Here at Bot we intend to make known to our users the general rules of privacy and processing of personal data that we collect in compliance with the Law on the Protection of Personal Data. These policies apply exclusively to the collection and processing of personal data made by Bot Recuperação de Dados
A. This Policy
This Policy is issued by the entities listed in Section M below (together, “Bot”, “we” or “our”). This Policy is addressed to people outside our organization with whom we interact, including visitors to our websites (our websites), customers, and other users of our Services (together, “the owner”). The definitions of the terms used in this Policy can be found in the Section (M) below. For the purposes of this Policy, Bot is responsible for the processing of the holder’s Personal Data. Contact information is provided in section (L) below so that the Bot entity concerned can answer questions about the use and processing of the holder’s Personal Data. This Policy may be amended or updated from time to time to reflect changes in our practices regarding the Processing of Personal Data, or changes in applicable law. Encorajamos o titular a ler cuidadosamente a presente Política, e a conferir esta página regularmente de forma a rever quaisquer alterações que possam ter sido efectuadas de acordo com os termos desta Política.
B. Data Minimization
We take all reasonable steps to ensure that the Personal Data of the data subject we Process is limited to the Personal Data reasonably necessary for the purposes described in this Policy (including the provision of Services to the data subject).
C. Divulgação de Dados Pessoais a terceiros
Poderemos divulgar os Dados Pessoais do titular a outras entidades do grupo Bot, de forma a cumprir as nossas obrigações contratuais com o mesmo ou para finalidades comerciais legítimas (incluindo a prestação de Serviços ao titular e a operação dos nossos Websites), de acordo com a lei aplicável. Adicionalmente, poderemos divulgar os Dados Pessoais do titular a:
• legal and regulatory authorities, upon request, or for the purpose of reporting any violation found or suspected of violation of applicable law or regulation;
• accountants, auditors, lawyers and other professional consultants outside bot, subject to legally or contractually binding confidentiality obligations;
• Subcontractors (such as payment service providers; channel and retail partners, transport/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 purposes of preventing, investigating, detecting or sanctioning criminal offences or the enforcement of criminal penalties;
• any third party acquiring, in the event of the sale or transfer of all or any part of our business or assets (including in the case of a reorganization, dissolution or liquidation), but only in accordance with applicable law; And
Caso contratemos com um Subcontratante para Tratar os Dados Pessoais do titular, concluiremos com o Subcontratante um acordo de tratamento de dados conforme exigido pelas leis aplicáveis em questão para que este fique sujeito a obrigações contratuais vinculativas para: (i) Process only Personal Data in accordance with our prior written instructions; And (ii) use measures to protect the confidentiality and security of Personal Data; along with any additional requirements required by applicable law. In all cases, Bot is primarily responsible for the acts and omissions of these third parties, to whom Bot has entrusted personal data. Bot will ensure that, prior to transferring personal data to third parties, all such third parties will maintain security and data handling measures in accordance with the standards prescribed by Bot. We may anonymize Personal Data about the use of the Websites (e.g. by storing the data in aggregate format) and share this anonymised data with our business partners (including external business partners).
D. Data Security
We have implemented appropriate technical and organizational measures to protect the Holder’s Personal Data from accidental or unlawful destruction, loss, alteration, disclosure or unauthorized access, as well as other forms of unlawful or unauthorized Processing, in accordance with applicable law.
The holder undertakes to ensure that any Personal Data you send to us is sent securely.
E. Data Accuracy
We take all reasonable steps to ensure that:
• the Personal Data of the data subject we process is reliable and, when necessary, kept up to date; And
• any Personal Data of the data subject that we process that is incorrect (taking into account the purposes for which they were Processed) are deleted or rectified without delay.
From time to time we may request confirmation of the accuracy of the holder’s Personal Data.
F. Data Retention
• we maintain an ongoing relationship with the holder (e.g. as long as he or she is a user of our Services, or is legally included in our recipient list without having cancelled the subscription); Or
In addition, we retain Personal Data for:
• any limitation period applicable under applicable law (i.e. any period in which a person may bring legal proceedings against bot relating to the holder’s Personal Data, or for which Personal Data may be relevant); And an additional period of two (2) months after the expiry of that applicable limitation period (so that, in the event that someone lodges a legal action at the end of the limitation period, Bot may still have a reasonable period to identify any Personal Data that is relevant to that action).
In the event of any legal action, we may continue to Process the Holder’s Personal Data for the necessary additional periods relating to such action.
During the periods listed above in connection with legal proceedings, Bot will restrict the Processing of the Holder’s Personal Data to the storage, and security of, personal data, except to the extent that Personal Data needs to be reviewed in connection with any legal action, or any obligation under applicable law.
After the expiry of the periods described above, within each applicable limit, bot will permanently erase or destroy the relevant Personal Data.
G. Legal rights of the holder
Subject to applicable law, the data subject may have certain rights in relation 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 such Personal Data;
• the right to request rectification of any inaccuracies of 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 oppose, on legitimate grounds, 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 your consent to treatment, in the event that the legality of 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 legal rights of the holder. 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 Processing of the Personal Data of the Holder, please use the contact information indicated in Section (L) below. In the event that we provide Services to the holder on the basis of orders, this provision of Services is governed by contractual conditions provided to the holder. If there are discrepancies between these conditions and this Policy, this Policy is supplemental.
