Privacy policy - Pontaltech

We take care of your data

It has always been our characteristic to work with transparency and responsibility, including the use of data we receive. We reaffirm our commitment to protect and protect everyone’s data and privacy, supported by the rules and regulations established by the laws in force.

Privacy Policy

Welcome to Pontaltech!

We consider it extremely important the privacy of our visitors and the security of their personal information, if you have any questions, do not hesitate to contact us by lgpd@pontaltech.com.br. Through this Privacy Policy we aim to offer greater transparency and security with respect to all processing of personal data performed by Pontaltech, thus indicating how PONTALTECH performs the collection and processing of information obtained from the user and how we use this information on all our digital platforms.
1 – DEFINITIONS
Whenever there is mention of the terms “Pontaltech”, “we” or “our” we will be referring to Pontaltech; as well as whenever there is mention of the terms “you”, “user”, “your”, “your”, we will be referring to you user, who is consenting to this Privacy Policy and the Terms of Use to make use of and access to the Platform.

2 – SCOPE
This Privacy Policy applies to all forms of processing of personal data performed by Pontaltech, related to its business activities, including data collected and processed through its website.

In case of disagreement in whole or in part with this document, it is recommended not to use the website or to fill in any personal data requested for this purpose.

3 – PRIVACY POLICY OBJECTIVES
This Privacy Policy (“Policy”) aims to establish the guidelines for the collection and other processing of personal data, as well as to provide essential information to data subjects, in a clear and comprehensive manner, with respect to the personal data processed, their legal bases, processing purposes, types of personal data processed, basic rights of holders, appropriate security measures taken with regard to the protection of privacy and personal data, having as reference in particular the General Law for the Protection of Personal Data (Law No. 13,709/2018 – “LGPD”) and the Internet Civil Framework (Law No. 12,965/2014).

This Privacy Policy has the following purposes:
✓ Ensure that you understand what personal data we collect;
✓ Indicate the purposes for which we collect and use your personal data;
✓ Inform with whom we share personal data;
✓ Explain how we use shared personal data;
✓ Clarify what are the rights of the holders in relation to their personal data collected and processed by Pontaltech;
✓ Provide access to a communication channel for questions, information, complaints or, furthermore, for the exercise of rights related to personal data or this Policy;
✓ Inform the mechanisms to guarantee the inviolability to privacy and the appropriate protection of personal data.

4 – ANALYTICS
Like many other sites, Pontaltech uses log files that record visitors to the Platform, this being a standard procedure for hosting companies and part of service analysis. The information contained in the log files includes: Internet protocol (IP) addresses, browser type, ISP (Internet Service Provider), timestamp, reference/output pages, and in some cases the number of clicks. This information is used to analyze trends, administer the Platform, track a user’s movement through the Platform, and collect demographic information. IP addresses and other information are not linked to any personally identifiable information.

You may have more information about this in our cookie policy, available on our website.

5 – COLLECTED INFORMATION
The information collected depends largely on the interaction that occurs between you and Pontaltech, most of which can be categorized according to the following:

a)   Using Pontaltech platforms as a Service: When you use Pontaltech platforms, we store all content you enter, including but not including, but not including, but not sure, accounts created for team customers, files, photos, project information, and any other information you provide to the services you use.

b)   For any Pontaltech software: with the Platform, we also collect data about the use of the software, this may include, among others, user numbers, streams, transmissions, etc.

5.1   Types of personal information: (i) Users: identification, social media profile information available to the public, email, IT information (IP addresses, usage data, cookie data, browser data); financial information (credit card details, account details, payment information). (ii) customers: identification and social media profile information available to the public (name, date of birth, gender, geographic location), chat history, browsing data (including chatbot usage information), application integration data and other electronic data sent, stored, sent or received by end users and other personal information, the extent of which is determined and controlled by customer in its sole discretion.

5.2   Data collected to and from our users: By using our services, you may import into our system personal information that you have collected from your customers or others. We have no direct relationship with your customers or anyone other than you, and for this reason you are responsible for ensuring appropriate permission to collect and process information about such individuals. As part of our services, we may use and incorporate into the resources the information you have provided, that we collect from you or your customers.

5.3   Automatically collected information: Our servers may automatically record certain information about how you use our Platform, including customers and occasional visitors. Logs may include information such as the IP address, device and type of browser, operating system, pages or features of our Platform on which the user navigated and the time spent on those pages or resources, how often the Platform is used by a user, search terms, links on our Platform on which a user has clicked or used and other statistics. We use this information to administer the Platform and analyze (and may involve third parties to analyze it) to improve and improve the Platform, expanding its features and functionality and adapting it to the needs and preferences of our users.

5.4   Sensitive personal information: Subject to the following paragraph, we ask that you do not send us or disclose sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, sexual life, biometric or genetic characteristics, and even union membership through the Platform.

