Privacy Policy

Teamworksp is committed to complying with the laws that protect the privacy of customer and general public data. This page is designed to provide information on how we are following data protection standards, what information we collect while you are browsing our communication channels, and how this information is collected, used, and protected by us, in compliance 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 on the acceptance of this Privacy Policy, including with regard to our employees.

1. Source of Personal Data

Teamworksp will have access to personal data in the following situations:

•Through interaction with a customer: When the Customer provides and enters personal data necessary for the provision of services and use of products provided by Teamworksp.

•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 the contractual relationship they have.

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 the legal relationship they have, Teamworksp may also collect the following personal data:

•Names and contact details, such as first and last name, email 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 about how the User navigates within our services, their browsing history and which elements of Teamworksp's services are most used;

Sensitive personal data, which may eventually be collected by Teamworksp, will have its purpose informed separately to the User, who must consent for Teamworksp to use it in a specific manner, and in case of disagreement, the data will be automatically deleted from Teamworksp's databases.

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

3. Use of collected personal data

When collected, Teamworksp will use personal data to:

•Provide and improve contracted services;

•Comply with a legal or regulatory obligation;

•Manage the relationship with Users;

•Set up and manage User accounts;

•Provide technical assistance, support and training to the User;

•Contact Users;

•Internal investigation and development purposes and to improve, test and refine the features and functions of Teamworksp's services;

•Provide Users with marketing, advertising, including from Partner companies of Teamworksp, as permitted by law;

•Meet internal and external audit requirements, including information security obligations of XXXXXXXX;

•Send messages by electronic mail to: a) confirm or cancel requests through the use of the platform; b) communicate future changes that this policy may undergo; and c) disclose updates, changes, inclusions of new data sources and improvements to the platform.

•To exercise Teamworksp's rights, including, but not limited to, the privacy, security, networks, systems and properties of Teamworksp and/or third parties;

•Comply with requests from courts, law enforcement agencies, 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 Teamworksp's rights and to defend against eventual lawsuits, as well as to comply with any legislation or regulation applicable to Teamworksp or third parties with whom we work, as well as for the exercise of the proper fulfillment of contracts signed between Teamworksp and its users;

4. Sharing of personal data with third parties

The User accepts and agrees that Teamworksp shares their personal data with the following categories of recipient:

•Companies that provide access or are responsible for the registration on which the user is dependent;

•Partner companies, such as outsourced 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 Teamworksp owes satisfaction or has authorization to disclose information by law (Example: government agencies, regulatory agencies, 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 Teamworksp's business, in which case the User's data will be considered an asset and transferred in an eventual negotiation;

•Third parties that need the data to protect Teamworksp's rights;

•Any natural or legal person to whom the User requests the portability of their data.

5. International transfer of personal data

Teamworksp does not intend to transfer any personal data of the User collected outside Brazil, and it is certain that if the hypotheses listed below are not met, Users will be previously informed by email, at which time the user may accept or not the transfer, and in case of disagreement, their access rights may be impeded by Teamworksp.

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

6. Protection of personal data

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

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

This Policy represents Teamworksp's effort to safeguard User information. However, due to the very nature of the Internet, it is not possible to guarantee that malicious third parties will not succeed in unduly accessing stored information, which is why, if this occurs, Teamworksp will be responsible within the limits provided for by Law.

Teamworksp, within a reasonable period to be defined by the National Data Protection Authority (“ANPD”), must communicate to the ANPD and the affected User the occurrence of a security incident that may cause relevant risk or damage to the affected User, mentioning, at a minimum:

•the description of the nature of the personal data affected;

•information about the data subjects involved;

•indication of the technical and security measures used to protect the data, 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 were or will be adopted to reverse or mitigate the effects of the damage.

7. Data processing and responsibility of xxxxxxx

Teamworksp will have its processing responsibility as follows:

•When dealing with personal data provided directly by its Customers, Teamworksp will be the Operator, and will act without interference in the form of processing indicated by the Controller, but under the terms of the LGPD;

•Teamworksp will be the Controller of the Personal Data of its employees, treating them based on the Execution of Contracts, Compliance with a legal or regulatory obligation, and also, in specific and determined situations, on Consent.

Teamworksp may adopt different legal bases for different processing of personal data.

8. Term of personal data processing

Teamworksp calculates the personal data retention period according to the following criteria:

•Period necessary to fulfill the purpose of the collection;

•The moment the Customer/User stops using Teamworksp's services;

•The moment there is revocation of consent or request for elimination of personal data by the Holder;

•The time necessary to demonstrate compliance with Teamworksp's duties and obligations;

•The necessary period provided for in Law, regulations, judicial decisions, etc.;

•Determination of 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 eventual judicial disputes;

•Transfer to a third party, provided that the data processing requirements set out in law are respected; or

•Exclusive use of the controller, access by a third party being prohibited, and provided that the data is anonymized.

9. 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 of Confirmation: the User may confirm whether Teamworksp processes any of their personal data;

•Right of Access: the User may make a written request to obtain details of how their information is being used, as well as to have a copy of the said information;

•Right to Correction: the User may correct or remove any of their data that is incomplete, inaccurate or outdated;

•Right of Anonymization, blocking or elimination: the User may request the anonymization, blocking or elimination of unnecessary, excessive data or data treated in disagreement with the purposes for which consent was given, observing, for this purpose, other rules of the legal system;

•Right of Exclusion: the User may request the exclusion of some data, except those in which the law authorizes its conservation;

•Right to Information: The User may request information from public and private entities with which Teamworksp has shared their data, as well as the consequences if they choose not to consent to the collection and processing of their personal data;

•Right to Refuse Marketing: The User may, at any time, request the cancellation of receiving advertisements and other materials through the link provided in the email marketing sent.

•Right of Portability: The User may request that their personal data be transferred to themselves or third parties, except those that have already been anonymized and excluded by Teamworksp

•Right to Revocation of Consent: The User may cancel any consent previously granted to Teamworksp to use their personal data. The User is aware that the cancellation will not affect the use or sharing of data carried out prior to the request for revocation of consent.

The rights provided for in this chapter are not absolute, and the User, whenever they wish to exercise them, must contact Teamworksp through the channel: [BLANK EMAIL]

Teamworksp undertakes to respond 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, reasons of fact or law, at which time the User will be notified.

Teamworksp will immediately communicate to the processing agents with whom it has shared User data about the correction, elimination, anonymization or blocking of the data, so that they 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, which indicates the origin of the data, the non-existence of registration, the criteria used and the purpose of the processing, always observing the commercial and industrial secrets of Teamworksp.

10. Cookies

Teamworksp and eventual 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 a standard on websites and platforms, through which information about the User's 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 can perform the following functions:

•Necessary Cookies: 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 Teamworksp platform and serve to improve their 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) and provide enhanced and more personal features.

•Advertising Cookies: they track the User's browsing habits and are used to provide targeted advertising. These cookies also limit the number of times you see an ad 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.

Teamworksp uses necessary and performance cookies.

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

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

Web Server and Platform Logs: Teamworksp'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 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 typed texts;

•Links and buttons clicked;

Social Media Connections: Some of Teamworksp's services may include social media functionalities, such as Facebook “Like” buttons, “Share” buttons and interactive mini-programs. Teamworksp may also allow you to log in to some of our services using social media accounts, such as Facebook. If you choose to log in using a social media account, Teamworksp may receive information about you from that social media, such as your name, email address, profile picture and other information you choose to make available.

11. Final Provisions

Teamworksp reserves the right to change this Privacy Policy at any time, by publishing the updated version on its website.

This Privacy Policy is governed by the laws of the Federative Republic of Brazil.

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