Privacy Policy: User Rights and Contact

General information

In compliance with Federal Law No. 13.709/2018 (General Personal Data Protection Law - LGPD) and other applicable rules, Holmes Technology, committed to showing its commitment to treat your personal data with security, privacy and transparency, makes this Privacy Policy public, describing the main information about the treatment and your rights in relation to this data.

This website is maintained and operated by Holmes TechnologyLTDA, referred to in this policy as Holmes Technology.

We collect and use some personal data belonging to those who use our site. In doing so, we act as the Controller of this data and are subject to the provisions of the LGPD.

We care about the protection of your personal data and have therefore made available this Privacy Policy, which contains important information about:

- Who should use our website;
- What data we collect and what we do with it;
- Your rights in relation to your personal data; and
- How to contact us.

1. Who should use our website

Our website should only be used by people over the age of eighteen. Therefore, if personal data of children and adolescents is detected, it will be discarded immediately.

2. Data we collect and reasons for collection

Our website collects and uses some personal data from our users when they use the contact form. The data is collected so that the sales team can contact the user via email and telephone, while the other data isused to help Holmes Technology in the sales process with segment data, company name and number of employees.

3. Personal data expressly provided by the user

We collect the following personal data that our users expressly provide to us when using our website:

Full name;
Cell phone;
E-mail; and
Name of the company where the user works.

This data is collected at the following times:

- When the user uses the contact form.

The data provided by our users is collected for the following purposes:

- Prospecting sales and/or partnerships; and

- Sending newsletters.

4. Sensitive data

No sensitive data will be collected from our users, as defined in articles 11 et seq. of the LGPD. Thus, there will be no collection of data on racial or ethnic origin, religious conviction, political opinion, membership of a trade union or religious, philosophical or political organization, data relating to health or sex life, genetic or biometric data, when linked to a natural person.

5. Cookies

Cookies are small text files that are automatically downloaded to your device when you access and browse a website. They are basically used to identify users' devices, activities and preferences.

Cookies do not allow any files or information to be extracted from the user's hard disk, and it is not possible to access personal information that does not come from the user or from the way they use the site's resources.

a. Website cookies

Website cookies are those sent to the user's computer or device and administered exclusively by the website. The information collected through these cookies is used to improve and personalize the user experience, and some cookies may, for example, be used to remember user preferences and choices, as well as to offer personalized content.

b. Third-party cookies
Some of our partners may set cookies on the devices of users who access our website.

These cookies, in general, aim to enable our partners to offer their content and services to the user who accesses our site in a personalized way, by obtaining browsing data extracted from their interaction with the site.

The user can obtain more information about third-party cookies and how the data obtained from them is processed, as well as having access to a description of the cookies used and their characteristics, by accessing the following link:

Google Analytics:

https://policies.google.com/technologies/cookies?hl=pt-BR

Hubspot Clarity

https://clarity-software.com/privacy-policy/

Facebook

https://pt-br.facebook.com/privacy/policy/?entry_point=facebook_page_footer

Cloudflare

https://www.cloudflare.com/pt-br/privacypolicy/

The entities responsible for collecting cookies may transfer the information obtained to third parties.

c. Management of cookies

The user may object to the use of cookies by the site by simply deactivating them when they start using the service, following the instructions described below.

The user can disable cookies directly in their browser, but the site/application does not have a specific tool in which the user can disable them within the site/application itself. Disabling all cookies, however, will not be possible, since some of them are essential for the website to function correctly.

6. Collection of data not expressly provided for

Occasionally, other types of data not expressly provided for in this Privacy Policy may be collected, provided that they are provided with the user's consent, or that the collection is permitted on the basis of another legal basis provided for by law.

In any case, the collection of data and the processing activities resulting from it will be informed to the users of the website.

The user can disable cookies directly in their browser, but the website/application does not have a specific tool in which the user can disable them within the website/application itself;

7. Sharing personal data with third parties

We do not share your personal data with third parties. However, we may do so in order to comply with a legal or regulatory requirement, or to comply with an order issued by a public authority.

8. How long your personal data will be stored

The personal data collected is stored for as long as you are a Client or Prospect, during your use of our products and services and for as long as Holmes Technology stores your personal data, it will be kept at

secure and controlled environment, according to each process developed and its purpose in compliance with legal obligations.

