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”, “us” or “our”). This Policy is addressed to individuals outside our organization with whom we interact, including visitors to our websites (our “Websites”), customers, and other users of our Services (collectively, “you”). Definitions of the terms used in this Policy can be found in Section (M) below.

For the purposes of this Policy, Bot is the Data Controller of your Personal Data, and this Policy applies regardless of whether you interact with Bot in Brazil, Portugal, Spain, or elsewhere. We comply with all applicable data protection laws, including but not limited to the General Data Protection Regulation (GDPR – EU/EEA), the Portuguese and Spanish Data Protection Laws, and the Brazilian General Data Protection Law (LGPD).

Contact information is provided in Section (L) below for each Bot entity. This Policy may be amended or updated periodically to reflect changes in our Personal Data Processing practices or changes in applicable law. We encourage you to read this Policy carefully and check this page regularly to review any changes.

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B. Data Minimization

We take all reasonable steps to ensure that the Personal Data we process is limited to what is necessary for the purposes described in this Policy (including the provision of Services to you), in line with the principle of data minimization required by GDPR and LGPD.

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C. Disclosure of Personal Data to Third Parties

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

We may also 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 subject to binding confidentiality obligations;
• Subcontractors (e.g., payment service providers, logistics companies, technology providers, customer survey providers, live-chat service operators), under data processing agreements as required by law;
• Any relevant third party, law enforcement agency, or court as necessary for legal claims, defense, compliance, or prevention and investigation of crimes;
• Acquiring entities in the event of a sale or transfer of all or part of our business or assets, but only in accordance with applicable law;
• Third-party content providers (e.g., social media platforms) if you interact with their content on our Websites.

We will ensure that third parties maintain appropriate data security and confidentiality measures and comply with all applicable laws. We may anonymize your Personal Data (e.g., in aggregate form) and share anonymized data with business partners.

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D. Data Security

We implement appropriate technical and organizational measures to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access, and other unlawful or unauthorized forms of Processing, as required by GDPR, LGPD, and local regulations.

You are responsible for ensuring that any Personal Data you submit to us is transmitted securely.

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E. Data Accuracy

We take reasonable steps to ensure that:
• Your Personal Data is accurate and, where necessary, kept up to date;
• Any inaccurate Personal Data is rectified or erased without delay.

We may periodically request you to confirm the accuracy of your data.

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F. Data Retention

We retain your Personal Data only as long as necessary for the purposes set out in this Policy or as required by law. Data will be retained:
• As long as you have an ongoing relationship with us (e.g., user of our Services or subscriber to our communications);
• For as long as we have a valid legal basis (such as a contract, legal obligation, or legitimate interest).

Additionally, we may retain data for the duration of any applicable statutory limitation period, and for an additional period as required to protect our legal rights or comply with legal obligations.

When these periods expire, Personal Data will be securely deleted or destroyed.

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G. Your Legal Rights

Depending on your jurisdiction (EU/EEA, UK, Brazil, etc.), you may have the following rights:
• Access to your Personal Data and information about its processing;
• Correction of inaccurate Personal Data;
• Erasure of your Personal Data (“right to be forgotten”) in certain cases;
• Restriction of Processing in certain circumstances;
• Objection to the Processing of your data for specific purposes;
• Data portability (to receive your data in a structured, commonly used format or have it transmitted to another controller);
• Withdrawal of consent at any time (where Processing is based on consent);
• Lodge a complaint with your local Data Protection Authority.

To exercise these rights, please use the contact information in Section L.

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H. Cookies

We use cookies and similar technologies on our Websites to enhance your experience, analyze usage, and for marketing purposes. For details, please see our Cookie Policy.

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I. Terms of Use

Use of our Websites is subject to our Terms and Conditions and this Privacy Policy.

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J. Direct Marketing

Where permitted by law, and with your express consent where required, we may process your Personal Data to send you direct marketing communications (by email, telephone, etc.) about our Services, promotions, or news. You can unsubscribe at any time by following the instructions in our communications.

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K. Processing of Personal Data

We may collect and process your Personal Data when:
• You contact us (by email, phone, or otherwise);
• You fill in forms on our Website;
• You use our Websites and Services (which may include automatic data collection such as IP address, device information, etc.);
• In the normal course of business and Service provision.

Personal Data we may process includes, but is not limited to:
• Identification and contact details (name, address, phone, email, etc.);
• Device information (model, serial number, etc.);
• Service-related information (e.g., support queries, order history);
• Other data required to fulfill our contractual or legal obligations.

Provision of data is voluntary but necessary for us to provide Services. If you do not provide data, we may not be able to fulfill our contractual obligations.

Data destruction: Physical documents are securely shredded; digital data is permanently deleted after expiry of the relevant retention period. We do not retain data from recovered devices after delivery to the client.

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L. Contact Information

For questions or to exercise your rights, please contact the relevant entity:

Brazil:
Bot Data Recovery LTDA
200 Susana Maria Street, Ouro Preto
Belo Horizonte, Minas Gerais, Brazil, Zip Code 31340-025
[email protected]

Portugal ans Spain:
MatrixMassive LDA
Regus Building
Rua Augusto Rosa, 79
Porto, Portugal, CP 4000-098
[email protected]

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M. Definitions
• Controller: The entity deciding how and why Personal Data is processed.
• Data Protection Authority: The independent public authority monitoring data protection compliance.
• Personal Data: Any information relating to an identified or identifiable individual.
• Processing: Any operation performed on Personal Data (collection, storage, use, transmission, etc.).
• Sub-processor: Any third party processing Personal Data on behalf of the Controller.
• Services: Services provided by Bot.
• Sensitive Personal Data: Data relating to race, ethnicity, political opinions, religion, health, sex life, criminal convictions, or similar.

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Last updated: October 2024