Note: this is a translation of the PolĂtica de Privacidade in Portuguese. If the two versions differ, the Portuguese version prevails.
Last updated: 14 October 2026.
This policy explains what data the transgeneros.com.br website records, why it records it, who it shares it with and how you can decide about it.
We have written it in plain language. If anything is unclear, please contact us at the e-mail address below.
Who is responsible for your data
The controller of the data processed on this website is:
- Registered company name: Clinica da Plastica Transgender Center Brazil LTDA
- Trading name: Transgender Center Brazil
- CNPJ (Brazilian company number): 06.928.786/0001-98
- Address: R. Armando Odebrecht, 70, Salas 807-808, Garcia, Blumenau/SC, 89020-403
- E-mail: clinicadr.martins@hotmail.com
In this text, âclinicâ, âweâ, âusâ and âourâ refer to the controller above.
What data the website records
The website has no registration form. Contact with the clinic takes place on WhatsApp. For this reason, the website records very little, in three groups.
1. Browsing data, through cookies and similar technologies
When measurement is switched on, the website uses these tools:
- Google Tag Manager: organises how the other measurement tools load.
- Google Analytics 4: measures visits, pages viewed, where visits come from and how the website is used.
- Google Ads: measures whether a visit or a contact came from a Google advert.
- Meta Pixel: measures whether a visit or a contact came from an advert on Facebook or Instagram.
- Microsoft Clarity: shows how the pages are used (clicks, scrolling, heatmaps and session recording). Clarity is set up with strict masking: the text shown on screen and what you type are hidden before they leave your browser.
These tools may receive, among other things, your IP address, the type of device and browser, your language, the pages visited, the referring page and identifiers generated by the cookies themselves.
2. Attribution record of the WhatsApp click
When you click a WhatsApp button on the website, we save a record so we know where that contact came from. This record contains:
- a code generated for that click;
- the campaign parameters of the landing page (UTMs);
- advert click identifiers, when present:
gclid,gbraid,wbraid,fbclid,fbpandfbc; - the button clicked and the pages visited;
- the country of access, estimated from the IP address at the time of the click;
- your consent choice at that moment.
This record contains no name and no phone number. Nor does it store the IP address, the browser type or any free text. For visitors from the European Union, the United Kingdom and Switzerland who have not accepted advertising measurement, click identifiers are not saved.
3. The WhatsApp conversation
The conversation takes place outside the website, in the WhatsApp app. WhatsApp is a Meta service and follows Metaâs privacy policies. What you write in the conversation (for example, your name, phone number and the reason for getting in touch) is received by the clinicâs team and recorded in the clinicâs customer service system (CRM). The message the website suggests on WhatsApp ends with a code (for example, âCĂłdigo: [G-HOME-12345]â, where âCĂłdigoâ means âCodeâ). This code links the contact to where the visit came from, without identifying you. You can delete it before sending the message.
What we use the data for and on what legal basis
The clinic processes personal data in accordance with Brazilâs General Data Protection Law (Lei nÂș 13.709/2018, LGPD).
| Purpose | Data used | Legal basis |
|---|---|---|
| Making the website work and storing your cookie choice | tc_consent and the websiteâs session keys | Legitimate interest and compliance with the obligation to record consent (LGPD, art. 7, II and IX) |
| Measuring website use and improving the pages | Google Analytics 4, Microsoft Clarity | Consent or legitimate interest, depending on the region (see below) |
| Measuring advert results | Google Ads, Meta Pixel, click attribution record | Consent or legitimate interest, depending on the region (see below) |
| Replying to and looking after people who get in touch | WhatsApp conversation and CRM record | Preliminary steps towards a contract at the data subjectâs request (LGPD, art. 7, V) |
Consent rule by region
- Visitors from the European Union, Iceland, Liechtenstein, Norway, the United Kingdom and Switzerland: measurement starts switched off and is only enabled after you accept. Without your acceptance, the Meta Pixel and Microsoft Clarity are not triggered, and Googleâs tools do not save measurement or advertising cookies.
- Visitors from everywhere else, including Brazil: measurement is on from the moment you arrive on the website. You can refuse at any time, and your refusal applies from then on.
The region is identified by Google from the IP address of the connection. This indicator is approximate (a VPN, for example, changes the result). If that applies to you, use the âCookie preferencesâ button to refuse.
With measurement refused, Googleâs tools may still send signals without cookies and without advert identifiers, for aggregate counting. In this state, the website may also keep the advert click identifier in the address of internal pages, instead of saving it in a cookie.
Sensitive data
The website does not ask for information about health, gender identity or sex life. Even so, we know that visiting the website of a gender affirmation clinic may say something about a person. That is why measurement does not record what you type, and the click record contains no name or phone number. Any health information you choose to share in the WhatsApp conversation is treated by the clinic with the confidentiality that belongs to medical care.
How long we keep data
- WhatsApp click attribution record: 180 days. After that, it is deleted by an automatic clean-up.