5.5   If you submit or disclose any sensitive personal information to us (such as when you submit user-generated content to the Platform), you must agree to the processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to the processing and use of such sensitive personal information, you must not provide it. You may use your data protection rights under the General Data Protection Act (Law 13.709/2018 -LGPD), to challenge or restrict the processing of this sensitive personal information or to delete such information, as detailed below in the title “Your Data Protection Rights and Options”.


6 – PURPOSE OF DATA COLLECTION
For service operations (i) operate, maintain, administer and improve the Platform; (ii) manage and communicate with you regarding your service account if you have one, including sending service announcements, technical notices, updates, security alerts, and administrative and support messages; (iii) process payments you make through the Platform; (iv) to better understand your needs and interests and personalize your experience with the Platform; (v) send product information by email (vi) to respond to your requests, questions and comments related to the Platform.

6.1   To communicate with you: If you request information, register on the Platform or participate in our surveys, promotions or events, we may send you marketing communications related to Pontaltech in the form of the law, but we will provide you with the choice to opt out.

6.2   Law enforcement: We use your personal information as we deem necessary or appropriate to comply with applicable laws, legal requests, and legal processes, such as to respond to subpoenas or requests from government authorities.

6.3   With your consent we may use or share your personal information, for example, when you agree to let us post your testimonials or endorsements on our Platform, you instruct us to take specific action in relation to your personal information or you opt for third-party marketing communications.

6.3.1   We may create anonymous data from your personal information and other individuals whose personal information we collect. We turn personal information into anonymous data, excluding information that personally identifies you, and use that anonymous data for our legal business purposes. For compliance, prevention and fraud security. We use your personal information as we deem necessary or appropriate to (a) enforce the terms and conditions governing the Platform; (b) protect our rights, privacy, security or property and/or yours or those of third parties; and (c) protect, investigate and prevent against fraudulent, harmful, unauthorized, unethical or illegal activities. To provide, support and improve the services we offer we use data that our customers provide to us to enable them to use the services and communicate with their customers, this also includes, for example, aggregating information from the use of the services or visiting our websites and sharing that information with third parties to improve our services. This may also include sharing your information or the information you provide about your customers with third parties in order to provide and support our services or make certain features of the services available. When we have to share personal information with third parties, we take steps to protect your information by requiring those third parties to enter into a contract with us that requires them to use the personal information we transfer to them in a manner consistent with this Privacy Policy, necessary to comply with the General Data Protection Act (Law 13.709/2018 – LGPD).

7 – HOW WE SHARE YOUR PERSONAL INFORMATION
We do not share or sell personal information that is provided by you to other organizations without your express consent, in accordance with the provision of this Privacy Policy and the provision of the LGPD (Law 13.709/2018).

We disclose personal information to third parties in the following circumstances:

7.1   Service providers. We may employ third-party companies and individuals to administer and provide the Platform on our behalf (such as account and credit card payment processing, customer support, hosting, email delivery, and database management services). These third parties are permitted to use your personal information only to perform these tasks in a manner consistent with this Privacy Policy and are required not to disclose or use it for any other purpose.

7.2   Professional advisors. We may disclose your personal information to professional consultants, such as lawyers, bankers, auditors and insurance companies, when necessary in the course of the professional services they provide to us and indispensable to the development of Pontaltech’s activities.

7.3   Business transfers. As we develop our business, we can sell or buy businessor assets. In the case of corporate sale, merger, reorganization, dissolution or similar event, personal information may be part of the transferred assets. You acknowledge and agree that any successor or acquirer of Pontaltech (or its assets) will continue to have the right to use your personal information and other information in accordance with the terms of this Privacy Policy and Law 13.709/2018. In addition, Pontaltech may also disclose aggregated personal information to describe our services to potential acquirers or business partners.

7.4   Compliance with laws and law enforcement; Protection and security. Pontaltech may disclose information about you to government or law enforcement authorities, or private parties as required by law, and disclose and use the information we deem necessary or appropriate to comply with applicable laws, requests and legal processes, such as: responding to subpoenas or requests from government authorities; (b) enforce the terms and conditions governing the Platform; (d) protect our rights, privacy, security or property and/or yours or those of third parties; and (e) protect, investigate and prevent against fraudulent, harmful, unauthorized, unethical or illegal activities.

8 – YOUR RIGHTS AND DATA PROTECTION CHOICES
According to the General Data Protection Act (LGPD), you have the following rights:

✓ If you wish to access your personal information that Pontaltech collects, you may do so at any time by contacting us using the contact details provided in the “How to contact us” header below.
✓ Holders of a Pontaltech account may review, update, correct or delete personal information in their registration profile by logging into their account. Holders of a Pontaltech account may also contact us to perform the above or if you have additional requests or questions.

We respond to all requests we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. Access to data controlled by our customers. Pontaltech has no direct relationship with individuals whose personal information is contained in the custom user fields processed by our Platform. An individual seeking to access, or seek to correct, change or delete personal information provided by our users must forward their request directly to the bot owner.

9 – INFORMATION RETENTION
We will retain the personal information we process on behalf of our users for as long as necessary to provide our services or indefinitely to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our agreements. If required by law, we will delete personal information by deleting it from our database.

