We, from Ativy Digital and other group companies, recognize the importance of privacy and protection of personal data and we want you to become familiar with the way we collect, store and treat your data.
Ativy Digital (“Company”, “we”, “us” or “our”) is committed to respecting your privacy and recognizing your need for adequate protection and management of any personally identifiable information (“Personal Data”) that you come to share with us.
The executed processing of personal data is subject to Brazilian legislation, in particular Law No. 13.709/2018 (“LGPD”) and fulfill the following principles: (a) limiting the use of personal data to what is extremely necessary for business purposes; (b) access to personal data only by essential persons and deletion of data when no longer processed; (c) extra care in handling sensitive personal data; (d) transparency with customers, partners and employees; (e) security of personal data; and (f) establishment of a personal data processing contract with third parties.
To make your understanding easier, we present some useful definitions for your interpretation:
Legal basis: These are the legal hypotheses that authorize us to Process Personal Data: it could be your consent, the need to fulfill a contract we have with you, or fulfillment of a legal obligation, for example.
Consent: It is the hypothesis that authorizes the Processing of Personal Data based on the free, informed and unambiguous expression of the Holder when agreeing to the processing of his Personal Data for a specific purpose, informed by us.
Cookies: These are small files that we transfer to your browser or device (such as mobile phone or tablet) that allow us to recognize your browser or device, and know how and when pages and Platforms are visited, as well as how many people access the Platforms. They can be useful, for example, for us to make the Platforms fit your screen, better understand your preferences and offer you more efficient Products, Businesses and Experiences.
Personal Data or Data: It is data relating to a natural person, which is able to identify the person or make their identification possible.
Examples of Personal Data that allow your identification are: Name, tax registration CPF, identity card RG, address, cell phone, e-mail etc.
Sensitive data: It is any information on racial or ethnic origin, religious conviction, political opinion, affiliation to a union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a natural person.
Officer: It is our Personal Data Protection Officer (Data Protection Officer), who acts as a communication channel between Ativy Digital, the Data Subjects and the National Data Protection Authority (ANPD), when it comes to the protection of your Personal Data.
Personal Data are yours and Brazilian law guarantees that you have a series of rights related to them. We are committed to fulfilling these rights and, in this section, we will explain how you can exercise them with Ativy Digital. Brazilian law guarantees you the following rights:
Confirmation and Access
It allows you to check whether Ativy Digital handles your personal data and, if so, request a copy of the personal data we hold about you.
Allows you to request correction of your incomplete, inaccurate or outdated Personal Data.
Anonymity, blocking or deleting
Allows you to ask us to: (a) anonymize your data so that it can no longer be related to you and therefore is no longer Personal Data; (b) block your Data, temporarily suspending your ability to process; and (c) delete your Data, in which case we will delete all your Data without the possibility of reversal, except as provided by law.
You have the right to request, upon express request, that Ativy Digital provide you, or any third party you choose, your Personal Data in a structured and interoperable format, for transfer to another supplier, provided that it does not violate intellectual property or confidentiality of the company’s business. Likewise, you can ask other companies to send Ativy Digital your Personal Data to facilitate the contracting of our Products and services, for example.
You have the right to know the public and private entities with which Ativy Digital makes shared use of data. If you have questions or want further details, you have the right to ask us for this information.
Information about the possibility of not consenting
It allows you to have clear and complete information about the possibility and consequences of not providing consent. Your consent, when necessary, must be free and informed. Therefore, whenever we ask for your consent, you are free to deny it – although in those cases we may have to limit our Products and services.
Revocation of consent
You have the right to withdraw your consent in relation to Treatment activities that are based on this Legal Basis. However, this will not affect the legality of any Treatment carried out previously. If you withdraw your consent, we may not be able to provide certain products and experiences, but we will notify you when this occurs.
The law authorizes the Processing of Personal Data even without your consent or a contract with us. In this case, it is necessary to demonstrate that there are legitimate reasons to Process your Data, such as, for example, to prevent fraud or to improve our communication with you. If you do not agree with this Treatment, you may object to it, requesting its interruption.
You can exercise your rights by accessing our Privacy Portal.
INFORMATION WE COLLECT
The Company treats your personal information to fulfill our contractual legal obligations and provide you with our products and services. We will never collect unnecessary personal data from you and we will not treat your information in any ways other than those specified in this policy.
Ativy Digital may collect the following types of personal data (i) provided directly by you, (ii) automatically collected about you and/or (iii) obtained from other sources:
- Data provided directly by you: These are information that you actively enter on the website, social networks, landpages and/or webinars such as full name, telephone number, email, information about the use of our products/services. Registers for job vacancies, information for applications for job vacancies offered by the company, records of your progress in the selection processes with the People and Culture area in which you participate.
- Data collected automatically: This is information automatically collected about you when using the website such as IP address (with date and time), type of device used to access the website, type of browser used, location of your device, identifier number of your device, click sequence, pages accessed and searches performed. In addition, we may store phone recordings between you and our team and/or any other data arising from your interaction with us via our contact channels and/or social networks.
We may also collect data that you provide in response to opinion and market surveys, or other types of surveys that you choose to participate in, organized and/or sponsored by/on behalf of Ativy Digital.
HOW WE USE YOUR DATA
We at Ativy Digital place great value on your privacy. Therefore, all data and information about you are treated as confidential, and we will only use this information for the purposes described herein and authorized by you so that you can fully use the services of Ativy Digital, always aiming to improve your experience as a customer.