The period informed is no longer than is strictly necessary, taking into account the purposes and legal justifications for processing the data.

In accordance with current legislation, Holmes Technology uses your Personal Data for as long as necessary to satisfy the purposes for which your Personal Data was collected, and may store your Personal Data for auditing purposes, compliance with legal or regulatory obligations, for the regular exercise of rights or for the period necessary according to the legal basis that justifies the retention of the data.

At the end of the processing of your data, it will be deleted within the scope and technical limits of the activities, with retention authorized in the situations provided for in current legislation.

9. Legal bases for processing personal data

Every personal data processing operation must have a legal basis, i.e. a legal basis, which is a justification that authorizes it, as provided for in the LGPD. All of our personal data processing activities have a legal basis that supports them, among those permitted by law.

More information on the legal bases we use for specific personal data processing operations can be obtained from our contact channels, which are listed at the end of this Policy.

10. User rights

Website users have the following rights under the LGPD:

- confirmation of the existence of processing;

-access to data;

-correction of incomplete, inaccurate or outdated data;

-anonymization, blocking or deletion of data that is unnecessary, excessive or processed in breach of the law;

-portability of data to another service or product provider, upon express request, in accordance with the regulations of the national authority, observing commercial and industrial secrets;

-deletion of personal data processed with the consent of the data subject, except in the cases provided for by law;

-information on public and private entities with which the controller has shared data;

-information on the possibility of not providing consent and the consequences of refusing to do so;

- revocation of consent.

It is important to note that, under the terms of the LGPD, there is no right to delete data processed on legal grounds other than consent, unless the data is unnecessary, excessive or processed in breach of the law.

a. How the data subject can exercise their rights

The holders of personal data processed by us may exercise their rights by sending a message to the following e-mail address: privacidade@holmes.app.

In order to ensure that the user who wishes to exercise their rights is in fact the holder of the personal data which is the subject of the request, we may ask for documents or other information which may help to correctly identify them, in order to safeguard our rights and the rights of third parties. This will only be done, however, if it is absolutely necessary, and the requester will receive all related information.

11. Security measures in the processing of personal data

We employ technical and organizational measures to protect personal data from unauthorized access and from destruction, loss or alteration.

The measures we use take into account the nature of the data, the context and purpose of the processing, the risks that a possible breach would generate for the rights and freedoms of the user, and the standards currently employed in the market by companies similar to ours.

Among the security measures adopted by us, we highlight the following:

Holmes Technology uses advanced security technologies to ensure the protection of personal data collected, website and related. The data collected and the connections to the website are encrypted, prioritizing security and user experience.

Although we do everything in our power to prevent security incidents, it is possible that a problem may occur that is caused exclusively by a third party - such as in the case of hacker or cracker attacks, or even in the case of the user's sole fault, which occurs, for example, when they transfer their data to a third party. Therefore, although we are generally responsible for the personal data we process, we disclaim liability in the event of an exceptional situation such as this, over which we have no control whatsoever.

In any case, should any type of security incident occur that could generate significant risk or damage to any of our users, we will notify those affected and the National Data Protection Authority of what has happened, in accordance with the provisions of the LGPD.

12. Complaint to a supervisory authority

Without prejudice to any other administrative or judicial remedy, holders of personal data who feel in any way harmed may lodge a complaint with the National Data Protection Authority.

13. Changes to this policy

This version of this Privacy Policy was last updated on: 12/05/2023. We reserve the right to modify these rules at any time, especially to adapt them to any changes made to our website, either by making new features available or by deleting or modifying existing ones.

Whenever there is a change, our users will be notified of the change. We recommend that you access it frequently, or whenever you have questions, to see any updates or changes to our Privacy Policy.

14. How to contact us

If you have any questions about this Privacy Policy or the personal data we process, please contact our Personal Data Protection Officer through one of the channels mentioned below:

E-mail:privacidade@holmes.app
Data Protection Officer: Athena Security
Postal address: Av. das Nações Unidas, 12901 - Cidade Monções, São Paulo - SP, 04578-910
Telephone: +55 (11) 4890-8960

Privacy Policy