book your demo

To facilitate the understanding of this Notice, we provide a summary table of the information that will be presented to you in this document:

This Notice is intended for all data subjects, natural persons, who use PUPILA's services through our Platform ("USER").

This Notice is intended for all data subjects, natural persons, who use PUPILA's services through our Platform ("USER").Your personal data will be processed by PUPILA. We assume the predominant role of Personal Data Controller, that is, we decide how your personal data will be processed, applying good practices in data protection and following the provisions of the LGPD.

The information we process about you may have been provided directly by you to PUPILA or collected automatically through our Website or Platform.

Let's better understand each of these data collection situations:

a. Information provided directly by you

From the beginning of your interaction with us, you voluntarily provide us with information about yourself. For example, when you sign up to use our Platform, contact us through social networks or our customer service channels, when you interact with the content of our Website or Platform, by email, or other tools.

b. Information obtained automatically

In some situations, we may also collect personal data automatically through the devices you use to access our Platform and Website. This information helps us generate access statistics and thus better understand our audience. This is important so that we can improve our services and adapt them to diverse audiences. Some of this data may be collected through cookies or similar technologies, as we will explain in a separate topic below.

In order to respect your privacy, we understand that all processing of personal data should be limited to the minimum necessary, in a relevant and proportionate manner to allow the intended purpose to be carried out.

Therefore, the personal data we collect about you will vary depending on the relationship you choose to have with us. Below, grouped into categories, we present the main personal data that may be processed by us and the purpose of the processing:

1. Registration data: full name;

2. Contact information: phone and email; and

3. Attributes associated with your electronic devices: access provider, operating system, browser (type, version, enabled options, and installed plugins), video settings (size/resolution and number of colors), access date and time, pages viewed through cookies, access device characteristics; IP (with date and time); IP origin; language preference; country setting; click information and geolocation.

We do not collect sensitive personal data on our Website/Platform.

The Personal Data we collect can be used as described in the table below:

Cookies are files or information that can be stored on your devices when you access PUPILA's Website/Platform.

We use cookies to facilitate usage and tailor our pages to the interests and needs of data subjects, as well as to compile information about the use of the Site, aiding in the improvement of its structure and content. Below, you can see the types of cookies and their respective purposes that justify the use of the information we collect, in accordance with the LGPD:

PUPILA may share the use of your personal data, in which case it will be restricted to the minimum necessary and required for the fulfillment of specific purposes previously informed to you in this Notice.

Thus, we may share your data with third parties in the following situations:

‍

• Business partners and service providers, to enable the operation of communication and marketing channels, as well as the provision of necessary structures for the viability of our services, and

• In the event of a corporate operation, such as mergers, acquisitions, spin-offs, and incorporations, and

• With administrative and judicial authorities when necessary to comply with a legal obligation or to assist in the investigation of suspicious or illegal activities, and  

• With law firms, legal advisors, and other legal representatives when necessary to defend PUPILA's interests in administrative, arbitration, or judicial proceedings, and  

• With operators and service providers essential to our activities, including information technology services, data hosting, cloud database hosting, Power BI (Business Intelligence), among others, in accordance with the instructions and purposes provided for in the contractual instruments signed with PUPILA.

Finally, it is possible that some transfers may occur abroad, notably to companies providing cloud data storage services, on servers located outside of Brazil. On this occasion, PUPILA undertakes to do so observing all current legal determinations and best practices in security and privacy.

In any of the above cases, PUPILA will make its best efforts to establish responsibilities with the companies receiving personal data, through adequate contractual instruments, containing provisions on legal bases, purposes, forms of treatment, security measures, among other safeguards conferred to data subjects, in accordance with the LGPD.

To protect the privacy of data subjects, personal data processed by PUPILA will be automatically deleted when they are no longer useful for the purposes for which they were collected, or when the data subject requests their deletion, except if their maintenance is expressly authorized by law or applicable regulation.

We emphasize that information may be retained to comply with legal or regulatory obligations, transfer to third parties – provided that the data processing requirements are respected – and for the exclusive use of PUPILA in exercising its rights in judicial or administrative proceedings.

Finally, the data subject should be aware that their request may be legally rejected, either for formal reasons (such as their inability to prove their identity) or legal reasons (such as the request for deletion of data whose retention is permitted to PUPILA by current legislation).

We use reasonable market means and those legally required to preserve the privacy of the personal data we collect. Thus, we adopt various precautions, in compliance with the guidelines on security standards established in Decree No. 8,771/2016, such as:

• Protection against unauthorized access to our systems,

• Authorization of access only to previously authorized persons at the location where the collected information is stored, including employees and representatives of PUPILA and/or duly authorized partners, and  

• Those who encounter personal data must commit to maintaining absolute secrecy. Breaking the confidentiality will result in civil liability in accordance with Brazilian law.

In addition to technical efforts, we also adopt institutional best practices aimed at protecting personal data. It is important to note that, although PUPILA makes its best efforts to preserve privacy and protect the data of data subjects, no transmission of information is completely secure, so we cannot guarantee fully that all data received or sent will not be subject to unauthorized access executed with methods aimed at obtaining information improperly.

Regardless of the relationship you choose to establish with PUPILA, you have all the rights related to your personal data provided by law, including:

1. Knowing if we process any of your personal data,

2. Knowing which of your personal data are processed by us,

3. Correcting incomplete, inaccurate, or outdated data,

4. Requesting anonymization, blocking, or deletion of unnecessary, excessive, or possibly processed data in violation of the law,

5. Requesting data portability to another service or product provider,

6. Asking for a review of solely automated decisions that affect your interests,

7. Requesting the deletion of data processed with your consent,

8. Obtaining information about public or private entities with whom we share your data, and

9. When processing activity requires your consent, you may refuse to consent. In this case, we will inform you about the consequences of not performing such activity. If you consent, you may revoke it at any time.

You can exercise your rights at any time by contacting us by email privacy@pupila.ai.

To do so, we ask that you identify yourself and indicate which right you intend to exercise. It is possible that other information and/or documents may be requested by PUPILA to confirm the identity or veracity of your information.

Requests involving personal data and/or documents of other data subjects will not be met, except by proxy, parental authority, or another hypothesis authorizing the exercise of another data subject's right by you.

It is important to inform that, in specific circumstances, your request may not be met. In these cases, we will explain the reasons for not meeting the request.

If you have any questions, you can contact us by email privacy@pupila.ai.

Some of the information provided here may be updated or changed. Therefore, we advise you to periodically consult this Privacy Notice. When there is any change, we will inform you on our homepage.

This Privacy Notice was last changed and published on our Website/Platform in:

May/2024

THE RIGHT TO UNDERSTAND: EXPLANATIONS ABOUT SOME TECHNICAL TERMS OF THIS NOTICE.