

For credit protection, including the provisions of the relevant legislation.

4.1.3 Purposes of processing personal data

The personal data collected by the company are intended to facilitate, expedite and fulfill the commitments established with the user and to enforce requests made by filling in forms. They may also be used for commercial purposes, to personalize the content offered to the user, as well as to provide support to the company in order to improve the quality and functioning of its services.

The registration data will be used to allow the user to access the services offered by the Portrait of the Soul Gêmea in order to provide the parties with legal certainty, in addition to facilitating and enabling the conclusion of the business.

The processing of personal data for purposes not provided for in this Privacy Policy will only occur upon prior notice to the user, and, in any case, the rights and obligations set forth herein will remain applicable.

4.1.4 Period of retention of personal data

The user's personal data will be kept for a period not exceeding that required to fulfill the purposes for which they are processed. The data retention period is defined according to the following criteria:

The data will be stored for the time necessary to provide the services provided by the Portrait of the Soul Gêmea, which may vary according to the frequency of use of the service by the user.

Users' personal data may only be retained after the end of their treatment in the following cases:

For compliance with a legal or regulatory obligation by the controller;

For study by research body, guaranteed, whenever possible, the anonymization of personal data;

For the transfer to a third party, provided that the data processing requirements set out in the legislation are respected;

For the exclusive use of the controller, access by a third party is prohibited, and provided that the data is anonymized.

4.15. Recipients and transfer of personal data

User personal data will not be shared with third parties. Therefore, they will only be treated by the Portrait of the Soulmate.


5.1 We undertake to apply technical and organizational measures capable of protecting personal data from unauthorized access and situations of destruction, loss, alteration, communication or dissemination of such data. To guarantee security, solutions will be adopted that take into account: the appropriate techniques, the application costs, the nature, scope, context and purposes of the treatment and the risks to the user's rights and freedoms.

5.2 All data on the website of the Portrait of the Soulmate is hosted on cloud server structures that follow all the security standards of a Data Center, which guarantees that personal data is transmitted in a secure and confidential manner.

5.3 However, we are exempt from liability for the sole fault of third parties, as in the case of hackers or crackers, or the sole fault of the user, as in the case where he himself transfers his data to a third party. We are also committed to informing the user within an adequate period of time in the event of any type of violation of the security of their personal data that may pose a high risk to their personal rights and freedoms.

5.4 A breach of personal data security is one that causes, accidentally or unlawfully, the destruction, loss, alteration, disclosure or unauthorized access to personal data transmitted, stored or subject to any other type of treatment. 5.5 Finally, we are committed to treating the user's personal data with confidentiality, within the legal limits.


 6.1 Without prejudice to any other administrative or judicial remedy, all data subjects have the right to file a complaint with a supervisory authority. The complaint may be made to the authority of the company's headquarters, the user's country of habitual residence, his place of work or the place where the infringement was allegedly committed.


7.1 User, from this agreement, expressly authorizes the website to use resources, such as, but not limited to, “cookies”, in order to offer a better and more personalized service.

7.2 A cookie represents a small amount of data, usually including an anonymous unique identifier, sent to you by a website and stored on your computer's disk.

7.3 The User can configure his browser to accept all cookies, reject them or be notified when a cookie is sent.

7.4 As each browser does this in a different way, check your browser's constant help tool to find out how to modify your cookie preferences.

7.5 The cookies used by Retrato da Alma Gêmea relate to information about the purchase and sale of services.

7.6 ATTENTION: If the User chooses to reject all cookies in his browser, he will not be able to use all the resources and services offered by the website. The website uses its own cookies for various purposes, including:

Check your information when accessing, in order to have personalized content;

Display ads targeted to your profile;

Estimate Internet traffic;

Conduct research to improve the content and services of the website;

Advertisers or other companies do not have access to website cookies.


8.1 The Portrait of the Soulmate page may contain external links redirecting the user to other internet pages, over which the company has no control. Despite prior and regular checks carried out by the company, it disclaims any responsibility for the content found on these sites and the services offered by them.

8.2 Access to sites linked to such links is not governed by this privacy policy. The Portrait of the Soulmate recommends that the User consult the terms and conditions of use established by each site linked to the links inserted in the Site. The Portrait of the Soulmate will not be responsible, directly or indirectly, for any damages or losses caused or related to the use of any information, content, goods or services made available on the Site or on any third-party site accessed through the links made available on the Site.


9.1 This version of this Privacy Policy was last updated on: 12/06/2022.

 9.2 The company reserves the right to modify, at any time and without prior notice, these rules, especially to adapt them to the evolution of the service offered, either by making new functionalities available, or by suppressing or modifying those that already exist or to meet the evolution of current legislation.

9.3 Accordingly, we invite the user to periodically consult this page to check for updates.

9.4 By using the service after any modifications, the user demonstrates his agreement with the new rules. If you disagree with any of the modifications, you must immediately request the cancellation of your account and present your reservation to the customer service, if you so wish.


10.1 The City of São Paulo, State of São Paulo is elected, to resolve any doubts and resolve conflicts arising from this contract, with the waiver of any other, however privileged it may be, except for users who fit the legal concept consumer and opt for the legal prerogative.


11.1 This Agreement will be governed by the laws of Brazil and complies with the Brazilian legal system, the general principles of law and international standards of electronic commerce.

11.2 If the User does not agree with a certain clause of this Agreement, and obtains its nullity in court, the other provisions will not be affected and will remain in force.