We, at Digiteam, are committed to the privacy and protection of your personal data. Therefore, we present our Privacy Notice in accordance with the General Data Protection Law (LGPD).

Through this Notice, we inform you how we collect, use, process, and disclose your information and personal data in conjunction with your access to and use of the Platform.

Before accessing and using the functionalities of the Platform, we ask that you read and understand this Notice.

We are available to clarify your doubts, receive feedback, or complaints through the following email: privacidade@digiteam.cloud.

Information You Will Find in This Notice

1. IMPORTANT CONCEPTS FOR THIS NOTICE

2. WHO DOES THIS NOTICE APPLY TO?

3. WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL DATA?

4. HOW DO WE PROCESS YOUR PERSONAL DATA?

      4.1. Data Collected for Registration

      4.2. Data Collected from Field Agents

      4.3. Indirectly Collected Data

      4.5. Data Accuracy

5. HOW DO WE SHARE YOUR DATA?

      5.1. Company Data Sharing with Digiteam

      5.2. International Data Transfer

6. LINKS TO THIRD-PARTY SITES/PLATFORMS

7. HOW DO WE PROTECT YOUR DATA?

8. KNOW YOUR RIGHTS AND HOW TO EXERCISE THEM

9. HOW LONG DO WE STORE YOUR DATA?

10. GENERAL PROVISIONS

11. DATA PROTECTION OFFICER

1.      Important Concepts for This Notice

• Field Agent: An individual, collaborator of the Company, managed through the integrated mobile application of the Platform.
• Anonymization: The process by which collected personal data is transformed into files stored by the Controller in which it is impossible to identify to whom such data belongs.
• ANPD: The National Data Protection Authority, a public administration body responsible for overseeing, implementing, and enforcing compliance with the LGPD throughout the national territory.
• Controller: The individual or entity responsible for making decisions regarding data processing.
• Personal Data: Information that identifies a natural person, such as email, CPF, phone number, and address.
• Sensitive Personal Data: Personal data regarding racial or ethnic origin, religious beliefs, opinions, union membership, health or sexual life, genetic or biometric data.
• Demands: Services distributed and monitored by the Platform aimed at Field Agents.
• Company: A legal entity that contracts the Digiteam Platform to manage its external teams.
• IP: The IP address is the code assigned to a terminal in a network to allow its identification, defined according to international parameters.
• LGPD: The General Data Protection Law, Law No. 13.709/2018, which governs the processing and protection of data.
• Operator: The individual or entity that processes data according to the Controller’s instructions.
• Data Processing: Any operation carried out with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, assessment, or control of information, modification, communication, transfer, dissemination, or extraction.
• Platform, ‘Digiteam’ or ‘Digiteam Platform’: Software as a Service (SaaS) licensed through contract for use by the Company.
• Users: Those representing the Company, referred to as ‘Administrators’ of the Platform.
• Software as a Service (SaaS): A software distribution and commercialization modality.

2.      Who Does This Notice Apply To?

This Privacy Notice (Notice) applies to Users who access, administer, and manage the functionalities of the Platform.

3.      Who Is Responsible for the Processing of Personal Data?

DIGITEAM TECNOLOGIA LTDA. (DIGITEAM), registered under CNPJ No. 07.821.585/0001-50, located at St. Bancario Sul Quadra 02 Bloco E, number 12, Complemento Salas 402 à 406, Asa Sul, Brasília – DF, Zip: 70.070-12, owner of this Platform, acts as the Controller of personal data only concerning the personal data of the Company’s representatives necessary for the contractual relationship and service provision.

Digiteam acts as the Operator of the processing concerning data from third parties entered into the Platform by its Administrators. In this sense, the processing will be based on the decisions of the Company, the Controller of the data of its respective employees, suppliers, and/or service providers who use the Platform.

4.       How Do We Process Your Personal Data?

Below, we describe how we process your data, detailing the purposes and legal bases that justify this processing.

4.1 Data Collected for Registration

To register Users on the Platform, we will collect the name, email, and CPF (optional).

4.2 Indirectly Collected Data

Digiteam may collect data indirectly during the User’s navigation, such as IP address, session, date and time logs of actions, device/browser, and activities on the Platform.

Additionally, access logs are collected, which consist of a set of information regarding the date and time of using a particular internet application from a given IP address, as provided in Law No. 12.965/2014 (Marco Civil da Internet) and Article 7, II, of Law No. 13.709/2018.

4.3 Purposes and Legal Bases for Personal Data Processing

The personal data processed by Digiteam will only be used to meet the following purposes:

Collected Data	Purpose of Processing	Legal Basis
Full name, Email	For registration and identification of the Administrator User on the Platform.	Contract execution and preliminary procedures (art. 7, V, LGPD)
IP address, User session, date and time logs of actions, device/browser, User’s activities on the site.	To collect information to identify and protect Users, as well as comply with legal obligations.	Legal or regulatory obligation of the Controller (art. 7, II, LGPD); Compliance with the Marco Civil da Internet (art. 15); Legitimate interest of the Controller (art. 10, LGPD).

4.4 Data Accuracy

The User is responsible for the accuracy or inaccuracy of their personal data and the personal data of their dependents.

