Privacy Policy

Reditech Automation is committed to complying with the laws that protect the data privacy of customers and the general public.  This page is designed to provide information on how we are following data protection regulations, what information we collect while you are browsing our communication channels, and how this information is collected, used, and protected by us, in accordance with Law No. 13,709/2018 (General Data Protection Law – “LGPD”). The use of our products and services, as well as our platforms, and other means of interaction made available, is conditioned upon the acceptance of this Privacy Policy, including with regard to our employees.

Source of Personal Data

Reditech Automation will have access to personal data in the following situations:

Through interaction with a customer:  When the Customer provides and inputs personal data necessary for the provision of services and use of products provided by Reditech Automation.
Interaction with its employees: When its employees and collaborators of any nature use its systems and platforms to comply with the duties and obligations arising from their contractual relationship.

2. Types of personal data and sensitive personal data collected

Without prejudice to the data commonly collected and processed from its employees for the purposes of their legal relationship, Reditech Automation may also collect the following personal data:

Names and contact data, such as first and last name, e-mail address, postal address, telephone number, and other similar types of contact data, such as bank details;
Device information, such as information about your device, such as IP address, location, or provider;
Usage information and browsing history, such as information on how the User navigates within our services, their browsing history, and which elements of Reditech Automation's services are most used;

Sensitive personal data, which may eventually be collected by Reditech Automation, will have its purpose informed separately to the User, who must consent to Reditech Automation using them in a specific manner, and in case of disagreement, the data will be automatically deleted from the databases of Reditech Automation.

Reditech Automation does not collect data from minors, except with the authorization of parents or guardians. If collected without authorization, as soon as Reditech Automation becomes aware, it will immediately delete the collected data, according to the rules of the Terms of Use and this Privacy Policy.

Use of collected personal data

When collected, Reditech Automation will use personal data to:

Provide and improve the contracted services;
Comply with a legal or regulatory obligation;
Manage the relationship with Users;
Configure and manage User accounts;
Provide technical assistance, support, and training to the User;
Contact Users;
Internal research and development purposes and to improve, test, and enhance the features and functions of Reditech Automation's services;
Provide Users with marketing, advertising, promotions, including from Partner companies of Reditech Automation, as permitted by law;
Meet internal and external audit requirements, including information security obligations of Reditech Automation;
Send email messages to: a) confirm or cancel requests through the use of the platform; b) communicate future changes that this policy may undergo; and c) announce updates, changes, additions of new data sources, and platform improvements;
To exercise the rights of Reditech Automation, including, but not limited to privacy, security, networks, systems, and properties of Reditech Automation and/or third parties;
Comply with requests from courts, law enforcement authorities, regulatory bodies, and other public institutions and governmental authorities, including, but not limited to, any rules in force outside the user's country of residence;
The exercise of Reditech Automation's rights and to defend against any legal actions, as well as to comply with any legislation or regulation applicable to Reditech Automation or third parties with whom we work, as well as for the proper performance of contracts signed between Reditech Automation and its users;

Sharing of personal data with third parties

The User accepts and agrees that Reditech Automation may share their personal data with the following categories of recipients:

Companies that provide access or are responsible for the registration on which the user is dependent;
Partner companies, such as third-party service providers and other companies that assist us in offering our services or that may take action on our behalf, protecting our rights, users, systems, and services;
Third parties to whom Reditech Automation owes an explanation or has authorization to disclose information by law (Example: government bodies, regulatory agencies, the judiciary, and other public authorities);
Third parties in order to participate in the sale, merger, acquisition, restructuring, joint venture, assignment, transfer of part or all of Reditech Automation's business, a hypothesis in which the User's data will be considered an asset and transferred in a possible negotiation;
Third parties who need the data to protect the rights of Reditech Automation;
Any natural or legal person to whom the User requests the portability of their data.

International transfer of personal data

Reditech Automation does not intend to transfer any of the User's personal data collected outside of Brazil. If it is not one of the hypotheses listed below, Users will be previously informed by email, at which time the user may or may not accept the transfer, and in case of disagreement, may have their access rights blocked by Reditech Automation.

The international transfer of data described in the General Data Protection Law (LGPD) requires the designation of guidelines to be established by the National Data Protection Authority (ANPD), while, when defined, Reditech Automation will commit to fully complying with them.

