We use your personal data to provide and improve the Service. By using the Service, you consent to the collection and use of information in accordance with this Privacy Policy.
Words whose initial letter is capitalized have meanings defined under the following conditions. The following definitions have the same meaning regardless of whether they appear in the singular or plural.
For the purposes of this Privacy Policy:
(a) “Account” means a unique account created for you to access our Service or portions of our Service.
(b) “Company” (referred to herein as “Company”, “We”, “Us” or “Our”) means SMARTDINK TECHNOLOGY LTDA, a São Paulo company with registered office at Rua Coronal Joviniano Brandão, 100 – Vila Prudente, São Paulo – SP, CEP: 03127-175. For the purposes of the LGPD, the Company is the Data Controller.
(c) “Cookies” are small files that are placed on your computer, mobile device or any other device by a website, containing details of your browsing history on that website, among other uses.
(d) “Personal Data” means any information that relates to an identified or identifiable person. For the purposes of the LGPD, Personal Data means any information relating to you, such as your name, identification number, location data, online identifier, or one or more factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity.
(e) “Device” means any electronic device that can access the Service, such as a computer, a mobile phone, or a digital tablet.
(f) “Data Controller”, for the purposes of the LGPD, means the Company as a legal entity that, alone or jointly with others, determines the purposes and means of the processing of Personal Data.
(g) “Service Provider” means any natural or legal person who processes the data on behalf of the Company. Refers to third-party companies or individuals employed by the Company to facilitate the Service, provide the Service on behalf of the Company, perform Service-related services, or assist the Company in analyzing how the Service is used. For the purposes of the LGPD, Service Providers are considered Data Processors.
(h) “Service” means the online and/or mobile services, website, and software provided in connection with the service provided by SmartDink under this Agreement and as detailed on SmartDink’s website at (https:// smartdink.com).
(i) “Social Media Third Party” means any website or social networking site through which a user may log in or create an account to use the Service.
(j) “You” means the individual accessing or using the Service, or the company or other legal entity on behalf of which such individual accesses or uses the Service, as applicable. Under the LGPD, you may be referred to as the Data Subject or as the User, as you are the individual using the Service.
(a) Personal Data
When using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:
(b) Usage Data
Usage Data is collected automatically when you use the Service.
Usage Data may include information such as your Device’s IP address (e.g., IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.
When you access the Service through a mobile device, we may automatically collect certain information, including, but not limited to, the type of mobile device you use, your mobile device’s unique ID, your mobile device’s IP address, your mobile operating system, the type of mobile internet browser you use, unique device identifiers and other diagnostic data.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service through a mobile device.
(c) Social Media Third-Party Information
The Company allows you to create an account and log in to use the Service through the following Social Media Third Parties:
If you decide to register for or grant access to a Social Media Third Party, we may collect personal data already associated with your Social Media Third Party’s account, such as your name, email address, activities, or contact list associated with that account.
You may also have the option to share additional information with the Company through your Social Media Third Party account. If you choose to provide such information and Personal Data, during registration or otherwise, you are giving the Company permission to use, share, and store such information in a manner consistent with this Privacy Policy.
(d) Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track activity on our Service and store certain information. The tracking technologies used are beacons, tags, and scripts to collect and track information and improve and analyze our Service. The technologies we use may include:
Cookies can be either “Persistent” or “Session”. Persistent Cookies remain on your personal computer or mobile device when you go offline, while Session Cookies are deleted as soon as you close your web browser. Learn more about cookies: What are cookies?
We use Session and Persistent Cookies for the following purposes:
1.Necessary/Essential Cookies
2.Policy Cookies/Acceptance Notice
3.Functionality Cookies
4.Tracking and Performance Cookies
5.Targeting and Advertising Cookies
For more information about the cookies we use and your choices regarding cookies, please visit our Cookie Policy or the Cookies section of our Privacy Policy.
(e) Use of your personal data
The Company may use personal data for the following purposes:
We may share your personal information in the following situations:
(f) Retention of your personal data
The Company will retain your personal data only for as long as necessary for the purposes set out in this Privacy Policy. We retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period, except when this data is used to strengthen the security or improve the functionality of our service, or when we are legally obligated to retain this data for longer periods.