If you have consented to receive our promotional and marketing offers, you may withdraw this consent at any time. The purposes and reasons for the processing of your personal data are detailed below:
Provide our products, including updating, security and troubleshooting, as well as providing support. This also includes sharing data, when it is necessary, to provide the service or carry out the transactions you request.
Allow access to features and functionality of the Ativy environment.
Communication: The personal data collected will also be used to enable us to send you important notices and notifications relating to you, such as changes to this Policy. In addition, personal data will still be used to respond to any interactions you have with us.
Product marketing, new events and market research: The personal data collected may be used to send you advertising and promotional materials, product information and new product launches, and/or to invite you to participate in market research. Furthermore, personal data may be used to better understand your tastes and interests and thus send you more relevant information. We may need your consent for some of these activities and so your consent will be requested in due course. Without prejudice, we offer several ways for you to unsubscribe from our communications of this nature by email at any time, by selecting the unsubscribe link at the end of electronic communications, and/or informing the person responsible for any telephone contact, for example.
DELETION OF DATA
All data collected will be deleted from our servers when you so request, by a free and facilitated procedure, or when these are no longer necessary or relevant for us to offer you our services, unless there is any other reason for their maintenance, as a possible obligation retention of data or the need to preserve them to protect Ativy Digital’s rights.
SHARING YOUR DATA
Ativy Digital will only share your personal data with those who have a legitimate need. We do not share or disclose any of your personal data without your consent, except for the purposes specified in this policy or where there is a legal requirement. Operators acting on our behalf only handle your data in accordance with our instructions and fully comply with this policy, as well as data protection legislation and any other appropriate confidentiality and security measures.
Our suppliers and partners: We rely on the help of providers who can Process Personal Data we collect. We always seek to carefully evaluate our suppliers and sign contractual obligations with them for information security and protection of Personal Data, in order to minimize risks for the Data Subject. Among these suppliers are, for example, companies operating in the following fields: (i) Data hosting and activities; (ii) owner and property security, such as image monitoring; (iii) Advertising, marketing, digital and social media data and tools; (iv) service to the data subject and conducting research (v) operation and feasibility of certain Products, Businesses and Experiences for you; and (vi) advisory and audit reviews.
Therefore, your personal data may be shared with our parent company, subsidiary companies, affiliates and third parties, such as service providers and partners, for legitimate purposes as follows:
- To conduct the above-described personal data processing activities, including the storage of collected personal data;
- As part of corporate due diligence and/or due diligence relating to the merger, acquisition, change of the company, we may disclose your personal data to the potential buyer, new service provider and respective advisors, as necessary and appropriate for the achievement of the aforementioned purpose;
- In the case of corporate transactions, such as restructuring, merger or sale of assets, your personal data may be transferred, provided that the terms of this Policy are respected. The same may occur in cases of judicial recovery or bankruptcy; and/or
- With your consent legally obtained, this is given voluntarily and without you suffering any adverse consequences of your decision to deny or revoke your consent.
INTERNATIONAL TRANSFER OF PERSONAL DATA
We use some products or services (or parts of them) that are hosted in the United States and Mexico, which means that we may transfer any information sent to us by you outside the Brazilian territory for purposes of achieving the purposes described herein. We may also subcontract the processing or share your personal data with third parties located in other countries.
When we transfer your personal data to a country other than Brazil, we will ensure that such transfer complies with applicable laws, in particular the LGPD and is conducted in a way that preserves your personal data. Thus, we will only carry out the international transfer of your data, in the absence of a decision on the adequacy of the National Data Protection Authority (“ANPD”) and the safeguards provided for in item II of article 33 of the LGPD, in the event that it is necessary and as more appropriate given one of the following hypotheses: (i) the national authority authorizes the transfer; (ii) upon your authorization; (iii) to comply with a legal or regulatory obligation to which we are subject; (iv) to properly perform the contract entered into with you; or (v) for the regular exercise of rights.
PERSONAL DATA SECURITY
Ativy Digital is committed to protecting the security of your personal data. We use a wide range of security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. For example, we store the personal data that you provide on servers with limited access that are located in controlled facilities, and when we transmit certain personal information with a greater degree of sensitivity, we protect it through the use of encryption.
We maintain the security of your information by applying administrative, technical and physical measures to protect personal data against loss, theft, misuse, as well as against unauthorized access, disclosure, alteration and destruction, we adopt specific policies and procedures for employees and/or third parties who have contact with the personal data listed here. We are committed and will do our part in protecting the data provided, we emphasize that security is a shared responsibility.
Safety and compliance are shared responsibilities between ATIVY DIGITAL and the client. When the customer transfers their data and computing systems to the cloud, privacy and security responsibilities are shared between the customer and the cloud service provider. When customers move to ATIVY Cloud, ATIVY DIGITAL is responsible for protecting the underlying infrastructure that supports the cloud, and customers are responsible for everything they put in the cloud or connect to the cloud.
HOW LONG WILL THE DATA BE STORED
We will retain your personal data only for as long as necessary to fulfill the purposes for which we collect it, including for the purpose of complying with any legal, contractual, accountability obligations or requests from competent authorities.
HOW TO TALK TO ATIVY DIGITAL
If you have any questions about the collection and processing of your personal data, you can contact us via email email@example.com.
Exercise your rights through the Privacy Portal:
Address: Av. Pierre Simon de Laplace, 740 – Techno Park, Campinas – SP.
Last update: February, 12th 2021.