Privacy Policy

Privacy Policy – DIGITAL STRATEGY TECNOLOGIA DA INFORMAÇÃO LTDA

PREAMBLE

DIGITAL STRATEGY TECNOLOGIA DA INFORMAÇÃO LTDA, legal entity governed by private law, registered with the CNPJ under No. 26.208.565/0001-52, headquartered at Rua da Guia, No. 217, Recife neighborhood, CEP 50.030-210, Recife/PE, takes its privacy seriously and takes care of the security and data protection of all its customers, partners, suppliers and users of the domain https://tds.company website and any other website or application operated by the company.

This Privacy Policy is intended to inform you about how we use and disclose information collected from your visits to our website and in messages we exchange with you.

This Privacy Policy applies only to information collected through the website.

BY ACCESSING THE SITE, SENDING COMMUNICATIONS OR PROVIDING ANY KIND OF PERSONAL DATA, YOU ACKNOWLEDGE THAT YOU ARE AWARE OF THE TERMS PROVIDED HEREIN AND IN ACCORDANCE WITH THE PRIVACY POLICY, WHICH DESCRIBES THE PURPOSES AND WAYS OF PROCESSING YOUR PERSONAL DATA IN THE WEBSITE.

This Privacy Policy provides an overview of our privacy practices and the choices you can make, as well as the rights you can exercise in relation to Personal Data handled by us. If you have any questions about the use of Personal Data, please contact our data manager at support@strateegia.digital.

The identification of the Data Controller is inserted in the preamble of this instrument.

In addition, the Privacy Policy does not apply to any third-party applications, products, services, website or social media resources that may be offered or accessed through the website. Accessing these links will cause you to leave our site and may result in third parties collecting or sharing information about you. We do not control, endorse or are responsible for acts or facts that occur on third-party websites or their privacy practices, which may differ from ours. We recommend that you review the privacy policy of any website you interact with before allowing the collection and use of your Personal Data.

If you send us Personal Data relating to other individuals, you are responsible to DIGITAL STRATEGY TECNOLOGIA DA INFORMACAO LTDA for the legality of such submission, declaring that you have the power to do and that you have obtained the necessary consent to authorize the use of such information under this Privacy Policy.

 

Section 1 – Definitions

For the purposes of this Privacy Policy:

“Personal Data”: means any information that, directly or indirectly, identifies or may identify a natural person, such as name, CPF, date of birth, IP address, among others;

“Sensitive Personal Data”: means any information that reveals, related to a natural person, 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 life sexual, genetic or biometric data;

“Processing of Personal Data”: means any operation carried out within the scope of Personal Data, by means of automatic or non-automatic means, such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, dissemination by transmission, dissemination or, alternatively, making available, harmonizing or associating, restricting, deleting or destroying. Processing of Personal Data is also considered to be any other operation provided for in the terms of the applicable legislation;

“Data Protection Laws”: means all legal provisions that regulate the Processing of Personal Data, including, but not limited to, Law No. 13.709/18, General Personal Data Protection Law (“LGPD”).

 

Section 2 – Use of Personal Data

We collect and use Personal Data to manage your relationship with us and better serve you when you are purchasing products and/or services on the website, customizing and improving your experience. Examples of how we use the data include:

Enable you to purchase products and/or services on the website;

To confirm or correct the information we have about you;

To submit information that we believe will be of your interest;

To customize your experience using the website;

We can contact you by the phone number and/or email address you provide. We may contact you personally, by voice message, by automatic dialing equipment, by text messages (SMS), by email, or by any other channels of communication that your device is capable of receiving, under the law and for reasonable business purposes.

In addition, the Personal Data provided may also be used in any way we deem necessary or appropriate: (a) under the Data Protection Laws; (b) to meet legal process requirements; (c) to comply with court order, regulatory decision or decision of competent authorities, including authorities outside the country of residence; (d) to apply our Terms and Conditions of Use; (e) to protect our operations; (f) to protect the rights, privacy, safety of us, you or others; (g) to detect and prevent fraud; (h) allow us to use available actions or limit damages we may suffer; and (i) in other ways permitted by law.

 

Section 3 – Non-providing of Personal Data

There is no obligation to share the Personal Data we request. However, if you choose not to share them, in some cases we will not be able to provide you with full access to the website, some specialized resources or be able to provide the necessary assistance or even enable the delivery of the product or provide the contracted service.

