There is no fine print here. We are transparent!

A. This Policy

This Policy is issued by the entities listed in Section L below (together, “Bot”, “we” or “our”). This Policy is directed to people outside of our organization with whom we interact, including visitors to our websites (our “Websites”), customers, and other users of our Services (collectively, “you”). Definitions of terms used in this Policy can be found in Section (M) at the bottom. For the purposes of this Policy, Bot is the Data Controller of the data subject’s Personal Data. Contact information is provided in Section (L) below so that the relevant Bot entity can answer questions about the use and handling of the data subject’s Personal Data. This Policy may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Policy carefully, and to check this page regularly in order to review any changes that may have been made in accordance with the terms of this Policy.

B. Data minimization

We take all reasonable steps to ensure that the Data Subject Personal Data that we process is limited to Personal Data reasonably necessary for the purposes described in this Policy (including the provision of Services to you).

C. Disclosure of Personal Data to Third Parties

We may disclose your Personal Data to other entities within the Bot group in order to fulfill our contractual obligations to you or for legitimate business purposes (including the provision of Services to you and the operation of our Websites) in accordance with applicable law. Additionally, we may disclose your Personal Data to:

– legal and regulatory authorities, upon request, or to report any actual or suspected violation of applicable law or regulation;

– accountants, auditors, lawyers and other professional advisors external to Bot, subject to legally or contractually binding confidentiality obligations;

– Subcontractors (such as payment service providers; channel and retail partners, transportation/courier companies; technology providers, customer satisfaction survey providers, live-chat service operators) located anywhere in the world, subject to the requirements described below in this Section (C);

– any relevant third party, law enforcement agency or court, to the extent necessary to establish, exercise or defend legal rights, or any relevant party for the purpose of prevention, investigation, detection or punishment of criminal offenses or the enforcement of criminal sanctions;

– any third-party acquiring entity, in the event of the sale or transfer of all or any part of our business or assets (including in the event of a reorganization, dissolution or liquidation), but only in accordance with applicable law; and

– our Web sites may use content from third parties. If you decide to interact with any such content, your Personal Data may be shared with the third party provider of the relevant social platform. We recommend that you review the third party’s privacy policy before interacting with its contents.

If we contract with a Subcontractor to Process the Data Subject’s Personal Data, we will enter into a data processing agreement with the Subcontractor as required by the applicable laws in question so that it will be subject to binding contractual obligations to: (i) Process Personal Data only in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of Personal Data; together with any additional requirements required by applicable law. In all cases, Bot is primarily responsible for the acts and omissions of those third parties to whom Bot has entrusted personal data. Bot will ensure that, before transferring personal data to third parties, all such third parties will maintain security and data handling measures in accordance with standards prescribed by Bot. We may anonymize Personal Data about the use of the Websites (e.g., by storing the data in aggregate form) and share such anonymized data with our business partners (including external business partners).

D. Data Security

We implement appropriate technical and organizational measures to protect the data subject’s Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access and other unlawful or unauthorized forms of Processing, in accordance with applicable law.

You agree to ensure that any Personal Data you submit to us is sent in a secure manner.

E. Data Accuracy

We take all reasonable steps to ensure that:

– the Personal Data of the data subject that we process is accurate and, where necessary, kept up to date; and

– any Personal Data of the data subject which we process that is inaccurate (having regard to the purposes for which it is processed) is erased or rectified without delay.

From time to time we may request confirmation of the accuracy of your Personal Data.

F. Data retention

We take all reasonable steps to ensure that your Personal Data is only processed for the minimum period necessary for the purposes described in this Privacy Policy. We retain copies of the holder’s Personal Data in order to allow identification only as long as:

– we have an ongoing relationship with you (e.g., for as long as you are a user of our Services, or are lawfully included in our recipient list without unsubscribing); or

– your Personal Data is necessary for the purposes described in this Privacy Policy for which we have a valid legal basis (e.g., in the event that your Personal Data is included in an order placed by your employer, and Bot has a legitimate interest in the processing of such data for the operation of the business and the performance of its obligations under that contract).

Additionally, we retain Personal Data during:

– any applicable limitation period under applicable law (i.e., any period in which a person may file a lawsuit against Bot relating to the Holder’s Personal Data, or for which the Personal Data may be relevant); AND an additional two (2) months after the end of such applicable limitation period (so that, in the event that someone files a lawsuit at the end of the limitation period, Bot may still have a reasonable period of time to identify any Personal Data relevant to such lawsuit).

In the event of the filing of any legal action, we may continue to Process your Personal Data for the additional periods necessary in connection with such action.

During the periods indicated above in connection with legal proceedings, Bot will restrict Processing of the data subject’s Personal Data to storing, and maintaining the security of, the Personal Data, except to the extent that the Personal Data needs to be reviewed in connection with any legal proceedings, or any obligation under applicable law.

Upon the expiration of the periods described above, within each applicable limit, Bot will permanently delete or destroy the relevant Personal Data.

G. Legal rights of the holder

Subject to applicable law, you may have certain rights with respect to the Processing of your Personal Data, including:

– the right to request access to or copies of your Personal Data processed or controlled by Bot, as well as information about the nature, processing and disclosure of that Personal Data;

– the right to request rectification of any inaccuracies in your Personal Data processed or controlled by Bot;

– the right to request, on legitimate grounds: the erasure of your Personal Data Processed or controlled by Bot or the restriction of the Processing of your Personal Data Processed or controlled by Bot;

– the right to object, on legitimate grounds, to the Processing of your Personal Data by Bot or its representative;

– the right to transfer your Personal Data Processed or controlled by Bot to another Controller to the extent applicable;

– the right to withdraw its consent for processing, in case the lawfulness of the processing is based on consent, although this does not compromise the lawfulness of the processing carried out on the basis of the consent previously given; and

– the right to lodge complaints with the Data Protection Authority regarding the Processing of your Personal Data by Bot or its representative.

