Dedalus Prime Sistemas e Serviços de Informática Ltda., A company registered with CNPJ / MF under nº 07.214.045 / 0001-08, headquartered at Av. Engenheiro Luiz Carlos Berrini, nº 550, Conjunto 61, 6th floor, São Paulo, São Paulo State (“Dedalus”) recognizes that privacy is a fundamental human right, as well as recognizing the importance of privacy, security and data protection for our customers.

This Privacy Statement provides an overview of our privacy practices and the choices you can make and the rights you can exercise in relation to the personal data collected by Dedalus, including information that can be collected both through online activities and interactions with Dedalus offline, such as when engaging with our sales team and support representatives.

This Privacy Statement applies to all websites, domains, services (including device management), applications and products owned by Dedalus (collectively, “Dedalus Services”). If you have any questions regarding this Privacy Statement, please check Section X – Exercising Your Rights and Our Contact in this Privacy Statement to learn more.

This Privacy Statement does not apply to third party applications, products, services, websites or social media features that may be offered or accessed through the Dedalus Services. Accessing these links will cause you to leave the Dedalus Services and may result in the collection or sharing of information about you by third parties. We do not control, endorse or make any representations about these third party sites or their privacy practices, which may differ from ours. We recommend that you review the privacy policy of any website with which you interact before allowing the collection and use of your personal data.

I. General Privacy Notice

PURPOSE OF DATA PROCESSING

We collect and use personal data to manage your relationship with Dedalus and better serve you when you are enjoying Dedalus Services, personalizing and improving your experience.

Please check Section III – How We Use the Data in this Privacy Statement to learn more.

FORM AND DURATION OF DATA PROCESSING

We process data collected directly from you or through third parties. We take reasonable and appropriate physical, technical and administrative measures to safeguard the information we collect and process.

Please check Section IV – What Data We Collect and Section VI – How to Keep Your Data Safe in this Privacy Statement to learn more.

We keep your information for as long as necessary or relevant to our business, as permitted by applicable law. We also maintain information to resolve disputes, enforce our contracts and as otherwise required by law.

Please check Section II – Our Privacy Principles and Section III – How We Use the Data in this Privacy Statement to learn more.

CONTROLLER IDENTIFICATION

Dedalus is the data controller and the information of the company Dedalus is described in the preamble of this Privacy Statement.

CONTROLLER CONTACT INFORMATION

To exercise your rights, or if you have questions or concerns about our Privacy Statement, our collection and use of your data or a possible violation of privacy laws, you can contact Dedalus through the Data Protection Officer at email dedalus@dedalusprime.com.br

SHARING OF PERSONAL DATA

We may share your information primarily among Dedalus’ economic group, our advertisers, service providers and partners, and only with the appropriate contractual obligations in force. Please refer to Section VII – How We Share Data in this Privacy Statement to learn more.

RESPONSIBILITIES OF THE AGENTS THAT WILL PERFORM THE TREATMENT

Dedalus will only authorize third parties to process your personal data under the appropriate contractual obligations in force.

If we are unable to resolve your issues or if you believe that data protection rules have been violated, you have the right to contact the Brazilian government authorities or seek legal remedy.

Please check Section X – Exercising Your Rights and Our Contact in this Privacy Statement to learn more.

YOUR RIGHTS

You can, at any time, request Dedalus: (i) confirmation that your personal data is being processed; (ii) access to your personal data; (iii) changes to incomplete, inaccurate or outdated data; (iv) anonymizing, blocking or deleting unnecessary, excessive or improperly obtained data; (v) portability of personal data to another service provider, as long as it does not affect our industrial and commercial secrets; (v) elimination of personal data processed with your consentto the extent permitted by law; (vi) information about the entities to which your personal data has been shared; (viii) information about the possibility of not providing consent and about the consequences of the refusal (as an example, we can say that in some cases, Dedalus will not be able to provide certain services or answer questions that you may have); and (ix) withdrawal of consent.

 

II. Our Privacy Principles

We have a responsibility-based program and are committed to the following principles, which are based on internationally recognized privacy and data protection structures and principles:

LEGALITY, REASONABILITY AND TRANSPARENCY

We treat personal data in accordance with the law and with transparency and reasonableness towards you. Our data processing activities are carried out: 1) with your consent; 2) For the execution of contracts or preliminary steps in our relationship with you ;; 3) to answer questions sent through our website or other communication channels (whether in person or not) by you; 4) In case of the need for regular exercise of Dedalus’ rights in judicial or extrajudicial demands; 5) For the conduct of activities that aim to prevent the occurrence of fraud; 6) for the legitimate purposes of operating our businesses (which include cross-selling between Dedalus departments), promoting innovation and providing a continuous customer experience; or 7) otherwise provided by law.

DATA USE CHOICE AND NOTICE

We are transparent and provide a clear warning about the types of personal data collected and the purposes for which they are collected and processed. We will not use personal data for purposes that are incompatible with these Principles, our Privacy Statement or specific notices associated with Dedalus Services.

