EN 
PT 
ES Last update September 19, 2022
Privacy Policy
We, from Smart Research (“Company” or “Smart”), registered with the CNPJ/ME (registered number) under n. 33.828.467/0001-83 and headquartered at Scopa Platinum Corporate, R. Monsenhor Bruno, 1153, 7 andar, sala 720 – Aldeota, ZIP CODE 60115-191 Fortaleza/CE,
Brasil, we take your privacy and the protection of your data seriously and are committed to guaranteeing your rights.
Therefore, this document explains how we process your personal data, what your rights are and how you can exercise them.
Why do we process your personal data?
Our platform allows the user to follow the research carried out in favor of the company to which he belongs, in an interactive and visual way, optimizing his results.
In order for us to offer this service, we need to process some personal data (the treatment of which will be detailed throughout this document), in order to, among other activities, perform registration, identification of the user and contact with him.
1. WHAT IS NEEDED TO UNDERSTAND THE PRIVACY NOTICE?
Before we begin, let’s agree on some formalities about the terms we will use in this “Notice” or “Privacy Policy”. We list below some concepts and definitions that will be used throughout this document. These are concepts and definitions used by the General Data Protection Law and other regulations on this topic. When these terms are used, they will be capitalized:
| Tem | Definition |
|---|---|
| Notice | It is this document: Privacy Notice. |
| Personal Data Art. 5º, I, LGPD | It is any information relating to a natural person that can identify that person or making his identification possible. Examples of personal data that may allow your identification are Name, CPF, address, telephone, e-mail, etc. |
| Controller Art. 5º, VI, LGPD | It is the individual or legal entity, public or private, who can decide on the purpose and processing of data. In this case, as a rule, the Controller will be the Condominium for which we provide services. |
| Company | It’s us, Smart Research. |
| Operator Art. 5º, VII, LGPD | It is the natural or legal person, public or private, that performs the processing of data on behalf of the Controller. In this case, as a rule, the Operator is Smart Research, as we process the personal data of the joint owners on behalf of the Controller. |
| Processing Art. 5º, X, LGPD | It is every form of use that we may make of your Personal Data, including, but not limited to, the following activities:collection, storage, consultation, use, sharing, transmission, classification, reproduction, deletion, and evaluation. This term (and other derivatives thereof) will not be capitalized in this document. |
| Holder Art. 5º, V, LGPD | It is the natural person to whom the data refer. |
2. WHAT TYPES OF PERSONAL DATA DOES THE COMPANY HANDLE?
The types of Personal Data we process are those that directly relate to the service we provide, as well as those that, by law or another rule, we are required to process. We process data from some types of users, they are: i) Customer representatives (Legal Entities that hire Smart Research to carry out and monitor market and product research).
We do not need to process sensitive personal data. If we do process them, we will amend this Notice to inform you what data we process and how we do so.
We list below some situations in which we may process your Personal Data in the context of the relationship you have (may have) with us:
| Data Types | Data | Purpose |
|---|---|---|
| Registration data | Name, Email, Position and Company | User identification in the registration and use of the platform, as well as contact for any questions or requests. |
| Tracking data | Device IP | Data necessary to identify the device used to access the platform, aiming at the safety of the user. |
We may also, during access to the platform, make use of technologies (such as cookies) that collect data considered personal. Cookies are small files placed on your device to store data that can be retrieved by a web server in the domain that placed the cookie. We use this technology to store and honor your preferences and settings, fight fraud, analyze the performance of our products, and fulfill other legitimate purposes.
Necessary cookies are essential for the website to function and therefore cannot be disabled. Are they:
- User identifier (token) data;
- User language data;
- Data about the browser used;
- Domain, start timestamp (first visit), last timestamp (last visit), current timestamp
- (current visit) and number of sessions;
- Browsing behavior;
- Browsing history;
- Distinction of Users;
- First navigation;
- Registration and navigation data;
- Registration data via IP address; and
- Data for navigability tuning and optimization.
Minors’ data
We do not knowingly collect personal data from children and adolescents (under 18 years of age). If we become aware that a minor has submitted information to the Company, we will delete that information immediately.
We encourage parents to instruct their children never to give out their real names, addresses or telephone numbers without permission when using the Internet.
3. WITH WHOM WE SHARE PERSONAL DATA
In order to carry out our activities in the best possible way, we operate in partnership with other organizations. We work in partnership with these companies as they are specialized in certain services (such as Cloud Storage), which improves the quality of the service.
We describe below the situations and companies with which we share personal data:
| Our partners |
|---|
| Amazon AWS Serviços Brasil Ltda. ( https://aws.amazon.com/pt/privacy/?nc1=f_pr ) Company responsible for storing personal data. |
Our partners may subcontract and share data with third-party companies (such as Cloud computing services, for the purpose of improving the service, as well as keeping the data intact, available, and secure). In these cases, we adopt strict rules, so that the same criteria for processing data that we adopt are required from subcontractors.
In addition, we may share some personal data depending on judicial authorization or legal requirement.