This provision does not affect the holder’s legal rights. To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Policy, or about our Treatment of your Personal Data, please use the contact information listed in Section (L) below. In case we provide Services to you on the basis of orders, such provision of Services is governed by contractual conditions provided to you. If there are discrepancies between those conditions and this Policy, this Policy is supplemental.

H. Cookies

Cookies are small files placed on your device when you visit a website (including our websites). Cookies record information about your device, browser and, in certain cases, your browsing preferences and habits. We may Process Personal Data using cookie technology, in accordance with our Cookie Policy.

I. Terms of Use

All use of our Web sites is subject to our Terms and Conditions and our Privacy Policy.

J. Direct Marketing

Subject to applicable law, where you have given your express consent in accordance with applicable law or when we send advertising and marketing communications relating to similar products and services, Bot may Process your Personal Data in order to contact you by email, telephone, direct mail or other communication formats to provide you with information or Services that may be of interest to you. In the event that we provide Services to you, we may send you information about our Services, future promotions and other information that may be of interest to you, using the contact information provided by you and always in compliance with applicable law. You may unsubscribe from our promotional mailing list or newsletters at any time simply by selecting the unsubscribe link included in each email or newsletter we send. Upon cancellation of the subscription, Bot will no longer send e-mails, but may continue to contact the subscriber as necessary for the purposes of any Service requested by the subscriber.

K. Processing of personal data

Personal Data Collection:
– When you contact us by e-mail, telephone or any other means.

– In the normal course of our relationship with you (for example, Personal Data obtained by Bot when filling out the form on the site).

– When you visit any of our Websites or use any features or resources available on or through our Websites. When you visit a Website, your device or browser may automatically disclose certain information (such as your device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connection to a Website, and other technical communications information), some of which may constitute Personal Data.

Creation of Personal Data:
In providing our Services, we may also create Personal Data about the data subject, such as records of your interactions with us and details of your order history.

Personal data about you that we may process includes:

Form field Purpose (legality of processing) Legal basis Maximum storage time
Nif Comply with the law Article 52º CIVA. 10 years
Cpf Comply with the law Law 5.172, National Tax Code, Art. 173; 5 years
Device Mandatory item for budget composition Civil code and consumer law 5 years
Manufacturer Mandatory item for budget composition Civil code and consumer law 5 years
Capacity Mandatory item for budget composition Civil code and consumer law 5 years
Model or serial number Mandatory item for budget composition Civil code and consumer law 5 years
What happened to the device? Mandatory item for budget composition Civil code and consumer law 5 years
What was done after the problem was identified? Mandatory item for budget composition Civil code and consumer law 5 years
Mode of analysis Mandatory item for budget composition Civil code and consumer law 5 years
Name / Corporate Name Mandatory item for budget composition Law 5.172, National Tax Code, Art. 173 and CIVA; 5 years
Telephones Mandatory item for budget composition Civil code and consumer law 5 years
Email Mandatory item for budget composition; sending information about the services; surveys to get feedback about our services. Civil Code and Consumer Law 5 years
Postal Code Mandatory item for budget composition Law 5.172, National Tax Code, Art. 173; 5 years
Address Mandatory item for budget composition Law 5.172, National Tax Code, Art. 173; 5 years
Number and complement Mandatory item for budget composition Civil code and consumer law 5 years
City/Town Mandatory item for budget composition Law 5.172, National Tax Code, Art. 173; 5 years
State/District Mandatory item for budget composition Law 5.172, National Tax Code, Art. 173; 5 years
Voluntary provision of Personal Data and consequences of not providing it: The provision by you of your Personal Data is voluntary and will generally be a necessary requirement to enter into a contract with us and to enable us to fulfill our contractual obligations to you. You are under no legal obligation to provide us with your Personal Data; however, if you choose not to provide us with your Personal Data, we will not be able to conclude the contractual relationship with the data subject and fulfill our contractual obligations to you.

Data destruction:

Physical documents are destroyed with a paper shredder. The other data is securely and permanently destroyed once the time limit has expired. The bot does not keep the data from the eventually recovered devices in its lab once they are sent to the client which are destroyed immediately.

L. Contact Information

Should you have comments, questions or concerns about any information contained in this Policy, or other matters relating to Bot’s Handling of Personal Data, please contact the appropriate entity identified below:

Brazil:

Bot Data Recovery LTDA

200 Susana Maria Street, Ouro Preto

Belo Horizonte, Minas Gerais, Brazil, Zip Code 31340-025

[email protected]

Portugal:

MatrixMassive LDA

Regus Building

Rua Augusto Rosa, 79

Porto, Portugal, CP 4000-098

[email protected]

M. Definitions

– ‘Controller’ means the entity who decides how and why Personal Data is Processed. In many jurisdictions, the Controller is primarily responsible for compliance with applicable data protection legislation.

– ‘Data Protection Authority’ means an independent public authority legally charged with monitoring compliance with applicable data protection legislation.

– ‘Personal Data’ means information about any individual, or that can identify any individual. Examples of Personal Data that may be processed by Bot are provided in Section (K) above.

– ‘Process’, ‘Treatment’ or ‘Treaty’ means any processing of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

– ‘Sub-processor’ means any person or entity who Processes Personal Data on behalf of the Controller (other than employees of the Controller).

– ‘Services’ means any services provided by Bot.

– ‘Sensitive Personal Data’ means Personal Data about race or ethnicity, political opinions, religious beliefs or philosophical convictions, trade union membership, physical or mental health, sexual life, any established or alleged criminal offenses or penalties, national identification number, or any other information that may be considered sensitive under applicable law.