The purpose of this Policy is to demonstrate our commitment to safeguarding your privacy and protecting your Personal Data, establishing the rules on Processing, as well as explaining what your rights are and how to exercise them.

Please read this Policy carefully and, if you have any remaining questions, feel free to contact us through the Service Channels provided here.

BASIC CONCEPTS

For a better understanding of this Policy, the following definitions should be considered:

Algorithm: a set of rules that provide a sequence of operations capable of solving a specific problem or performing a task.

Personal DataPersonal data: data relating to a natural person which is capable of identifying them or making them identifiable. For example: name, e-mail address, ID number, personal preferences, IP address, geolocation.

Sensitive Personal DataSensitive Personal Data: is any data concerning racial or ethnic origin, religious conviction, political opinion, membership of a trade union or religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data, when linked to a natural person.

Data Protection Officer Data Protection Officer (DPO)person appointed by Datami to act as a communication channel between us, the Data Subjects and the National Data Protection Authority (ANPD).

Applicable legislationAll legislation that deals with privacy and protection of Personal Data, especially Law No. 13.709/2018 (General Law on Protection of Personal Data – LGPD).

Our environments: designates the e-mail address https://www.datami.com.br/ and its subdomains (“Site”), as well as the physical environments.

Policyis this Privacy and Personal Data Processing Policy.

Personal Data SubjectYou are the natural person to whom the Personal Data refer, whether as a user of the Site and/or a Datami customer.

ProcessingProcessing: any operation carried out with Personal Data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

ABOUT THE DATA WE PROCESS

How we process data. Data may be processed when you interact with Our Environments.

Updating and veracity of data. You are solely responsible for the accuracy, veracity or updating of the Data you provide to us. We are not obliged to process your Data if there is reason to believe that such Processing may cause us to infringe any applicable law, or if you are using our environments for any illegal or illicit purposes.

Database. The database formed through the collection of Data is our property and is under our responsibility, and its use, access and sharing, when necessary, will be made within the limits and purposes described in this Policy.

HOW WE SHARE DATA

Possibilities of sharing data. The Data processed and the activities recorded(logs) may be shared:

1. With competent judicial, administrative or governmental authorities, whenever there is a legal determination, request, requisition or order to that effect;
2. With the companies that make up the Economic Group to which Datami belongs, including its subsidiaries, always in compliance with the guidelines of this Policy;
3. With service providers or partner companies, to facilitate, provide or carry out activities related to Our Environments;
4. Automatically, in the event of corporate changes, such as a merger, acquisition or incorporation of Datami.

If you have any questions about who we share your Data with, please contact us through the Service Channels provided at the end of this Policy.

HOW WE PROTECT YOUR DATA AND HOW YOU CAN PROTECT IT TOO

Security and Governance Practices. To safeguard your privacy and protect your Data, we have a governance program that contains rules of good practice, internal policies and procedures, which establish conditions of organization, training, educational actions and mechanisms for supervision and mitigation of risks related to the Processing of Personal Data.

Data access, proportionality and relevance. Internally, the Data processed is only accessed by duly authorized professionals, respecting the principles of proportionality, necessity and relevance to our business objectives, in addition to the commitment to confidentiality and preservation of your privacy under the terms of this Policy. In the event of individual leaks or unauthorized access to your Personal Data, we may promote direct conciliation under the terms of art. 52, § 7, of the General Personal Data Protection Law, provided that these represent a relevant damage or risk to you and you agree.

External links. When you use Our Environments, you may be taken via a link to other websites, portals or platforms, which may collect your Data and have their own privacy policy. It is up to you to read these policies and it is your responsibility to accept or reject them. We are not responsible for the privacy policies of third parties or for the content of any sites or services linked to environments other than our own.

Processing by third parties under our directive. We carefully evaluate our partners and service providers and enter into contractual obligations with them regarding confidentiality, information security and data protection in order to protect you.

HOW WE STORE YOUR DATA AND ACTIVITY LOGS

Storage location. The Data processed and the activity records(logs) are stored in a secure and controlled environment, which may be on our servers located in Brazil, as well as in a resource use environment or cloud servers (cloud computing), which may require the transfer and/or processing of your Data outside Brazil. These transfers only involve companies that demonstrate compliance with the applicable legislation, maintaining a level of compliance similar to or stricter than that provided for in Brazilian legislation.

Storage period. We store Data only for as long as is necessary to fulfill the purposes for which it was processed or to comply with any legal or regulatory obligations or to preserve rights.

Data Disposal. At the end of the maintenance period and legal necessity, the Data will be deleted using secure disposal methods or used in an anonymized form for statistical purposes.

WHAT YOUR RIGHTS ARE AND HOW TO EXERCISE THEM

Your basic rights. The Data is yours and the applicable Legislation provides a series of rights related to it, which you can exercise by requesting our Data Controller through the Service Channel provided at the end of this Policy.

1. Confirmation and accessYou may request confirmation of the existence of Processing and access to your Data, including by requesting copies of records we hold on you.
2. CorrectionYou may request the correction of any incomplete, inaccurate or outdated data.
3. Anonymization, blocking or deletionYou may request the anonymization of your Data, so that it can no longer be linked to you, the blocking of your Data, temporarily suspending the possibility of Processing for certain purposes, or the deletion of your Data.
4. PortabilityYou may request that we provide your Data in a structured and interoperable format for transfer to a third party, while respecting our intellectual property or trade secrets.
5. Information on sharingYou may request information about third parties with whom we share your Data, limiting such disclosure to information that does not violate our intellectual property or trade secrets.
6. Withdrawal of consentYou may choose to withdraw your consent for any purpose to which you have consented. This withdrawal will not affect the lawfulness of any Processing previously carried out. If you withdraw your consent for purposes that are fundamental to the proper functioning of our environments and services, these may become unavailable to you.
7. ObjectionYou may object to the processing of your data if you do not agree with any of its purposes.
8. ReviewIn the case of decisions based exclusively on automated processing, you may request a review of the decision, indicating your interests that may have been affected.

Request. For your security, whenever you submit a request to exercise your rights, we may ask for additional information to prove your identity in order to prevent fraud.

Failure to fulfill requests. We may fail to comply with any request to exercise rights if compliance would infringe our intellectual property or trade secrets, or if there is a legal or regulatory obligation to retain Data. In addition, we may fail to comply with your request if we need to retain the Data to enable us to defend ourselves or third parties in disputes of any kind.

Responses to requests. We undertake to respond to all requests within a reasonable time and always in compliance with applicable legislation.

INFORMATION ABOUT THIS POLICY

Change of content and updating. You acknowledge our right to change the content of this Policy at any time, depending on the purpose or need. In the event of relevant updates to the Policy, you will be notified via the contact details you provide or by posting on our official profiles.

Inapplicability. If any point of this Policy is deemed inapplicable by a Data Authority or court, the other conditions will remain in full force and effect.

Service Channels. If you have any questions regarding the provisions of this Policy, including the exercise of your rights, you may contact our Officer, who is available at the following addresses:

In charge: Peck Advogados

Contact e-mail: dpo@cleartech.com.br

Request form: Contact our DPO – Datami

Applicable law. This Policy will be interpreted in accordance with Brazilian law, in the Portuguese language.

Update: May 23, 2024