This Privacy Policy describes how Fale Fale — Serviços de Psicologia e Psicanálise Ltda ("we," "our" or "the Company") collects, uses, stores and protects the personal data of clients, website visitors and all others whose data is processed in connection with our psychology and psychoanalysis services in Vinhedo, São Paulo.
As a registered limited company (Ltda) providing health-related services, we are committed to compliance with the LGPD (Lei nº 13.709/2018), the CFP Code of Professional Ethics (Resolução CFP nº 10/2005), CFP Resolution 11/2018 (telepsychology), the CDC (Lei nº 8.078/1990), and applicable tax legislation in São Paulo. All our psychologists and psychoanalysts are registered with the CRP-06 (Conselho Regional de Psicologia — SP).
Introduction and Scope
This Policy applies to personal data processed by Fale Fale — including prospective clients who contact us to enquire about services, active clients in psychological or psychoanalytic care, individuals who have completed their care with us, and website visitors. Given the sensitive nature of psychological services, we apply the highest standards of data protection — both under LGPD and under our professional ethical obligations.
Identity of the Controller
Entity type: Sociedade Limitada (Ltda)
CNPJ: 48.272.737/0001-90
Activity (CNAE): Atividades de Psicologia e Psicanálise
Professional registration: CRP-06 (São Paulo) — all psychologists individually registered
Address: Rua Francisco de Assis Freitas, 48, Caixa D'água, Vinhedo — SP, CEP 13282-114, Brasil
Email: privacidade@falefale.com.br
Personal Data We Collect
- Identification and contact data: Full name, phone, email and address — collected when a prospective or active client contacts us or schedules a session.
- Psychological session records (prontuário psicológico): Session notes, assessment results, clinical formulations and all records produced in the course of psychological or psychoanalytic care — maintained by the responsible psychologist in accordance with CFP Resolution 001/2009 on prontuário psicológico. These records are the property of the client and the responsible psychologist, and are governed by the CFP Code of Ethics.
- Assessment data: Psychological test results, assessment reports and related instruments where avaliação psicológica is commissioned — governed by CFP/SATEPSI requirements and the professional ethical framework.
- Health and wellbeing data: Information about mental and physical health, medications, family and personal history — shared by clients as part of their psychological care. This is sensitive data under LGPD Art. 5º, II and processed under the heightened protections of Art. 11.
- Telepsychology technical data: Platform connection logs for online sessions authorised under CFP Resolution 11/2018 — session metadata only, never session content.
- Billing data: Name and CPF or CNPJ for NFS-e issuance.
- Technical website data: IP address, browser type, pages visited and access times.
Purpose and Legal Basis
| Purpose | Legal Basis (LGPD) |
|---|---|
| Provision of psychological and psychoanalytic services | Performance of contract (Art. 7º, V); Consent for health data (Art. 11, I) |
| Maintenance of prontuário psicológico (CFP Res. 001/2009) | Legal obligation — CFP ethical framework (Art. 7º, II) |
| Psychological assessment (avaliação psicológica) | Performance of contract; Consent (Art. 11, I) |
| Telepsychology sessions (CFP Res. 11/2018) | Performance of contract; Consent |
| Issuing NFS-e; SEFAZ-SP tax compliance | Legal obligation (Art. 7º, II) |
| ISS — Prefeitura de Vinhedo | Legal obligation (Art. 7º, II) |
| Crisis intervention and mandatory reporting (when legally required) | Legal obligation; Protection of life (Art. 7º, II; Art. 11, II, "a") |
| Website analysis and improvement | Legitimate interest; Consent (cookies) |
Data Sharing
- SEFAZ-SP / Receita Federal: Tax data for NFS-e issuance and fiscal compliance only.
- Prefeitura de Vinhedo (ISS): For ISS/ISSQN obligations on psychological service activities.
- CFP / CRP-06: Where required by a professional ethics investigation or regulatory proceeding — and only as required by the applicable professional regulation.
- Mandatory reporting — imminent risk to life: Under CFP Code of Ethics Art. 10 and applicable Brazilian law, a psychologist may — and in certain circumstances must — break the sigilo where a client poses an imminent serious risk to their own life or to the life of another person. This is the most limited exception and is applied only in genuine emergencies, never as a matter of routine.
- Judicial order: When required by a competent judicial order compelling disclosure of information covered by sigilo — the minimum necessary information is disclosed, and the client is informed unless a court order prohibits it.
- PROCON-SP: When required in a consumer dispute — limited to non-clinical contractual information only.
International Transfers
Our psychological care is delivered in Vinhedo and via telepsychology across Brazil. Clinical records (prontuário psicológico) are stored in Brazil. Where telepsychology platforms involve international servers, we use only platforms that comply with Art. 33 of the LGPD and CFP Resolution 11/2018 requirements for secure and confidential digital communication in psychological services.
