Privacy and Personal Data Protection Policies

Hello, TRAKTO user. This is our Privacy Policy, based on Law No. 13,709 of August 14, 2018, of the Federative Republic of Brazil (“General Data Protection Law – LGPD”).

Personal data

“Personal data” refers to information that identifies or can identify the individual user. Personal data may be provided to TRAKTO either by the user directly or by a third-party data operator who shares this information with us. Depending on the services contracted, personal data may, in exceptional cases, include information related to a particular sensitive condition of the individual.

Sensitive Personal Data

“Sensitive personal data” refers to information about racial or ethnic origin, religious beliefs, political opinions, membership in a union or in a religious, philosophical, or political organization, data related to health or sexual life, as well as genetic or biometric data, when linked to a natural person (individual). For more detailed information regarding the collection, purpose, and control of sensitive personal data, please refer to the specific section of this document on sensitive data.

Personal Data Controller

“The ‘controller’ is the natural person or legal entity responsible for making decisions regarding the processing of personal data.”

1. User consent for the collection, storage, and processing of Personal Data

The collection, storage, and processing of personal data by TRAKTO is based on the LEGAL BASIS of CONSENT provided by the data subjects. Further details about the effects of CONSENT and how to revoke it are explained throughout this privacy policy document.

2. Personal Data collected by TRAKTO

2.1. User Personal Data
As a general rule, the platform collects only the user’s name and email address as personal data, for the purpose of user identification. However, TRAKTO uses Google Analytics to collect and process data. Google Analytics is a web analytics service that identifies your browsing patterns on our site and generates reports on these activities so that we can improve it. To do this, personal data about how you use the site is collected and shared, according to Google’s policies available at https://www.google.com/intl/pt-BR/policies/privacy/partners/, https://policies.google.com/privacy, and https://policies.google.com/terms, with which the User must also agree by accepting this Privacy Policy.Any use made by Google or its partners of the User Data collected through this tool is the sole and exclusive responsibility of Google, and TRAKTO is exempt from any liabilities resulting from such use by Google.TRAKTO also collects and stores public data from user profiles on the FACEBOOK platform only when users register on TRAKTO using FACEBOOK (www.facebook.com).

3. Use of personal data by (Company Name)

TRAKTO uses the personal data collected to provide the best possible service to its Users, which may include:

- Making non-automated decisions regarding the services accessed by users, within the parameters defined in the Terms of Use;

- Continuously promoting and testing the quality of our offered services;

- Managing our infrastructure and service operations, complying with internal policies and procedures for accounting audits, finance, IT system regulation, and general internal and external compliance standards, always aiming to provide the best service to our users;

- Addressing complaints, claims, and requests made by users of our services directly with TRAKTO, in accordance with the considerations present in this Privacy Policy;

- Complying with legislation and other national and international regulations and regulatory frameworks, and responding to judicial or administrative requests from the Judiciary or competent government bodies, such as the National Data Protection Authority (ANPD);

- Protecting our operations, trade secrets, or industrial secrets, and safeguarding ourselves from possible damages, including defending our business against credit fraud, under the terms of Article 7, item X of the General Data Protection Law.

As previously informed, TRAKTO uses your personal data for a variety of different purposes, all of which adhere to the regulatory principle of providing services to Users.

4. Processing of Sensitive Personal Data

TRAKTO does NOT collect, store, or process sensitive personal data from Users, except for sensitive personal data that is publicly available on users' profiles on the FACEBOOK platform.

5. Retention and Processing of Personal Data

TRAKTO ensures that appropriate procedures are in place to manage your personal data and to delete, anonymize, or archive it when necessary. In general, TRAKTO retains your personal data only in order to:

- Fulfill the purposes outlined in this Privacy Policy;

- Comply with our legal or regulatory obligations and protect our rights under applicable law.

When a User declares that they no longer wish to access our services, TRAKTO commits to deleting all personal data, EXCEPT when it is necessary to retain certain data for a specific period in order to comply with legal or regulatory obligations imposed on us, or when the data is used based on legitimate interest, strictly aligned with the purposes described under this legal basis (Articles 10 and following of Law No. 13,709, of August 14, 2018 – the Brazilian General Data Protection Law).

For more information regarding the retention and processing of your data, please contact us through our customer support channels.

6. Your Rights Regarding Your Personal Data

As the data subject, you—the user—have rights protected under Brazilian law, which we fully respect, especially those provided by Law No. 13,709/2018 – the General Data Protection Law (LGPD). Your rights as a user include:

- The right to confirm the existence of processing of your personal data;

- The right to access your personal data that we process or store;

- The right to correct incomplete, inaccurate, or outdated data;The right to anonymize, block, or delete data deemed unnecessary or excessive, as per applicable legal regulations;

- The right to data portability, upon express request, in accordance with regulations set by the National Data Protection Authority (ANPD), while safeguarding our trade and industrial secrets;

- The right to delete personal data processed with your consent, except in situations that permit data retention as provided in Article 16 of Law No. 13,709/2018 – LGPD;

- The right to be informed about public and private entities with whom we share your personal data for the purpose of providing our services, within the limits and terms set by law and the ANPD;

- The right to be informed about the possibility of not providing consent and the consequences of such refusal;

- The right to withdraw your consent, under the terms provided by Law No. 13,709/2018 – LGPD.

7. Personal Data Security

TRAKTO is committed to adopting appropriate technical, physical, organizational, and legal measures, in accordance with national data protection legislation, to safeguard your personal data.

8. Changes to the Privacy Policy

Throughout the provision of our services, changes may occur in our Privacy Policy in order to adjust to technical or legal requirements related to our services. In the event of any changes to TRAKTO’s Privacy Policy, the User will be directly and expressly informed, at which point they may renew their consent and exercise their legal rights.
The Terms of Use, Privacy Policy, and Cookie Policy are up to date and in compliance with Brazilian Law No. 13,709/2018 – the General Data Protection Law (LGPD).By accepting the Terms of Use, you, the user, consent to TRAKTO collecting, processing, and storing your personal data, including, when necessary, sensitive personal data.TRAKTO commits to using your personal data strictly for the purpose for which it was collected, or, when applicable, to comply with legal or regulatory obligations imposed on us by law, in accordance with Article 7, Item II of Law No. 13,709/2018 – General Data Protection Law.

Contact

Through the support chat on the platform itself at www.trakto.io
Sincerely,
The TRAKTO Team