10 – DATA TRANSFERS
Your personal information may be stored and processed in any country in which we have facilities or in which we hire service providers. By accepting the terms of this Privacy Policy, you acknowledge and agree to the transfer and processing of personal information on servers located outside the country in which you reside.

We reserve the right to access, read, preserve and disclose any information we believe is necessary to comply with or enforce the law or court order to the extent required by applicable laws and regulations, this Privacy Policy and any other agreements or terms with which users have agreed, as well as to protect the rights, property or security of the Platform, and its respective employees, service providers, users, customers and others.

11 – COOKIES
Pontaltech with its partners may use various technologies to collect and store information when you use our services, and this may include the use of cookies and similar tracking technologies on our Platform, such as pixels and web beacons, to analyze trends, administer the Platform, track user movements on the Platform, post targeted ads, and collect demographic information about our user base as a whole. Users can control the use of cookies at the individual browser level.

For more information on Pontaltech’s use of cookies, please visit our Cookie Policy on our website.

12 – SECURITY
12.1   Security breach warning
If a security breach causes an unauthorized intrusion into our system that materially affects you or your customers, Pontaltech will notify you as soon as possible and subsequently report the action we take in response to the Incident Response Plan.

12.2   Protecting your information
We take reasonable and appropriate steps to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and nature of the Personal Information.

We remind you that the security of your data does not depend solely on us, so you should also always be attentive to our guidelines:
•   It is important that you protect your information from unauthorized access to your computer or mobile device (mobile phones, tablets, etc.), accounts, and passwords. If there is use of password, it must always be personal and non-transferable, that is, it should not be shared with third parties, not even family members;
•   Keep your passwords secure and never share them with third parties;
•   Do not use your name, date of birth, common words, sequential numbers (e.g. 12345) or easily verifiable information about you in your passwords. Also avoid very short passwords;
•   Avoid using the same password for your important accounts or other Platforms;
•   Always keep your computer’s antivirus program up to date. If you do not have an antivirus, we recommend that you install one as soon as possible;
•   Shared computers are not always trusted. Whenever you access a website on a shared computer, make sure that you have ended your browsing when you finish accessing the site. The exit option varies from site to site and may be available on pages such as “Logout”, “Log out”, “Sign out”, etc.
•   Never allow your browser to automatically save your password on shared devices. Even on private devices, we do not recommend allowing the browser to remember your password;
•   Always keep your web browser up to date as directed by the manufacturer. The upgrade process varies by browser;
•   When accessing the internet in public places, be careful that people close to you cannot see what you are doing, your password and your personal data;
•   Make sure you are using a secure connection. Internet browsers generally display a padlock next to the site address at the top of the window (SSL technology) to illustrate that you are in a secure environment. You can click the padlock and get more information about the certificate and the website itself before proceeding. Although the default is the display of a padlock next to the website address, each internet browser has distinct functionality and can operate in different ways. If you have questions about this feature, we suggest that you refer to the user manual of your internet browser.

13 – ONLINE PRIVACY POLICY
This Privacy Policy applies only to our online activities and is valid for visitors to our Platform and in relation to information shared and/or collected on the Platform. This Privacy Policy does not apply to any information collected offline or through channels other than this site.

14 – LEGAL BASES FOR PROCESSING PERSONAL DATA
By using our Platform, you are aware of our Privacy Policy and their respective terms. In some cases, we may also have a legal obligation to collect personal information from you. If we ask you to provide personal information to comply with a legal requirement or enter into a contract with you, deixaremos isso claro e o informaremos se o fornecimento de suas informações pessoais é obrigatório ou não (assim como das possíveis consequências se você não fornecer suas informações pessoais), de acordo com os incisos II e VI, do artigo 7º, da LGPD.

Similarly, if we collect and use your personal information based on our legitimate business interests, we will clarify to you what these legitimate business interests are, in accordance with the consent provided, pursuant to Articles 7, items I and IX, and 8th LGPD.

If you have questions or need more information about the legal basis on which we collect and use your personal information, please contact us using the contact details provided in the “How to contact us” header below.

15 – ACHANGES TO OUR PRIVACY POLICY
Changes to this Privacy Policy will be made when necessary in response to legal or technical changes, or for commercial developments. When we update our Privacy Policy, we will take appropriate steps to inform you, in accordance with the meaning of the changes we make.

Pontaltech will request your consent to any relevant changes to the Privacy Policy, in accordance with the requirements of the General Data Protection Law (Law 13.709/2018 -LGPD) and other applicable laws.

For your convenience, the date of the last update of this Policy is at the end of the date of the last update.

We recommend that every time you access the Platform, be aware of new updates as the new Privacy Policy will apply to all current and past users of the Platform and will replace any previous notices that are inconsistent with it.

16 – HOW TO CONTACT US
If you need more information or have any questions about our privacy policy, please contact us at lgpd@pontaltech.com.br with the subject “Privacy Policy Questions”.

Last update: April 23º 2021.