Privacy Policy

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 our organization with whom we interact, including visitors to our websites (our “Websites”), customers, and other users of our Services (collectively, “the holder”). Definitions of terms used in this Policy can be found in Section (M) below. For the purposes of this Policy, Bot is the owner’s Personal Data Controller. Contact information is provided in Section (L) below so that the Bot entity concerned can answer questions about the use and treatment 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 legislation. We encourage the owner 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 Personal Information we process about you is limited to the Personal Information reasonably necessary for the purposes described in this Policy (including providing Services to you).

C. Disclosure of Personal Data to Third Parties

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

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

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

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

– 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 preventing, investigating, detecting or sanctioning criminal offences or the execution of criminal penalties;

– 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 Websites may use third-party content. Should the holder decide to interact with any such content, his/her Personal Data may be shared with the third party provider of the relevant social platform. We recommend that the owner review the privacy policy of the third party entity before interacting with its contents.

If we contract with a Subcontractor to Treat the Personal Data of the holder, we will conclude with the Subcontractor a data treatment agreement as required by the applicable laws in question in order to make it subject to binding contractual obligations to: (i) treat 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 maintain security measures and data handling 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 such anonymized data with our business partners (including external business partners).

D. Data Security

We implement appropriate technical and organizational measures to protect the holder’s Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or 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 submit to us are sent in a secure manner.

E. Data Accuracy

We take all reasonable steps to ensure that:

• the Personal Data of the holder that we process is reliable and, where necessary, kept up to date; and

• any Personal Data of the holder that we process that is incorrect (taking into account the purposes for which it was processed) is deleted or rectified without delay.

Periodically we may request confirmation of the accuracy of the Personal Data of the holder.

F. Data Retention

We take all reasonable steps to ensure that the Personal Data of the holder are only treated for the minimum period necessary for the purposes described in this Privacy Policy. We keep copies of the holder’s Personal Data in order to allow identification only while:

• maintain an ongoing relationship with the holder (e.g., as long as the holder is a user of our Services, or is lawfully included on our recipient list without having unsubscribed); or

• the Personal Data of the holder are necessary for the purposes described in this Privacy Policy, for which we have a valid legal basis (e.g. in case the Personal Data of the holder are included in an order made by its employer, and Bot has a legitimate interest in the treatment of such data for the operation of the business and fulfillment of its obligations under this contract).

Additionally, we keep the Personal Data during:

• any applicable limitation period under applicable law (i.e., any period in which a person may bring a lawsuit against Bot regarding the Holder’s Personal Data, or for which the Personal Data may be relevant); and an additional period of two (2) months after the expiration of this 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 that lawsuit).

In the event of filing any lawsuit, we may continue to treat the holder’s Personal Data for such additional periods as may be necessary in connection with such lawsuit.

During the periods indicated above related to lawsuits, Bot will restrict the holder’s Personal Data Processing to the storage, and maintaining the security, of Personal Data, except to the extent that the Personal Data need to be reviewed in relation to any lawsuit, or any obligation under applicable law.

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

G. Legal rights of the holder

Subject to applicable law, the holder 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 treated or controlled by Bot, as well as information on the nature, treatment and disclosure of such Personal Data;

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

• the right to request, on legitimate grounds: the erasure of your Personal Data treated or controlled by Bot or the restriction of the Treatment of your Personal Data treated 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 treated or controlled by Bot to another Controller, to the extent applicable;

• the right to withdraw your consent to Treatment, where the lawfulness of the treatment is based on consent, although this does not compromise the lawfulness of the Treatment 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 Handling of the holder’s Personal Data, please use the contact information indicated in Section (L) below. If we provide Services to the holder based on orders, such 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 supplementary.

H. Cookies

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

I. Terms of Use

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

J. Direct Marketing

Subject to applicable law, where the holder has given his express consent in accordance with applicable law or when sending advertising and marketing communications relating to similar products and services, Bot may Treat the holder’s Personal Data in order to contact by email, telephone, direct mail or other communication formats to provide information or Services that may be of interest to you. If we provide Services to the holder, 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 can 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. After unsubscribing, Bot will not send any further emails, but may continue to contact the holder as necessary for the purposes of any Service requested by the holder.

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 (for example, Personal Data obtained by Bot when filling out the form on the site).

• When the holder visits any of our Websites or uses any features or resources available on or through our Websites. When the owner visits a Website, his or her 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), among which some may constitute Personal Data.

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

Personal data about the holder that we may process includes:

Voluntary Supply of Personal Data and Consequences of Non-Supply: The supply 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 fulfill our contractual obligations with it. The owner has 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 owner of the data and fulfill our contractual obligations with the owner.

Data destruction:

Physical documents are destroyed with a paper shredder. Other data is destroyed safely and definitively once the deadline has expired. The Bot does not keep the data from the devices eventually recovered in its lab once sent to the customer that are 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:

Portugal:

MatrixMassive LDA

Rua Augusto Rosa, 79

Porto, Portugal, CP 4000-098

contacto@botrecuperacao.pt

Brasil:

Bot Recuperação de Dados LTDA

Rua Maria Francisca Gomes, 15, Ouro Preto

Belo Horizonte, Minas Gerais, Brasil, CEP 31340-025

contato@bot.rec.br

M. Definitions

• ‘Controller’ means the entity that decides how and why Personal Data are handled. In several jurisdictions, the Controller is primarily responsible for compliance with applicable data protection legislation.

• ‘Data Protection Authority’ means an independent public authority legally responsible for monitoring compliance with applicable 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 handled by Bot are provided in Section (K) above.

• ‘Treat’, ‘Processing’ or ‘Treaty’ means any treatment of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, deletion or destruction.

• ‘Subcontractor’ means any person or entity who Processes Personal Data on behalf of the Controller (in addition to the 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, union membership, physical or mental health, sexual life, any observed or alleged criminal offences or sanctions, national identification number, or any other information that may be considered sensitive under applicable law.