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⚡ Guapiaçu · SPPrivacy · LGPD · Wholesale Electrical · SEFAZ-SP · ICMS-SP

Privacy Policy.

Ltda Br Lux Ltda · CNPJ 48.279.035/0001-38

Company

Br Lux Ltda

CNPJ

48.279.035/0001-38

Last updated

January 2025

Legislation

LGPD · Lei 13.709/2018 · ICMS-SP · SEFAZ-SP

This Privacy Policy describes how Br Lux Ltda ("we," "our" or "the Company") collects, uses, stores and protects personal data of our clients, website visitors and all persons whose data we process in connection with our wholesale electrical materials distribution activities in Guapiaçu, São Paulo, Brazil.

As a registered limited liability company (Ltda) operating in the wholesale electrical materials trade sector, we are committed to full compliance with the LGPD (Lei nº 13.709/2018), the Brazilian Consumer Protection Code (CDC — Lei nº 8.078/1990) where applicable to our commercial relationships, and the tax obligations of SEFAZ-SP and ICMS-SP. As a wholesale distributor (comércio atacadista), our primary clients are legal entities (electricians, construction companies, contractors and resellers) rather than individual consumers — which shapes the nature of the personal data we process and the legal framework that applies.

01

Introduction and Scope

This Policy applies to all personal data processed in connection with our wholesale electrical materials distribution — clients who purchase materials, prospective clients who request quotes, website visitors and any person whose data we process. Our primary client base consists of legal entities (companies, MEIs and firms) rather than individual consumers. Personal data we process relates primarily to the natural persons who are the legal representatives, contacts and beneficial owners of these companies — not to the companies themselves, which are legal persons not directly protected by the LGPD. However, sole traders (MEIs), individual electricians and sole proprietors are natural persons and are directly protected by the LGPD with respect to their personal data.

02

Identity of the Controller

Company name: Br Lux Ltda
Type: Sociedade Limitada (Ltda)
CNPJ: 48.279.035/0001-38
Activity (CNAE): Comércio Atacadista de Material Elétrico
Address: R. Leonardo Comar, 117, Residencial Leonor, Guapiaçu — SP, CEP 15110-000, Brazil
Email: privacy@brlux.com.br
03

Personal Data We Collect

A. Business client registration and purchase data:

  • Company clients (CNPJ): Company name, CNPJ, billing address, delivery address, name and contact details of the procurement or purchasing contact. The company itself is not a data subject under the LGPD, but the natural person who is the contact is.
  • Individual professional clients (MEI / CPF): Name, CPF, address, WhatsApp and email of electricians, sole-trader contractors and individual professionals who purchase wholesale from us. These individuals are natural persons directly protected by the LGPD.
  • Purchase and order history: Records of materials purchased, quantities, order dates and delivery addresses — retained as part of the commercial relationship and required for NF-e documentation.

B. Quote and prospecting data:

  • Name, WhatsApp, company name and material description when prospective clients request a wholesale quote via our website or WhatsApp.

C. Technical website data:

  • IP address, browser type and pages visited when a visitor accesses our website.
04

Purpose and Legal Basis

PurposeLegal Basis (LGPD)
Wholesale order management and commercial relationshipContract performance (Art. 7º, V)
Client registration and credit assessmentContract performance; Legitimate interest
Issuing NF-e per wholesale orderContract performance; Legal obligation (Art. 7º, II)
ICMS-SP — fiscal bookkeeping (SEFAZ-SP)Legal obligation (Art. 7º, II)
Sped Fiscal / EFD contributions (SEFAZ-SP)Legal obligation (Art. 7º, II)
Purchase history and client account managementContract performance; Legitimate interest
Website analytics and improvementLegitimate interest; Consent (cookies)
05

Sharing of Data

Commercial data confidentiality — B2B context: In a wholesale electrical materials business, client purchasing data (what products they buy, in what quantities, at what prices) constitutes commercially sensitive information. We treat client purchasing history and pricing agreements with the same confidentiality as financial data. This information is never shared with competitors, industry associations, manufacturers' representatives or any third party who could use it to the client's commercial disadvantage — without the client's express authorisation.
  • SEFAZ-SP / Receita Federal: NF-e data — client CNPJ or CPF on every invoice, transmitted electronically as required. SPED Fiscal / EFD obligations transmitted to SEFAZ-SP.
  • Logistics / transport partners (where applicable): Delivery address and order reference shared with transport companies for physical delivery of materials. Governed by a data processing agreement.
  • Financial institutions / credit assessment (where applicable): For credit limit assessments on commercial accounts — only with the client's prior knowledge as part of the commercial account opening process.
  • PROCON-SP / Senacon: When required under the CDC or commercial dispute resolution.
  • Legal authorities: When required by court order or administrative authority.
06

