At Sm4rt Solutions, privacy and security are priorities, and we are committed to the transparency of our users’/customers’ personal data processing. Therefore, this Privacy Policy establishes how we collect, use, and transfer information from customers or other individuals who access or use our website.

By using our services, you understand that we will collect and use your personal information as described in this Policy, under the Data Protection regulations (LGPD, Federal Law 13,709/2018), the consumer provisions of Federal Law 8078/1990, and other applicable norms of the Brazilian legal system.

Thus, SMRT SOFT SOLUTIONS LDTA, hereinafter referred to simply as “Sm4rt Solutions”, registered with CNPJ/MF under number 10.631.252/0001-72, in its role as Data Controller, commits to the provisions of this Privacy Policy.

1. What data do we collect about you and for what purpose?

Our website collects and uses some of your personal data to enable the provision of services and improve the user experience.

1.1. Personal Data Provided by the Data Subject

• Full name
• Email
• Position/Profession (in some cases)
• Company (in some cases)

1.2. Personal Data Collected Automatically

• Our website does not collect personal data automatically and without your consent

2. How do we collect your data?

In this regard, the collection of your personal data occurs through our own scripts and third-party scripts, as follows:

• Google Analytics
• RD Station
• OptinMonster

2.1. Consent

It is based on your consent that we process your personal data. Consent is the free, informed, and unequivocal manifestation by which you authorize Sm4rt Solutions to process your data.

Thus, in accordance with the General Data Protection Law, your data will only be collected, processed, and stored with prior and express consent.

Your consent will be obtained specifically for each purpose described above, demonstrating Sm4rt Solutions‘s commitment to transparency and good faith towards its users/clients, in compliance with relevant legislative regulations.

By using Sm4rt Solutions‘s services and providing your personal data, you are aware of and consent to the provisions of this Privacy Policy, in addition to knowing your rights and how to exercise them.

You may revoke your consent at any time and at no cost.

It is important to note that revoking consent for data processing may result in the impossibility of adequately performing some website functionality that depends on the operation. Such consequences will be informed in advance.

3. What are your rights?

A (simplified company name) ensures its users/customers their rights as data subjects provided for in Article 18 of the General Data Protection Law. Therefore, you can, free of charge and at any time:

• Confirm the existence of data processing, in a simplified format or in a clear and complete format.
• Access your data, being able to request them in a legible copy in printed form or by electronic, secure, and suitable means.
• Correct your data by requesting the editing, correction, or updating of this data.
• Limit your data when unnecessary, excessive, or processed in non-compliance with the legislation through anonymization, blocking, or deletion.
• Request the portability of your data, through a report of registration data that Sm4rt Solutions processes about you.
• Delete your data processed based on your consent, except in cases provided by law.
• Revoke your consent, withdrawing authorization for the processing of your data.
• Be informed about the possibility of not providing your consent and about the consequences of refusal.

4. How can you exercise your rights as a data subject?

To exercise your data subject rights, you must contact Sm4rt Solutions through the following available channels:

• Simple email to contato@smartsw.com.br requesting removal or adjustment of your registration
• Via the removal link in the emails sent to you.

To ensure your correct identification as the data subject of the request, we may request documents or other evidence that can prove your identity. In this case, you will be informed in advance.

5. How and for how long will your data be stored?

Your personal data collected by Sm4rt Solutions will be used and stored for the time necessary to provide the service or to achieve the purposes listed in this Privacy Policy, considering the rights of data subjects and controllers.

In general, your data will be kept as long as the contractual relationship between you and Sm4rt Solutions persists. Every 12 months, a consent email is resent to all users in the registration database requesting renewal for an equal period of their data in the database. If the user does not authorize maintenance, the record is deleted from our legal database or anonymized, except for the legally provided hypotheses in Article 16 of the General Data Protection Law, namely:

I – Compliance with a legal or regulatory obligation by the controller;

II – Study by a research body, ensuring, whenever possible, the anonymization of personal data;

III – Transfer to a third party, provided that the data processing requirements set forth in this Law are respected; or

IV – Exclusive use of the controller, with third-party access prohibited, and provided that the data is anonymized.

That is, personal information about you that is essential for compliance with legal, judicial, and administrative determinations and/or for the exercise of the right of defense in judicial and administrative proceedings will be maintained, despite the deletion of other data.

The storage of data collected by Sm4rt Solutions reflects our commitment to the security and privacy of your data. We employ technical protection measures and solutions capable of ensuring the confidentiality, integrity, and inviolability of your data. In addition, we also have appropriate security measures for the risks and access control to stored information.

6. What do we do to keep your data secure?

To keep your personal information secure, we use physical, electronic, and managerial tools aimed at protecting your privacy.

We apply these tools considering the nature of the personal data collected, the context and purpose of the processing, and the risks that any violations would pose to the rights and freedoms of the data subject of the collected and processed data.

Among the measures we adopt, we highlight the following:

• Only authorized persons have access to your personal data
• Access to your personal data is made only after a confidentiality commitment
• Your personal data is stored in a secure and suitable environment.

A Sm4rt Solutions is committed to adopting the best practices to avoid security incidents. However, it is necessary to highlight that no virtual page is entirely secure and free from risks. It is possible that, despite all our security protocols, problems may occur exclusively due to third parties, such as cyberattacks by hackers, or also due to the negligence or imprudence of the user/customer themselves.

In case of security incidents that may generate relevant risk or damage to you or any of our users/customers, we will communicate to those affected and to the National Data Protection Authority about the occurrence, in accordance with the provisions of the General Data Protection Law.