(g) Transfer of your personal data
Your information, including personal data, is processed at the Company’s operating offices and any other locations where the parties involved in the processing are located. This means that this information may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or country unless there are adequate controls in place, including the security of your data and other personal information.
(h) Disclosure of your personal data
1.Business Transactions
If the Company is involved in a merger, acquisition, or sale of assets, your personal data may be transferred. We will inform you before your personal data is transferred and becomes subject to a different privacy policy.
2.Law enforcement
In certain circumstances, the Company may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).
3.Other legal requirements
The Company may disclose your personal data in the good faith belief that such action is necessary to:
(i) Security of your personal data
The security of your personal data is important to us, but please remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.
The service providers we use may have access to your personal data. These third-party vendors collect, store, use, process, and transfer information about your activity on our service in accordance with their privacy policies.
(a) Analysis
We may use third-party service providers to monitor and analyze the use of our service.
1.Google Analytics
2.Firebase
3.Google AdSense e DoubleClick Cookie
4.Facebook
5.Linkedin
(b) Email Marketing
We may use your personal data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt-out of receiving any or all of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
We may use email marketing service providers to manage and send emails to you.
(c) Payments
We may offer paid products and/or services within the service. In this case, we may use third-party services for payment processing (e.g., payment processors).
We will not store or collect your payment card details. This information is provided directly to our third-party payment processors, whose use of your personal information is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSS, managed by the PCI Security Standards Council, which is a joint effort of brands such as Visa, Mastercard, American Express, and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
(d) Behavioral remarketing
The Company uses remarketing services to advertise to you after you have accessed or visited our Service. We and our third-party vendors use cookies and non-cookie technologies to help us recognize your device and understand how you use our service, so that we can improve our service to reflect your interests and serve you ads that are likely to be of most interest to you.
These third-party vendors collect, store, use, process, and transfer information about your activity on our service, in accordance with their privacy policies and to enable us to:
Some of these third-party vendors may use non-cookie technologies that may not be affected by browser settings that block cookies. Your browser may not allow you to block these technologies. You can use the following third-party tools to opt out of the collection and use of information for the purpose of serving interest-based advertising:
You can opt out of receiving all personalized advertising by turning on privacy features on your mobile device, such as Limit Ad Tracking (iOS) and Opt Out of Personalized Ads (Android). Please refer to your mobile device’s help system for more information.
We may share information, such as encrypted email addresses (if available) or other online identifiers collected on our service with these third-party vendors. This allows our third-party vendors to recognize and deliver ads across different devices and browsers. To learn more about the technologies used by these third-party vendors and their cross-device capabilities, please refer to each vendor’s privacy policy listed below.
The third-party providers we use are:
1.Google Ads (AdWords)
2.Twitter
3.Facebook
(a) Legal basis for processing personal data under the LGPD
We may process personal data under the following conditions:
In any case, the company will be happy to help clarify the specific legal basis that applies to the processing and, in particular, whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
(b) Your rights under the LGPD
The company is committed to respecting the confidentiality of your personal data and ensuring that you can exercise your rights.
You have the right, in accordance with this Privacy Policy and by law, if you are located in Brazil, to:
(c) Exercising your LGPD data protection rights
You can exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will do our best to respond as quickly as possible.
You have the right to lodge a complaint with a Data Protection Authority about our collection and use of your personal data. For more information, if you are in Brazil, please contact your local data protection authority.
(a) Legal basis for processing personal data under GDPR
We may process personal data under the following conditions:
In any case, the company will be happy to help clarify the specific legal basis that applies to the processing and, in particular, whether the provision of personal data is a legal or contractual requirement, or a requirement necessary to enter into a contract.
(b) Your rights under the GDPR
The company is committed to respecting the confidentiality of your personal data and ensuring that you can exercise your rights.
You have the right, in accordance with this Privacy Policy and by law, if you are in the EU, to:
(c) Exercising your GDPR data protection rights
You can exercise your rights of access, rectification, cancellation and opposition by contacting us. Please note that we may ask you to verify your identity before responding to these requests. If you make a request, we will try to respond as quickly as possible.
You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
We may share your personal information identified in the above categories with the following categories of third parties:
(a) Sale of personal information of minors under the age of 16
We do not sell personal information from consumers we know to be under 16 years of age, unless we receive affirmative consent (the “right to opt-in”) from the consumer who is between 13 and 16 years of age or the legal guardian of a consumer under 13 years of age. Consumers who opt out of the sale of personal information may opt out of future sales at any time. To exercise the right to opt out, you (or your authorized representative) may submit a request to us by contacting us.
