1. OVERVIEW AND SCOPE
1.1. Overview
This Policy and the applicable supporting procedures are designed to provide Digibee with a documented and formalized process for protecting the privacy of individuals. Respect for the privacy of personal and other information is paramount to us. This Privacy Policy describes our collection of personal information from users of our website (“Website” or “Site”), our Platform, as well as all related applications, widgets, software, tools and other services provided by us and on which a link to this Policy is displayed (collectively, together with the Website, our “Service”). This Policy also describes our use and disclosure of such information. By using our Service, you consent to the collection and use of personal information in accordance with this Policy.
1.2. Scope
This policy and supporting procedures cover the privacy of all data collected by Digibee in its interaction with individuals in its business operations.
2. FUNCTIONS AND RESPONSIBILITIES
The following roles and responsibilities shall be developed and subsequently assigned to authorized Digibee personnel in relation to privacy practices:
- Privacy Officer: Responsibilities include providing overall guidance, direction, leadership, and support on methods and tools for implementing a security and privacy-related program. The Chief Privacy Officer will lead resource and investment planning to implement the management, operational, technical, and privacy requirements of the program.
- Privacy Committee: Responsibilities include approving and monitoring adherence to this policy, analyzing the organization's environment and the legal requirements it must comply with. Additional responsibilities include:
- Perform the company's privacy operations, including monitoring the system used to request, evaluate, and respond to individual privacy complaints and concerns. T Evaluate the privacy controls implemented;
- Evaluate existing policies and procedures that address areas of privacy; T Work with appropriate departments to ensure compliance with privacy policies and procedures;
- Recommend and monitor, together with the competent departments, the development of internal systems and controls to meet the organization's privacy objectives; T Report to the Privacy Officer on the effectiveness of the privacy controls/program in complying with applicable regulatory requirements and standards.
3. PERSONAL INFORMATION
“Personal Information,” as used in this policy, is information that specifically identifies an individual, such as an individual’s name, social security number, telephone number, or email address. Personal information also includes information about an individual’s activities, such as information about their activity on the Site or credit history, and demographic information, such as date of birth, gender, address, geographic area, and preferences, when any of this information is linked to personal information that identifies that individual.
Personal information does not include “aggregated” information or other non-personally identifiable information. Aggregated information is information we collect about a group or category of products, services, or users that is not personally identifiable or from which individual identities are removed. We may use and disclose aggregated information and other non-personally identifiable information for a variety of purposes.
4. INFORMATION COLLECTION
4.1. Passive information collection
When you use the Service, some information may be collected automatically, such as your IP address, browser type, system type, the content and pages you access on the Site, “referring URL” (i.e., the page from which you navigated to the
Site), the pages you browse on the Site and from which you leave the Site, as well as the time you spend on the Site.
We collect this information passively using technologies such as standard server logs, cookies, and clear GIFs (also known as “Web beacons”). We use passively collected information to administer, operate, and improve the Site and our other services and systems, and to provide personalized services and content to you. If we link or associate any information collected by passive means with personal information, we will treat the combined information as personal information in accordance with this policy. Otherwise, we use information collected by passive means only in a non-personally identifiable form.
Additionally, please be aware that third parties may set cookies on your hard drive or use other means to passively collect information about your use of their services or content. We have no access to or control over these third party means of passive data collection.
4.2. Collection of voluntarily provided information
We may collect personal information that our users provide to us in a variety of ways through our Service. For example, when you request information about our services or otherwise communicate with us, we collect the personal information that you provide to us. We may collect personal information such as your name, email address, city, state, country, other demographic information, and your interests and preferences in this way.
4.3. Information from other sources
We may receive information about you, including personal information, from third parties, and we may combine that information with other personal information we hold about you. If we do so, this policy will govern any combined information we hold in a personally identifiable format.
5. USE OF PERSONAL INFORMATION
We use personal information to provide services and information that you request; to enhance, improve, operate, and maintain the Site and Service, our programs, services, website, and other systems; to prevent fraudulent use of our Site and Service; to personalize your user experience; to keep a record of our dealings with you; and for other administrative purposes.
