Privacy Policy

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

• Through interaction with a customer: When the Customer provides and imputes personal data necessary for the provision of services and use of products provided by CAMARASYS.
  
• Interaction with your employees: When your employees and collaborators of any nature use their systems and platforms to fulfill the duties and obligations of the contractual relationship they have.

CAMARASYS may still collect the following personal data, without prejudice to the data commonly collected and processed from its employees for the legal relationship they have:

• Names and contact details such as first and last name, email address, postal address, telephone number, and other similar types of contact details such as bank details;
• Device information, such as information about your devices, 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 the CAMARASYS services are most used;

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

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

When collected, CAMARASYS will use personal data to:

• Provide and improve the contracted services;
• Comply with a legal or regulatory obligation;
• Manage the relationship with Users;
• Configure and administer User accounts;
• Provide technical assistance, support, and training to the User;
• Contact Users;
•  For internal research and development purposes and to improve, test, and improve the features and functions of CAMARASYS services;
• Provide Users with marketing, advertising, ads, including from CAMARASYS Partner companies, as permitted by law;
• Meet internal and external audit requirements, including CAMARASYS' information security obligations;
• Send messages by email 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, additions of new data sources, and improvements to the platform.
• To exercise the rights of CAMARASYS, including but not limited to privacy, security, networks, systems, and properties of CAMARASYS and/or third parties;
• Comply with requests from courts, law enforcement authorities, regulatory bodies, and other public institutions and government authorities, including, but not limited to, any rules in force outside the user's country of residence;
• The use of CAMARASYS' rights and to defend itself against any legal actions, as well as for the compliance with any legislation or regulation applicable to CAMARASYS or third parties with whom we work, as well as for the exercise of the proper fulfillment of contracts signed between CAMARASYS and its users;

The User accepts and agrees that CAMARASYS shares its data with the following categories of recipients:

• Companies that provide access or are responsible for the registration on which the user is dependent;
• Partner companies, such as third-party service providers and other companies that assist us in providing our services or who may take action on our behalf, protecting our rights, users, systems, and services;
• Third parties to which CAMARASYS owes satisfaction or is authorized to disclose information by law (Example: government agencies, regulatory agencies, the judiciary, and other public authorities);
• Third parties to participate in the sale, merger, acquisition, restructuring, joint venture, assignment, transfer of part or all of CAMARASYS' business, in which case the User's data will be considered an asset and transferred in an eventual negotiation;
• Third parties who need the data to protect the rights of CAMARASYS;
• Any person or company for which the User requests the portability of their data.

CAMARASYS does not intend to transfer abroad any personal data of the User, provided that if the hypotheses listed below are not met, Users will be previously informed by e-mail, at which time the User may accept or not the transfer, and in case of disagreement, you may have your access rights prevented by CAMARASYS.

The international transfer of data described in the General Data Protection Law (LGPD) lacks the designation of guidelines to be established by the National Authority for the Protection of Personal Data (ANPD), while, when defined, CAMARASYS commits to comply with them in their entirety.

CAMARASYS 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 the data in line with legal provisions, regulatory requirements, technology changes, among other relevant factors that may influence the way to protect personal data.

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

This Policy represents CAMARASYS' effort to protect 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 improperly accessing the stored information, which is why, if this occurs, CAMARASYS will be responsible within the limits provided by law.

CAMARASYS, within a reasonable period to be defined by the National Data Protection Authority (“ANPD”), shall notify the ANPD and the affected User of the occurrence of a security incident that may cause relevant risk or damage to the affected User, mentioning, in the Minimum:

• a description of the nature of the personal data affected;
• information about the involved holders;
• indication of the technical and security measures used for data protection, 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 have been or will be adopted to reverse or mitigate the effects of the loss.

CAMARASYS will be responsible for the treatment as follows:

• When dealing with personal data provided directly by its Customers, CAMARASYS will be the Operator and will act without interference in the form of treatment indicated by the Controller, but under the terms of the LGPD;
• CAMARASYS will be the Controller of the Personal Data of its employees, treating them based on the Execution of Contracts, in Compliance with legal or regulatory obligations, and also, in specific and determined situations, in Consent.

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

CAMARASYS calculates the retention period of personal data according to the following criteria::

• Period necessary to fulfill the purpose of the collection;
• The moment when the Client/User stops using CAMARASYS' services;
• The moment when there is a revocation of consent or a request for deletion of personal data by the Holder;
• The time required to demonstrate compliance with CAMARASYS' duties and obligations;
• The necessary period provided for by law, regulations, court 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 any legal disputes;
• Transfer to a third party provided that the data processing requirements established by law are complied with; or
• Exclusive use of the controller, its access by a third party is prohibited, and provided that the data is anonymized.

