Please read this Privacy and Personal Data Protection Policy carefully to understand our policies and practices regarding Personal Data and how this data is processed.
This Policy applies to individuals (natural persons), referred to here as user (“You), who interact with the services of the Softrack platform, installed at the root URL address secure.softrack.com.br of the company SOFTRACK. This Policy explains how your Personal Data is collected, used and disclosed by SOFTRACK (referred to in this policy as “SOFTRACK”, “We”, “Us”). It also tells you how You can access and update your Personal Data and make certain decisions about how your Personal Data is used.
This Policy covers Our online data collection activities, covering Personal Data that We collect through the Softrack Software installed at the URL with root secure.softtrack.com.br . You can consult the section “About your rights regarding Personal Data” for more information on how to object.
In some specific cases, if You decide not to provide us with your Personal Data designated as necessary (We will indicate when this is the case, for example, by explicitly placing this information on our registration forms), We may not be able to provide You with our products and/or services.
Expressions used in this Policy, such as ‘data subject’, ‘personal data’, ‘processing’, ‘personal data breach’, etc., will be interpreted based on the meaning attributed to them in data protection laws. The USER will act as “data holder” and SOFTRACK will act as “controller” in the strict sense of GDPR and LGPD.
We collect your Personal Data from the following sources:
During your interaction with SOFTRACK, using one of the previously mentioned collection sources, we may collect various types of personal data about You, as set out below:
SOFTRACK does not knowingly request, collect, process, store or share personal data from minor children and adolescents. If we discover that any type of unintentional handling of said data has occurred, we will quickly remove the personal data of that child or adolescent from our records.
The following items describe the purposes for which SOFTRACK collects your Personal Data, and the different types of Personal Data we collect for each purpose. Please note that not all uses below will be relevant to all individuals and may only apply to specific situations.
Reasons for registration and access: The Holder’s Personal Data is used to allow the Holder to access the records, reports and graphs available from the Softrack Software.
Reason for using the Holder’s personal data in this situation:
Our legitimate interests.
Our legitimate interests in this situation:
Improve and develop new products and services;
Protect our systems, networks and employees;
Fully comply with legal obligations.
Legal reasons or merger/acquisition: If SOFTRACK or its assets are acquired by, or merged with, another company, including due to bankruptcy, we will share your Personal Data with our legal successors, respecting the requirements of current legislation. We will also disclose your Personal Data to third parties (i) when required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from the competent legal authority; (iv) to protect our rights, privacy, safety or property; or (v) to enforce the terms of any agreement or the terms of our website, products and services, in accordance with applicable law.
Reason for using your personal data in this situation:
Legal obligations;
Our legitimate interests;
Our legitimate interests in this situation:
Fully comply with legal obligations;
Protect our systems, assets and employees.
Other purposes and situations in general: In accordance with current legislation, SOFTRACK uses your Personal Data for other general business purposes, such as maintaining your account, conducting internal or market research. We also use your Personal Data to manage and operate our communications, IT and security and data protection systems.
Reason for using your personal data in this situation:
Fulfill contractual obligations;
Legal obligations;
Our legitimate interests;
We obtain your consent (where necessary).
Our legitimate interests in this situation:
Improve and develop new products and services;
Be more efficient in fulfilling your orders;
Protect our systems, networks and employees;
Fully comply with legal obligations.
About the retention and termination of processing of your Personal Data
In accordance with current legislation, SOFTRACK uses your Personal Data for as long as necessary to satisfy the purposes for which your Personal Data was collected, as described in this policy, or to comply with applicable legal requirements.
You can obtain further details about the retention of your Personal Data through the communication channels detailed in this policy.
When the processing of your Personal Data ends, it will be deleted within the scope and technical limits of the activities, with conservation authorized in the situations provided for in current legislation.
About the disclosure, storage or transfer of your Personal Data
SOFTRACK adopts appropriate measures to ensure that your Personal Data is kept confidential and secure. However, these protections do not apply to information that You have chosen to share in public areas, such as third-party social networks.
Provide guidance on the guidelines applicable to the privacy and protection of personal data of customers, employees and partners to which SOFTRACK has access due to the performance of its activities, establishing the applicable rules on the collection, registration, storage, use, sharing, enrichment and elimination of collected data, in accordance with current laws.
Coverage
All administrators, directors, and employees of the company SOFTRACK, hereinafter referred to as (“SOFTRACK”), as well as third parties, service providers and/or suppliers who have access to SOFTRACK customer information.
