This Privacy Policy describes how Symbio Plus Biotecnologia Ltda ("we," "our" or "the Company") collects, uses, stores and protects the personal data of our research partners, clients, collaborators, website visitors and all others whose data is processed in connection with our biotechnology research and experimental development activities in Torrões, Recife, Pernambuco.
As a registered limited company (Ltda) conducting biotechnology research, we comply with the LGPD (Lei nº 13.709/2018), the CDC (Lei nº 8.078/1990), applicable ANVISA regulations for biological products, CTNBio frameworks for genetically modified organisms, MAPA regulations for agricultural biotechnology, and applicable tax legislation in Pernambuco. Biotechnology research involves biological data, proprietary strains, genetic information and potentially human participant data — each with distinct governance requirements described below.
Introduction and Scope
This Policy applies to all personal data processed in connection with our biotechnology R&D activities — including industry partners and clients who commission research, academic and institutional collaborators, individual researchers who collaborate with us, website visitors who submit partnership enquiries, and research participants in human-involving studies. Biotechnology research involves specialised data governance considerations — including biological materials, genetic data and proprietary scientific information — that this Policy addresses in addition to standard LGPD requirements.
Identity of the Controller
Entity type: Sociedade Limitada (Ltda)
CNPJ: 48.278.946/0001-40
Activity (CNAE): Pesquisa e Desenvolvimento Experimental em Ciências Físicas e Naturais
Address: Rua Prof. Artur Coutinho, 585, Torrões, Recife — PE, CEP 50650-000, Brasil
Email: privacidade@symbioplus.com.br
Personal Data We Collect
A. Partner organisations and clients:
- Company name, CNPJ, address and the name, role, phone and email of the responsible scientific or commercial contact — collected when organisations engage our biotechnology R&D services.
- Billing data (CNPJ or CPF) for NFS-e issuance.
B. Research data — biological and scientific:
- Biological sample data: Where research involves biological samples provided by partners — sample origin, collection metadata, species identification and any associated geographic data. This is scientific data rather than personal data in most cases, but may become personal data where samples are traceable to identified individuals.
- Genetic and genomic data (where applicable): Sequence data, genomic analysis outputs and genetic characterisation data generated in molecular biology research. Where such data is associated with identified human individuals, it constitutes sensitive personal data under LGPD Art. 5º, II.
- Research participant data (where applicable): In studies involving human participants — identification, consent records, health or biological data collected under a specific CEP/CONEP-approved protocol and its associated data governance framework.
C. Research collaboration and website:
- Names, institutional affiliations and contact data of collaborating researchers and academics.
- Name, organisation and message when submitting partnership enquiries via our website or email.
- IP address, browser type, pages visited and access times.
Purpose and Legal Basis
| Purpose | Legal Basis (LGPD) |
|---|---|
| Biotechnology R&D and experimental development services | Performance of contract (Art. 7º, V) |
| Research involving human participants | Consent (Art. 7º, I); CEP/CONEP approved research (Art. 7º, IV) |
| Genetic / biological data from identified individuals | Consent — Art. 11, I (sensitive data) |
| CTNBio registration of biological materials (GMOs) | Legal obligation (Art. 7º, II) |
| ANVISA compliance for biological products | Legal obligation (Art. 7º, II) |
| MAPA compliance for agricultural biotech | Legal obligation (Art. 7º, II) |
| Issuing NFS-e; SEFAZ-PE tax compliance | Legal obligation (Art. 7º, II) |
| ISS — Prefeitura de Recife | Legal obligation (Art. 7º, II) |
| Scientific publication (anonymised data only) | Legitimate interest; Consent where required |
| Website analysis and improvement | Legitimate interest; Consent (cookies) |
Data Sharing
- CTNBio — Comissão Técnica Nacional de Biossegurança: Where research involves genetically modified organisms, registration and disclosure to CTNBio as required by Lei 11.105/2005 (Lei de Biossegurança) — including project description, organisms involved and researcher identification.
- ANVISA: Where research generates biological products subject to ANVISA regulation — minimum necessary regulatory documentation.
- MAPA — Ministério da Agricultura: For agricultural biotechnology research involving plant or animal biological agents subject to MAPA oversight.
