Management Policy

Last Updated: December 6, 2021.



Welcome! Thank you for choosing INDIKATORE!


The INDIKATORE platform was developed and is fully managed by the company INDIKATORE CONSULTORIA E DESENVOLVIMENTO DE SOFTWARE EIRELI, a company registered with CNPJ/MF no. 28.683.491/0001-31, with address at Rua 1822, no. 330, Room 02, Centro, Balneário Camboriú/SC, CEP: 88330-484.


When you use INDIKATORE's Technological Resources ("Software," "Website," or other "Platforms"), you entrust us with your data and information. We are committed to maintaining that trust.


In this regard, this Privacy Policy (“Policy”) clearly and accessibly explains how your information and data will be collected, used, shared, and stored through our platforms.


You accept our Policy when you access our platforms or use INDIKATORE services. This indicates that you are aware of and fully agree with how we will use your information and data.


This Policy is divided as follows to facilitate its understanding:


1. Definitions
2. Data and information we collect
3. How we use the data and information collected
4. How, when and with whom we share your data and information
5. Cookie Categories
6. Links and hypertext to other websites and social networks
7. Your rights over the data and information we collect
8. How we protect your data and information
9. Privacy Policy Updates
10. Final provisions

If you have any questions or need to address any matter related to this Policy, please contact us via email at contato@indikatore.com.


1. DEFINITIONS


• “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, in relation to a natural person, racial or ethnic origin, religious belief, political opinion, membership of a trade union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data.


• “Personal Data Processing”: means any operation carried out on Personal Data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or, alternatively, making available, harmonization or combination, restriction, erasure or destruction. Any other operation provided for under applicable legislation is also considered Personal Data Processing.


• “Data Protection Law”: 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”).


2. DATA AND INFORMATION WE COLLECT


2.1. Information collected when you register on our website www.indikatore.com.


Whether to present the benefits that our products and services can provide to you and your business, to execute their functionalities, or to offer you educational and informative materials that are available on our website, you will voluntarily provide us with the following data:


• Registration data: Name, email, contact telephone number, login, password.


• Contact details: First name, last name, email, company, segment, city and contact telephone number.


When browsing the website in general, we may also collect:


• Location data: geolocation data when you access our website.


• Navigational 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 of the website from which you arrived. Some of this information is collected using our Automatic Data Collection Tools, which include cookies, web beacons, and embedded web links.


• Anonymous or aggregated data: anonymous survey responses or anonymous and aggregated information about how the store is used. 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 this data with available technology.


• Other information we may collect: information that does not specifically reveal your identity or that does not directly relate to an individual, such as browser and device information; and information collected through cookies, pixel tags, and other technologies.


We do not collect Sensitive Personal Data.
When you visit a website, it may store or retrieve information on your browser, mostly in the form of cookies, which are text files containing small amounts of information. This information might be about you, your preferences, or your device and is primarily used to make the website work as you expect it to. The information does not usually directly identify you, but it can provide a more personalized web experience.
In accordance with this Privacy Policy, we and our third-party service providers, with your consent, may collect your Personal Data in a variety of ways, including, but not limited to:
• Through your browser or device: Some information is collected by most browsers or automatically through internet access devices, such as your computer type, screen resolution, operating system name and version, device model and manufacturer, language, and the type and version of the internet browser you are using. We may use this information to ensure the website functions properly.


• Use of cookies: Information about your use of the website may be collected by third parties through 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 website, pages visited, language preferences, and other anonymous traffic data. We and our service providers use information for security protection, to facilitate navigation, display information more efficiently, and 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 with issues related to the website.


If you do not wish for your information to be collected through cookies, there is a simple procedure in most browsers that allows you to automatically reject cookies, or to give you the option to accept or reject the transfer of a specific cookie (or cookies) from a given website to your computer. However, this may cause inconvenience in using the website.
The settings you choose may affect your browsing experience and functionality that requires the use of cookies. Therefore, we decline any responsibility for the consequences resulting from limited website functionality caused by disabling cookies on your device (inability to set or read a cookie).
• Use of pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used to track the actions of website users (including email recipients), measure the success of our marketing campaigns, and collect statistical data about website usage and response rates, as well as for other unspecified purposes. We may hire behavioral advertising companies to obtain reports on website advertising across the internet. To this end, 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.


