SCUTUM

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

3. The SCUTUM application

What happensHow
Where documents, analyses, reports and records are keptIn an encrypted vault on the client's USB drive (AES-256-GCM; keys protected by a passphrase with Argon2id)
Internet connectionNone. The application blocks any network access and sends no telemetry
External AI servicesNot used. The AI models run on the computer itself
License verificationPerformed on the USB drive itself, with no contact with ROC Intelligence
Passphrases, recovery shares and keysKept 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

DataPurposeLegal basisRetention
Name, email, company and message sent by emailReplying and presenting proposalsPre-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 invoicesPerformance 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 FrameworkLegal 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:

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).