- Cookies and browser storage: each item has its own duration, shown in the table in the section âCookie and local storage tableâ.
- Data in Google, Meta and Microsoft tools: follow the retention period set in each tool and each companyâs rules.
- Conversation data recorded in the CRM: for as long as needed for care and for the clinicâs legal obligations.
When the purpose ends and there is no legal obligation to keep the data, it is deleted or anonymised.
Who we share data with
We do not sell personal data. We share it only with the suppliers that make the website and our service work:
| Company | Role | What it receives |
|---|---|---|
| Tag Manager, Analytics 4 and Google Ads | Browsing data and Google advert click identifiers | |
| Meta | Meta Pixel and WhatsApp | Browsing data, Meta advert click identifiers and the WhatsApp conversation |
| Microsoft | Microsoft Clarity | Page usage data, with text masked |
| Vercel | Website hosting | Technical access data, such as IP address and server logs |
| Supabase | Database for the click record | The click attribution record (no name and no phone number) |
| Kommo | The clinicâs customer service system (CRM) | Contact details and the WhatsApp conversation |
We may also share data when required by law, a court order or a competent authority.
Google and Meta may also use part of this data for their own purposes, such as showing adverts. In that case, each companyâs privacy policy applies.
International transfer
Google, Meta, Microsoft and Vercel are companies headquartered outside Brazil. Supabase and Kommo may also store data on servers outside Brazil.
For this reason, some data may be transferred to other countries, including the United States. These transfers follow art. 33 of the LGPD, based on the contractual safeguards offered by these suppliers.
Your rights
Under art. 18 of the LGPD, you may ask the clinic, at any time, for:
- confirmation that we process your data;
- access to the data;
- correction of incomplete, inaccurate or out-of-date data;
- anonymisation, blocking or deletion of data that is unnecessary, excessive or processed unlawfully;
- portability of the data to another provider;
- deletion of data processed on the basis of your consent;
- information about who we share your data with;
- information about the option not to give consent and what happens if you do not;
- withdrawal of consent.
You may also object to processing carried out on the basis of legitimate interest, if you believe it does not comply with the law. And you may lodge a complaint with Brazilâs National Data Protection Authority (Autoridade Nacional de Proteção de Dados, ANPD).
How to exercise your rights
Write to clinicadr.martins@hotmail.com with the subject âPrivacyâ.
- Tell us which right you wish to exercise.
- To protect you, we may ask you to confirm your identity before providing or deleting data.
- The click record contains no name or phone number. To find a record of yours, you may need to give the approximate date of the visit or the code that appeared in the WhatsApp message.
The clinic replies within the time limits set by the LGPD. In simplified form, confirmation and access are immediate. In full form, the reply is sent within 15 days of the request.
Cookie and local storage table
The websiteâs own items
| Name | Purpose | Duration |
|---|---|---|
tc_consent | Stores your cookie choice (accept or refuse) | 180 days |
tc_attr | Stores where the visit came from (UTMs and landing page) while you browse | Until the tab is closed |
tc_landing | Stores the landing page of the visit | Until the tab is closed |
tc_lead_id | Stores the WhatsApp click code | Until the tab is closed |
tc_lp_sent | Prevents the same visit being recorded more than once | Until the tab is closed |
tc_attr_last | Stores where the last visit came from, to attribute a contact made later | 90 days |
tc_click_ids | Stores advert click identifiers (gclid, gbraid, wbraid, fbclid) | 90 days |
tc_attr_last and tc_click_ids are not saved when the browser is set to a European time zone and you have not yet accepted cookies.
Third-party items
The durations below are each supplierâs defaults and may change at their discretion.
| Name | From | Purpose | Default duration |
|---|---|---|---|
_ga | Google Analytics 4 | Distinguishes visitors | 2 years |
_ga_<ID> | Google Analytics 4 | Keeps the session state | 2 years |
_gcl_* (for example, _gcl_au, _gcl_aw) | Google Ads | Links visits and contacts to the advert click | 90 days |
_fbp | Meta | Identifies the browser to measure adverts | 90 days |
_fbc | Meta | Stores the advert click identifier (fbclid) | 90 days |
_clck | Microsoft Clarity | Identifies the visitor across sessions | 1 year |
_clsk | Microsoft Clarity | Groups the pages viewed in the same session | 1 day |
How to change your preferences
Use the âCookie preferencesâ button in the footer of every page.
- There you can accept or refuse measurement.
- You can change your mind as often as you like.
- Your new choice applies from that moment on.
You can also delete cookies and website data in your browser settings. If you do, the website will ask you again or apply your regionâs rule again.
Data Protection Officer (DPO)
Until a data protection officer is named here, requests about personal data can be sent to clinicadr.martins@hotmail.com.
Updates to this policy
This policy may change when the website, the tools or the law change. The date of the last update is shown at the top of this page. If the change is significant, we will let you know on the website itself.