We may also use the personal information you provide to contact you about our products and services. We allow you to opt out of receiving marketing communications from us as described in the “Choice” section below.
6. DISCLOSURE OF PERSONAL INFORMATION
We will not disclose your personal information to third parties without your consent, except as described in this policy. We may disclose personal information to third party service providers (e.g. data storage and processing facilities) who assist us in our work. We limit the personal information provided to these service providers to what is reasonably necessary for them to perform their functions.
We may also disclose personal information if we believe that doing so is legally required or in our interest to protect our property or other legal rights (including, without limitation, the enforcement of our agreements), or the rights or property of others.
Additionally, information about our users, including personal information, may be disclosed as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information may be transferred to a third party as one of our business assets.
7. CHOICE
If you receive a commercial email from us, you may unsubscribe at any time by following the instructions contained in the email. You may also opt out of receiving commercial emails from us by sending us an email or writing to us at the address provided at the end of this policy.
8. LINKS
For your convenience, the Site may contain links to other websites, products or services that we do not own or operate. If you choose to visit or use any third-party products or services, please be aware that this policy will not apply to your activities or any information that you disclose when using third-party products or services or when otherwise interacting with third parties.
9. KIDS
Children’s safety is important to us and we encourage parents and guardians to take an active interest in their children’s online activities. We do not knowingly collect personal information from children under the age of 13 without obtaining parental consent.
10. INTERNATIONAL VISITORS
Our Site and Service are hosted in the United States and Brazil and are generally intended for visitors from the United States and Brazil. Our Site and Service clearly identify the region in which they are hosted. If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from those in the United States and Brazil, please be aware that you are transferring personal information to the United States or Brazil. The United States and Brazil do not have the same data protection laws as the European Union and some other regions. By providing us with personal information, you consent to the transfer of your personal information to the corresponding hosting country and to our use of it in accordance with this policy.
11. SECURITY
Digibee protects the personal information it collects with reasonable and appropriate physical, electronic, and procedural safeguards. We use reasonable security measures designed to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please note, however, that no data security measures can be guaranteed to be completely effective. Accordingly, we cannot ensure or warrant the security of any personal information or other information. You transmit information to us at your own risk.
12. UPDATES TO THIS POLICY
We may occasionally update this Policy. When we do, we will also revise the “last updated” date at the top of the policy. Your continued use of this Service after any such changes will be subject to the then-current policy. We encourage you to periodically review this policy to stay informed about how we collect, use and disclose personal information.
13. CONTACT US
If you have any questions, comments or concerns about this privacy policy or your personal information, please contact us at Privacy. If you have a complaint that we have violated these privacy principles and have attempted in good faith to resolve the complaint through our customer service process, but the complaint has not been resolved by us within a reasonable period of time, you may enforce these privacy principles against us.
14. POLICY ADMINISTRATION
14.1. Ownership and review
The Policy Owner owns this Policy and is responsible for reviewing it for annual updates or after major changes to Digibee’s compliance environment. The Policy Approver retains approval authority over this Policy.
14.2. Monitoring and Application
Digibee periodically monitors adherence to this Policy to help ensure compliance with applicable laws, requirements, and contractual agreements that apply to Customer and Consumer Data. Digibee may also establish enforcement mechanisms, including disciplinary actions, to help ensure compliance with this Policy.
14.3. Related documents
- Information Security Policy
- Data Protection and Processing Policy
TITLE Privacy Notice Policy FILE NAME Privacy Notice Policy.pdf TIMESTAMP 04/11/2022 at 18:10:18 VERSION V-1
OWNER Rodrigo Lara APPROVER Peter Kreslins
Historical document
V-1 04/11/2022 at 18:10:18
Modified by: Rodrigo Lara rodrigo.lara@digibee.com.br Comments: We have modified the International Visitors section to refer to US and Brazilian data protection laws