International Transfers

Our wholesale distribution operation is based in Guapiaçu, SP. All client data is processed in Brazil. Tax records (NF-e, SPED Fiscal) are processed exclusively in systems certified by the Receita Federal and SEFAZ-SP. 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-SP): Minimum 5 years as required by Brazilian federal and São Paulo state tax legislation. SPED Fiscal / EFD retained for the same period.
  • Active client data (CNPJ / CPF, contact, purchase history): Retained for the duration of the commercial relationship and for 5 years after the last purchase — consistent with tax retention and commercial statute of limitations.
  • Quote requests without order: Up to 1 year from the date of the quote — to follow up on project timelines and respond to reactivated enquiries.
  • Website analytics: Aggregated and anonymised after 12 months.
08

Security Measures

  • Client purchasing data and pricing agreements stored in access-controlled commercial management systems — not accessible to unauthorised staff;
  • NF-e issued using a certified digital certificate (A1/A3) approved by the Receita Federal;
  • Client contact data handled via WhatsApp and email with discretion — not shared within the team beyond what is necessary to process each order;
  • Website encrypted (HTTPS);
  • Incident response procedures in accordance with LGPD Art. 48.
09

Your Rights under the LGPD

Natural persons in our client base — individual electricians, MEIs, sole-trader contractors and individual purchasing contacts at companies — have the following rights:

  • 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 changes, contact updates).
  • Deletion (Art. 18, IV): Request deletion — subject to mandatory fiscal retention (NF-e: 5 years; SPED Fiscal: 5 years) and commercial statute of limitations.
  • Portability (Art. 18, V): Receive your personal 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 wholesale electrical materials distribution is directed exclusively at professional buyers — registered companies, MEIs and individual professionals operating in the electrical installation and construction sectors. We do not sell to or process data of minors. If a minor contacts us, we ask them to have an adult business representative manage any commercial enquiry.

12

Wholesale Trade, NF-e and ICMS-SP

Wholesale (atacado) vs. retail (varejo) — fiscal and LGPD distinctions: Br Lux Ltda operates as a comércio atacadista — selling electrical materials in volume to professional buyers (electricians, construction companies, contractors and resellers) who will use or resell the materials commercially. This is legally and fiscally distinct from retail (varejo). The primary fiscal obligations are: (a) ICMS-SP on all wholesale transactions, administered by SEFAZ-SP; (b) NF-e (Nota Fiscal Eletrônica) for every wholesale transaction, transmitted electronically to SEFAZ-SP; (c) SPED Fiscal / EFD (Escrituração Fiscal Digital) — the electronic fiscal bookkeeping obligation that captures all ICMS transactions and is transmitted to SEFAZ-SP periodically. There is no ISS on wholesale trade — ISS applies only to services (prestação de serviços), not to the sale of goods. ICMS is the primary tax on the sale of physical electrical materials.
NF-e for wholesale orders — client CNPJ and CPF data: Every wholesale purchase from Br Lux Ltda is documented by a NF-e issued to the buyer's CNPJ (for companies and MEIs) or CPF (for individual buyers). The NF-e contains: the buyer's CNPJ or CPF, full name or razão social, billing address, list of products purchased (with NCM codes, quantities and values), ICMS-SP applied and CFOP codes for wholesale operations. The CFOP (Código Fiscal de Operações e Prestações) codes used by Br Lux reflect the nature of the wholesale transaction — typically CFOP 5.102 (wholesale within São Paulo state) or 6.102 (interstate wholesale). These codes are not personal data themselves but appear on the NF-e alongside client identifying data and must be retained for the mandatory 5-year period. For resellers who purchase from Br Lux and resell to end consumers, the NF-e from Br Lux is their cost document and does not create any direct relationship with the end consumer's personal data.
MEI and individual electrician data — LGPD as natural persons: A significant portion of Br Lux's client base consists of individual electricians and sole-trader contractors operating as MEIs (Microempreendedores Individuais) or as individual natural persons. An MEI has a CNPJ for fiscal purposes but is legally a natural person (pessoa física). The LGPD protects natural persons — so while a large company's CNPJ data is institutional (not personal data in the LGPD sense), an MEI electrician's data — their CPF, home address used as the MEI address, personal WhatsApp — is personal data protected by the LGPD. Br Lux applies the LGPD protections to all individual professionals and MEIs in our client base: their data is used only for the commercial relationship and NF-e issuance, is not shared without consent, and can be accessed, corrected or deleted upon request subject to fiscal retention obligations.
13

Updates to this Policy

This Policy may be updated to reflect changes in our activities, in the LGPD, in ANPD guidance, or in the tax legislation of the State of São Paulo. Material changes will be communicated by email or WhatsApp to active clients.

14

Contact and Data Protection Officer

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

Privacy — Br Lux Ltda

CompanyBr Lux Ltda
CNPJ48.279.035/0001-38
AddressR. Leonardo Comar, 117, Residencial Leonor, Guapiaçu — SP, CEP 15110-000, Brazil
WhatsApp+55 (17) 9 0000-0000
HoursMon–Fri: 08:00–17:30 · Sat: 08:00–12:00
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