J. Direct Marketing
Subject to applicable law, where the holder has given his express consent in accordance with applicable law or when we send advertising and marketing communications related to similar products and services, Bot may Process the Holder’s Personal Data in order to contact him/her by email, telephone, addressed advertising or other communication formats to provide information or Services that may be of interest to him or her. In the event that we provide Services to the owner, 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 the holder and always in compliance with applicable law. The holder may unsubscribe from our list of promotional recipients or newsletters at any time by simply selecting the cancellation link included in each email or newsletter we send. Upon cancellation of the subscription, Bot will no longer send e-mail, but may continue to contact the holder to the extent necessary for the purposes of any Service requested by bot.
K. Processing of personal data
Collection of Personal Data:
• When the holder contacts us by e-mail, telephone or any other means.
• In the normal course of our relationship with the holder (e.g. Personal Data obtained by Bot when filling out the form on the website).
• When the owner visits any of our websites or uses any features or features available on or through our websites. When the owner visits a Website, your device or browser may disclose certain information automatically (such as 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), including 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 the holder that we may process includes:
|Form field||Purpose (treatment lawfulness)||Legal basis||Maximum storage time|
|Nif||Comply with the law||Article 52 CIVA.||10 years old|
|Cpf||Comply with the law||Law 5.172, National Tax Code, Art. 173;||5 years old|
|Device||Mandatory item for budget composition||Civil code and consumer law||5 years old|
|Manufacturer||Mandatory item for budget composition||Civil code and consumer law||5 years old|
|Ability||Mandatory item for budget composition||Civil code and consumer law||5 years old|
|Model or serial number||Mandatory item for budget composition||Civil code and consumer law||5 years old|
|What happened||Mandatory item for budget composition||Civil code and consumer law||5 years old|
|What was done after||Mandatory item for budget composition||Civil code and consumer law||5 years old|
|Analysis mode||Mandatory item for budget composition||Civil code and consumer law||5 years old|
|Name / Corporate Name||Mandatory item for budget composition||Law 5.172, National Tax Code, Art. 173 and CIVA;||5 years old|
|Phones||Mandatory item for budget composition||Civil code and consumer law||5 years old|
|Mandatory item for budget composition; sending information about the services; surveys to get feedback on our services.||Civil code and consumer law||5 years old|
|Zip code||Mandatory item for budget composition||Law 5.172, National Tax Code, Art. 173;||5 years old|
|Address/Address||Mandatory item for budget composition||Law 5.172, National Tax Code, Art. 173;||5 years old|
|Number and complement||Mandatory item for budget composition||Civil code and consumer law||5 years old|
|City/County||Mandatory item for budget composition||Law 5.172, National Tax Code, Art. 173;||5 years old|
|State/District||Mandatory item for budget composition||Law 5.172, National Tax Code, Art. 173;||5 years old|
Voluntary provision of Personal Data and non-provision consequences: The provision by the holder of your Personal Data is voluntary and will generally be a necessary requirement to enter into a contract with us and allow us to fulfil our contractual obligations with it. The holder has no legal obligation to provide us with his/her 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 fulfil our contractual obligations with the holder.
Physical documents are destroyed with paper shredder. The other data is destroyed safely and definitively once the deadline has expired. Bot does not keep data from devices eventually recovered in its lab once sent to the customer it is destroyed immediately.
L. Contact information
If you have comments, questions or concerns about any information contained in this Policy, or other questions regarding bot’s Processing of Personal Data, please contact the appropriate entity identified below:
MatrixMassive Unipessoal LDA
Praça Mouzinho de Albuquerque, 113 – 3 Andar
Porto, Portugal, CP 4100-359
Bot Tecnologia e Serviços LTDA
Rua Maria Francisca Gomes, 13, Ouro Preto
Belo Horizonte, Minas Gerais, Brasil, CEP 31340-025
• ‘Controller’ means the entity that decides how and why Personal Data is Processed. In several jurisdictions, the Controller is primarily responsible for compliance with data protection legislation.
• ‘Data Protection Authority’ means an independent public authority, legally responsible for monitoring compliance with data protection legislation.
• ‘EEA’ means the European Economic Area.
• ‘Personal Data’ means information about any individual, or that can identify any individual. Examples of Personal Data that may be processed by Bot in Section (K) above are provided.
• ‘Treat’, ‘Processing’ or ‘Treaty’ means any processing of Personal Data, whether or not by automated means, such as collection, registration, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or other provision, alignment or combination, restriction, erasure or destruction.
• ‘Processor’ means any person or entity who Processes Personal Data on behalf of the Controller (in addition to employees of the Controller).
• ‘Services’ means any services provided by Bot.
• ‘Sensitive Personal Data’ means Personal Data on race or ethnicity, political opinions, religious beliefs or philosophical beliefs, union membership, physical or mental health, sexual life, any criminal offences or penalties found or alleged, national identification number, or any other information that may be considered sensitive under applicable law.