Privacy Policy

Based on the General Data Protection Law, we have revised this Policy in view of the use of the website and all the applications we develop, which may involve the provision and processing of personal data. Therefore, we want to show our clear commitment to comply with the law by protecting and respecting your privacy, through all our efforts to establish security measures at each stage of the services we provide. In this Policy, the provision of personal data may involve your name, e-mail address, home address, telephone number or any other additional and optional information used to identify you. The term “website” includes all Cadmus websites, as well as platforms: Cadmus, beefor, Liga Ágil, Cadmus Play, Goobee Play, Coin2u and Goobee Help.

Purpose

The purpose of this Privacy Policy is to inform the user and visitor to our website and all the platforms we make available, of the measures used to protect the personal data provided, to clarify how it is used and to ensure clarity about their rights as data subjects. This includes informing you how we collect data, for what purpose and what processing is done to ensure data security. We are also committed, as software providers, to measures such as Privacy by Design and Privacy by Default, while encouraging and requiring our customers and business partners to follow the same level of good practice. We understand our role as the controller of the personal data you may provide and how important it is that the information we obtain is secure. Therefore, we go to great lengths to meet these needs, to transparently inform you by various means, including the Privacy Policy, about how your data may be processed, to respect all the principles contained in the General Data Protection Law no. 13.709/18, as well as to take all technical security measures so that you can have the safest possible experience with us. This Policy is just part of our Privacy Program, which is made up of other documents, guidelines and internal policies, including our Code of Ethics and Conduct.

Legal references in Brazil

– Law 13.709/2018 – General Personal Data Protection Law.

– Law 12.965/2014 – Civil Rights Framework for the Internet

Controller

Our website and all the platforms we make available belong to Cadmus, a legal entity governed by private law, which seeks to bring the best technologies, creativity and experience to customers. The controller of your personal data may vary depending on the site you are visiting, for example when accessing our website from Brazil, accessing the global site, or interacting on our platforms.

Access by minors

Normally our service and product provision involves natural persons who are of legal age and in the process of carrying out commercial relations, but in the event that a minor accesses our site, he/she may only provide personal data with the consent of at least one parent or legal guardian, in accordance with art. 14, §1 of the LGPD. If you are a parent or guardian and you authorize a minor to provide personal data on this site, you agree to this Policy on the use of the site by minors. We will not knowingly ask minors to provide us with data, unless it involves the registration of minors for the benefit of employees and the respective fulfillment of legal and regulatory obligations. In any case, even if a parent or legal guardian has given consent to collect data from a minor, they may at any time request information, review, revoke or change their consent options.

How we collect personal data

– Registration: when you create and update your account on the platform. Particularly for use of the Beefor platform, it is hereby declared that the profile registered on the platform will be visible to other users who also use it in the company, depending on the type of access granted;

– Contact request: by providing basic identification data to enable your experience through access to experience and explore the platform or for relations in the electronic service channel;

– Navigation: by registering your preferences, skills and other characteristics for profiling and interaction with the team;

– Cookies: when you set your preferences and give your consent to use and browse the platform;

The data collected depends on how you choose to interact either on the website or on the platforms, which includes your privacy settings and what you intend to use. It is also necessary to inform you that it is a personal decision to provide personal data and that refusal is free and guaranteed by the LGPD, however it is also our duty to inform you, in accordance with the same legislation, that many of our products and some functions of the use of the site require the data for the service to be carried out. Therefore, if you choose not to have your data collected, you will not be able to do so.

What we use personal data for

Since this organization is the Controller, we inform you below what your personal data may be collected for:

– To personalize your experience by offering easier navigation according to your characteristics, interests and preferences, for this purpose computer or mobile device identifiers are also used, as well as information such as operating system and IP address are recorded on the platforms;

– To provide the services contracted by the platform, to meet your requests as users and data subjects;

– Create and maintain a commercial relationship, so that products can be customized;

– Provision of Services;

– Use the services of email providers for communication when registering, receiving welcomes, sending information on relevant content, tips on using the platform and marketing activities;

– Provide security and protect rights through third-party services that help maintain the operating environment in order to prevent fraudulent activity;

– Efficiently measure access to services through analysis and statistics, define traffic and demographic patterns, and maintain the functionality of the services offered.

– Cooperate with judicial measures and regulatory bodies that request the sharing of data within the limits and in compliance with current laws.

In the role of Operator, we use personal data as requested by the Controller, provided that it complies with Law no. 13,709/18.

Data processing

It is important to point out that the organization, as the operator, has no knowledge of the data stored by the client/commercial partner in our database, but we act in such a way that all the information entered there is kept and classified as confidential.

