At ContratosDigitais.com, privacy is a priority. This Privacy Policy defines how ContrasDigitais.com, and its group of companies (“we”, “our”, “us” or “us”) collect and use information from customers and other individuals who access or use our websites, including ContrasDigitais.com and our applications, our web client or professional client, and/or any of our other websites, products, or services that reference this Privacy Policy (the “Services”). By using our Services, you understand that we will collect and use your information as described in this Privacy Policy (collectively, “you,” “your,” or “yours”).

If you or your organization has a contract with us and/or has accepted our terms of use, that contract or terms may have privacy terms that also apply to the information you provide to us under the contract. Please review the terms of the agreement as they may be different or more restrictive than the terms in this Privacy Policy.

This Privacy Policy does not apply to any third-party websites and applications that you may use, including any that are linked from our Services. You should review the terms and policies for third-party websites and applications before clicking any links.

ContractsDigitais.com’s main products and services help users generate or upload documents, register signatories and/or users, send documents via the web to collect signatures, with ICP-Brasil certificate, TOKEN and/or CPF via WhatsApp, collect data from digital or electronic transactions, such as electronically signing a contract or documents of any nature, and/or including a digital signature. As part of our Services, users ask us to collect and record information that helps parties prove the validity of transactions. This information includes people who are involved in transactions and/or signatures, as well as data on WhatsApp numbers of users and/or signatories.

We recommend that you read this Privacy Policy in its entirety to ensure that you are fully informed. All rules contained in this policy aim to help ensure the security of your data and its use, in compliance with the legal provisions of the  BRAZILIAN GENERAL DATA PROTECTION LAW (LGPD) – Law No. 13,709/2018

1. How We Collect Information

To provide and improve our Services and support advertising and marketing, we collect information about visitors to our websites, users of our Services, the devices they use, and sometimes their locations.

We collect certain information directly from you when you fill out forms: name, email, sector you work in, telephone number and/or how you found out about us. We collect other information, typically about devices, web browsers, or locations, automatically (without needing you to enter it into a form). We may also collect information about you from other sources, such as referrals from friends, about our Services, believing that you may be interested in our Services.

You can choose to visit our websites, take a free trial, create a free account and/or provide information to us. However, if you do not provide us with certain information, you may not be able to use some parts of our Services. For example, if you do not provide your CPF and/or CNPJ you will not be able to hire our solutions or even inform who will be the people authorized to access the system and view the respective documents.

Information We Collect from You You provide us with information about yourself when:

• Register or log in to your account

• Create, sign, or review an electronic document

• Create or edit your user profile

• Contact customer support

• Comment on our blogs or community forums

Examples of information you provide are: name, email address, mailing address, telephone number, billing information, or electronic signature.

You also provide us with information about others when you use parts of our Services, for example when you:

• Create or participate in an electronic transaction, as a signatory on a document

• Add others as members of an existing account

• Indicates friends

Information We Collect Automatically. We automatically collect information from you and your devices when you use our Services, even when you visit our websites or apps without logging in. Regarding the choices you have about what information we automatically collect.

The information we collect automatically includes:

• Device Data, Usage and Transactional Information. We collect information about how you use our Services and the computers or other devices, such as cell phones or tablets, that you use to access our Services. Some examples include:

  • IP address

  • We may use applications to collect the precise geolocation that you allow our applications to access (typically from your mobile device)

  • Unique device identifiers and device attributes, such as operating system and browser type

  • Usage data, such as: web log data, indicating entry and exit pages, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of these pages, time spent on pages specific information, the date and time you used our Services, the frequency of your use of our Services, error logs, and other similar information

  • Transactional data, such as: names and email addresses, CPF, WhatsApp number of the parties to a transaction, subject, history of actions that individuals take with the transaction (e.g. review, sign, enable features) and information about these individuals or their devices, such as name, email address, IP address, and authentication methods.

• Cookies and Related Technologies. We may use cookies, which are text files containing small amounts of information saved on your device (“Cookies”), or related technologies, local shared objects and tracking pixels to store and collect information. We also allow others to use Cookies in conjunction with the Services as described below. Cookies can store your preferences, your username and help personalize advertising.

  • Analysis. We use services like Google Analytics. These services use Cookies to collect usage data and help us understand how people use our Services, for example the pages they visit and for how long and the website or page they were on before entering the ContrasDigitais.com website.

  • Personalized Advertising.

    • Advertisements for Other Products & Services. Third parties whose products or services are offered on our Services may place or read Cookies on your computer or other device to collect information. They do this to (I) personalize and serve ads based on information such as past visits to our Services and other websites; and (II) report the number of advertisements presented and the responses to those advertisements;

Information We Collect from Other Sources. We may collect information about you from other places, such as:

• Third Party Sources. Examples of third-party sources include merchants, partners, researchers, affiliates (such as companies linked to ContrasDigitais.com), service providers, and others who are authorized by you to share your information with us. For example, if you register for our Services on another website, that website may provide us with information that you have authorized for our business partners to view.

