Introduction
Your privacy is vital to ELOSOFT INFORMÁTICA LTDA. (Elosoft), and we are committed to protecting your personal data. In this document, called the Information Security Policy (Privacy Policy), we want to inform you about how we collect and use your data based on the principles of regulations and laws related to the privacy of personal data.
Elosoft understands the electronic records and personal data recorded in the use of its website as relevant. This Privacy Policy regulates, in a simple, transparent, and objective way, which personal data will be obtained, as well as when and how they may be used.
This Policy applies to all movements on Elosoft’s official website at www.elosoft.com.br. This Policy is aimed at Elosoft’s customers and the general public and covers the fundamentals of how Elosoft handles these people’s personal data. If you are an employee or supplier of Elosoft, or if you are participating in any specific project or activity with Elosoft, seek the relevant privacy notice issued by Elosoft or the person responsible for your hiring at Elosoft to provide you with the applicable terms and inform you of your data rights.
To better illustrate how we process data, we present our Privacy and Personal Data Protection Policy (“Policy”);
This Policy may be updated at any time by Elosoft, with notice on the website and/or by email.
Definitions
If you have any questions about the terms used in this policy, see the following table:
Personal data: any information related to an individual that identifies them, or used in combination with other information Processed identifies them. Or any information through which it is possible to identify a person or contact them.
Sensitive personal data: personal data on racial or ethnic origin, religious belief, political opinion, membership to a union or organization of a religious, philosophical, or political nature, data regarding health or sexual life, and genetic or biometric data, when linked to an individual.
Data subject: natural person to whom personal data refer, such as old, present, or potential customers, employees, suppliers, contractors, commercial partners, and third parties.
Person in charge: a person appointed by Elosoft to act as a communication channel between the controller, the data subjects, and the National Data Protection Authority (ANPD).
Storage: cloud computing is a virtualization technology service built from the interconnection of more than one server through a shared information network (e.g., the Internet) to reduce costs and increase the availability of sustained services.
Uniquely automated decisions: These are decisions that affect the user and have been programmed to work automatically, without the need for a complement of human operation, based on automated processing of personal data.
What data do we use?
Elosoft may collect the information actively entered by the data subject at the time of contact or registration. Also, information is automatically collected when using the services and/or the network, such as identification of the commercial establishment used and IP with the date and time of connection, among others.
Thus, two types of personal data are processed:
(a) those provided by the Data Subject themself, used for the same purposes for which they were provided;
(b) those collected automatically:
(i) Personal data provided by the Data Subject: Elosoft collects all personal data actively entered or forwarded by the Data Subject when contacting or accessing Elosoft’s portals, such as full name, corporate name, email, city, and state, when filling out forms, with the addition of other personal data actively provided by the Data Subject when contacting Elosoft. Regardless of what data the Data Subject actively provides to Elosoft, we will only use those that are effectively relevant and necessary to achieve the purposes declared to it on a case-by-case basis;
(ii) Data collected automatically: Elosoft also collects a series of information automatically, such as characteristics of the browser access device, IP (with date and time), IP origin, information about clicks, pages accessed, and search terms typed on our portals, among others. For such collection, Elosoft uses standard technologies, such as cookies, pixel tags, beacons, and local shared objects, which are used to improve the Data Subject’s browsing experience according to their habits and preferences.
You may disable the automatic collection of information through some technologies, such as cookies and caches, on your Internet browser settings. However, the Data Subject must be aware that if these technologies are disabled, some features offered by the website, which depend on the processing of these data, may not work correctly.
Elosoft reinforces that it does not treat, for the general purposes set forth herein, data considered sensitive by Law No. 13,709/2018, understood as those related to racial or ethnic origin, religious conviction, political opinion, membership to union or organization of a religious, philosophical, political nature, data related to health or sexual life, genetic or biometric data, being confident that, in the remote and specific cases in which it does so, the treatment is based on particular terms previously made available to the Data Subjects, with their specific consent or based on express legal authorization.
How do we use the data?
The personal data processed by Elosoft have as primary purpose to establish a contractual relationship or management, administration, provision, expansion and improvement of services to the Data Subject, including adapting them to their preferences and tastes, as well as the creation of new services and products to be offered to the Data Subjects.
Elosoft, in some cases, may also process personal data when necessary to comply with a legal or regulatory obligation.