Data sharing/transfer

Your data may be transferred and processed by partners who collaborate with storage services, server hosting, communications networks, email providers, monitoring of service use, among others, always in accordance with this policy and the terms of use of the service, respecting the applicable legislation, within the established purpose.

We may transfer data to other countries for the same purpose as in the previous paragraph. This is a prerequisite for transferring data if it has specific rules on the subject and meets the same level of information protection in practice. When sharing/transferring data, we recognize our duty and are committed to taking appropriate measures to protect your personal data. In the event of an international data transfer in the course of providing services, the relevant contractual clauses specifying and detailing the form and purpose of the transfer must always be established. In addition, exceptionally, data may be shared to comply with legal requirements in accordance with current laws, to collaborate with efforts to investigate or prevent suspected fraudulent or illegal activities and to protect the security and integrity of the services. We understand the importance of complying with Brazilian data protection legislation, while being aware of what happens in other countries, and observing the rules of other countries when necessary.

Storage time

The data will only be stored during the fulfillment of its agreed purpose for the execution of the contract or provision of services, unless it is for the fulfillment of legal obligations or to meet requirements in legal actions. Registrations made for contact requests that remain inoperative will be discarded after a period of 90 days.

Use of Cookies

This topic applies to all citizens in Brazil, in compliance with the LGPD (Law n. 13.709/18), as well as users residing in other countries that have data protection laws and regulations. So that you can better enjoy and have better experiences with us, we inform you that we use cookies and related technologies, which we will also refer to as “cookies”, such as web beacons and pixels. Before specifying the types, we can define cookies as text files saved on the user’s device for later retrieval.

They help the website to function better and also provide us with information about how users interact. Cookies are not used for the purpose of identifying users, unless they voluntarily identify themselves through contact requests and register on the platforms. We collect your consent for the use of cookies according to your preferences, and this website uses the following types:

- Mandatory: are necessary for the correct functioning of the site, allowing basic functionalities during navigation, such as logging in, filling in forms and setting preferences, among others. The correct functioning of the site depends on the use of these cookies. These cookies do not store information about you that can be used in product or service communication actions.

- Analytics: help improve the performance of our websites, offering an enhanced user experience. They allow us to obtain information on the quality and/or effectiveness of our services and help us to understand how our visitors use our sites so that we can improve the presentation of the content, by understanding, for example, the number of visits and length of stay on the site, etc.

- Preferences: collect information about your choices and preferences, allowing us to remember your language or other local settings and customize the Site accordingly.

- Marketing: allows better targeting of advertising according to the user's interests, helping to make it more effective.

We use your IP address and browser type to analyze patterns, diagnose problems on our site, improve services and make your visit safer.

We would like to make it clear that you can change your cookie settings by clicking on "Cookie Preference" in the Preferences tab. When you log in, you can disable cookies, but mandatory cookies must be retained. Changing the settings may affect the functioning and experience of the site.

Service Channel for Rights Holders

In all of the above, we reinforce our commitment to good business practices and maintaining the highest ethical standards. We also reinforce that we have adopted the best practices in our data protection program, aiming for a high standard of compliance, so that there is transparency on our part and the data subject is in control of exercising their rights.

For this reason, as part of our duty, we make our contact details available to data subjects so that they can ask questions, open requests related to the LGPD, identify vulnerabilities in our products or services or report a security incident.

We reaffirm the exercise of the following rights of data subjects, provided for in art. 18 of the LGPD:

- Confirmation of the existence of treatment;

- Data access;

- Correction of incomplete, inaccurate or outdated personal data;

- Anonymization, blocking or deletion of Personal Data that is unnecessary, excessive or processed in breach of the LGPD;

- Portability of Personal Data to another service or product provider, upon express request by the Data Subject;

- Obtaining information about the public or private entities with which Cadmus shares the Data Subject's Personal Data;

• Information on the possibility of the data subject not providing consent for the processing of Personal Data, as well as being informed of the consequences in the event of refusal;

- Revocation of consent;

- Other questions related to data processing and based on current legislation.

Therefore, please feel free to contact our Data Officer - DPO Adriana Garcia, through the contact below:

E-mail: lgpd@cadmus.com.br

Policy change

We are not stagnant. Our movement is growing and we are always improving everything we do, and this policy is the result of this continuous process of improvement, which accompanies changes in new resources, tools, services, new technologies and laws, so there may be revisions of content and changes, with the addition or removal of parts of the policy. When this occurs, we will update the publication date of the latest version.

Last version: 27/10/2023

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