III. Guidelines
Initial provisions
1.1. This Policy aims to demonstrate SOFTRACK’s commitment to:
1.1.1. Ensure the privacy and protection of personal data collected from SOFTRACK customers, employees and partners, depending on the performance of their activities;
1.1.2. Adopt guidelines that ensure comprehensive compliance with standards and good practices relating to privacy and protection of personal data;
1.1.3. Promote transparency about the way in which SOFTRACK processes personal data; It is
1.1.4. Adopt protective measures in relation to the risk of security incidents involving personal data.
Information subject to the Policy
2.1 The following are subject to this Policy:
2.1.1. All information provided or collected in the context of providing services by SOFTRACK to its customers, including the capture, transportation, processing of information and settlement of transactions, as well as the offering of other related services and products; It is
2.1.2. All employee and partner information collected in the context of contractual or legal obligation.
2.2. Regarding its nature, the information can be classified into 2 (two) groups:
2.2.1. Information provided by the data subject: Information entered or forwarded by the data subject or their legal representative, resulting from contact or registration with SOFTRACK, such as: full name, CPF, date of birth, full address, bank details, email address -email and telephone number.
2.2.2. Information collected from the use of our services by the data subject: These are those related to the use for the provision of services, captured by SOFTRACK and transmitted and/or shared with third parties in the context and limit necessary for the object of service provided by SOFTRACK.
2.3. The specific privacy practices in relation to services that SOFTRACK makes available to its customers will be associated with the acceptance by the customer or third party of each product or service.
3.Data Collected, form and purpose of collection
3.1. The information will be collected by ethical and legal means and stored in a safe and controlled environment, for the period required by current regulations. SOFTRACK undertakes to take all reasonable measures to maintain absolute secrecy and strict confidentiality of all information, personal data or specifications to which it has access or which may come to know or be aware of transactions, cardholders, card data and means of payment, of its customers, as well as individuals directly related to customers, to which it may have access due to the provision of services by SOFTRACK (i.e., the capture, transportation, processing of information, among other services) , and you are prohibited from giving and/or allowing third parties access to such information, except in the cases described in this Policy.
3.2. Access by third parties to information collected by SOFTRACK is provided exclusively to meet the purposes stated in this Policy and within the limit necessary to carry out activities related to the normal course of SOFTRACK’s business.
3.3. The use of information collected by SOFTRACK, in any of the hypotheses provided for in item 3.1 above, is made exclusively to meet the purposes stated in this Policy and in the performance of SOFTRACK’s activities or in offering the customer specific content based on the use of information from anonymized and aggregated form about your area of activity.
3.4. SOFTRACK may share information in aggregate form, publicly and/or with its partners, as long as such information is not personally identifiable. For example, you may publicly share information to demonstrate trends in the general use of SOFTRACK products and services.
3.5. Whenever it becomes necessary to use the information collected by SOFTRACK for purposes other than those defined in this Policy or that expressly authorized by the data subject, SOFTRACK will directly inform the data holder about this new purpose and, when necessary, collect a new authorization.
4. Relationship with third parties
4.1. SOFTRACK requires all third parties to maintain the confidentiality of the information shared with them or to which they have access due to the exercise of their activity, as well as to use such information exclusively for the expressly permitted purposes. However, SOFTRACK will not be responsible for the misuse of such information, whether by third parties or its employees, due to non-compliance with this Policy and the contractual obligations assumed by said third parties with SOFTRACK through their own instruments.
5. Information security
5.1. Aiming at the security of information provided by customers, SOFTRACK has physical, logical, technical and administrative security processes compatible with the sensitivity of the information collected.
5.2. SOFTRACK implements new procedures and continuous technological improvements to protect all personal data collected from customers.
5.3 Despite the security measures adopted, SOFTRACK is not responsible for losses resulting from the breach of confidentiality of information due to the occurrence of any fact or situation that is not attributable to it.
5.4 When processing the information collected, SOFTRACK uses systems structured to meet security and transparency requirements, standards of good practice and governance and the general principles established in Law No. 13,709/2018 General Personal Data Protection Law ( “LGPD”).
5.5. All technologies used will always comply with current legislation and the terms of this Policy.
Cooperation with regulatory authorities
6.1. In cases where it is necessary to disclose the personal data of customers, employees or partners, whether due to compliance with the law, court order or competent body supervising the activities carried out by SOFTRACK and/or third parties, such information must only be revealed in the strict terms and limits required for its disclosure, and the holders of the disclosed information, as far as possible, will be notified of such disclosure, so that they can take appropriate protective or remedial measures.
