Personal Data Privacy Policy cVortex

Last update: 05/01/2022

Overview

We are clearly committed to practices aimed at ensuring the privacy of personal data and we are constantly evolving to ensure compliance. Therefore, this document describes the policy adopted by us to ensure guidelines set out in the General Data Protection Law (law nº 13.709/18) – LGPD. This document has been written in a simple and accessible way, precisely so that you can read and understand how we use your data to offer you a safe and comfortable experience in the use of the services we offer you.

1.About policy acceptance

This Privacy Policy applies when you use our products that involve online and offline data collection, including Personal Data that we collect through our various services and channels, including websites, applications, third-party social networks, Customer Service Consumer, points of sale and events.

Acceptance of our Policy will be made when you create an account on our platform, autonomously or through an authorized cVortex professional, consume marketing content, request support or contact, participate in surveys or even provide personal data for the purposes of strictly business relationship with our team.

Such acceptance will take place when you affirmatively agree to the use of your data for each of the purposes described by us here. This will indicate that you are aware of and in full agreement with how we will use your information and data.

If you choose not to provide us with the Personal Data necessary to use our products, or to provide our services (we will indicate where applicable), or you do not agree with this Policy, we will not be able to provide you with our products and/or or services. If you do not agree with this Policy, please do not continue your registration procedure and do not use our services. However, please let us know your disagreement so that we can clarify or improve it.

Also, this policy will always be visible on our website – cvortex.com – for immediate access.

2. Information we collect and control

Some of this is information that you actively provide to us when you sign up for an account, register for an event, register to receive marketing materials, register for training, request customer support, or purchase something from us. We store your name and contact information, but we do not store credit card numbers (except with your permission).

When you visit one of our websites or use our software, we automatically record some basic information, such as how you got to the website, where you browsed and what features and settings you use. We use this information to improve our websites and services and to drive new product development.

Sometimes we receive information indirectly. If you inquire about our products through one of our referral programs or reseller partners, or sign into one of our products through an authentication service provider such as LinkedIn or Google, they will pass your contact information to us. We will use this information to complete the request you have made. If you engage with our brand on social media (e.g. by liking, commenting, retweeting, mentioning or following us), we will have access to your interactions and profile information. We will still have this information even if you later remove it from the social media site.

Also, as the essence of a CRM platform for engagement and relationship, there is the collection of data from its own customers, to which it makes sense and is in compliance with the Principle of Purpose of the LGPD.

3. Purpose of collection and use

As an engagement and relationship CRM platform, your data and that of your customers are inherently used for the following purposes:

To communicate with you (such as by email) about products you have downloaded and services you have signed up for, changes to this Privacy Policy, or important notices.
To keep you informed of new products and services, upcoming events, offers, promotions and other information that we believe may be of interest to you.
To ask you to participate in surveys or request feedback on our products and services.
To understand how users use our products and services, monitor and prevent problems, and improve our products and services.
To provide customer support, analyze and improve our interactions with customers.
Detect and prevent fraudulent transactions and other illegal activities, report spam and protect the rights and interests of cVortex, its users, third parties and the public.
To update, expand and analyze our records, identify new customers and provide products and services that may be of interest to you.
To analyze trends, administer our sites and track visitor navigations on our sites to understand what visitors are looking for and to better assist them.
To monitor and improve marketing campaigns and make relevant user suggestions.
To ensure that your customer data is present to ensure the real value of a CRM platform for engagement and relationship.

4. How we use information we collect

We use your information to provide you with the services you have requested, create and maintain your accounts, and monitor unauthorized activity on your accounts. We also use it to communicate with you about the products you are currently using, your customer support requests, new products you may like, chances of you giving us feedback, and policy updates. We analyze the information we collect to understand user needs and improve our websites and services. We do not use your customer data for any purpose except those that are inherently applicable to your business demand.

We are required to have a legal basis for collecting and processing your information. In most cases, we have your consent or need the information to provide you with the service you have requested. When this is not the case, we must demonstrate that we have another legal basis, such as our legitimate business interests.

You can opt out of certain types of use of information by not providing the information in the first place or by opting out later. You can also disable cookies to prevent your browser from providing us with information, but if you do so, some features of the website may not function properly. We have completely disabled non-essential and intrusive third-party cookies for all cVortex websites and products.

We limit access to your personal information to our employees and contractors who have a legitimate need to use it. If we share your information with other parties (such as developers, service providers, domain registrars and reseller partners), they must have appropriate security measures and a valid reason to use your information.

We keep your personal information for as long as necessary for the purposes stated in this Privacy Policy. When we no longer have a legitimate need to process your information, we will delete, anonymize or isolate your information, as appropriate.

5. Duration of the Processing of Personal Data

If you handle other people’s data using cVortex, such as information about your customers or employees, you are entrusting that data to us for processing. We protect it, limit access to it and only process it according to your instructions. You can access it, share it through third-party integrations, and request that we export or delete it.

We keep data in your account for as long as you choose to use cVortex. After closing your account, your data will be automatically deleted from our active database within 6 months and from our backups within 3 months thereafter.

6. Data visibility

Your (or your customers’) data is kept completely secure. Only you can see your own data and that of your customers. Also, if you request support from one of our trained professionals and temporary access to your data is assigned, this will only be done with your express authorization and agreement.