According to the Brazilian General Data Protection Law, the User will have the following rights regarding the treatment of their data:

• Right of Confirmation: the User may confirm whether CAMARASYS processes any of his/her 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 said information;
• Right to Correction: the User may correct or remove any data that is incomplete, inaccurate, or outdated;
• Right to Anonymization, blocking or deletion: The User may request the anonymization, blocking, or deletion of unnecessary, excessive, or treated data in disagreement with the purposes for which consent has been given, observing, for that purpose, other rules of the legal system;
• Right of Deletion: the User may request the deletion of some data, except those in which the law authorizes its conservation;
• Right to Information: The User may request information from the public and private entities with which CAMARASYS has shared their data, as well as the consequences if they choose not to consent to the collection and processing of their data;
• Right to Refuse Marketing: The User may, at any time, request the cancellation of advertisements received and other materials through the link provided in the marketing email sent.
• Right of Portability: The User may request that their data be transferred to themselves or third parties, except for those that have already been anonymized and excluded by CAMARASYS.
• Right of Withdrawal of Consent: The User may cancel any consent previously granted to CAMARASYS to use their data. The User is aware that the cancellation will not affect the use or sharing of data carried out before the request for revocation of consent.

The rights provided for in this chapter are not absolute, and the User must, whenever he wants to exercise them, contact CAMARASYS through the channel: contato@camarasys.com.br

CAMARASYS is committed to responding 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, opportunity in which the User will be communicated.

CAMARASYS will immediately inform the processing agents with whom it has shared User data about the correction, elimination, anonymization, or blocking of data so that they can repeat the same procedure.

Confirmation of the existence or access to the User's data provided for in this chapter will be provided, electronically or expressly, in a simplified format or using a clear and complete statement, indicating the origin of the data, the inexistence of registration, the criteria used and the purpose of the treatment, always observing the commercial and industrial secrets of CAMARASYS.

CAMARASYS and any 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 that is being used and to collect information, and can perform the following functions:

• Necessary Cookies: They are essential to allow the user to browse a platform and use its features. 
• Performance Cookies: they collect information about how the User uses the CAMARASYS platform and are used to improve your navigation and improve your experience. The information collected includes, for example, the internet browsers and operating systems used, the domain name of the website previously visited, 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 the User is in) and provide enhanced and more personal features.
• Advertising Cookies: they track the User's browsing habits and are used to deliver targeted advertising. These cookies also limit the number of times you see an ad and measure the effectiveness of advertising campaigns. They also remind you that the User has already visited a website and this information is shared with other organizations, such as advertisers.

CAMARASYS uses necessary and performance cookies.

At any time, the User may disable Cookies through the settings of his browser, install plug-ins available on the market, or even make use of other technologies that he deems necessary.

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

Web Server and Platform Records: CAMARASYS 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 the Unique Device Identifier (UDID), MAC address, Identifier for Advertisers (IFA), and similar identifiers assigned by us or a third party;
• The device's operating system and other technical data;
• The city, state, and country from where you are accessing the CAMARASYS platform, including for fraud prevention;
• Typed information or texts;
• Clicked links and buttons;

Connections via Social Networks: Some of CAMARASYS' services may include social networking features, such as Facebook “Like” buttons and widgets; “Share” button and interactive mini-programs.

CAMARASYS may allow the User to choose to use the logins of their social networks to access some of the services offered, in which case CAMARASYS may receive and store authentication information for these services.

Doubts, comments, suggestions, and/or complaints regarding this Privacy Policy, as well as any need for information, alteration, or deletion of personal data, may be made by the User directly to CAMARASYS, by e-mail: contato@camarasys.com. br

CAMARASYS seeks constant updates and improvements, so this Privacy Policy may be updated at any time, always aiming a better service provision and protection to users.

In the event of changes that reach the purpose and duration of the processing of the User's data, the User will be informed through the email registered in our services or through the platform itself 30 (thirty) days in advance. If there is disagreement with the changes, the User may revoke the consent provided, being unable to use the services of CAMARASYS.

If in the future, CAMARASYS changes its policy intending to share data with third parties, it will send a notice 30 (thirty) days in advance to the user via the registered user's e-mail, who may disagree with the sharing, at which time will continue to use CAMARASYS services.

Users are advised to periodically read this policy to keep up to date with its content.

This Policy will be governed, interpreted, and executed in following the laws of the Federative Republic of Brazil, regardless of the conflicts of these laws with the laws of other states or countries, and the São Paulo Forum is competent to resolve any doubts arising from this instrument, with the waiver of any other, however privileged it may be.