- CEP/CONEP: Ethics committees receive research protocols and progress reports for human-involving studies as required by Resolução CNS 466/2012 — participant data is de-identified in all committee submissions except where identification is essential for ethics oversight.
- Research collaborators (under agreement): Scientific collaborators and co-investigators receive only the minimum data necessary for their specific role in the research, under appropriate data governance agreements.
- FAPERPE / CNPq / FINEP (where applicable): Minimum necessary reporting for funded research grants, including anonymised data summaries where open data requirements apply.
- SEFAZ-PE / Receita Federal: NFS-e data for research service contracts.
- Prefeitura de Recife (ISS): For ISS obligations on research and development service activities.
- Legal authorities: When required by a competent judicial or administrative order.
International Transfers
Our research activities are based in Recife, PE. Where biotechnology research involves international collaborations or publications in international journals, partner and researcher identification data may be transmitted internationally as required by the collaboration — always under the guarantees of Art. 33 of the LGPD. Biological materials transferred internationally are subject to Brazilian biosafety and export regulations independently of LGPD. Human participant data is never transmitted internationally without specific consent and a distinct data governance framework.
Retention Periods
- NFS-e and fiscal records: Minimum 5 years under Receita Federal and SEFAZ-PE requirements.
- Research contracts and partner data: Duration of the research relationship plus 5 years.
- Scientific research data and records: Minimum 5 years from project completion in accordance with Brazilian scientific research standards and any applicable funding body requirements — longer where required by CTNBio, ANVISA, MAPA or CEP/CONEP regulatory obligations.
- CTNBio registration records: For the duration of any registered biological material's use plus applicable regulatory retention period under Lei 11.105/2005.
- CEP/CONEP human research records: Minimum 5 years from project completion per Resolução CNS 466/2012 — or longer as specified in the approved research protocol.
- Genetic and biological data from identified individuals: Defined in the specific study consent and governance framework — participants are informed of retention periods before enrolment.
- Partnership enquiry data (no engagement): Up to 1 year from last contact.
Security Measures
- Partner biological materials and research data accessible only to researchers directly working on that specific project;
- Genetic and biological data from identifiable individuals stored in access-controlled systems with encryption at rest;
- Physical biological samples stored in compliant biosafety conditions per applicable ANVISA and MAPA requirements;
- CTNBio-registered organisms maintained in designated, controlled areas with access logging;
- Website and digital communications encrypted in transit (HTTPS/TLS);
- 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 personal data and receive a copy.
- Correction (Art. 18, III): Request correction of inaccurate data.
- Anonymisation / Blocking / Deletion (Art. 18, IV): Request deletion — subject to scientific, regulatory and fiscal retention obligations.
- Portability (Art. 18, V): Receive your data in a structured format.
- Withdrawal of Consent (Art. 8º, §5º): Withdraw consent at any time — for research participants, withdrawal rights are also described in the specific study consent form and follow Resolução CNS 466/2012 procedures.
- 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 uses cookies for essential functionality and aggregated performance analysis only. We do not use behavioural tracking or advertising cookies. Preferences can be managed through browser settings.
Protection of Minors
Research partnerships are engaged by organisations and adult professionals. Where any research study involves minor participants, a specific ethical review under Resolução CNS 466/2012, parental consent framework and additional data governance measures are implemented before any data collection — in compliance with LGPD Art. 14. We do not collect personal data from children under 13 via our website.
Biotechnology Data Governance
Biotechnology research involves data governance considerations beyond standard LGPD requirements. We apply the following frameworks to our specific research activities:
Updates to this Policy
This Policy may be updated to reflect changes in our research activities, the LGPD, ANPD guidance, ANVISA regulations, CTNBio requirements, MAPA or CEP/CONEP frameworks, or applicable Pernambuco tax legislation. Material changes will be communicated to active research partners by email and via our website.
Contact & Data Protection Officer
All privacy requests — including from research participants — should be directed to our Data Protection Officer (Encarregado — LGPD Art. 41):
Privacy Contact — Symbio Plus Biotecnologia Ltda
ANPD — Autoridade Nacional de Proteção de Dados · www.gov.br/anpd
For human research ethics concerns:
CONEP — Comissão Nacional de Ética em Pesquisa · conselho.saude.gov.br/web/conep