PRIVACY POLICY 

Introduction 

PROMOB SOFTWARE S/A (“we”, “us”, “our” or “PROMOB”) is committed to the highest level of integrity when dealing with its customers and visitors. When using our website, services, purchasing or requesting information about our products and services or providing us with personal data, you agree to the policies, practices and terms contained herein. We routinely update our policy and therefore invite you to review it from time to time to ensure that you are aware of any changes.

 

Please read this policy carefully and make sure you understand it. This policy describes how we treat certain information about you, your computer or mobile device (“Device”). When you use PROMOB’s internet and electronic media services directly, we may collect, process and/or use data that identifies you or makes you identifiable (“PERSONAL DATA”). Some examples of PERSONAL DATA are your name, address, telephone number, email address, credit card information, IP (Internet Protocol), and profession. We only process PERSONAL DATA that is necessary to provide our services and maintain a relationship with you.

 

PROMOB understands your desire to protect personal data and intends to inform you about how it will be collected, tracked, processed or used, for what purposes and on what legal grounds, as well as the alternatives that are offered to you in this regard. If you cannot find the information about how we process personal data, you can contact us through one of the communication channels detailed at the end of this document.

 

What information we collect

PROMOB collects personal data that we consider to be reasonably necessary to provide our services to you, for example, to fulfill our contractual obligations and serve a legitimate business purpose. We request personal information when you place an order, create an account, register a product, request a service, answer a survey, participate in a course, take a training program, participate in our selection processes, participate in digital campaigns on our channels, request a contact from our team, show an interest in some content available on our blog, talk to us on WhatsApp, correspond with us, or engage in other activities on our website. If you request online technical support, you must provide the necessary information so that we can recognize you and complete the transaction. At any time, you will have the option to decide not to proceed with the transaction that requires your personal information.

Creating an account and personal information

To activate and/or use some of our products or services, you will need to create an account on our Service Page. During the process of setting up your account, we will ask you for some PERSONAL DATA, such as your email address. We need this information to enable you to activate, manage or use your PROMOB products and services. We may associate your email address and other PERSONAL DATA (such as name, phone number and address) with your account. You can also provide us with your contact information through other interactions with us, whether through the use of our services, filling out a form on our digital channels, an interaction with our sales or customer support team, or by responding to one of our surveys.

Job opportunity

When you forward your personal data for the job opportunities we post on our Website, you will be redirected to our partner supplier’s page: https://promob.gupy.io/. It is essential that you read, understand, and give your consent to the specific Privacy Policy terms on that page before moving forward.

Device and browser data

We collect information from the device and app you use to access our services. Device data primarily means its IP address, operating system version, device type, system, performance information, and browser.

Register data

As most websites today, our web servers and service provider (WP Engine) keep log files that record data each time a device accesses these servers. The log files contain data on the nature of each access, including source IP addresses, Internet service providers, the files viewed on our website (for example, HTML pages, graphics, etc.), operating system versions, type of device, and time/date stamps.

Information from third parties and partners offering services and products complementary to those offered by Promob

We collect your personal data if you allow these third parties to share your information with us, or if you have made that information publicly available online.

Do not forget that Promob has links to other websites, which may contain useful information/tools for our visitors. Our Privacy Policy does not apply to third-party websites, so if you visit another website from ours, you should carefully read their privacy policy. We are not responsible for the privacy policy or content present on these websites.

How do we use your personal data?

We use your personal data on the following cases:

  • To enable you to create an account.

  • To fulfill your request or transaction.

  • To enable you to buy and download products, gain access to services, or otherwise engage in the activities you select.

  • To provide you with information about new products or services, product updates, newsletters, informational emails, and surveys on future product ideas or improvements.

  • To improve your user experience.

  • To offer you opportunities to work with us.

  • To send you advertising campaigns about our products and services.

  • To provide special offers or training options that may be of interest to you or relevant to you.

  • To help you quickly find software, services or product information that is important to you.

  • To assist us in creating content, information or training that is relevant to you and your use of our products and services.

  • To assist us in creating better products and services to meet your needs.

With whom can we share your information?

PROMOB does not sell PERSONAL DATA to third parties. If we work with advertising and publishing partners, we will only share non-personal information and in accordance with the applicable privacy laws.

 

However, we can hire other companies or consultants to provide certain services to PROMOB. In these situations, PROMOB will share the necessary PERSONAL DATA if we have an appropriate agreement in place with the partner or, on certain occasions, the partner will interact directly with you, based on their own web terms and conditions and privacy policy, to collect the PERSONAL DATA necessary to complete their services at our request (such as the human resources platform, for example). If necessary, PROMOB will only transfer the PERSONAL DATA necessary to perform the requested services. These companies must strictly comply with data protection legislation. They must also process your PERSONAL DATA confidentially and use it only to provide services to us and to serve the purposes of this Policy.

 

International transfer

PROMOB is part of the 2020 group, a Canadian company that operates globally and has offices in several countries. Thus, we may store and process your personal information on a server outside the country where you live. In addition, the personal information you have provided to us may be transferred to other companies in the PROMOB group worldwide, also outside your jurisdiction, in compliance with the rules for the international transfer of personal data. It is important to reinforce that your PERSONAL DATA will be shared with companies that are part of the 2020 group and our service providers, to the extent necessary to perform our services and permitted by law or by the consent you have given us.

 

Finally, PROMOB may disclose your PERSONAL DATA if required by public and governmental authorities to comply with court orders or requests from administrative authorities that have the legal competence to request them.

Consequences of us not being able to collect your PERSONAL DATA

We need your PERSONAL DATA to provide our services and interact with you. Without providing these PERSONAL DATA, we may not be able to provide you with the services you intend to receive.

