Privacy Policy
Last updated on June 25, 2022
This “Rabbot Privacy Policy” (“Privacy Policy”) aims to provide a transparent view of the practices related to the Processing of Personal Data by RABBOT SERVICIOS DE TECNOLOGIA S.A.1 (“Rabbot”), especially Personal Data Processed in connection with our Platforms, such as: https://www.rabbot.co (“Main Site”), on a secondary site that is in the Main Site subdomain, on a software as a service model platform (“SaaS Sites” and, together with Site Principal, the “Sites”), in the Rabbot APP application (“Application”) ) and/or the Rabbot RPA - Robotic Process Automation software (“Software” and, together with Sites and Application, “Rabbot System”). Rabbot Treats Personal Data in various ways, as specified below, under the terms of the General Data Protection Law (“LGPD”), always with the objective of balancing the adequate provision of our services and compliance with legal obligations regarding the Personal Data it controls. New services may be developed and offered. If the introduction of these results in any significant change in the way in which we collect or Process the User's Personal Data, we will provide more information, terms or additional policies. Reading, understanding and acceptance of this Privacy Policy, as well as of our General Terms of Contract (“Terms”), is essential for the User to be able to use the Platform. If you do not agree to the terms set out here, please do not use the Rabbot Services.1 Definitions Unless otherwise defined in this Privacy Policy, the terms capitalized here have the same meaning ascribed to them below, in the Terms, or in the Service Agreement. “ANPD” National Data Protection Authority. 1 RABBOT SERVIÇOS DE TECNOLOGIA S.A., a joint-stock company with headquarters at AV. Faria Lima, 1755 - Box 06 - São Paulo - SP, CEP: 01452-001, registered with the CNPJ under number 32,254,779/0001-68. “Controller” the individual or legal entity responsible for decisions related to the Processing of Personal Data. “Customer” means the legal entity that is a client of Rabbot. “Personal Data” information related to the identified or identifiable natural person, relating to the Users. “Operator” means an individual or legal entity that processes Personal Data on behalf of the Controller. “Platforms” following Rabbot Platforms: Main Site, SaaS Site, Application and Software. “User” represents an individual person of the Rabbot Client who accesses our Platforms. “Rabbot Services” services offered through the Platforms. “Data Subject” or “Holder” natural person to whom the Personal Data that are subject to Treatment refer. “Treatment”, “Treat” and “Treated” any operation carried out with Personal Data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer. “Third Party” natural person whose Personal Data may be Processed by Rabbot, including people who had their data entered by the Customer on the Platforms.
2. PROCESSING OF PERSONAL DATA BY RABBOT2.1. The Rabbot Client acts as Controller in relation to the Personal Data of Users and Third Parties that it enters on the Platforms, and it is certain that Rabbot acts as the Operator for the Treatments related to the Personal Data of Third Parties on the Platforms. ArabBot does not have any control over the decision of which Personal Data will be collected from Users or entered by them into the Rabbot 2.2 System. Rabbot acts as a Controller when carrying out Treatments aimed at complying with a legal obligation, communicating with Holders, improving the performance of the Platforms.2.3. To learn more about what Personal Data are Processed and their respective purposes, below is a table indicating the main Personal Data Processing activities. This table summarizes in a practical way the main uses we make of your Personal Data. Data Subject Form of Collection Personal Data Processed Purposes Visitors to the Main Site Provided by the Owner through the Site Name; Email; and Telephone To enable contact with the representative of the company that is interested in being a customer. Visitors to the Site automatically collected when visiting the Site User's access browser; Internet protocol (“IP”) address; date and time of access; location of the User; and the User's actions on the Site. Comply with the Site with legal obligation From the Civil Internet Framework Customers, potential customers and third parties Provided by the Owner Personal Data that are entered in the communications, such as e-mail, name, telephone number, social network profile and communication applications, such as WhatsApp and Telegram. Enable communication and clarification between Rabbot and Users Enable the sending of newsletters and communications to Users, as they may register on the respective registration held on the site Third Party Users collected by Rabbot through the use of the Software by the Users of Service Providers: Name; CNPJ ; CPF; Email; Cell Phone; Segment; and Address. of Vehicle Drivers: for example, Name; Social Security Number; ID; E-mail; Cell Phone; and Address. Of the Client's employees: Name; Position; E-mail; and Address.