If you have reason to believe that a child under the age of 13 (or 16) has provided us with personal information, please contact us with sufficient detail so that we can delete that information.
(b) Your rights under the LGPD
The LGPD grants residents of Brazil specific rights related to their personal information. If you are a resident of Brazil, you have the following rights:
– The categories of personal information shared
– Complete the transaction for which we collected the personal information, provide a good or service requested by you, take actions reasonably anticipated in the context of our ongoing business relationship with you, or otherwise perform our contract with you.
– Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
– Conduct scientific, historical, or statistical research in the public interest that complies with all other applicable privacy and ethical laws and standards, where deletion of the information would likely make it impossible or seriously impair the scope of the research, if you have previously given informed consent.
– Comply with a legal obligation.
– Make other internal and lawful uses of this information that are compatible with the context in which you provided it.
– Deny you goods or services
– Charging different prices or rates for goods or services, including using discounts or other benefits or imposing penalties
– Provide a different level or quality of goods or services to you
– Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services
(c) Exercising your LGPD data protection rights
To exercise any of your rights under the LGPD and if you are a resident of Brazil, you can contact us:
By email: hello@smartdink.com
Your request to us must:
We cannot respond to your request or provide you with the necessary information if we are unable to:
We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The deadline to provide the necessary information may be extended once for an additional 45 days, when necessary and with prior notice.
Any disclosures we provide will only cover the 12-month period prior to receipt of the verifiable request.
For data portability requests, we will select a format for providing your personal information that is easily usable and allows you to transmit the information from one entity to another without hindrance.
(d) Do Not Sell My Personal Information
You have the right to opt out of having your personal information sold. Once we receive and confirm a verifiable consumer request from you, we will stop selling your personal information. To exercise your right to deletion, please contact us.
Please note that any opt-out is specific to the browser you use. You may need to opt out in all browsers you use.
1.Website
Opting out will place a cookie on your computer that is unique to the browser you use to opt-out. If you switch browsers or delete the cookies saved by your browser, you will need to opt out again.
2.Mobile Devices
Your mobile device may give you the option not to use information about the apps you use to serve ads targeted to your interests:
You can also stop the collection of location information from your mobile device by changing the preferences on your mobile device.
Our service does not respond to Do Not Track signals.
However, some third-party websites keep track of your browsing activities. If you are visiting these websites, you can set your preferences in your web browser to tell the websites that you do not want to be tracked.
Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not allow or require removal in certain circumstances.
(a) Links to Other Websites
Our Service may contain links to other websites that are not operated by Us. If you click on a third-party link, you will be directed to that third-party’s website. We strongly encourage you to review the Privacy Policy of every website you visit.
We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services.
(b) Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will inform you of any changes by posting the new Privacy Policy on this page.
We will inform you via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “Last Updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for changes. Changes to this Privacy Policy are effective when they are posted on this page.
(c) Contact Information
If you have any questions about this Privacy Policy, you can contact us by email: hello@smartdink.com
Smartdink adopts high security standards to protect its users’ personal data and prevent incidents. However, it is important to emphasize that no virtual platform is completely risk-free. In this context, Smartdink is not responsible for the following cases:
I – Actions or omissions of users related to their own personal data:
Consequences arising from negligence, recklessness or lack of skill on the part of users in protecting their personal data.
The responsibility for the security of their access data, such as passwords, lies exclusively with the user.
Smartdink guarantees the security only of data processing processes carried out under its management and for the purposes described in this policy.
II – Malicious actions by third parties:
Security incidents resulting from hacker attacks or other malicious actions by third parties, except when there is proven culpable or willful conduct on the part of Smartdink.
In the event of security incidents that may pose a risk or significant damage to users or customers, Smartdink undertakes to promptly notify those affected and the National Data Protection Authority (ANPD), adopting all appropriate measures to mitigate the damage.
III – False information provided by the user/customer:
Smartdink is not responsible for false information or information entered in bad faith by the user/customer in the records required for the use of our services. All consequences arising from these practices are the sole responsibility of the user/customer.
We reaffirm our commitment to transparency, security and compliance with applicable legislation, especially the General Data Protection Law (LGPD).
