LGPD structure overview
LGPD entered into force Sept 2020 (administrative sanctions from Aug 2021). Modeled on GDPR with Brazilian-specific elements: 10 lawful bases for processing (vs GDPR's 6), explicit consent for children + adolescents, mandatory data protection officer (DPO/encarregado) for certain processors, ANPD (Autoridade Nacional de Proteção de Dados) as the enforcement authority.
Encarregado (DPO) designation
Per LGPD Art 41, processors must designate an encarregado (DPO) for personal data protection. Koydo's appointed encarregado for Brazilian operations is identified at /trust-center; Brazilian controllers + data subjects can contact directly.
Children + adolescent specific rules
Per LGPD Art 14, processing personal data of children (under 12) requires specific, prominent consent of at least one parent or guardian. Adolescents (12-18) have additional protections. Koydo's verifiable parental consent flow + parent portal align with both COPPA + LGPD Art 14 requirements.
Brazilian-resident data subjects' rights
Per LGPD Art 18, Brazilian data subjects have rights to: confirmation, access, correction, anonymization/blocking/deletion of unnecessary or excessive data, portability, deletion of consented-data, information about shared parties, information about consent revocation, revocation of consent. Koydo's data subject request flow handles all 9 rights.
Brazilian breach notification
Per LGPD Art 48, the controller must notify the ANPD + the data subject in reasonable time of an incident that may cause relevant risk or damage. Koydo's commitment: notify Brazilian controllers within 48 hours of confirmed material breach so controllers have time to make their ANPD notification.
Cross-border transfer to/from Brazil
Per LGPD Art 33-36, international data transfers require: adequate country (limited list), consent, contract clauses, binding corporate rules, OR specific authorization. Koydo's Brazil → US transfer uses standard contractual clauses signed with US-based sub-processors. Brazilian controllers receive signed copies on request.
How Brazilian institutions engage
Brazilian schools (escolas particulares, federal/state public schools, universities) engage via the standard CONSED/FNDE procurement frameworks or institution-specific DPAs. Koydo provides Portuguese-language DPA + LGPD addendum on request. CEFR-aligned Portuguese cohorts available; CELPE-Bras prep specialists in the tutor pool.