Changes
7.1. This Privacy and Data Protection Policy may be modified at any time, according to the purpose or need for adequacy and compliance with legal provisions or whenever SOFTRACK deems necessary. The changes will be published on our website, http://www.softtrack.com.br/privacidade. The continued use of SOFTRACK services or provision of services to SOFTRACK, as applicable, after disclosure of changes will be considered acceptance by the customer and third parties of the new terms and conditions.
Consequence Management
Employees, suppliers or others who observe any deviations from the guidelines of this Policy may report the fact to SOFTRACK, via email at ricardo.raschiatore@softrack.com.br, whether or not they may identify themselves.
Internally, non-compliance with the guidelines of this Policy leads to the application of liability measures for agents who fail to comply with it, depending on the respective severity of the non-compliance.
When a reported incident involves personal data and/or sensitive personal data, the Ethics Channel must promptly report the complaint to the Controller, Ricardo Alexandre Raschiatore, by email at ricardo.raschiatore@softrack.com.br, in accordance with Law 13,709/2018.
The data subject may contact:
Ask questions or comments about this Policy and our privacy and Personal Data protection practices;
Complain;
Confirmation of the existence of processing of your Personal Data;
Obtain information on how to access your Personal Data;
Correct incomplete, inaccurate or outdated personal data;
Obtain information about the anonymization, blocking or deletion of unnecessary, excessive or processed data that does not comply with the provisions of current legislation;
Obtain information about the portability of your personal data to another service or product provider, upon express request, in accordance with current legislation;
Request the deletion of personal data processed with your consent, except in the cases provided for in current legislation;
Request details of the public and private entities with which we share your Personal Data;
Obtain information about the possibility of not providing consent and the consequences of such refusal;
Revoke consent for the processing of your Personal Data, except in the cases provided for in current legislation;
Other rights of the holder of personal data, in accordance with current legislation.
To do this, we ask that you contact us using the following channels:
Responsible for Processing Personal Data:
Full Name: Ricardo Alexandre Raschiatore
email: privacy@softtrack.com.br
55 19 9 7420-1371
Privacy Portal:
www.softtrack.com.br/privacidade
By phone:
55 19 2517-0215
In person or by snail mail:
Av. Dr. Antonio Carlos Couto de Barros, 2350 – Jd Conceição (Sousas) – Campinas – SP. ZIP code: 13.105-000
SOFTRACK will receive, investigate and respond, within a period considered reasonable, to any request or complaint about the way we treat your Personal Data, including complaints about disrespect for your rights under current privacy and Personal Data protection laws.
Responsibilities
Administrators, collaborators and third parties:
Observe and ensure compliance with this Policy and, when necessary, contact the Controller for consultation on situations that involve conflict with this Policy or upon the occurrence of situations described therein.
Controller:
Clarify doubts regarding this Policy and its application;
Accept complaints and communications from data subjects, provide clarifications and take action;
Receive communications from the National Data Protection Authority (“ANPD”) and adopt measures;
Adopt initiatives to share information about incidents containing personal data with the ANPD and data holders, when necessary.
Juridical area:
Clarify doubts regarding relevant legislation and regulations.
Keep this Policy updated to ensure that any regulatory/legal changes to the guidelines and general rules established here are observed;
Guide SOFTRACK employees and third parties regarding the practices to be taken in relation to the protection of personal data;
Concepts and Acronyms
Clients: Natural person, who has registered in the SOFTRACK system, to whom the personal data that is the subject of work refers;
Personal data: Any information related to an identified or identifiable natural person, such as: name, surname, date of birth, personal documents (CPF, RG, CNH, Work Card, passport, voter registration card, among others), residential or business address , telephone, email, cookies and IP address;
Sensitive personal data: Any personal data on racial or ethnic origin, religious conviction, political opinion, membership of a trade union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a natural person;
Information: Data, processed or not, that can be used for the production and transmission of knowledge, contained in any medium, support or format;
Privacy and Data Protection: Possibility for the holder to determine, autonomously, the use made of their own personal data, together with the establishment of a series of guarantees to prevent this personal data from being used in a way that causes discrimination or damages of any kind.
Third parties: Natural or legal person, under public or private law, who provides services to SOFTRACK, on its premises or remotely, and in the course of carrying out their activities may have access to information relating to the business of SOFTRACK or its Clients.
This Cookies Policy is a complementary document to Softrack’s Privacy Policy, available above, on this same page. Here, you will find objective and clear information about what Cookies are, which Cookies we use in our applications, what role they play and how to configure them.
1. What are Cookies?
Cookies are small text files or fragments of information that are downloaded to your computer, smartphone or any other device with internet access when you visit our application.
