Privacy Policy — SCUTUM
Version 2.0 — effective October 2026
English translation. In case of any discrepancy, the Portuguese version prevails.
1. Who we are
CROCE INTELIGÊNCIA APLICADA LTDA (trade name ROC Intelligence), Brazilian taxpayer ID (CNPJ) 69.332.436/0001-84, headquartered at SAUS Quadra 04, Bloco A, Sala 411, Edifício Victory Office Tower, Asa Sul, Brasília/DF, Brazil, ZIP 70.070-938. We are the developer of SCUTUM.
2. In short
- •SCUTUM works without internet, on the client's computer, from a USB drive.
- •ROC Intelligence does not receive, access or store documents, analyses, reports or records processed in SCUTUM.
- •On the website, we process only the data needed to answer inquiries, sell licenses and keep the site secure.
3. The SCUTUM application
| What happens | How |
|---|---|
| Where documents, analyses, reports and records are kept | In an encrypted vault on the client's USB drive (AES-256-GCM; keys protected by a passphrase with Argon2id) |
| Internet connection | None. The application blocks any network access and sends no telemetry |
| External AI services | Not used. The AI models run on the computer itself |
| License verification | Performed on the USB drive itself, with no contact with ROC Intelligence |
| Passphrases, recovery shares and keys | Kept only by the client. ROC Intelligence does not store them and cannot recover the vault's contents |
Roles under Brazil's data protection law (LGPD). For personal data contained in the documents it processes in SCUTUM, the client is the controller. ROC Intelligence does not process that data and therefore does not act as a processor. The client is responsible for having a legal basis for processing (LGPD Arts. 7 and 11), responding to data subjects, and defining retention and deletion (Art. 16).
4. The website
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Name, email, company and message sent by email | Replying and presenting proposals | Pre-contractual steps (Art. 7, V) | Up to 12 months after the last contact |
| Purchase and billing data (when online sales are available) | Delivering the license and issuing invoices | Performance of contract and legal obligation (Art. 7, II and V) | For the period required by tax law |
| Access logs (IP address, date and time) | Security and compliance with Brazil's Internet Civil Framework | Legal obligation (Art. 15 of Law 12,965/2014) | 6 months |
The website does not use advertising or audience analytics cookies. Fonts and libraries are served by the website itself: no visitor data is sent to third parties to display the pages.
5. Sharing
We share data only with:
- •hosting and email providers, under contract and solely for those purposes. They may store data outside Brazil, with the safeguards of LGPD Art. 33;
- •authorities, when required by law or court order.
We do not sell personal data.
6. Your rights
You may request: confirmation of and access to your data, correction, anonymization, blocking or deletion, portability, information about sharing, withdrawal of consent, and objection (LGPD Art. 18).
How to request: contato@rocintelligence.com. We reply within 15 days. You may also file a complaint with Brazil's Data Protection Authority (ANPD).
7. Security and incidents
We adopt technical and administrative measures to protect website data. In the event of an incident that may cause relevant risk or harm, we will notify the ANPD and the affected data subjects under LGPD Art. 48 and ANPD Resolution CD/ANPD No. 15/2024.
8. Privacy contact
Requests, questions and complaints about personal data: contato@rocintelligence.com.
9. Audience
SCUTUM and the website are intended for professional use by persons aged 18 or older.
10. Changes
Relevant changes will be published here, with the new effective date.
Version 2.0 — October 2026. History: 1.0 (May 2026).