Retention Periods
- Prontuário psicológico (clinical records): Minimum 5 years from the last session, as required by CFP Resolution 001/2009. For minors, minimum 5 years after the client reaches the age of majority. Records may be retained longer where required for legal, ethical or clinical reasons. Clients have the right to request a copy of their own prontuário.
- Psychological assessment reports: As required by the commissioning purpose and applicable CFP guidance — typically 5 years minimum.
- NFS-e and fiscal records: Minimum 5 years under tax legislation (CTN, Art. 174; SEFAZ-SP).
- Contact and enquiry data (no care commenced): Up to 1 year from last contact.
- Website analytics: Aggregated and anonymised after 12 months.
Security Measures
- Prontuário psicológico records stored in secure, access-controlled systems — accessible only to the responsible psychologist and, where applicable, a supervising professional;
- Physical records (where used) stored in locked facilities accessible only to authorised professionals;
- Telepsychology sessions conducted via encrypted, LGPD and CFP-compliant platforms — session content is never recorded without explicit informed consent;
- Strict access controls — no clinical data accessible to administrative staff;
- Website and digital communications encrypted in transit (HTTPS/TLS);
- PCI-DSS certified payment platforms — card data never retained;
- 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 data and receive a copy — including a copy of your own prontuário psicológico, as provided for by CFP Resolution 001/2009.
- Correction (Art. 18, III): Request correction of inaccurate identification or contact data. Note that clinical records reflect the professional judgment of the psychologist and corrections are subject to professional ethical constraints.
- Anonymisation / Blocking / Deletion (Art. 18, IV): Request deletion — subject to the mandatory CFP retention period for prontuário psicológico (minimum 5 years after last session) and fiscal retention obligations for NFS-e.
- Portability (Art. 18, V): Receive your data, including a copy of your prontuário, in a structured format.
- Deletion of consent-based data (Art. 18, VI): Withdraw consent for consent-based processing — note that withdrawing consent does not affect the mandatory retention of clinical records under CFP rules.
- Information on sharing (Art. 18, VII): Find out whether your data has been shared and with whom.
- Withdrawal of Consent (Art. 8º, §5º): Withdraw consent at any time for consent-based processing.
- Complaint to the ANPD (Art. 18, §1º): Lodge a complaint at www.gov.br/anpd.
- Complaint to the CFP/CRP-06: Ethical complaints about a psychologist's conduct can be lodged with the CRP-06 (São Paulo) or CFP — independently of LGPD rights.
We respond within 15 business days.
Cookies and Tracking
Our website may use cookies for essential functionality and aggregated performance analysis. We do not use behavioural tracking or advertising cookies. We are mindful that people seeking psychological services may value additional discretion in their browsing — we do not use any tracking that could identify or profile visitors by their interest in mental health services.
Protection of Minors
Where psychological services are provided to minors (individuals under 18), we apply the heightened protections required by LGPD Art. 14 and the CFP Code of Ethics:
- Parental or guardian consent is required for the initiation of psychological services for minors under 16, in compliance with LGPD Art. 14 and applicable CFP guidance;
- The minor's own confidentiality rights are respected — information shared by the minor in sessions is protected by the sigilo profissional and is not automatically disclosed to parents or guardians, in accordance with the CFP Code of Ethics and the Statute of the Child and Adolescent (ECA);
- Clinical records for minors are retained for the minimum 5 years after the client reaches 18, per CFP Resolution 001/2009;
- We do not collect personal data from children under 12 via our website.
Sensitive Data — Health and Mental Health Data
All personal data processed in the context of psychological and psychoanalytic care is sensitive data under LGPD Art. 5º, II — specifically, data relating to health, including mental health. We apply the heightened protection of LGPD Art. 11 to all clinical data:
Mental health data is among the most sensitive categories of personal data. We apply strict access controls, minimum-data principles and the full weight of our professional ethical obligations to protect every client's health information.
Sigilo Profissional — Professional Secrecy
Questions about the sigilo profissional — as distinct from LGPD data protection questions — can be directed to our DPO or to the CRP-06.
Updates to this Policy
This Policy may be updated to reflect changes in our activities, the LGPD, ANPD guidance, CFP resolutions or applicable tax legislation. Material changes will be communicated to active clients by email or WhatsApp and via our website.
Contact & Data Protection Officer
All privacy requests, questions and complaints — including requests for your prontuário psicológico — should be directed to our Data Protection Officer (Encarregado — LGPD Art. 41):
Privacy Contact — Fale Fale Psicologia e Psicanálise Ltda
ANPD — Autoridade Nacional de Proteção de Dados · www.gov.br/anpd
Ethical complaints about professional conduct may be lodged with:
CRP-06 — Conselho Regional de Psicologia de São Paulo · www.crpsp.org.br