Privacy Policy

Acade Sistemas Ltda is committed to complying with laws that protect the privacy of its customers and its general public. This page is designed to provide information about how we are following data protection regulations, what information we collect while you are browsing our communication channels, and how this information is collected, used and protected by us in accordance with Law No. 13.709/2018 (General Data Protection Law - "LGPD"). The use of our products and services, as well as our platforms and other available means of interaction, is subject to acceptance of this Privacy Policy, including with regard to our employees. As Data Controller, Acade Sistemas Ltda behaves as described below.

1. Source of Personal Data

Acade Sistemas Ltda will have access to personal data in the following situations:

• Through interaction with the customer: When the Customer provides and imputes personal data necessary for the provision of services and use of the products provided by Acade Sistemas Ltda.

• Interaction with your employees: When your employees and collaborators of any nature use your systems and platforms to comply with the duties and obligations arising from the contractual relationship they have.

2. Types of personal data and sensitive personal data collected

Without prejudice to the data commonly collected and processed from its employees for the purposes of their legal relationship, Acade Sistemas Ltda may still collect the following personal data:

• Names and contact details, such as first and last name, email address, postal address, home and mobile phone number, and other similar types of contact information, as well as bank details;

• Device information such as IP address, location or provider;

• Usage information and browsing history, how the User navigates within our services, and which elements of Acade Sistemas Ltda's services are most used;

Sensitive personal data, which may be collected by Acade Sistemas Ltda, will have their purpose separately informed to the User, who must consent so that Acade Sistemas Ltda can use them in a specific way, and in case of disagreement, the data will be automatically deleted from your digital database.

Acade Sistemas Ltda does not collect data from minors, except with the authorization of those responsible, and in case of collection without authorization, Acade Sistemas Ltda will immediately delete the collected data from the moment of its knowledge, as rules of the Terms of Use and this Privacy Policy.

3. Use of collected personal data

When collected, Acade Sistemas Ltda will use personal data to:

• Provide and improve contracted services;

• Comply with 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 when necessary or opportune;

• In-house research and development purposes and to improve, test and enhance the features and functions of Acade Sistemas Ltda.'s services;

• Provide Users with marketing, advertising and personalized advertising, including from Acade Sistemas Ltda Partner companies, as permitted by law;

• Meet internal and external audit requirements, including information security obligations of Acade Sistemas Ltda, using data restricted to what will be requested in this document;

• Send messages by email to: a) confirm or cancel requests using 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.

• 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 exercise of the rights of Acade Sistemas Ltda, including, but not limited to the privacy, security, networks, systems and properties of the Parent Company and/or third parties, and to defend itself against any legal actions, for the fulfillment of any legislation or regulation applicable to Acade Sistemas Ltda or third parties with whom we work, as well as for the exercise of proper compliance with contracts signed between the Parent Company and its users;

4. Sharing personal data with third parties

The User accepts and agrees that Acade Sistemas Ltda shares their personal data with the following recipient categories:

• 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 that may take action on our behalf, protecting our rights, users, systems and services;

• Third parties to which Acade Sistemas Ltda responds or is authorized to disclose information by law (Example: government agencies, regulatory agencies, the Judiciary and other public authorities);

• Third parties in order to participate in the sale, merger, acquisition, restructuring, joint venture, assignment, transfer of part or all of Acade Sistemas Ltda's business, in which case the User's data will be considered an active asset and transferred in an eventual negotiation ;

• Third parties who need the data to protect the rights of Acade Sistemas Ltda;

• Any natural or legal person for which the User requests the portability of their data.

5. International transfer of personal data

Acade Sistemas Ltda does not intend to transfer any personal data of the User captured outside Brazil, given that, if not in the following cases, the User will be previously informed by e-mail, when which may or may not accept the transfer, and in case of disagreement, may have their access rights prevented by Acade Sistemas Ltda.

The international transfer of data from the above and described in the General Data Protection Law (LGPD) lacks the designation of legal guidelines to be established by the National Authority for the Protection of Personal Data (ANPD), whereas, when defined , Acade Sistemas Ltda will undertake to comply with them in their entirety.

6. Protection of personal data

Acade Sistemas Ltda uses appropriate technologies and procedures to protect any personal data collected (including administrative, technical and physical protections) in accordance with the level of risk and the service provided, having a legally responsible team to handle secure management data in accordance with legal provisions, regulatory requirements, technology changes, among other relevant factors that may influence the way in which personal data is protected.

Acade Sistemas Ltda employs all reasonable market efforts to ensure the security of its systems and collected data, using highly reliable, qualified and reputable Internet providers and database and storage servers, as well as security certificates (SSL) and software to protect against unauthorized access to systems, as well as methods to encrypt and anonymize the collected data.

This Policy represents the effort of Acade Sistemas Ltda to safeguard User information. However, due to the very nature of the Internet, there is a remote possibility that malicious third parties will succeed in improperly accessing the stored information, which is why, in the event of such a fact, Acade Sistemas Ltda will be responsible within the limits provided for in Law, and it is up to the resolution of situations caused by the fact.

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

• a description of the nature of the personal data affected;

• information about the holders involved;

• 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, if the communication was not immediate;

• the measures that have been or will be taken to reverse or mitigate the effects of the damage.

