This page was created to provide information about how we look after your information

2nd – SOFTRACK PRIVACY AND PERSONAL DATA PROTECTION POLICY
goal

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.