Data Processing and Privacy Policy –
Seasoned

Introduction

Seasoned (“Seasoned” or “We”) believes in the importance of privacy, information safety and in a trust-based relationship. These are the reasons why We want You to know how your Personal Data (“Data”) that we process are collected, stored and used.

This Data Processing and Privacy Policy (“Policy”) was carefully drafted looking to clarify every aspect of the Data and its processing to our users (“You”). We will constantly update this Policy, with the most updated version always available at “seasoned.cc/data-processing-and-privacy-policy” for You to look up at any given time. We suggest that You frequently access this link to keep up with our news and updates.

We highly recommend the entire read of this Policy. In case You have any questions, feel free to contact us at lgpd@seasoned.cc. We are available and will gladly assist You in answering any questions.

Please remember that, by using our Services, You give us your consent to collect and process your Data, according to the terms and conditions described in this Policy.

1. Definitions

In this Policy, We will use the following definitions:

General Data Protection Law - LGPD: Federal Brazilian Law No. 13,709 published on August 14th, 2018 that regulates the activities of personal Data Processing, including in digital media, by natural person or legal entity of public or private law, in order to protect the fundamental rights of freedom and privacy and the free development of the personality of the natural person.

Processing: Any operation carried out with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

Data: Any information related to an identified or identifiable natural person processed under the Contract.

Services: Any service provided by Seasoned for business entities or individuals.

Controller: Natural person or legal entity, under public or private law, who is in charge of the decision-making concerning the processing of personal data.

Processor: A natural person or legal entity under public or private law who processes personal data on behalf of the Controller.

Data Subject: The natural person to whom the personal Data that are the object of the Data Processing belong.

Client: anyone that hires Seasoned’s services.

2. Which Data we collect and how we collect?

We collect your Data by five different methods, such as:

2.1. Data provided by You: when You use our Services, You can provide Us with a series of information necessary to your registration and identification, such as full name, email, date of birth, location, taxpayer number, ID number, address, telephone and/or cell phone number, social network profiles (i.e. Google ID, LinkedIn) and financial information.

2.2. Data provided by our Clients: We provide software development and technological consulting services to our Clients.

If You are the Data Subject of any Data that our Clients are considered Controllers regarding the data processing, We kindly ask You that any request is sent to the respective Controller. If We receive any request from data subjects regarding Data We are not Controllers in the Data Processing, We will submit the request to the proper Controller to address it.

2.3. Technical Data from your device: We can collect Data from the devices You use to access our Services, such as your operating system, IP address, geolocation information and device identification.

2.4. Data obtained from third-parties: We can collect your Data that is publicly available, such as in social network profiles that You allow to share your Data, as well as receive them from third-parties or contractors. We ask our contractors and third-parties to comply with the applicable laws and to protect your privacy when necessary.

2.5. Analytical Data obtained automatically: We can use technologies such as cookies, web beacons, pixels and others to automatically collect and store data regarding the Services use.

3. How and why do we use your Data?

We believe our Services shall be provided at the highest possible standards, with constant improvements and development of new technologies, products and ideas to better serve our Clients’ interests, without prejudice to your rights and privacy.

We may collect your Data to provide our Services, when We receive them from our Clients. In these cases, We assure ourselves, to the extent that is possible, that our Clients have rules and procedures to protect your privacy, according to the applicable legislation, following the Controller’s, to whom You have initially provided your Data, guidelines regarding all of our data processing.

Your Data help us to improve our Services and offer a custom experience to each Client too, according to its profile and goal. We also analyze your Data to provide support and guarantee yours and our Service’s safety, avoiding and fighting frauds and illegal or forbidden activities.

Moreover, We keep your Data to fulfill legal and regulatory obligations We have to comply with from the public administration, as well as contractual obligations with our Clients.

4. How do we protect your Data?

Seasoned uses the best techniques of management, physical and organizational tools to mitigate the risks to your security, looking to block any act that may harm your privacy. Your Data are always processed with the necessary caution and by the use of advanced security and technological measures.

We use, in particular, physical and electronic walls, firewalls, cryptography protection and access authorization’s control. Our security measures are subject of constant reviews, looking to keep them updated and compatible with the best technology available.

5. Who do we share your Data with?

To provide our Services to the best of our capabilities, We may share your Data with third-parties contractors. We always take reasonable precautions to guarantee, to the extent that is possible, the compliance of our third-parties with the data protection legislation.

We seek to incorporate into our agreements, whenever possible, clauses that provide about the adequate use of Data and the measures that should be taken to keep them safe.

Thus, We may share your Data in the following cases, highlighting that, in every one of them, We adopt the necessary measures aiming to guarantee the adequate protection of your Data, based on the LGPD:

5.1. Contractors: We may share your Data with our contractors that support our services. We demand our contractors to comply with the applicable legislation and to implement data security and privacy measures. The concern with your privacy is a main criterion in our process of contractor’s selection and evaluation.

5.2. Clients: We may transfer your Data with Clients who hire our Services and share the same Data with our contractors, since this is necessary for the fulfillment of our agreement and the provision of the Services.

5.3. Corporate transactions: We may also share your Data in case of a corporate transaction, assets transactions or as part of a due diligence in these transactions.

5.4. Public or private authorities of regulation or fraud combat: We may share your Data to comply with requests from public and government authorities, as well as private entities to investigate abuse, fraud or other illegal acts in the uses of Services.

Besides that, please be aware that We may share your Data with foreign contractors, including cloud-based contractors. Every time this occurs, We will adopt the necessary measures to guarantee the security of your Data, based on the LGPD, prioritizing contractors located in countries with data protection regulations with at least the same level of rules as the LGPD.

6. Minors’ Data

Seasoned understands and values the importance of privacy, particularly when involving minors’ data. We require, to the extent that is possible, that the Controllers guarantee the possession of the legal consent of one of the parents or legal representatives of persons under 18 years of age.

In case it comes to our awareness that We are processing a minor’s Data without the specific legal consent mentioned, We will inform this to the respective Controller and will remove the Data as soon as possible.

7. What are your rights?

7.1. Access to your Data: You may request access to your Data we collect and process, as well as the Data source and the processing purpose.

7.2. Review, modification and/or deletion of your Data: You may request that We review, modify or, when applicable, delete your Data. Please be aware that, in certain circumstances, the Data deletion will disable you from using our Services.

7.3. Consent withdrawal: You can withdraw your consent for the processing and storage of your Data anytime you want. In this case, We will delete your Data, except when there is a legal, contractual or regulatory requirement or another legal ground for the Data processing.

For security reasons, We highlight that We will need to be sure of your identity to answer any of the requests listed above. Thus, We may request additional Data or information from You, aiming to confirm your identity as the Data Subject and the request’s authenticity.

In case We receive any request regarding Data where we are Processors in the Data Processing, We will inform the respective Controller to take appropriate actions.

All of these requests, as well as complaints and questions, can be submitted at our email lgpd@seasoned.cc.

8. For how long do we keep your Data?

Your Data will be stored and processed by Seasoned for the necessary period for Us to comply with our legal, contractual and regulatory obligations or until the purpose of the Data processing is achieved.

Despite that, You can withdraw your legal consent for the Data Processing and request the deletion of your Data anytime You want, as per item 7. In this case, We will delete your Data every time applicable, as per item 7.3, when your legal consent is the sole legal ground for the Data Processing.

9. Contact us

If You have any question, comment, complaint or suggestion about this Policy and our privacy rules, feel free to submit them to our email lgpd@seasoned.cc. This email is also available for You to file any request related to your rights, as per item 7. We commit ourselves to carefully analyze all received requests and answer them as soon as possible.