4. YOUR RIGHTS AS A HOLDER OF PERSONAL DATA
The General Data Protection Law (LGPD) grants you several rights, as personal data is yours. We are committed and concerned about your privacy and the protection of personal data, for that reason we list your rights below, as guaranteed by law.
| Your rights | Explanation |
|---|---|
| Confirmation and Access | Confirmation and Access You can ask the Company to confirm that your Personal Data is being processed so that, if so, you can access it, including by requesting copies of the records we hold about you. |
| Correction | You can request correction of your Personal Data if it is incomplete, inaccurate, or out of date. |
| Anonymization, blocking or deletion | You can request:
|
| Information about sharing | You have the right to know which are the public and private entities with which the Company makes shared use of your Personal Data. Above, in topic 3 of this Notice, there is an indication of our relationships with third parties that may involve the sharing of Personal Data. In any case, if you have questions or want more details, you have the right to ask us for this information. Depending on the case, we may limit the information provided to you if its disclosure could violate our intellectual property or business secret. In addition, the CONTROLLER may share its data with other entities, in which case, it is necessary to contact them to obtain this information. |
| Information about the possibility of not consenting | You have the right to receive clear and complete information about the possibility and consequences of not providing consent, when requested by the Data Controller. Your consent, when necessary, must be free and informed. Therefore, whenever your consent is requested, you are free to deny it – in these cases, it is possible that some services cannot be provided. |
| Revocation of Consent | If you have consented to the processing of your Personal Data for any purpose, you can always choose to withdraw your consent. However, this will not affect the legality of any Treatment carried out prior to revocation. If you withdraw your consent, we may be unable to provide you with certain services. |
| Objection | The law authorizes the processing of Personal Data even without your consent or a contract. In these situations, we will only process your Personal Data if we have legitimate reasons to do so, for example, when necessary to ensure the security of our application. If you do not agree with any purpose of processing your Personal Data, you may object, requesting its interruption. |
IMPORTANT NOTICES
- For your security, whenever you submit a request to exercise your rights, we may request certain additional information and/or documents so that we can prove your identity in order to prevent fraud.
- In some cases, the Company may have legitimate reasons for failing to comply with a request to exercise rights. These situations include, for example, cases where a disclosure of specific information could violate the Company’s or third parties’ intellectual property rights or business secrets.
If you have any questions about these points, or other questions about your rights, feel free to contact us through the channels provided at the end of this Notice.
5. HOW LONG WILL PERSONAL DATA BE STORED?
Personal Data is only stored for as long as necessary to fulfill the purposes for which it was collected, unless there is any other reason for its maintenance such as compliance with legal, regulatory, contractual, among others permitted by law.
We always carry out a technical analysis to determine the appropriate retention period for each type of Personal Data collected, considering its nature, need for collection and purpose for which it will be processed, as well as any retention needs for the fulfillment of obligations or the rights protection.
6. HOW DO WE PROTECT YOUR PERSONAL DATA?
Our responsibility is to take care of your Personal Data and use it only for the purposes described in this Notice. To ensure your privacy and the protection of your Personal Data, we have adopted the necessary technological and administrative resources to ensure the security of all data processed by us. Among the technical and administrative security measures implemented are: authentication through Token (through approaches such as JWT), access controls to data processing systems and environments, encryption techniques and the installation of barriers against unauthorized access to databases (including firewalls), among other information security controls.
We also adopt clauses and terms related to the Protection of Personal Data with our partners and customers, in order to ensure that they have at least the same concerns and care for the privacy and protection of the customers’ personal data.
In addition, we internally adopt Privacy Policies, Data Protection Agreements with our employees who interact with personal data, as well as Information Security and Incident Response Policies, in accordance with the guidelines of the National Authority for the Protection of Personal Data.
UNDER NO CIRCUMSTANCES DO WE SELL, RENT, OR SHARE THE PERSONAL DATA WE PROCESS.
We strive to protect the privacy of your Personal Data, but unfortunately, we cannot guarantee complete security. Unauthorized entries and uses by third parties of your information, hardware or software failures that are not under our complete control, and other external factors may compromise the security of your Personal Data.
Therefore, its performance is essential for maintaining a safe environment for everyone. If you identify or become aware of any factor that compromises the security of your data in your relationship with us, please contact us using the contact information indicated below.
7. HOW DO I CONTACT ABOUT PERSONAL DATA?
If you believe that your Personal Data has been processed in a way that is incompatible with this Policy or with your choices as the Subject of your Personal Data, or if you have questions, comments or suggestions related to this Policy and the way we handle your Data, please contact us.
We have a Data Protection Officer who is available at the following contact addresses:
| Mailing address: | Scopa Platinum Corporate, R. Monsenhor Bruno, 1153, 7 andar, sala 720 – Aldeota, CEP 60115-191 Fortaleza/CE, Brasil |
| Contact email: | privacy@smartmresearch.com |
8. CHANGES TO THIS PRIVACY NOTICE
As we are always looking to improve our services and the way we operate, this Privacy Notice may undergo certain updates, in order to reflect the improvements made and eventual additions to our services.
Therefore, we recommend that you periodically visit this page so that you are aware of the changes made.
© 2022 Smart Research, All rights reserved.