Release date: January 2024
Version: 1.0
We, at Digiteam, are committed to the privacy and protection of your personal data and, therefore, we present our Privacy Notice (Notice), in accordance with the General Personal Data Protection Law (LGPD).
Through this Notice, we tell you how we collect, use, process and disclose your personal information and data, in conjunction with your access to and use of the Platform.
Before accessing and using the features of the Platform, we ask that you read and understand this Notice.
We are available to answer your questions, receive feedback or complaints through the following e-mail: privacidade@digiteam.com.br.
WHAT INFORMATION YOU WILL FIND IN THIS NOTICE
1. IMPORTANT CONCEPTS FOR THIS NOTICE
2. TO WHOM DOES THIS NOTICE APPLY?
3. WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA?
4. HOW DO WE PROCESS YOUR PERSONAL DATA?
4.1. Data collected for registration
4.2. Data collected from the Field Agent
4.3. Data collected indirectly
4.5. Veracity of data
5. HOW WE SHARE YOUR DATA
5.1. International Data Transfer
6. LINKING TO THIRD-PARTY WEBSITES/PLATFORMS
7. HOW WE PROTECT YOUR DATA
8. KNOW YOUR RIGHTS AND HOW TO EXERCISE THEM
9. HOW LONG DO WE STORE YOUR DATA?
10. MISCELLANEOUS
11. DATA CONTROLLER
1. IMPORTANT CONCEPTS FOR THIS NOTICE
Below are some concepts to help you understand this Notice.
Field Agent. Individual, employee of the Company, which is managed through the Platform's integrated mobile application.
Anonymization. Process by which the personal data collected becomes files stored by the Controller in which it is impossible to identify to whom such data belongs.
ANPD. National Data Protection Authority, a public administration body responsible for ensuring, implementing and supervising compliance with the LGPD throughout the national territory.
Controller. The person responsible for decisions regarding data processing.
Personal data. Information that identifies a natural person, such as: e-mail, CPF, telephone number and address.
Sensitive Personal Data. Personal data on racial or ethnic origin, religious belief, opinion, membership of a trade union or organization of a religious, philosophical or political nature, data relating to health or sex life, genetic or biometric data.
Demands. Services distributed and monitored by the Platform for Field Agents.
Enterprise. Legal entity that hires the Digiteam Platform for the management of its external teams.
IP. The IP address is the code assigned to a terminal in a network to allow its identification, defined according to international parameters.
LGPD. General Personal Data Protection Law, Law No. 13,709/2018, which governs data processing and protection.
Operator. Who carries out the data processing according to the Controller's guidelines.
Data Processing. Any operation carried out with personal data, such as those related to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
Platform, 'Digiteam' or 'Digiteam Platform'. Software as a Service that is licensed, by contract, for the use of the Company.
Users. Those who represent the Company, referred to as 'Administrators' of the Platform.
Software as a Service (SaaS). Modality of distribution and commercialization of software.
2. WHO DOES THIS NOTICE APPLY TO?
Below, we describe who is subject to the rules of this Notice.
This Privacy Notice (Notice) applies to Users who access, administer and manage the functionalities of the Platform.
3. WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA?
DIGITEAM TECHNOLOGY LTD. (DIGITEAM), registered with the CNPJ under No. 07.821.585/0001-50, headquartered at St Bancario Sul Quadra 02 Bloco E, number 12, Complement Salas 402 à 406, Asa Sul, Brasília - DF, Cep: 70.070-12, owner of this Platform, assumes the role of Controller of personal data only in relation to the personal data of the Company's representatives, necessary for the contractual relationship and provision of services.
Digiteam is the Operator of the processing in relation to the data of third parties, inserted in the Platform by its Administrators. In this sense, the processing will be carried out based on the decisions of the Company, the Data Controller of its respective employees, suppliers and/or service providers who use the Platform.
4. HOW DO WE PROCESS YOUR PERSONAL DATA?
Below, we describe how we process your data, detailing the purposes and legal bases that justify this processing.
- Data collected for registration
For the registration of Users on the Platform, the name, e-mail and CPF (optional) will be collected.
- Data collected indirectly
Digiteam may collect data indirectly during the User's browsing, such as IP address, session, timestamps of actions, device/browser, activities on the Platform.
In addition, access logs are collected, a set of information referring to the date and time of use of a certain internet application from a certain IP address, under the terms of Law No. 12,965/2014 (Civil Rights Framework for the Internet), and article 7, II, of Law No. 13,709/2018.
3. Purposes and legal bases of the processing of personal data
The personal data processed by Digiteam will only be used for the following purposes:
| Data Collected | Purpose of the processing of your data | Legal basis |
|
For registration and identification of the Administrator User on the Platform.
|
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| IP address, User's session, timestamps of actions, device/browser, User's activities on the website. | Collect information to identify and protect Users, as well as comply with legal obligations. |
|
4. Veracity of data
The User is responsible for the veracity or inaccuracy of this in relation to his/her personal data and the personal data of his/her dependents.
Digiteam is not obliged to process or treat any data provided by the User if there are reasons to believe that the processing may cause a violation of any applicable law or that the User is using the Platform for illegal, illicit purposes or contrary to the Notice.
5. HOW WE SHARE YOUR DATA
Digiteam only shares the data necessary for the provision of the services offered by the Platform.
