Privacy Notice Policy

Privacy Policy of


1.1. Overview 

This policy and applicable supporting procedures are designed to provide Digibee  with a documented and formalized process for protecting individuals’ privacy. Respect for the privacy of personal and other information is fundamental to us. This  privacy policy describes our collection of personal information from users of our  Web site (“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.


The following roles and responsibilities are to be developed and subsequently assigned  to authorized personnel within Digibee regarding privacy practices:

  • Chief Privacy Officer: Responsibilities include providing overall direction, guidance,  leadership, and support on methods and tools for the implementation of a security and  privacy-related program. The Chief Privacy Officer will conduct 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 with  which it must comply. Additional responsibilities include: 
    • Execute the privacy operations of the firm, including monitoring the systemused  to solicit, evaluate, and respond to individual privacy complaints andproblems. T Evaluate implemented privacy controls; 
    • Assessing existing policies and procedures that address privacy areas; T Working with appropriate departments to ensure compliance with privacy policies  and procedures; 
    • Recommending and monitoring, in conjunction with the relevant departments,the  development of internal systems and controls to carry out the organization’s  privacy objectives; T Report to the Chief Privacy Officer on the effectiveness of the privacy  controls/program in meeting applicable regulatory requirements and standards.


“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  e-mail address. Personal information also includes information about an individual’s  activities, such as information about his or her 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 “aggregate” or other non-personally identifiable  information. Aggregate information is information that 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 aggregate information, and  other non-personally identifiable information, for various purposes.


4.1. Passive Information Collection 

When you use the Service, some information may be automatically collected, such  as your IP address, browser type, system type, the content and pages that you  access on the Site, “referring URL” (i.e., the page from which you navigated to the

Site), the pages you navigate to 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 services and content that are tailored to you.  If we link or associate any information gathered through passive means with  personal information, we treat the combined information as personal information  under this policy. Otherwise, we use information collected by passive means in a  non-personally identifiable form only. 

Also, please be aware that third parties may set cookies on your hard drive or use  other means of passively collecting information about your use of their services or  content. We do not have 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 instance, when you request information about our  services or otherwise communicate with us, we collect the personal information that  is provided to us. We may collect personal information such as name, e-mail  address, city, state, country, other demographic information, and your interests and  preferences in these manners. 

4.3. Information from Other Sources 

We may receive information about you, including personal information, from third  parties, and may combine this information with other personal information we  maintain about you. If we do so, this policy governs any combined information that  we keep in a personally-identifiable format.


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 tailor  your user experience; to maintain a record of our dealings with you, and for other  administrative purposes.

We may also use the personal information you provide to contact you regarding our  products and services. We allow you to opt-out from receiving marketing  communications from us as described in the “Choice” section below.


We will not disclose your personal information to third parties without your consent,  other than as described in this policy. We may disclose personal information to third party service providers (e.g., data storage and processing facilities) that assist us in our  work. We limit the personal information provided to these service providers to that which  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 is in our interest to protect our property or other legal rights (including, but not limited  to, enforcement of our agreements), or the rights or property of others. 

In addition, 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 could be transferred to third parties as one of our  business assets.


If you receive commercial email from us, you may unsubscribe at any time by following  the instructions contained within the email. You may also opt-out from receiving  commercial email from us by sending us an email or by writing to us at the address  given at the end of this policy.


For your convenience, the Site may contain links to other Web sites, 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 you disclose while using third-party products or services or otherwise  interacting with third parties.


Children’s safety is important to us, and we encourage parents and guardians to take an  active interest in the online activities of their children. We do not knowingly collect personal information from children under the age of 13 without obtaining parental  consent.


Our Site and Service is hosted in the United States and Brazil and is generally intended  for United States and Brazil visitors. Our Site and Service clearly identifies the region it  is hosted in. If you visit from the European Union or other regions with laws governing  data collection and use that may differ from U.S. and Brazil law, please be aware that  you are transferring personal information to the United States or Brazil. Both the United  States and Brazil do not have the same data protection laws as the European Union  and some other regions. By providing personal information to us, you consent to the  transfer of it to the corresponding hosting country and the use of it in accordance with  this policy. 


Digibee protects the Personal Information it collects with reasonable and appropriate  physical, electronic, and procedural safeguards. We use reasonable security measures  that are 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. Consequently, we  cannot ensure or warrant the security of any personal information or other information.  You transmit information to us at your own risk. 


We may occasionally update this Policy. When we do, we will also revise the “last  updated” date at the beginning of the policy. Your continued use of this Service after  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. 


If you have any questions, comments, or concerns about this privacy policy or your  personal information, please contact us at the Privacy email. If you have a complaint  that we have breached these privacy principles and attempted in good faith to resolve  the complaint through our customer service process, but the complaint was not resolved by us within a reasonable amount of time, then you may enforce these privacy  principles against us. 


14.1. Ownership and Review 

The Policy Owner owns this Policy and is responsible for reviewing the Policy for  updates annually, or following major changes to Digibee’s compliance environment.  The Policy Approver retains approving authority over this Policy. 

14.2. Monitoring and Enforcement 

Digibee periodically monitors adherence to this Policy to help ensure compliance  with applicable laws, requirements, and contractual agreements that apply to Client  & 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 Handling 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 

Document History 

V-1 04/11/2022  at 18:10:18 

Changed by: Rodrigo Lara Comments: We have changed the International Visitors session so that it refers to both US and Brazilian data protection laws