1. Overview and Scope
1.1. Overview
This policy and applicable support procedures are designed to provide Digibee with a documented and formalized process for protecting the privacy of individuals. Respect for the privacy of personal information and other information is fundamental to us. This privacy policy describes our collection of personal information from users of our website ("Site"), our Platform, as well as all related applications, widgets, software, tools, and other services provided by us and in which a link to this Policy is displayed (collectively, together with the Site, our "Service"). This Policy also describes our use and disclosure of such information. By using our Service, you agree 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. Roles and Responsibilities
The following roles and responsibilities shall be developed and subsequently assigned to authorized Digibee personnel in relation to privacy practices:
Privacy Director: Responsibilities include providing general guidance, direction, leadership, and support in methods and tools for the implementation of a security and privacy-related program. The Privacy Director 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:
- Executing the company's privacy operations, including monitoring the system used to request, evaluate, and respond to individual privacy complaints and issues
- Evaluating implemented privacy controls
- Evaluating existing policies and procedures that address privacy areas
- Working with appropriate departments to ensure compliance with privacy policies and procedures
- Recommending and monitoring, in conjunction with relevant departments, the development of internal systems and controls to meet the organization's privacy objectives
- Reporting to the Privacy Director on the effectiveness of privacy controls/program in meeting 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, phone 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 that information is linked to personal information that identifies that individual.
Personal information does not include "aggregate" information or other non-personally identifiable information. Aggregate 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 aggregate information and other non-personally identifiable information for various 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, and 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.
4.2. Voluntarily Provided Information Collection
We may collect personal information that our users provide to us in various ways through our Service. For example, when you request information about our services or otherwise communicate with us, we collect the personal information provided to us. We may collect personal information such as name, email address, city, state, country, other demographic information, and your interests and preferences in this manner.
4.3. Information from Other Sources
We may receive information about you, including personal information, from third parties, and we may combine this 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 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 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 about our products and services. We allow you to opt out of receiving our marketing communications, 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) that 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 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 third parties.
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 insolvency, bankruptcy, or receivership in which personal information may be transferred to third parties as one of our business assets.
7. Choice
If you receive a commercial email from us, you can unsubscribe at any time by following the instructions contained in the email. You may also opt out of receiving our commercial emails 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, be aware that this policy will not apply to your activities or to any information you disclose when using third-party products or services or otherwise interacting with third parties.
9. Children
The safety of children is important to us and we encourage parents and guardians to take an active interest in their children's online activities. We do not intentionally collect personal information from children under the age of 13 without obtaining parental consent.
10. International Visitors
Our Site and Service is hosted in the United States and Brazil and is generally intended for visitors from the United States and Brazil. If you visit from the European Union or other regions with laws governing the collection and use of data that may differ from U.S. and Brazilian law, be aware that you are transferring personal information to the United States or Brazil. By providing us with personal information, you agree to the transfer thereof to the corresponding hosting country and to the use thereof 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 as completely effective. Accordingly, we cannot guarantee 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 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 information.
13. Contact
If you have any questions, comments, or concerns about this privacy policy or your personal information, please contact us via our Privacy email. 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 is the owner of this Policy and is responsible for reviewing it for annual updates or after major changes in Digibee's compliance environment. The Policy Approver retains approval 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 Customer and Consumer Data. Digibee may also establish enforcement mechanisms, including disciplinary actions, to help ensure compliance with this Policy.