In addition, Elosoft may also process personal data based on its legitimate interest (or the legitimate interest of other units, headquarters, and subsidiaries, always within the limit of what is expected by the Data Subject and never to the detriment of its interests, rights, and fundamental freedoms).
In addition, the information collected may, with the consent of the Data Subject, be used for advertising purposes, such as sending product and promotion information, disclosing events, or conducting research related to its activities.
How do we use cookies?
Cookies are files or information that can be stored on your devices when you visit the website or use Elosoft’s online services. Generally, a cookie contains the name of the website that originated it, its lifetime, and a value, which is randomly generated.
Elosoft uses cookies to facilitate the use and better adapt its pages to the interests and needs of the Data Subjects, as well as to compile information about the use of our websites and services, helping to improve their structures and their contents. Cookies may also be used to speed up your future activities and experiences on our portal. After the Data Subject consents to the use of cookies, when accessing Elosoft’s pages, a cookie will be stored on their device to remember this in the next session.
The Data Subject may withdraw their consent to the use of cookies at any time. This would delete the cookies from Elosoft’s pages using the settings of their preferred browser. Finally, remember that certain services may not work correctly or optimally if the Data Subject does not accept some cookies from Elosoft’s pages.
Who do we share the data with?
The information collected is processed within Elosoft and will only be shared when it is necessary: (1) for the adequate provision of the services object of its activities with partner companies; (2) for protection in case of conflict; (3) by judicial decision or request of a competent authority; (4) with companies that provide technological and operational infrastructure, such as payment intermediary companies if they provide information storage services.
How do we keep the data secure?
Elosoft implements technical and organizational measures, taking into account the nature, impact and context of the personal data you have shared with us and all the risks involving their processing, to protect your data and, more specifically, to prevent any unauthorized access and accidental or unlawful destruction, loss or alteration.
Retention of collected information
Elosoft stores your personal data for as long as necessary for processing and/or under the appropriate legal basis.
This storage period depends on the purpose for which Elosoft is processing the personal data and takes into account regulations or other legal requirements that impose a specific retention period for certain categories of data.
The personal data processed by Elosoft will be deleted when they cease to be helpful for the purposes for which they were collected, or when the Data Subject requests their deletion, unless their maintenance is expressly authorized by applicable law or regulation.
Your rights
In compliance with the applicable regulations, with regard to the processing of personal data, Elosoft respects and guarantees the Data Subject the possibility of submitting requests based on the following rights:
a) Confirm that your data is being processed;
b) Access your data;
c) Request the correction of your data;
d) Require data portability to another service or product provider;
e) Delete personal data;
f) Obtain information from the public and private entities with which the data were
shared;
g) Receive information on the possibility of not providing consent and on the
consequences of denial;
h) Withdraw consent;
i) Object to the processing of your personal data;
j) Request anonymization, blocking, or deletion of your data.
Elosoft will make every effort to fulfill such requests in the shortest possible time; however, justifiable factors, such as the complexity of the requested action, may delay or prevent its immediate and quick fulfillment.
Finally, the Data Subject must be aware that their request may be legally rejected, either for formal reasons (such as their inability to prove their identity) or legal reasons (such as the request to delete data whose maintenance is free exercise of rights by Elosoft).
You may exercise the rights above by contacting us.
How can you contact us?
Requests can be directed to the following contact:
Data Protection Officer
Ernesto Luis Oviedo
Elosoft Informática Ltda.
Alameda Rio Branco, 238 – 2º andar – Ed. Bauhaus – Centro.
89010-300 – Blumenau/SC – Brazil
Email: dpo@elosoft.com.br
Phone: +55 47 2102 4444
Please provide your details, including your full name and email address and how you relate to Elosoft, so that we can identify you, as well as any other relevant information to confirm your identity.
Law and jurisdiction
This policy will be governed, interpreted, and executed by the Laws of the Federative Republic of Brazil, especially Law No. 13,709/2018, regardless of the Laws of other states or countries, and the domicile of Blumenau/SC is fully competent to resolve any doubts arising from this document.
This policy is dated November 30, 2022, and may be modified or updated anytime. We recommend that you regularly check the latest version of this Notice. Suggestions, questions, or complaints may be sent to the Ombudsman by email: ernesto.oviedo@elosoft.com.br
Blumenau, February 8, 2023.