Protection of personal data

Reditech Automation uses appropriate technologies and procedures to protect any collected personal data (including administrative, technical, and physical safeguards) according to the level of risk and the service provided, having a legally responsible team to deal with secure data management in line with legal provisions, regulatory requirements, technological changes, among other relevant factors that may influence how personal data is protected.

Reditech Automation employs all reasonable market efforts to ensure the security of its systems and the collected data, using highly qualified and reputable Internet providers, database servers, and storage, in addition to security certificates (SSL) and software to protect against unauthorized access to the systems, as well as standard methods to encrypt and anonymize the collected data.

This Policy represents Reditech Automation's effort to safeguard the User's information. However, due to the very nature of the Internet, it is not possible to guarantee that malicious third parties will not succeed in improperly accessing the stored information, which is why, should this occur, Reditech Automation will be liable within the limits provided by law.

Reditech Automation, within a reasonable period to be defined by the National Data Protection Authority ("ANPD"), must notify the ANPD and the affected User of the occurrence of a security incident that may result in significant risk or damage to the affected User, mentioning, at a minimum:

a description of the nature of the affected personal data;
information about the data subjects involved;
an indication of the technical and security measures used for data protection, observing commercial and industrial secrets;
the risks related to the incident;
the reasons for the delay, in case the communication was not immediate; and
the measures that have been or will be adopted to reverse or mitigate the effects of the damage.

Data processing and responsibility of Reditech Automation

Reditech Automation will have its processing responsibility as follows:

When it comes to personal data provided directly by its Customers, Reditech Automation will act as the Operator, and will act without interference regarding the form of processing indicated by the Controller, but under the terms of the LGPD;
Reditech Automation will be the Controller of the Personal Data of its employees, processing them based on the Performance of Contracts, Compliance with a legal or regulatory obligation, and also, in specific and determined situations, on Consent.

Reditech Automation may adopt different legal bases for distinct processing of personal data.

Personal data processing period

Reditech Automation calculates the retention period for personal data according to the following criteria:

The period necessary to fulfill the purpose of the collection;
The moment the Customer/User stops using the services of Reditech Automation;
The moment consent is revoked or deletion of personal data is requested by the Data Subject;
The time necessary to demonstrate compliance with the duties and obligations of Reditech Automation;
The necessary period provided by law, regulations, judicial decisions, etc.;
Determination by the National Data Protection Authority;
Compliance with a legal or regulatory obligation by the Controller;
Perfect execution of the contract;
Needs related to compliance with the legal system, as well as for potential legal disputes;
Transfer to a third party, provided the data processing requirements set forth in law are respected; or
Exclusive use by the controller, prohibiting its access by a third party, provided the data is anonymized.

User Rights

According to the Brazilian General Data Protection Law, the User will have the following rights regarding the processing of their personal data:

Right to Confirmation: the User may confirm whether Reditech Automation processes any of their personal data;
Right of Access: the User may make a written request to obtain details on how their information is being used, as well as to have a copy of said information;
Right to Correction: the User may correct or remove any of their data that is incomplete, inaccurate, or outdated;
Right to Anonymization, blocking, or deletion: the User may request the anonymization, blocking, or deletion of unnecessary, excessive data or data processed in noncompliance with the purposes for which consent was given, observing, for this purpose, other norms of the legal system;
Right to Deletion: the User may request the deletion of certain data, except those for which the law authorizes their retention;
Right to Information: The User may request information from public and private entities with which Reditech Automation has shared their data, as well as the consequences should they choose not to consent to the collection and processing of their personal data;
Right to Opt-out of Marketing: The User may, at any time, request to cancel receiving advertisements and other materials through the link provided in the email marketing sent.
Right to Portability: The User may request that their personal data be transferred to themselves or third parties, except for those that have already been anonymized and deleted by Reditech Automation.
Right to Revoke Consent: The User may cancel any consent previously granted to Reditech Automation to use their personal data. The User is aware that the cancellation will not affect the use or sharing of data performed prior to the request for revocation of consent.

The rights provided for in this chapter are not absolute, and the User must, whenever they wish to exercise them, contact Reditech Automation through the channel: This email address is being protected from spambots. You need JavaScript enabled to view it.