Digiteam is not obligated to process or handle any data provided by the User if there are reasons to believe that the processing may violate any applicable law or that the User is using the Platform for illegal, illicit purposes or contrary to this Notice.

5.      How Do We Share Your Data?

Digiteam shares only the data necessary for the provision of services offered by the Platform.

In this sense, Digiteam may share data with contracted companies so that the functionalities are available, which may process personal data as Data Operators.

Thus, the following third parties may have access to the personal data of Users:

• Comtele, for sending online SMS;
• Zendesk, for internal organization;
• AWS, or cloud storage;
• Azure, for single sign-on protection and cloud storage.

In addition to the companies mentioned above, Digiteam may share personal data with legal advisors, collaborators, specific service providers, in order to ensure the proper performance of the Services.

Digiteam’s contracts prioritize the secure processing of User information.

Furthermore, once these third parties have access to the shared data, they will be responsible for processing and securing this data, not being able to process it for other purposes, while respecting applicable law and the terms of this Privacy Notice.

5.1 Company Data Sharing with Digiteam

Companies may share with Digiteam personal data of their clients and collaborators. In this case, Digiteam acts as a Data Operator, while the Company will be the Controller and must define the purpose and legal basis for the processing of these data.

Thus, the responsibility for making essential decisions about data processing and addressing the rights of data subjects (employees and clients) rests with the Company, as it provides the data to Digiteam.

5.2 International Data Transfer

Digiteam may, to the extent permitted by the LGPD, share data outside Brazil.

This international transfer occurs when we use cloud services for data processing or storage to enable the optimal execution of our services in a secure environment.

In doing so, Digiteam will take all necessary measures to ensure that your data is processed and shared securely and in compliance with applicable legislation and this Privacy Notice.

6.      Links to Third-Party Sites/Platforms

The Platform may occasionally contain links to third-party sites/platforms, such as partners, advertisers, and affiliates. When following a link, it is important to note that these sites/platforms have their own privacy notices and policies, and Digiteam is not responsible for these documents.

Digiteam recommends reviewing these notices and policies before submitting any personal data to these sites.

7.      How Do We Protect Your Data?

Digiteam is committed to the security of all its Users and, therefore, adopts physical, electronic, and administrative procedures that ensure the privacy and security of your data, with technical measures compatible with international standards and using good practices, as suggested by the National Data Protection Authority (ANPD).

To ensure that the data is stored in a secure environment, it uses Amazon Web Services (AWS) servers, which implies an international transfer of personal data to the country where this server is located, in the United States of America.

Whenever possible, data will be anonymized. Sensitive personal data will be treated with a higher level of protection and security.

8.      Know Your Rights and How to Exercise Them

Access and Confirmation of Processing

You can request from Digiteam access to the complete list of collected and processed data, as well as confirmation of the processing of your personal data.

Correction of Personal Data

You can request Digiteam to correct data that is incomplete, inaccurate, or outdated.

Anonymization, Blocking, or Deletion

All data collected and processed by Digiteam is aimed at providing services and ensuring the proper functioning of the Platform.

If you believe that any of your data is being processed unnecessarily, excessively, or in non-compliance with the LGPD, you can request the anonymization, blocking, or deletion of such data, provided you can prove the excess, unnecessary nature, or non-compliance with the LGPD.

Information About Sharing

You can request Digiteam for information about our partners and suppliers with whom we share data.

We have verified that all our partners are also concerned about your security and adopt appropriate measures to protect your data.

Automated Decisions

You can request a review of decisions made solely based on automated data processing and the criteria used in such decisions, always observing the trade and industrial secrets of Digiteam.

Data Portability

You may request the portability of your personal data to another service provider that offers services similar to those provided by Digiteam, in accordance with the provisions of the LGPD.

To exercise any of your rights as a Data Subject, please contact Digiteam at the email address privacidade@digiteam.cloud.

9.      How Long We Store Your Data

The data provided by the User on the Platform will be stored and processed for a retention period of up to 2 (two) years from the termination of the contract, according to Digiteam’s Security Management Plan.

If the User wishes, they can request the deletion of their account and personal data by emailing suporte@digiteam.cloud.

Upon the request for deletion or termination of the processing purpose, the User will have all their data permanently deleted, except for data whose maintenance is required by law or regulation, or necessary for the regular exercise of rights in judicial, administrative, or arbitration processes.

10.      General Provisions

Digiteam informs that, at any time and unilaterally, it may modify/update this Notice. If this occurs, the User will be notified, and the updated version will take effect upon its publication.

The continued access or use by the User, after the announcement of the update, will confirm the validity of the new Privacy Notice by the Users.

In addition to this Privacy Notice, Digiteam has its Terms and Conditions of Use, which define the conditions of use that will govern the use of the Platform. These terms are inseparably integrated into this Privacy Notice.

11.      Data Protection Officer

Digiteam has a data protection officer, in accordance with Article 41 of the LGPD, responsible for accepting complaints and communications from data subjects and the National Data Protection Authority, providing clarifications, and taking appropriate actions.

If you have any questions, complaints, or concerns regarding any aspect of this Notice, please contact our data protection officer:

Barbara Barbosa

Data Protection Officer of Digiteam

barbara@digiteam.cloud

We are also available to clarify your questions, receive feedback, or complaints through the following email: privacidade@digiteam.cloud.