7. Data processing and responsibility of Acade Sistemas Ltda

The Parent Company will have its responsibility for handling it as follows:

• When dealing with personal data provided directly by its Clients, Acade Sistemas Ltda 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;

• Acade Sistemas Ltda will be the Controller of the Personal Data of its employees, treating them based on the Execution of Contracts, on the Fulfillment of legal or regulatory obligations, and also, in specific and determined situations, on the Consent.

Acade Sistemas Ltda may adopt different and specific legal bases for different processing of personal data.

8. Deadline for processing personal data

Acade Sistemas Ltda calculates the retention period of personal data according to the following criteria:

• Period required to fulfill the purpose of the collection;

• The moment when the Client/User stops using the services of Acade Sistemas Ltda;

• The time required to demonstrate compliance with the duties and obligations of Acade Sistemas Ltda;

• The period required 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 regarding compliance with the legal system, as well as for any legal disputes;

• Transfer to a third party, provided that the data processing requirements laid down by law are respected;

• Exclusive use of the controller, its access by third parties prohibited, except in the light of the provisions previously presented in this Privacy Policy, provided that the data is anonymized.

9. User Rights

In accordance with the Brazilian General Data Protection Law, the User will have the following rights regarding the treatment of their personal data:

• Right of Confirmation: the User can confirm whether Acade Sistemas Ltda handles any personal data of his/her;

• Right of Access: the User may submit 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 out of date;

• Right of Anonymization, blocking or deletion: the User may request the anonymization, blocking or deletion of unnecessary, excessive or processed data in disagreement with the purposes to which he gave consent, observing, for this purpose, other rules of the order legal in question;

• Right of Exclusion: the User may request the deletion of the data provided, except those where the law authorizes its conservation;

• Right of Information: The User may request information from the public and private entities with which Acade Sistemas Ltda shared their data, as well as the consequences if they choose not to consent to the collection and processing of their personal data ;

• Right to Refuse Marketing: The User may, at any time, request the cancellation of receiving advertisements, newsletters and other promotional materials through a link provided in the marketing email sent.

• Portability Right: The User may request that their personal data be transferred to themselves or third parties, except those that have already been anonymized and deleted by Acade Sistemas Ltda.

• Right to Withdraw Consent: The User may cancel any consent previously granted to Acade Sistemas Ltda to use their personal data. The User is aware that the cancellation will not affect the use or sharing of the data made prior to the request to revoke consent.

The rights provided for in this chapter are not absolute, and the User must, whenever he wishes to exercise them, contact Acade Sistemas Ltda through the channel: This email address is being protected from spambots. You need JavaScript enabled to view it.. Acade Sistemas Ltda undertakes to respond to such requests as soon as possible and at no cost to the User, limited to a maximum period of 15 (fifteen) days from receipt of the request, unless a longer period is required. long to respond due to the complexity, factual or legal reasons and opportunity in which the User will be communicated.

Acade Sistemas Ltda will immediately notify the processing agents with whom it has shared the User's data about the correction, deletion, anonymization or blocking of the data, so that they repeat the same procedure.

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

10. Cookies

A cookie is a small text file, placed on a computer or other device, used to identify the User, device 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 resources to their fullest.

• Performance Cookies: they collect information on how the User uses the Acade Sistemas Ltda platform and serve to improve your browsing experience and improve your experience. The information collected includes, for example, internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, the average length of 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 where the User is located) and provide enhanced and more personalized 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 remember that the User has already visited a website and this information is shared with other organizations, such as advertisers.

Acade Sistemas Ltda uses necessary and performance cookies

At any time, the User may disable Cookies through the settings of their browser, installing plug-ins available on the market, or even making use of other technologies that they deem necessary.

In addition to cookies, Acade Sistemas Ltda uses other tracking technologies, such as:

Web Server and Platform Records: Acade Sistemas Ltda's servers automatically collect certain information to assist, administer and protect the services offered, as well as to analyze usage and improve the User's experience. Information collected includes:

• IP address and browser type;

• Device information, including Device Unique Identifier (UDID), MAC address, Advertiser Identifier (IFA) and similar identifiers assigned by us or third parties;

• The device's operating system and other technical data;

• The city, state and country from which you are accessing the platform, including for fraud prevention;

• Information or typed texts;

• Links and buttons clicked;

Social Network Connections: Some of Acade Sistemas Ltda's services may include social networking features such as Facebook “Like” buttons and widgets; “Share” button and interactive mini-programs.

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

11. Contact information

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 Acade Sistemas Ltda, by e-mail: suporte@acade. com

12. Changes

Acade Sistemas Ltda seeks constant updates and improvements, so this Privacy Policy can be updated at any time, always aiming at better provision and protection to users.

In the event of changes that affect the purpose and duration of the processing of the User's personal 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 Acade Sistemas Ltda.

If in the future Acade Sistemas Ltda changes its policy aimed at sharing data with third parties, it will send a notice 30 (thirty) days in advance to the user through the registered email address, who may disagree with the sharing, at which time it will continue to use the services of Acade Sistemas Ltda.

The User is advised to periodically read this policy in order to be kept up to date with its content.

13. Legislation and jurisdiction

This Policy will be governed, interpreted and executed in accordance with the laws of the Federative Republic of Brazil, regardless of the conflicts of these laws with the laws of other states or countries, the Forum of João Pessoa/PB being competent to resolve any doubts arising of this instrument, with the waiver of any other, however privileged it may be.

All rights reserved.

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