• Other Customers. Other customers may provide us with their information. For example, if a customer expects you to sign an electronic document on our Services, he or she will provide us with your name and email address.

• Combining Information from Different Sources. We may combine information we receive from other sources with information we collect from you (or your device) and use it as described in this Privacy Policy.

Information We Collect and Process on Behalf of Customers. When our customers use our Services, we process and store certain information on your behalf as a data processor. For example, at ContractsDigitais.com when a customer (or the customer’s Authorized Users) submits contracts or other documents for review or signature, we act as a data processor and process the documents on the customer’s behalf and in accordance with their instructions . In these cases, the customer is a data controller and is responsible for most of the information processing features. If you have any questions or concerns about how information is processed in these cases, including how to exercise your rights as data subjects, we recommend contacting the customer and obtaining the appropriate authorizations.

2. Use of Information and access

Generally, we collect, use, store, and process your information to provide our Services, repair and improve them, to develop new Services, and to promote our companies and their products and Services. Below are some examples of how we use the information we process:

• Provide you with the Services and products you requested and bill you for them

• Send you records of our relationship, including for purchases or other events

• Offer features, products, or special events using email or telephone, or send you advertisements about third-party products and services that we believe may be of interest to you, given your authorization

• Record details about what happens to electronic documents, such as who viewed and/or signed, the devices used, and when these events occurred

• Create and review data about our users and how they use our Services

• Test changes to our Services and develop new features and products

• Fix problems you may have with our Services, including answering support questions or resolving disputes

• Manage the Services platform, including support and security systems (Each user information is restricted to each sector and/or user in accordance with the permissions granted by the security manager of digital contracts / TXR solutions, in addition to being used judiciously and robust access methods. We also emphasize that all security criteria used in the organization, whether in the digital and/or physical environment, are limited by physical security barriers, whether with hexadecimal passwords, protected rooms and in addition to individual contracts that govern the access. responsibilities and confidentiality of each employee according to their area of ​​activity.

• Prevent, investigate, and respond to: fraud, unauthorized access or use of our Services, violations of terms and policies, or other malicious behavior

• Comply with legal obligations

• Comply with legal retention periods

Other Uses. 

We may combine the information we collect (“aggregation”) or remove portions of the information (“de-identification”) to limit or prevent identification of any particular user or device in order to assist with research and advertising purposes. This Privacy Policy does not apply to our use of such aggregated or de-identified information.

We will normally collect or use information from you or others only where we have your consent to do so, where we need the information to perform our functions relating to our contract with you, or where the processing is done in our legitimate interests and does not override your data protection interests or fundamental rights and freedoms. In some cases, we may have a legal obligation to collect or retain personal information or need personal information to protect your vital interests or those of another person. For example, when we:

• We use information to create and manage a thing, we need the information to provide the related Services.

• We collect and record data associated with the use of a digital certificate or digital signature, we do this to comply with regulations.

• We use name and email address for email marketing purposes, we do so with your consent (which you can withdraw at any time).

• We collect usage data and analyze it to improve our Services, which we do based on our legitimate interest in protecting and improving our Services.

If you have questions or require further information regarding the legal basis on which we collect and use your personal information, we ask that you contact us using the contact information provided in Section 10 of this Privacy Policy.

3. Information Sharing

We share information as follows:

• Service Providers. We share your information with other companies that we use to support our Services. These companies provide services such as intelligent search technology, intelligent analytics, advertising, authentication systems, invoice collection, fraud detection, and customer support. We have contracts with our service providers to protect and properly use your personal information.

• Affiliates and/or independent consultants. We may share your information with other people and/or companies under common ownership or control of ContrasDigitais.com. These companies and/or people use your information in the manner described in this Privacy Policy.

• Advertising Partners. We may share your information with sponsors of events, webinars or sweepstakes for which you have registered and previously authorized, or other parties with whom we may engage in joint marketing activities.

• Government or Public Authorities. We may share your information to comply with applicable laws, or to respond to legal process (such as a court order). We may also share your information when there is a threat to the physical safety of any person, violations of this Privacy Policy or other agreements, or to protect the legal rights of others, including our employees, users, or the public.

• Business Operations. We may share your information during a corporate transaction, such as a merger or sale of our assets, or as part of due diligence for such contemplated transactions. If a corporate transaction occurs, we will notify you of any changes in control of your information, as well as the choices you may have.

• Consent. We may share your information in other ways if you have asked us to do so or if you have given us your consent. For example, with your consent, we publish testimonials from users who may identify you.

• Partners via API integration. We may share your information with API partners. These companies and/or people use your information in the manner described in this Privacy Policy.

Your information may also be shared as described below:

• Other users. When you authorize others to access, use, or edit content in your account, we share that content with them. For example, if you send a contract to others for review or signature, we make the contents of that document available to them.

• Third parties. When you make a payment to another user through our Services, we share your payment method details with the third party that will process the payment chosen by you or another user.

• Public Information.

  • User Created Content. When you comment on our blogs or in our community forums, that information may also be read, collected and used by others.