2.2. Information generated when you use our materials, products and services.


During the use of our products and services, some information is generated, which may include:


• Access logs. INDIKATORE may automatically collect application access logs, which include the IP address, with date and time, used to access INDIKATORE's Technology Resources. This data is mandatory, according to Law 12.965/2014, but will only be provided to third parties with your express authorization or through legal action.


• Usage data. We collect information about your interactions on the INDIKATORE platforms, such as your browsing, the pages or other content you access or create, your searches, participation in surveys or forums, and other actions.


• Communications with Indikatore. When you communicate with INDIKATORE through chat support, phone, or website contact, we collect information about your communication, including metadata such as the date, IP address, and time of the communication and all its content, as well as any information you choose to provide.


• Cookies and similar technologies. We use cookies, which are text files generated and stored on your browser or device by websites, applications, and online advertisements. Cookies may be used for the following purposes: Authenticating users and remembering user preferences and settings. It is important to note that you can prevent cookies from being set by adjusting your browser settings. However, be aware that disabling cookies will affect the functionality of this and many other websites you visit. Disabling cookies will usually result in also disabling certain functionality and features. Therefore, it is recommended that you do not disable cookies.


Third Party Information provided by you through the use of our products and services.


Considering the nature of the services offered by INDIKATORE, when using our Technological Resources, you and the users linked to your account may provide or upload data and information from third parties to perform the services, such as employees, collaborators, and other service providers of your company. In these cases, users are solely responsible for the information provided and its legal authorization, and INDIKATORE is responsible for processing such data, subject to contractual authorization.


3. HOW WE USE THE DATA AND INFORMATION COLLECTED


It's worth remembering that we value your privacy. Therefore, all data and information about you is treated as confidential, and we will only use it for the purposes described herein and authorized by you, primarily so that you can fully utilize INDIKATORE, always aiming to improve your user experience.


Authorized uses


In this way, we may use your data to:

• Send you information that we believe may be of interest to you;

• Contact you at a phone number and/or email address you provide. We may contact you directly by voice message, automatic dialing equipment, text message (SMS), email, or any other means of communication that your device is capable of receiving, as permitted by law and for reasonable business purposes;

• Allow you to access and use all INDIKATORE features;

• Comply with legal obligations;

• Perform the contractual obligations established with you, including providing customer service, support, reporting, data hosting and others;

• Communicate with you about products, services, promotions, news, updates, events, and other topics that may interest you. In the case of communication via email list, the user may unsubscribe from it;

• Analyze user traffic in our applications;

• Personalize services, products and features, constantly adapting them to your tastes and interests, as well as creating new ones;

• Detection and prevention of fraud, spam and security incidents;

• Verify or authenticate the information you provide, including by comparing it to data collected from other sources

• Better understand user behavior and build behavioral profiles;

• Para qualquer fim que você autorizar no momento da coleta de dados.

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


We may occasionally use your data for purposes not covered by this privacy policy, but these will be within your legitimate expectations. Any use of your data for purposes outside this prerogative will be done with your prior authorization.


3.1. Deletion of data


The data and information collected may be deleted from our servers upon your request, specifying such data, through a free and simplified procedure, respecting legal deadlines and considering the proportion of data.


Furthermore, data may also be deleted if it is no longer necessary or relevant to provide our services, unless there is any other reason for its retention, such as a possible legal obligation to retain data or the need to preserve it to protect INDIKATORE's rights.


3.2. Monitoring


INDIKATORE reserves the right to monitor all of its platforms, primarily to ensure that the rules are being observed, or that there is no violation or abuse of applicable laws.


3.3. User deletion


INDIKATORE reserves the right to exclude a user, regardless of their type, if this Policy or the Terms of Use are not respected. As we value a good relationship with our users, we recognize that they have the right to seek understanding and even challenge the reasons for their exclusion. This can be done by emailing contato@indikatore.com.