7. How do we protect your information

All data collected is stored on the infrastructure of Google Cloud, one of the largest cloud providers on the market, which implements ostensible security and encryption policies used both for data in transit and at rest. We also implement application layer security practices to provide additional mechanisms such as data transport via HTTPS.

In addition, we are constantly evolving and always focused on implementing industry best security practices, such as ISO 27001.

8. Legal Basis

The LGPD determines ten hypotheses or legal bases that must justify the processing of personal data. You should be aware that all these legal bases naturally apply to this privacy policy, such as:

Consent of the holder of personal data
legitimate interest
Compliance with legal or regulatory obligation
Execution of public policies
Studies by research body
Execution or creation of contract
Regular exercise of rights
life protection
health guardianship
credit protection

You can read more about the legal basis in the official LGPD by clicking here.

9. About sharing personal data

Partners and other commercial entities linked to cVortex, in addition to cVortex itself, have access to the information covered. We do not sell any personal information. We share your information only in the ways described in this Privacy Policy and only with parties that have appropriate confidentiality and security measures in place.

Employees, Business Partners and Independent Contractors: Employees, business partners and independent contractors of relevant entities have access to information when necessary and for a restricted purpose. We require all employees and independent contractors to follow this Privacy Policy for personal information we share with them.
Legal offices: with legal offices to act in legal proceedings.
Third-Party Service Providers: We may need to share your personal information and aggregated or de-identified information with third-party service providers that we hire, such as marketing and advertising partners, event organizers, web analytics providers, payment processors. These service providers are authorized to use your personal information only as necessary to provide these services to us.
Reseller Partners: We may share your personal information with our authorized reseller partners in your region solely for the purpose of contacting you about products you have downloaded or services you have signed up for. We will give you the option to opt out of continuing to work with that partner.

10. Rights of the holder of personal data

Anyone who has their personal data collected on the platform (obviously subject to processing) has rights guaranteed by the LGPD, such as:

Right of Access: the holder can request and receive a copy of the personal data that we have in relation to him or even understand how these data are used.
Right of Correction: the holder has the right to request the correction of the data stored by the company for reasons that are necessary, such as incompleteness or outdatedness.
Right to Anonymization: the holder has the right to request anonymization of the data.
Right of Portability: the holder may request the portability of their data to another service or product provider, upon express request, in accordance with the regulation of the national authority, observing commercial and industrial secrets.
Right of Blocking and Deletion: the holder can request the suspension of the processing of their personal data or even the deletion of these data.
Right of Information: the holder has the right to transparency, being able to request information about which entities, public or private, their data were shared.
Right of Restriction: the holder can request the restricted use of the processing of their data for the scenarios that they understand as relevant to their interests.
Right of Revocation: the holder has the right to revoke his own previously granted consent.
Right of Opposition: the holder has the right to oppose the Processing of their Personal Data when it is in disagreement or in breach of any determination of the LGPD.
Right of Review of Automated Decision: you can request that decisions taken solely on the basis of automated Processing of Personal Data that affect your interests be reviewed, respecting commercial and industrial secrets.

These rights can be exercised by contacting our responsible director directly. See Service Channels section for data privacy matters.

11. cVortex customer commitment

We understand that you, in the specific role of cVortex customer, are equally willing to follow the LGPD definitions, as well as the related guidelines of this privacy policy, as well as, when registering, you declare that you are the legitimate holder of your personal data (and any dependents). Failure to comply with these guidelines will result in the impossibility of using cVortex products or services.

12. Data retention

We retain your personal information for as long as necessary for the purposes stated in this Privacy Policy. Sometimes, we may retain your information for longer periods, as permitted or required by law or by business definition legally mandated in contract.

When we no longer have a legitimate need to process your information, we will delete or anonymize your information from our active databases. We will also isolate them from active databases, keeping the same security assumptions, until deletion is possible.

13. International Data Transfer

We may transfer and process personal data collected in Brazil (or from Brazilian citizens) to countries located outside of Brazil. In this aspect, the treatment of data and the security applied in addition to the sharing guidelines follow the same precepts already mentioned in this policy.

14. Service channels for data privacy matters

We have appointed a Data Protection Officer (DPO) to oversee our management of your personal information in accordance with this Privacy Policy.

If you have questions or concerns about our privacy practices in relation to your personal information, or would like to exercise your rights as a holder under the LGPD, please contact our DPO, Vitor Lourenço de Amorim, by sending an email to privacy@cvortex .io.

We will be happy to serve you in the best possible way.

15. Changes to this policy

Our Privacy Policy may be updated, depending on the evolution of our products or services, compliance with legislation, among others. Therefore, we will promptly post any future changes to this policy on this page. We ask that you review it frequently for clarification and updated information.

Furthermore, the date of the last change of this policy will always be explicit at the top of this page so that you understand its validity.

16. Applicable Law and Forum

This document is governed by and shall be interpreted in accordance with the laws of the Federative Republic of Brazil. The Forum of the Judicial District of Uberlândia city, state of Minas Gerais, Brazil, is elected to settle any dispute arising from this instrument.

If you need any support or have any questions, requests or suggestions regarding this Policy, we are at your disposal.