They contain information about your navigation on our pages and only retain information related to your preferences.
Thus, this page can store and retrieve data about your browsing habits, in order to improve the user experience, for example. It is important to emphasize that they do not contain specific personal information, such as sensitive or banking data.
Your browser stores cookies on your hard drive, but they take up minimal memory space and do not affect your computer’s performance. Most information is deleted immediately after closing the session, as you will see in the next topic.
1.1. Types of Cookies
Cookies, regarding their owners, can be:
Proprietary cookies: these are cookies set by us or by third parties on our behalf
Third-party cookies: these are cookies set by trusted third parties in our application
Cookies, in terms of their lifespan, can be:
Session or temporary cookies: these are cookies that expire as soon as you close your browser, ending the session.
Persistent or permanent cookies: these are cookies that remain on your device for a specified period of time or until you delete them.
Cookies, in terms of their purpose, can be:
Necessary cookies: these are essential cookies that enable navigation in our applications and access to all resources; If these, our services may perform poorly or not at all.
Performance cookies: these are cookies that optimize the way our applications work, collecting anonymous information about the pages accessed.
Functionality cookies: these are cookies that remember your preferences and choices (such as your username)
Advertising cookies: these are cookies that target advertisements based on your interests and limit the number of times the advertisement appears.
2. Why do we use Cookies?
Softrack uses Cookies to provide the best user experience, making our applications easier and more personalized, based on your browsing choices and behavior.
Therefore, we seek to understand how you use our applications and adjust the content to make it more relevant to you, in addition to remembering your preferences.
Cookies participate in this process by storing, reading and executing the data necessary to fulfill our objective.
4. Cookies Management
The installation of cookies is subject to your consent. Although most browsers are initially configured to automatically accept cookies, you can review your permissions at any time, in order to block, accept them or activate notifications when some cookies are sent to your device.
Currently, the first time you access our applications, you will be asked to agree to their installation. Only after your acceptance will they be activated.
To this end, we use a system (information banner or other mechanism that alerts and requests consent) on the home page of (business name). In this way, we not only ask for your agreement, but also inform you that continued browsing on our websites will be understood as consent.
As already mentioned, you can, at any time and at no cost, change permissions, block or refuse Cookies. You can also configure them on a case-by-case basis. However, revoking consent for certain Cookies may prevent the correct functioning of some features of the platform.
To manage your browser’s cookies, simply do so directly in your browser settings, in the Cookies management area.
You can access tutorials on the topic directly through the links below:
If you use Internet Explorer.
If you use Firefox.
If you use Safari.
If you use Google Chrome.
If you use Microsoft Edge.
If you use Opera.
5. Final provisions
For Softtrack, privacy and trust are fundamental to our relationship with you. We are always updating ourselves to maintain the highest security standards
Therefore, we reserve the right to change this Cookies Policy at any time. Changes will take effect shortly after publication, and you will be notified.
By continuing to browse our applications after this change becomes effective, you agree to them. We advise that you always check this Policy, as well as our Privacy Policy.
How to get in touch
You can contact:
Ask questions or comments about this Policy and our privacy and Personal Data protection practices;
Complain;
Confirmation of the existence of processing of your Personal Data;
Obtain information on how to access your Personal Data;
Correct incomplete, inaccurate or outdated personal data;
Obtain information about the anonymization, blocking or deletion of unnecessary, excessive or processed data that does not comply with the provisions of current legislation;
Obtain information about the portability of your personal data to another service or product provider, upon express request, in accordance with current legislation;
Request the deletion of personal data processed with your consent, except in the cases provided for in current legislation;
Request details of the public and private entities with which we share your Personal Data;
Obtain information about the possibility of not providing consent and the consequences of such refusal;
Revoke consent for the processing of your Personal Data, except in the cases provided for in current legislation;
Other rights of the holder of personal data, in accordance with current legislation.
To do this, we ask that You contact us using the following channels:
Responsible for Processing Personal Data:
Full Name: Ricardo Alexandre Raschiatore
email: privacy@softtrack.com.br
55 19 9 7420-1371
Privacy Portal:
www.softtrack.com.br/privacidade
By phone:
55 19 2517-0215
In person or by snail mail:
Av. Dr. Antonio Carlos Couto de Barros, 2350 – Jd Conceição (Sousas) – Campinas – SP. ZIP code: 13.105-000
SOFTRACK will receive, investigate and respond, within a period considered reasonable, to any request or complaint about the way in which We treat your Personal Data, including complaints about disrespect for your rights under current privacy and Personal Data protection laws.
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