● Enable storage in the Rabbot database in the Software, being certain that the data is collected through the daily use of the Users in the common administration of their business and stored by Rabbot and inserted into the Software Administered by the User as a form of organizing operational and logical processes ticos.● Enable Communication with Users, to keep them updated on new features and new possibilities for using the software. Users and third parties collected by Rabbot through the use of the Application by users. Name; Email; Cell Phone; ● Enable communication with Users, to keep them updated on new features and new possibilities for using the Software. ● Model of the device used; ● Amount of RAM available on the device used; ● Total space of the device used; ● Possible space of the device used; ● Location of the User by means of ● Provide and assist in the analysis of the occurrence of any open support calls by User; ● Allow device analysis to find performance and application stability improvements; geolocation tracking of the device used. 3. SHARING OF PERSONAL DATA.3.1. In addition to the item above, Rabbot may share the Personal Data contained in its databases to fulfill the purposes below: with whom we share the purpose of Service Providers for the execution of the contracted Rabbot Services, including technical service providers that operate the technical infrastructure we need to provide the Rabbot Services, in particular suppliers that host, store, manage and keep the Platform working, as well as the Platform database. In addition, we rely on the support of service providers in administrative routines, such as accounting firms, law firms, and other authorities for law enforcement, compliance with a court order: we will share the User's Personal Data when we believe it is necessary to comply with a legal or regulatory obligation, under applicable law, or to respond to a valid legal process, such as a search warrant, a court order or a subpoena. Third parties To enable the sale, in part or in full, of our business or of Our assets or actions (including in connection with bankruptcy or similar proceeding), or as part of any reorganization or restructuring of the business, merger, division, or incorporation, we may share Users' information with third parties that are part of the business, taking the necessary steps to ensure that privacy rights continue to be protected, in accordance with this Privacy Policy.4. INFORMATION SECURITY4.1. Rabbot uses technical and administrative measures to protect the personal data of unauthorized Users and from accidental or unlawful situations of destruction, loss, alteration, communication or dissemination of such data, consistent with the minimum data security standards provided for in article 46 of the LGPD.4.2. The access passwords and access keys to the Platform are stored in encrypted form, and it is certain that such information is protected with the securehash algorithm-2 (“SHA-2”) technology so that Users' Personal Data remains confidential, in order to prevent the information from being transmitted or accessed by third parties.4.3. Rabbot will immediately notify the ANPD of the occurrence of a security incident that may entail a relevant risk or harm to Users.
5. COOKIES5.1. Rabbot uses cookies and similar technologies, such as pixels and tags. The cookies collected by Rabbot only provide statistics and will not be used for purposes other than those expressly provided for in this Privacy Policy.5.2. Rabbot uses cookies for various purposes, including, but not limited to: (i) marketing actions for remarketing, a feature that allows us to reach Users or visitors to the Site to remind them to register with Rabbot or to easily access the platform again; and (ii) understand the behavior of using the Site and Software for better product development. 5.3. Rabbot uses companies specialized in the delivery of advertisements, inside and outside Rabbot, such as Google and Facebook. By accepting this Privacy Policy, the User agrees to the use of cookies by companies contracted by Rabbot for this purpose.5.4. Browsers generally allow the collection of cookies to be disabled. Thus, if the User does not change the cookie collection patterns of their browser, such User will be considered to agree to the collection of cookies.5.5. Consult your browser instructions or the help section to learn more about how to adjust or change your browser settings. Below, we provide links to some browsers that you can use so that you know how to change the cookie settings in such browsers: Firefox | Cookies, Safara | Cookies, Chrome | Cookies and Microsoft | Cookies.5.6. Disabling the