4. HOW, WHERE AND WITH WHOM WE SHARE YOUR DATA AND INFORMATION


INDIKATORE's practice is not to transmit data and information to external organizations and/or individuals, except with the free, informed and unequivocal consent of the platform user, or when consent is dispensable within the scope of legitimate hypotheses for processing personal data, provided for in current legislation.


To perform the Services, INDIKATORE may share your information with third-party service providers, who operate in various processes, such as:


• Cloud information storage;
• Service providers or partners may be providers of hosting and data storage services;
• Verification of information against public databases;
• Research, development and maintenance of applications;
• Providing INDIKATORE Services through third-party platforms and software tools (e.g., through integration with APIs);
• User Service;
• Marketing promotion, advertising activities (including digital and personalized advertising), including social media advertising services, lead prospecting and data analysis;
• Provision of consulting services (“Intellectual Resources”), legal, accounting and other professional service providers;
• Processing and ensuring payment security;
• With third parties in the event of any reorganization, merger, sale, joint venture, assignment, conveyance or transfer of all or any portion of our business, assets or capital (including in connection with bankruptcy or similar proceedings).


Your data and information may also be shared with other users of your corporate account, so that everyone can communicate and use the platforms in the best way.


It is worth noting that service providers have limited access to user data to perform specific tasks and are contractually obligated to protect the information, using it only for the contracted purposes and under the supervision of INDIKATORE.


INDIKATORE reserves the right to provide your data and information, including your interactions, if legally requested to do so, an act necessary for the company to comply with national laws, or if you expressly authorize it.


Finally, all data, information, and content about you may be considered assets in the event of negotiations in which INDIKATORE is involved. Therefore, we reserve the right, for example, to include your data among the company's assets if the company is sold, acquired, or merged with another company. By means of this Policy, you agree and acknowledge this possibility.


5. CATEGORIES OF COOKIES
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 website and enjoy essential features securely. One example is security cookies, which authenticate users, protect their data, and prevent fraudulent logins.

• Performance: Cookies in this category collect information in an encoded and anonymous form related to our website, such as the number of visitors to a specific page, the origin of the visits to the website, and which pages the user accessed. All data collected is used only for potential 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, for example, settings applied to the website layout or your responses to promotion and registration pop-ups -; this way, it will not be necessary to ask numerous times.

• Advertising: We use cookies to create targeted campaigns and deliver ads based on the pages you visit on the website.

6. HYPERTEXT LINKS TO OTHER WEBSITES AND SOCIAL NETWORKS
The website may, from time to time, contain hypertext links that will redirect you to the websites of our sources, partners, advertisers, etc. If you click on one of these links to any of these websites, please remember that each website has its own privacy practices and that we are not responsible for these policies. Please review these policies before submitting any Personal Data to these websites.

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 app provider, social media store, operating system, wireless internet service provider, or device manufacturer, including any Personal Data you disclose to other organizations through the apps, in connection with such apps, or posted on our social media pages. We recommend that you read the privacy policy of each website you visit or each service provider you use.

7. YOUR RIGHTS OVER THE DATA AND INFORMATION WE COLLECT
You can always choose not to disclose your data and information to us, but please note that some of this data may be necessary to use the features of our technological resources and to provide a good experience when browsing the website. Regardless, you always have rights regarding privacy and the protection of your personal data.

Therefore, below we summarize all the rights you have under Brazilian sectoral laws regarding data protection and the General Data Protection Law (“LGPD”), which are:

• Right of access. This right allows you to request and receive a copy of the personal data we hold about you.

• Right to rectification. This right allows you to request the correction and/or rectification of your personal data at any time if you identify that some of it is incorrect. However, for this correction to be effective, we will need to verify the validity of the data you provide. You can directly rectify some of your personal data by emailing us.

• Right to erasure. This right allows you to request that we delete the personal data we hold about you. All collected data will be deleted from our servers when you so request or when it is no longer necessary or relevant to provide our services, unless there is any other reason for its retention, such as a possible legal obligation to retain data or the need to preserve it to protect INDIKATORE's rights. To change your personal information or delete it from our database, simply send us your request by email.