Reditech Automation commits to attending to such requests as soon as possible and at no cost to the User, limited to a maximum period of 15 (fifteen) days, counting from the receipt of the request, unless a longer period is necessary to respond due to complexity, factual or legal reasons, at which time the User will be notified.

Reditech Automation will immediately communicate to the processing agents with whom it has shared the User's data regarding the correction, deletion, anonymization, or blocking of data, so that they may repeat the identical procedure.

The confirmation of existence or access to the User's personal data provided for in this chapter will be provided, electronically or expressly, in a simplified format or through a clear and complete declaration, indicating the origin of the data, the non-existence of a record, the criteria used, and the purpose of the processing, always observing the commercial and industrial secrets of Reditech Automation.

Cookies

Reditech Automation and any partners may use cookies and other similar technologies to store and manage User preferences, offer targeted advertising, enable content, and collect analytical and usage data, for example. The use of cookies and other tracking technologies is standard on websites and platforms, through which information about User activities on the platform, websites, or other services is collected.

A cookie is a small text file, placed on a computer or other device, used to identify the User, the device used, and to collect information, and may perform the following functions:

Strictly Necessary Cookies: these are essential to allow the User to navigate a platform and use its features.
Performance Cookies: they collect information on how the User uses the Reditech Automation platform and serve to improve navigation and enhance their experience. The information collected includes, for example, internet browsers and operating systems used, the domain name of the previously visited website, the number of visits, the average duration of the visit, and the pages viewed.
Functional Cookies: they allow the platform to remember choices the User has made (such as their username or ID, language preference, or the area or region where the User is located) and provide enhanced and more personal features.
Advertising Cookies: they track the User's browsing habits and are used to deliver targeted advertising. These cookies also limit the number of times you see an advertisement and measure the effectiveness of advertising campaigns. They also remember that the User has already visited a website and this information is shared with other organizations, such as advertisers.

Reditech Automation uses strictly necessary and performance cookies.

At any time, the User may disable Cookies through their browser settings, installing plug-ins available in the market, or using other technologies they deem necessary.

In addition to cookies, Reditech Automation uses other tracking technologies, such as:

Web Server and Platform Logs: Reditech Automation's servers automatically collect certain information to assist, administer, and protect the services offered, as well as to analyze usage and improve the User experience. The information collected includes:

IP address and browser type;
Device information, including Unique Device Identifier (UDID), MAC address, Identifier for Advertisers (IFA), and similar identifiers assigned by us or by third parties;
The device's operating system and other technical data;
The city, state, and country from which you are accessing the platform, including for fraud prevention;
Information or text typed;
Links and buttons clicked;

Connections via Social Networks: Some of Reditech Automation's services may include social network features, such as Facebook "Like" buttons and widgets; "Share" button and interactive mini-programs.

Reditech Automation may allow the User to choose to use their own social network logins to access some of the services offered, a hypothesis in which Reditech Automation may receive and store authentication information from these services.

Contact Information

Questions, comments, suggestions, and/or complaints regarding this Privacy Policy, as well as any need for information, alteration, or deletion of personal data, may be made by the User directly to Reditech Automation, by e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it.

Changes

Reditech Automation seeks constant updates and improvements, therefore this Privacy Policy may be updated at any time, always aiming for better provision and protection for users.

In the event of changes that affect the purpose and duration of the processing of the User's personal data, the User will be informed via the email registered in our services or through the platform itself 30 (thirty) days in advance. Should there be disagreement with the changes, the User may revoke the consent provided, rendering them unable to use the services of Reditech Automation.

If in the future Reditech Automation changes its policy to share data with third parties, it will send a notice 30 (thirty) days in advance to the user through the registered email, and the user may disagree with the sharing, in which case they will continue to use the services of Reditech Automation.

The User is advised to periodically read this policy to stay updated on its content.

Legislation and Jurisdiction

This Policy will be governed, interpreted, and executed in accordance with the laws of the Federative Republic of Brazil, regardless of any conflicts of these laws with laws of other states or countries, with the Jurisdiction of São Paulo being competent to resolve any doubts arising from this instrument, waiving any other, however privileged it may be.