 

Section 4 – Collected Data

The general public will be able to browse the website without the need for any registration and submission of Personal Data. However, some of the website’s features may depend on registering and sending Personal Data, such as completing the purchase/contracting of the service and/or enabling us to deliver the product/provision of the service.

By contacting the website, you authorize us to collect:

Contact details: name, surname, telephone number, address, city, state and email address;

Information sent: information you’ve sent by form (questions, complaints, suggestions, criticisms, compliments, etc.).

In general navigation on the site, you allow us to collect:

Location data: geolocation data when you access the website;

Preferences: information about your preferences and interests in the products/services (when you tell us what they are or when we deduce them from what we know about you);

Site navigation data: information about your visits and activities, including the content (and any advertisements) you view and interact with, information about the browser and device you are using, your IP address, your location, the address from the site you came from. Some of this information is collected using our Automatic Data Collection Tools, which include cookies, web beacons and embedded web links. To learn more, read how we use Automatic Data Collection Tools in section 7 below;

Anonymous or Aggregated Data: Anonymous responses to surveys or anonymous and aggregated information about how the site is enjoyed. During our operations, in certain cases, we apply a de-identification or pseudonymization process to your data so that it is reasonably unlikely that you will be identified through the use of that data with available technology;

Other information we may collect: information that does not specifically disclose your identity or is not directly related to an individual, such as browser and device information; website usage data; and information collected through cookies, pixel tags and other technologies.

We do not collect Sensitive Personal Data.

You authorize the performance of the treatments provided for in sections 2 and 5 of this document on the data provided in this section.

 

Section 5 – Sharing Personal Data with Third Parties

Do you authorize us to share your Personal Data:

With the partner company(ies) you select or choose to send your data, queries, questions, etc., as well as with service providers or partners to manage or support certain aspects of our business operations on our behalf. These service providers or partners may be located in the United States, Argentina, Brazil, or other global locations, including servers for validation and production, and data hosting and storage providers, fraud management, customer support, sales on our behalf, order fulfillment, content customization, advertising and marketing activities (including digital and personalized advertising), and IT services, for example; With third parties, to assist us in managing the site; With third parties, in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or transmission of all or part of our business, assets, or equity (including in relation to bankruptcy or similar proceedings).

 

The list of third parties with whom your data is shared: RD Station, SendGrid.

 

Section 6 – International Data Transfers

By accepting this privacy policy you agree that Personal Data and information of other nature collected by us may be transferred or accessed by entities belonging to the corporate group of partner companies worldwide in accordance with this Privacy Policy.

DIGITAL STRATEGY TECNOLOGIA DA INFORMACAO LTDA takes the precautions required by the General Personal Data Protection Law when transferring data internationally, only carrying out such procedure when: 1) the destination country offers a level of data protection equivalent to that of the LGPD; 2) when it has contractual guarantees with its foreign counterparty that oblige it to follow the same parameters as the LGPD; or in the other cases provided for in art. 33 of the LGPD.

 

Section 7 – Automatic Personal Data Collection

When you visit the website, it may store or retrieve information on your browser, primarily in the form of cookies, which are text files containing small amounts of information. This information may be about you, your preferences or your device and is primarily used to make the site work as you expect. The information usually doesn’t directly identify you, but it can provide a more personalized internet experience.

In accordance with this Privacy Policy, we and our third-party service providers, with your consent, may collect your Personal Data in a number of ways, including but not limited to:

By browser or device: Some information is collected by most browsers or automatically by internet access devices, such as computer type, screen resolution, operating system name and version, device model and manufacturer, language, type and version of the Internet browser you are using. We may use this information to ensure that the website functions properly.

Use of Cookies: Information about your use of the website may be collected by third parties from cookies. Cookies are information stored directly on the computer you are using. Cookies allow the collection of information such as browser type, time spent on the site, pages visited, language preferences, and other anonymous traffic data. We and our service providers use information for security protection, to facilitate navigation, to display information more efficiently, and to personalize your experience when using the site, as well as for online tracking. We also collect statistical information about website usage to continually improve our design and functionality, to understand how the website is used, and to assist you in resolving issues relating to the website.

The settings you choose may affect your browsing experience and operation that requires the use of cookies. In this sense, we reject any responsibility for the consequences resulting from the limited functioning of the website caused by the disabling of cookies on your device (inability to set or read a cookie).