In this sense, Digiteam may share data with contracted companies so that the functionalities are available, which may process personal data as Processing Operators.
Thus, they may have access to the personal data of Users:
- Comtele, for sending online SMS;
- Zendesk, for internal organization;
- AWS, for cloud storage;
- Azure, for single sign-on protection and cloud storage
In addition to the companies mentioned above, Digiteam may share personal data, such as legal advice, employees, specific service providers, in order to enable the proper performance of the Services.
Digiteam's contracts value the secure treatment of the User's information.
In addition, from the moment these third parties have access to the shared data, they will be responsible for the processing and security of this data, and may not carry out its processing for any other purpose, as well as in compliance with the applicable Law and under the terms of this Notice.
1.Business Sharing with Digiteam
Companies may share personal data of their customers and employees with Digiteam. In this case, Digiteam acts as the Data Operator, while the Company will be the controller, therefore, it must define the purpose and legal basis for the processing of this data.
Thus, the responsibility for making essential decisions about the processing of data and compliance with the rights of the holders (employees and customers) is the duty of the Company, since it provides the data to Digiteam.
2. International Data Transfer
Digiteam may, to the extent permitted by the LGPD, share the data outside of Brazil.
This international transfer occurs when we use cloud services for data processing or storage, so that we can perform our services in the best way, in a secure environment.
In doing so, Digiteam will take all reasonable measures to ensure that your data is treated and shared securely and in compliance with current legislation and this Privacy Notice.
6. LINKING TO THIRD-PARTY WEBSITES/PLATFORMS
The Platform may, from time to time, contain links to third-party websites/platforms, such as partners, advertisers and affiliates. When following a link, it is important to note that these websites/platforms have their own privacy notices and policies and that Digiteam is not responsible for these documents.
Digiteam recommends that you review these notices and policies before submitting any personal data to these sites.
7. HOW WE PROTECT YOUR DATA
Digiteam is committed to the security of all its Users and, therefore, adopts physical, electronic and administrative procedures that guarantee the privacy and security of your data, with technical measures compatible with international standards and the use of good practices, according to the measures suggested by the National Data Protection Authority (ANPD).
To ensure that the data is stored in a secure environment, Amazon Web Services (AWS) servers are used, which implies an international transfer of personal data to the host country of this server, in the United States of America.
Whenever possible, your data will be treated anonymously, i.e. it will not be possible to identify them in the set of data we are processing.
All technologies used and employed by Digiteam will always comply with current legislation and the terms of this Privacy Notice.
8. KNOW YOUR RIGHTS AND HOW TO EXERCISE THEM
Access and confirmation of treatment. You may request Digiteam to access the complete list of data collected and processed, as well as to confirm the processing of your personal data.
Correction of personal data. You may request Digiteam to correct data that is incomplete, inaccurate, or outdated.
Anonymization, blocking, or deletion. All data collected and processed by Digiteam is for the purpose of providing services and the good performance of the Platform.
If you believe that any of your data is being processed unnecessarily, excessively, or the processing is not in compliance with the LGPD, you may request anonymization, blocking, or deletion, if you prove that there was excess, unnecessity, or non-compliance with the LGPD.
Information About Sharing. You can ask Digiteam for information about our partners and vendors with whom we share the data.
We have already verified and all our partners are also concerned about your security, and take appropriate measures to protect your data.
Automated decision-making. You may request the review of decisions made solely on the basis of automated data processing and the criteria used in these decisions, always observing Digiteam's commercial and industrial secrets.
Data portability. You may request the portability of your personal data to another provider of the services provided by Digiteam, in compliance with the provisions of the LGPD.
To exercise any of your rights as a Data Subject, please contact Digiteam through the e-mail privacidade@digiteam.com.br.
9. HOW LONG DO WE STORE YOUR DATA?
The data provided by the User on the Platform will be stored and processed for a retention period of up to 2 (two) years from the end of the contract, according to Digiteam's Security Management Plan.
If the User wishes, he/she may request the deletion of his/her account and his/her personal data, through the e-mail suporte@digiteam.com.br.
In the event of a request for deletion or termination of the processing purpose, the User will have all his/her data permanently deleted, except for data whose maintenance is mandatory by law or regulation, or necessary for the regular exercise of rights in judicial, administrative or arbitration proceedings.
10. GENERAL PROVISIONS
Digiteam informs that, at any time, unilaterally, it may modify/update this Notice. If this happens, the User will be notified and the updated version will be valid from the date of its publication.
The User's continued access or use, after the update is disclosed, will confirm the validity of the new Privacy Notice by the Users.
In addition to this Privacy Notice, Digiteam has its Terms and Conditions of Use, which define the conditions of use that will govern the use of the Platform. These terms form an inseparable form of this Privacy Notice.
11. DATA OFFICER
Digiteam has a person in charge of the processing of personal data, under the terms of article 41 of the LGPD, who is responsible for accepting complaints and communications from data subjects and the National Data Protection Authority, providing clarifications and adopting measures.
If you have any questions, complaints, or concerns about any matter in this Notice, please contact our officer:
Bárbara Barbosa
Responsible for the processing of Digiteam's personal data
We are also available to answer your questions, receive feedback or complaints through the following e-mail: privacidade@digiteam.com.br
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