The legal grounds for the collection, processing and use of your PERSONAL DATA

Our services are subject to the laws in force at the countries where we provide our services. We collect, process, and use your PERSONAL DATA in accordance with the applicable laws of all relevant countries, and especially in Brazil, in compliance with Art. 7 of Law 13.709/18 – General Law on Protection of Personal Data.

Choose / double opt-in / opt-out

When you create an account, you will be asked to confirm your email address and your intention to receive our emails, newsletters, advertising, and bulletins. If, after agreeing to this, you do not wish to continue receiving our newsletters or informational bulletins by email, you can opt out of receiving these communications by replying with “Unsubscribe” in the subject line of the email. If you are an active customer using one of our products or services, please note that we can still communicate with you regarding such products and services.

 

Security and protection measures for PERSONAL DATA

We take the security of all PERSONAL DATA provided to us seriously, which is why we adopt best practices for information security, transformed into strict performance standards, following the legal provisions and a precautious culture, through constant investment in the implementation and updating of technological resources to ensure that all information and PERSONAL DATA we collect are not subject to destruction, loss, alteration, communication, or dissemination.

We implement legal and industry-standard safeguards to protect your PERSONAL DATA. For example, some information transmitted to PROMOB will be encrypted using the Secure Socket Layer (SSL) certificate. We do this to ensure that your PERSONAL DATA is not lost, damaged, or deleted.

We invest in training our teams to inform on the correct and legal way in which these data should be processed.

Website and cookies

You can visit most areas of the PROMOB website without revealing any personal information. PROMOB only registers the domain name, IP address and browser type of visitors to our website through our web server log files and analysis tools at irregular intervals. We use this information to record the global entry status of our website. This information is not related to any personal information and does not identify you.

PROMOB may use cookies from time to time. A Cookie is a unique text file that a website can send to your browser software. We may use Cookies to identify the browser you are using so that our website is displayed correctly. We also use cookies in various areas on our website to document your visit to the PROMOB website and allow for a more efficient website design.

For more information and learning how to manage cookies, access our Cookies Policy.

Links to business partners and co-branded websites

Some of the links contained on PROMOB websites may direct you to partner websites or to companies that have established business relationships with PROMOB. When submitting information to one of these co-branded websites or partner companies, you may send it either to PROMOB or these business partners. Under no circumstances can PROMOB be held responsible for the privacy practices of these business partners and, therefore, we encourage you to read their respective Privacy Policies, as they may differ from ours.

Consent and withdrawal

When you use our website, from time to time, we may ask you to consent to the collection, processing and use of your PERSONAL DATA for the purposes described above. Any consent is provided free of charge. If you give your consent, you have the right to withdraw it at any time. Withdrawal of consent does not affect the legality of processing based on consent given prior to withdrawal. After your withdrawal, we may collect, process, and use your PERSONAL DATA on another legal basis, as far as permitted by applicable laws. To withdraw your consent, send us an email or a letter to our contact information provided below.

How long do we keep your PERSONAL DATA?

For the same purpose of processing your PERSONAL DATA with transparency and protecting them, we keep them with us only as long as it is necessary to achieve a specific purpose, to comply with legal or regulatory requirements during the statutory limitation period for possible contractual or legal responsibilities.

 

Your rights related to data privacy

We process your PERSONAL DATA with transparency, and so you can, whenever you wish, contact us to exercise your rights, which are:

 

  • To know which PERSONAL DATA are used by PROMOB.

  • To ask for your data to be excluded.

  • To ask for your data to be altered or corrected.

  • To ask for information on how your data is shared.

  • To restrict, as much as possible, the use of your data, including with regard to receiving advertising campaigns and the use of Cookies by PROMOB.

  • To request a copy of your data in a legal and appropriate format and to transmit them for use by other services.

  • To revoke the consent you have given to PROMOB for the processing of your data.

  • To request the interruption of any marketing communications.

  • To request the portability of your PERSONAL DATA to another service or product supplier upon your express request, observing commercial and industrial secrets, in accordance with future regulations of the National Data Protection Authority (ANPD).

 

We will consider all requests and respond within the legal timeframe. However, before this period starts, we will need to confirm your identity, especially to make sure that your data will be made available exclusively to you.

In addition, it is important that you note that these rights do not always apply and that there are exceptions. The elimination of data, for example, will not be possible when your data appears on an invoice or even in the signing of a contract, as such documents will remain in our databases while our obligations related to them are in force and in progress.

If you have any complaints about how we use your personal information, we prefer that you contact us first. However, you can make a complaint to the National Data Protection Authority when it is up and running.

Public information

Please note that the information you send to PROMOB social networks is classified as public information and is not subject to this Privacy Policy. So be careful and treat your personal information responsibly while online.

Contact information

If you have any other questions about our notices, data protection and how we use your PERSONAL DATA, you can also contact our Privacy team at any time via email: lgpd@promob.com.  

 

PROMOB has appointed Marcos dos Santos as the Data Protection Officer (DPO) in charge of processing personal data, and he can be contacted by e-mail: lgpd@promob.com.  

 

If you prefer to contact us by mail or other physical means, you can send any correspondence to the address of our headquarters in Caxias do Sul/RS.

UPDATE AND LEGISLATION

This Privacy Policy may be revised from time to time. If we make significant changes, you will be informed of them before the changes take effect. Please be sure to carefully read any notices about this.

Any dispute arising from the terms set out in this External Privacy Policy will be resolved in accordance with, but not limited to, the General Data Protection Law, in accordance with Brazilian law.

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PROMOB values compliance with data protection laws around the world, in particular the General Personal Data Protection Law (LGPD - Law No. 13.709 / 2018).

Our DPO (Data Processor Officer), Marcos dos Santos, and our privacy and data protection team can be reached at lgpd@promob.com. Learn more about our Privacy Policy and Cookies Policy.