We currently do not use a cookie list and may use it without prior notification.

Use of pixel tags and other similar technologies: pixel tags (also known as web beacons and invisible GIFs) can be used to track the actions of website users (including email recipients), measure the success of our marketing campaigns, and collect statistical data on site usage and response rates, and for other unspecified purposes. We may contract with behavioral advertising companies to obtain reports on website advertisements across the internet. To do this, these companies use cookies, pixel tags and other technologies to collect information about your use, or the use of other users, of our website and third-party websites. We are not responsible for pixel tags, cookies and other similar technologies used by third parties. 

 

Section 8 – Cookies Categories

The cookies used on our website comply with legal requirements and fall into the following categories:

Strictly Necessary: ​​These cookies allow you to browse the site and enjoy essential features safely. One example is security cookies, which authenticate users, protect their data and prevent the creation of fraudulent logins.

Performance: Cookies in this category collect coded and anonymous information related to our website, such as, for example, the number of visitors to a specific page, origin of visits to the website and which pages were accessed by the user. All data collected is used only for possible improvements to the website and to measure the effectiveness of our communication.

Functionality: these cookies are used to remember user preference settings in order to improve your visit to our website, such as settings applied to the website layout or your responses to promotions and registrations pop-ups; that way, it won’t be necessary to ask over and over again.

Advertising: We use cookies to create targeted campaigns and deliver ads according to your consumption profile on our website. 

 

Section 9 – User’s Rights

You may, at any time, as provided for in art. 18 of the LGPD, require: (i) confirmation that your Personal Data is being processed; (ii) access to your Personal Data; (iii) corrections to incomplete, inaccurate or outdated data; (iv) anonymization, blocking or deletion of unnecessary, excessive or processed data in violation of the law; (v) portability of Personal Data to another service provider, as long as this does not affect our trade and trade secrets; (vi) deletion of Personal Data processed with your consent, to the extent permitted by law; (vii) information about the entities to which your Personal Data has been shared; (viii) information about the possibility of not providing consent and about the consequences of denial; and (ix) revocation of consent. Your requests will be handled with special care so that we can ensure the effectiveness of your rights. You may be asked to provide proof of your identity in order to ensure that Personal Data is only shared with the owner.

You should keep in mind that, in certain cases (for example, due to legal requirements), your order may not be immediately satisfied, either due to the volume of operations necessary to fulfill your order, or due to the absence of regulations, by ANPD, on how the rights of data subjects will be operationalized, in addition to the fact that we may not be able to serve you due to compliance with legal obligations (for example, we cannot exclude information that is legally protected, such as those present in notes tax).

 

Section 10 – Personal Data Security

We seek to adopt the technical and organizational measures provided for by the Data Protection Laws to protect Personal Data in our organization. Unfortunately, no data transmission or storage system is guaranteed to be 100% secure.

If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the security of any of your accounts has been compromised), please notify us immediately.

 

Section 11 – Hypertext Links to others websites and social networks

The website may, from time to time, contain hypertext links that will redirect you to websites of our partners’ networks, advertisers, suppliers, etc. If you click on one of these links to any of these sites, please remember that each site has its own privacy practices and that we are not responsible for those policies. Please review these policies before submitting any Personal Data to these sites.

We are not responsible for the collection, use, and disclosure policies and practices (including data protection practices) of other organizations, such as Facebook, Apple, Google, Microsoft, or any other software developer or application provider, media store social, operating system, wireless internet service provider or device manufacturer, including any Personal Data that you disclose to other organizations through the apps, in connection with such apps, or posted on your social media pages. We recommend that you inform yourself about the privacy policy of each website visited or each service provider used. 

 

Section 12 – Updates to this Privacy Policy 

If we change our Privacy Policy, we will post the new text on the website, with an updated revision date. We may change this Privacy Policy at any time. If there is a significant change to the terms of this Privacy Policy, we may inform you through the contact information we have in our database or through a notification on our website.

We remind you that we are committed not to treat your Personal Data in a way that is incompatible with the purposes described above, unless otherwise required by law or court order.

 

Section 13 – Personal Data Processing Officer

If you intend to exercise any of the rights provided for, including withdrawing your consent, in this Privacy Policy and/or in the Data Protection Laws, or to resolve any queries related to the Treatment of your Personal Data, please contact us by support@strateegia.digital.