• Right to object to processing. You also have the right to object to where and in what context we are processing your personal data for different purposes. In certain situations, we may demonstrate that we have legitimate grounds to process your data that override your rights, for example, if the data is essential for the provision of our applications.

• Right to request anonymization, blocking, or deletion. This right allows you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the accuracy of the data; (b) when you need us to keep the data even if we no longer need it, as necessary to establish, exercise, or defend legal claims; or (c) if you have objected to the use of your data, but in this case we need to verify whether we have legitimate grounds to use it.

• Right to portability. We will provide you, or third parties you have chosen, with your personal data in a structured and interoperable format.

• Right to withdraw your consent. You have the right to withdraw your consent to the terms of this Privacy Policy. However, this will not affect the lawfulness of any processing carried out previously. If you withdraw your consent, we may not be able to provide certain services.

• Right to review automated decisions. You also have the right to request a review of decisions made solely based on automated processing of your personal data that affect your interests, including decisions aimed at defining personal, professional, consumer, and credit profiles and/or aspects of your personality.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who has no right to receive it. We may also contact you for further information regarding your request to expedite our response. We attempt to respond to all legitimate requests within 5 (five) business days.

Occasionally, it may take longer than 5 (five) days if your request is particularly complex or if you have made multiple requests. In this case, we will notify you and keep you updated on the progress of your request.

If you have any questions about these issues and how you can exercise these rights, please feel free to contact us at contato@indikatore.com.br.

8. HOW WE PROTECT YOUR DATA AND INFORMATION

All your data is confidential and will only be accessed by those with the appropriate authorizations. Any use of this data will be in accordance with this Policy. INDIKATORE will make every reasonable effort to ensure the security of our systems and your data. Our servers are located in different locations to ensure stability and security, and can only be accessed through previously authorized communication channels.

We strive to adopt appropriate technical and organizational measures required by Data Protection Laws to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be 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.

Todas as suas informações serão, sempre que possível, criptografadas, caso não inviabilizem o seu uso pela plataforma. A qualquer momento você poderá requisitar cópia dos seus dados armazenados em nossos sistemas. Manteremos os dados e informações somente até quando estas forem necessárias ou relevantes para as finalidades descritas nesta Política, ou em caso de períodos pré-determinados por lei, ou até quando estas forem necessárias para a manutenção de interesses legítimos da INDIKATORE.

INDIKATORE considers your privacy extremely important and will do everything in its power to protect it. However, we cannot guarantee that all data and information about you on our platform will be free from unauthorized access, especially if the credentials required to access our application are improperly shared. Therefore, you are solely responsible for keeping your password safe and secure, and sharing it with third parties is prohibited. You agree to notify INDIKATORE immediately, via secure means, of any unauthorized use of your account, as well as unauthorized access by third parties.

9. PRIVACY POLICY UPDATES

INDIKATORE may change any of the terms of this Policy upon prior notice, at least 15 days in advance. If you do not agree with the changes, you may immediately request cancellation. Failure to cancel or use our services and products after notification of the change implies acceptance of the new terms.

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

Your use of the website after the changes are made means you accept the revised Privacy Policy. If, after reading the revised version, you do not agree with its terms, please end your access to the website.

10. FINAL PROVISIONS

All legal documentation on the platform, including this Privacy Policy, has been prepared in Portuguese. INDIKATORE may, at its sole discretion, make translations of such documents available on the website/platform solely for the user's convenience. However, the Portuguese version of this Privacy Policy is the only one authorized by INDIKATORE. In the event of any contradiction or discrepancy between the Portuguese version and any translation into any other language, the Portuguese version shall prevail.

In the event of a conflict between this policy and the modifying policies, the later policies will prevail with respect to that conflict.

This document is governed by and shall be construed in accordance with the laws of the Federative Republic of Brazil. The Court of the District of Balneário Camboriú, Santa Catarina, is hereby elected as the competent court to resolve any disputes arising from this document, with express waiver of any other court, however privileged it may be.

If you wish to exercise any of the rights provided for, including withdrawing your consent, in this Privacy Policy and/or in the Data Protection Laws, or resolve any queries related to the Processing of your Personal Data, please contact us at contato@indikatore.com.br.

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