ACCESS DATA

We provide you with reasonable access, along with the ability to review, correct, change or delete the personal data you have shared with us.

You can always request changes to incomplete, incorrect or outdated personal data. You can also request the elimination of unnecessary, excessive or improperly obtained personal data. As for the necessary and correctly collected data from you, the elimination will be done only to the extent permitted by law and you should be aware that this may substantially affect the Dedalus Services provided to you.

DATA INTEGRITY AND PURPOSE LIMITATION

We only use personal data for the purposes described at the time of collection or for additional compatible purposes and timely reported to you, in accordance with the law. We take reasonable steps to ensure that personal data is accurate, complete and current and only collect personal data that is relevant and limited to what is necessary for the purposes for which it is collected.

We will keep personal data for no more than necessary for the purposes for which they were collected and then, to the extent permitted by law, we will safely delete or destroy them. We also maintain information to resolve disputes, enforce our contracts and as otherwise required by law.

DATA SECURITY

To protect personal data from unauthorized use or disclosure, we have implemented strong information security controls in our own operations and offer industry-leading products and solutions with high levels of data security protection.

III. How We Use Data

We collect and use personal data to manage your relationship with Dedalus and to better identify you when you are using Dedalus Services, personalizing and improving your experience. Examples of how we use the data include:

  • To recognize new customers or
  • To respond to your requests or
  • To provide a perfect experience for your
  • Provide Dedalus Services
  • Improve our services and support (we may use your information to conduct market research and analysis to improve our website and Services. We may combine information we receive from you with information about you obtained from third parties)
  • To communicate with you about the Services
  • Maintain security (this includes detecting and preventing illegal behavior)
  • Conduct common business operations, including identity verification, conducting business research and analysis, reporting and management
  • In case of need for regular exercise of Dedalus’ rights
  • Better understand the interests of our customers and visitors to our
  • To serve advertising for Dedalus Services that may be of common interest
  • To contact you about this policy or terms of our

IV. What Data We Collect

Personal data is any information that personally identifies an individual or from which an individual can be identified directly or indirectly. We may collect personal data pthrough the use of Dedalus Services or during interactions with Dedalus representatives.

The personal data we collect corresponds to the nature of your interaction with us or the Dedalus Services you use, but may include the following:

INFORMATION YOU PROVIDE DIRECTLY

  • Contact Data – We may collect personal and / or business contact information, including your name, surname, mailing address, telephone number, fax number, e-mail address and other data.
    Account Data – We collect information about how you purchased or signed up for Dedalus Services, your transaction history, billing and support, the Dedalus Services you use and anything else related to the account you have.
  • Location Data – we collect geolocation data when you activate location-based services or when you choose to provide location-related information during product registration or when interacting with ours.
  • Security Credentials Data – We collect user IDs, passwords, password hints and similar security information needed for authentication and access to Dedalus accounts.
  • Demographic Data – We collect or obtain certain demographic data from third parties, including, for example, country, gender, age, preferred language and data of interest.
  • Preferences – We collect information about your preferences and interests related to Dedalus Services (when you tell us what they are or when we deduce them from what we know about you) and how you prefer to receive our communications.
  • Social Media Data – We can provide social media features that allow you to share information with your social networks and interact with us on various social media sites. Depending on the resource, the use of these resources may result in the collection or sharing of information about you by the media resources.
  • Information you submit – We collect information that you submit on our.
  • Other Unique Identifying Information – Examples of other unique information we collect may include product serial numbers, information provided when you interact in person, online or by phone or email with Dedalus representatives.
  • Site / Application Navigation Data – We collect information about your visits and activities on Dedalus websites, applications or websites maintained by another company on our behalf, including the content (and any ads) with which you view and interact, information about the browser and the device you are using, your IP address, your location, the website address from which you arrived and other clickstream behavior (such as the pages you view, the links clicked on or what items you added to your basket purchases). Some of this information is collected using our Automatic Data Collection Tools, which include cookies, web beacons and embedded web links.
  • Anonymous or Aggregate Data – We collect anonymous responses to surveys or anonymous, aggregated information about how our Dedalus Services are used. During our operations, in certain cases, we apply a process of de-identification or pseudonymization to your data so that it is reasonably unlikely that you will be able to identify yourself through the use of that data with the available technology.

INFORMATION ON THIRD PARTY SOURCES

We collect data from the following third parties:

  • Dedalus Corporate Customers – To provide certain Dedalus services at the corporate level, your business contact details may be provided to Dedalus by a designated entity within your company or enterprise (such as a member of your IT department).
  • Analytics Vendors – We also receive non-personal data, such as aggregated or unidentified demographic / profile data, from third party sources, such as companies specializing in providing corporate data, analytics and software as a service.