cookies we use may impact your experience in our applications, for example, you may not be able to visit certain areas of our Platforms or you may not receive personalized information when you visit our Platforms.6. INTERNATIONAL TRANSFERS6.1. Rabbot is based in Brazil, but the Personal Data contained in our databases may be stored on third-party servers located in other countries. In this case, we guarantee that our subcontractors, service providers or partners will also be subject to the obligations of the LGPD.7. STORAGE AND DELETION OF PERSONAL DATA.7.1. Rabbot retains Personal Data for as long as necessary for the purpose for which it was made available, unless a longer period is made possible by another appropriate legal basis, such as compliance with a legal or regulatory obligation or for defense in legal proceedings, for example. The retention periods for Personal Data vary according to the purposes for which it was collected or subsequent legitimate purposes. Some of the criteria used by Rabbot to assess appropriate retention periods include: (i) the nature of the Personal Data and the activities involved, (ii) the Owner's interactions with Rabbot, and (iii) legal obligations.8. RIGHTS OF PERSONAL DATA SUBJECTS8.1. In relation to your Personal Data and Treatments carried out by Rabbot, the Data Controller has the rights indicated in the table below. Access Rights Request a copy of your data stored in our systems at any time. The Owner may request a copy: (1) of the categories of specific Personal Data that we collect about the Owner; (2) of the specific categories and sources from which the Personal Data is collected; (3) of the purpose of the collection of the Personal Data; and (4) of the specific categories and third parties with whom we share the Personal Data. Correction and Update Request the correction and updating of your Personal Data. If so, we will inform the third parties with whom your Personal Data has been shared of the correction and update. Portability Request transfer of your Personal Data from the Rabbot database to a third party. Revocation of consent Revoke consent granted, if applicable. In this case, the Data Subject will be informed of the consequences of revoking consent. Restriction, Opposition or Exclusion (i) Request the blocking of your data, temporarily suspending your ability to Process, (ii) object to the Processing of your Personal Data, if you suspect that they are Treated in non-compliance with the terms of this Privacy Policy, (iii) request the deletion of your data, in which case we will delete all your data without the possibility of reversing, except for the cases provided for by law. We may keep your Personal Data if necessary for (i) Stop to comply with applicable law; or (ii) to comply with a contract or to exercise our rights in judicial, administrative, or arbitral proceedings. Except in the cases mentioned, we will delete or keep your data anonymized (we will use the technique available at the time). Request for Review of Automated Decisions Request the review of decisions made solely based on automated Processing of your Personal Data. Currently, the Platforms do not make automated decisions based on Personal Data of Holders. Complaint to the ANPD Make complaints to the ANPD regarding Personal Data Treatments carried out by Rabbot. The Owner may contact the ANPD through the means indicated on the authority's website: ANPD — Portuguese (Brazil) (www.gov.br) 8.2. Proof of the identity of the Owner and/or his attorney is necessary so that we can guarantee the exercise of his rights. This is a security measure to ensure that Personal Data is not disclosed to anyone who has no right to receive it.9. FINAL PROVISIONS 9.1. From time to time, we may make changes to this Privacy Policy in order to keep you updated on our practices involving Personal Data Processing. When we make material changes to this Privacy Policy, we will make a visible and appropriate communication according to the circumstances.9.2. For the purpose of complying with the provisions of article 41 of the LGPD, Rabbot has already indicated the following as responsible for the Processing of Personal Data: Julio Eduardo Mena Herrera Address: Av. Brigadeiro Faria Lima, 1755 — Room 1 — 8th Floor - São Paulo - SP, CEP:01452-001. Telephone: (11) 4200-8008 E-mail: julio@rabbot.co 9.3. Rabbot elects and ratifies, through the acceptance of this Privacy Policy and the use of the Rabbot System, as the case may be, the District Court of the city of São Paulo, State of São Paulo, as the sole competent to resolve any questions or disputes arising from this Privacy Policy, expressly waiving any other, however privileged it may be or may be.9.4. This Privacy Policy is governed, materially and procedurally, by the laws of the Federative Republic of Brazil. São Paulo, June 25, 2022 RABBOT SERVIÇOS DE TECNOLOGIA S.A.