4. Information Retention and security criteria

We keep your personal information only for as long as it is necessary for the purposes of processing it. The period for which we retain information depends on the purposes for which we collect and use it and/or as required to comply with applicable law. In cases where there are technical limitations that prevent deletion or anonymization, we protect personal data and limit the active use of that data.

5. Your Options

This section describes many of the steps you can take to change or limit the collection or use of your information.

• Profile. You are not required to complete a profile. If you do, you can access and review that information. If any information is inaccurate or incomplete, you may make changes to your account settings.

• Advertising Messages. You can opt out of receiving email marketing messages that we send. You can opt out of receiving these messages by clicking the “unsubscribe” (or “unsubscribe”) link in the email message, or unsubscribe. Please be advised that we may send you a message to confirm that you have opted out of receiving further messages. If you are a registered user of our Services, or if you have engaged in transactions with us, we may continue to send you transactional and relationship messages (e.g., subscription or account notifications) after you opt out of receiving marketing messages. If you wish to add your telephone number to our Register to Block Receiving Telemarketing Calls, please contact our customer service center. Please include your first name, last name, company and telephone number. You may also notify us during a telemarketing call that you no longer wish to receive calls for telemarketing purposes.

• Cookies and Other Related Technologies. You can reject cookies in your internet browser settings. However, if you reject cookies, you may not be able to use some parts of our Services.

  • To apply choices about personalized advertising, please visit the following websites (please note that you will still receive advertising, but it will no longer be personalized for you, and that ContrasDigitais.com does not control these services that are offered by third parties):

  • We do not recognize or respond to Do Not Track signals from web browsers.

• Device and Usage Information. If you do not want us to see your device’s location, you can turn off location sharing on your device, change your device’s privacy settings, or refuse to share location in your internet browser.

• Closing Your Account. If you wish to close your account, please log into your account and open a ticket requesting such action or for more information, contact our support center.

• Complaints. We are committed to resolving all valid complaints about your privacy and our collection or use of your personal and/or business data. For questions or complaints about our data use practices or Privacy Policy, please contact us via email: contato@ContratosDigitais.com

6. Children’s Privacy

Our Services are not designed for and are not offered to persons under the age of 18. We do not knowingly collect or solicit information from minors. We do not knowingly allow minors to use our Services. If you are a minor, please do not use our Services or send us your information. We delete information that we learn has been collected from a minor without verified parental consent.

7. Your Privacy Rights

When using our Services, you:

• acknowledges that your information will be processed in the manner described in this Privacy Policy;

• You consent to having your information transferred to our affiliates and facilities throughout Brazil or elsewhere, to the facilities of the third parties with whom we share this information, as described in this Privacy Policy.

You may have certain rights relating to your personal data, subject to local data protection laws. These rights may include:

•  You may also request the following information: how we collect and use your information and why; the categories of personal data involved; the categories of recipients of your personal data; how we receive your personal data; and how long we use or store your personal data or the way in which we determine relevant retention periods.

• You also have the right to correct your personal and/or business data. In certain situations, you can request the deletion or cease use of your information (and object to the use of your personal data) or the export of your data.

• When we rely on your consent to process your personal data, you have the right to refuse to give consent and/or if you have given, to withdraw your consent at any time. This will not affect the lawfulness of the processing before you withdraw your consent. At any time, you may request that we cease using your information for direct marketing purposes.

• You may have the right to receive information regarding financial incentives we offer you. You also have the right not to be discriminated against for (as provided by applicable law) exercising certain rights. Please be advised that your rights and choices vary depending on your location. Certain information may be excluded from such requests under applicable law. We need certain types of information so that we can provide products and/or Services to you. If you ask us to delete, you may no longer be able to access or use our products and/or Services. We will take reasonable steps to verify your identity.

8. How We Protect Your Information

To keep your information secure, we use physical, electronic and administrative tools. We apply these tools based on the sensitivity of the information we collect, use, and store, and the current state of technology. We work to prevent unauthorized access to or use of personal information. However, we cannot guarantee 100% the inviolability of our systems from criminals and malicious hackers. We store your data on several servers to prevent loss of data and/or documents. However, this scenario involves some risk, which is not associated with a lack of security criteria for digital contracts, but rather arising from the digital medium in question itself. For this reason, we cannot guarantee that the information we collect or store will always be protected from unauthorized access, or that it will only be used as described in this Privacy Policy. If any criminal action is detected, where your data may be at risk, we will notify you through the contact channels registered on our platform, in addition to notifying the competent bodies, such as the National Personal Data Protection Agency (ANPD)

9. Changes to this Policy

We may change this Privacy Policy to reflect changes in the law, our companies, our Services, our data collection and use practices, or technological advances. Our use of the information we collect is subject to the Privacy Policy in effect at the time such information is used. Depending on the type of change, we may notify you of changes on this page or by email or request new authorizations. Please periodically review this Privacy Policy and carefully consider any changes made to this Privacy Policy. 

10. How to Contact Us

For questions or complaints regarding our use of your information or the Privacy Policy, please contact us at contato@ContratosDigitais.com or at TXR soluções.