In order to guarantee the accuracy of the data and offer a superior customer experience, providing better personalized services, content, marketing and advertisements, in some cases, we link or combine the information collected from the different sources described above with the information collected directly from you. For example, we compare geographic information acquired from commercial sources with the IP address collected by our Automatic Data Collection Tools to derive your general geographic area. The information can also be linked using a unique identifier, such as a cookie or an account number.

When necessary, we obtain information to conduct due diligence checks on business contacts as part of our anti-corruption compliance program and in accordance with our legal obligations.

IF YOU CHOOSE NOT TO PROVIDE DATA

You are not required to share the personal data we request, however, if you choose not to share the information, In some cases, we may not be able to provide you with Dedalus services, some specialized resources or be able to respond effectively to any queries you may have.

V. Child Privacy

Dedalus does not target its websites or mobile applications to individuals under 18 (eighteen) years of age.

However, during the exercise of its activities, if it is necessary to collect individuals under 18 (eighteen) years of age, treatment should always be carried out in your best interest. In addition, in the case of data processing for children (under 12 years of age), this will occur with prior specific and prominent consent from a parent or guardian of the minor.

VI. Keeping Your Data Safe

To prevent loss, unauthorized access, use or disclosure and to ensure the proper use of information, we use reasonable and appropriate physical, technical and administrative procedures to protect the information we collect and handle. The standard security measures we use will depend on the type of information collected and, when legally required, will include strict access controls and access to authentication methods. Dedalus retains the data as required or permitted by law and as long as the data continues to have a legitimate business purpose. We maintain access information (logs) and use encryption or other measures to protect information.

The Internet is not 100% secure. We cannot promise that the use of our websites and applications will be completely safe. If you believe that the unauthorized interaction with us was done using your name, please contact us in accordance with Section X below.

VII. How We Share Data

We will only share personal data as follows and, when applicable, only with the appropriate contractual obligations in force:

SHARING WITH SERVICE SUPPLIERS AND PARTNERS

We contract with service providers or partners to manage or support certain aspects of our business operations on our behalf. These service providers or partners may be located in the United States, Brazil or other global locations and may provide services such as credit card processing and fraud management, customer support, sales on our behalf, order fulfillment, delivery of products, content personalization, advertising and marketing activities (including digital and personalized advertising), IT services, email service providers, data hosting, live help, debt collection and management or support of Dedalus websites .

SHARING WITH OTHER INFORMATION WITH ADVERTISERS

We may also transfer information to advertising partners (including ad networks, ad serving companies and other service providers that they can use) so that they can recognize devices and deliver interest-based content and ads. The information can include name, postal address, e-mail, device ID or other identifier in encrypted format. Providers can process information in a hashed or unidentified manner. These providers may collect additional information, such as IP address and information about the browser or operating system, and may combine data with information from other companies in data sharing cooperatives in which we participate.

CORPORATE TRANSACTIONS

Circumstances may arise where, whether for strategic or other business reasons, Dedalus decides to sell, buy, merge or reorganize businesses. In such transactions, we may disclose or transfer personal data to potential or actual buyers or receive personal data from sellers. Our practice is to seek adequate protection for your personal data in these types of transactions.

COMPLIANCE WITH LAW

We may also share personal data when we have a good faith belief that we have an obligation to: (i) respond to duly authorized requests for information from law enforcement agencies, regulators, courts and other public authorities, including to meet national security or other law enforcement requirements; (ii) comply with any law, regulation, subpoena or court order; (iii) investigate and help prevent security threats, fraud or other criminal or malicious activities; (iv) enforce / protect the rights and properties of Dedalus or its subsidiaries; or (v) protect the rights or personal safety of Dedalus, our employees and third parties on Dedalus’ property, where permitted and in accordance with the requirements of applicable law.

SHARING WITH OTHER THIRD PARTIES

We may share your information for reasons not described in this Privacy Statement. In this case, we will identify you before we do so and, if legally required, obtain your consent.

VIII. How We Use Automatic Data Collection ToolsData

We use and allow other companies to use cookies, click capture, pixels, web beacons, web collection forms and other similar technologies (collectively, “Automatic data collection tools”) in our Dedalus Services. We do this to understand your use of our Dedalus Services; improve your user experience and enable personalized features and content; optimize our ads and marketing; and to allow third-party advertising companies to help us serve ads specific to their interests on the Internet.

AUTOMATIC ONLINE DATA COLLECTION TOOLS

When you visit any Dedalus website, it can store or retrieve information in your browser, mainly in the form of cookies, which are text files containing small amounts of information. This information can be about you, your preferences or your device and is used primarily to make the site work as you expect. The information generally does not identify you directly, but it can provide a more personalized web experience.

Dedalus uses automatic data collection tools for the following reasons:

Strictly Necessary Tools

These are necessary for the website to function and cannot be turned off. Without this, the website or mobile service you are requesting would be impossible to provide, as we cannot activate the appropriate content based on the type of device you are using.

Performance and Analysis Tools

These tools collect aggregated, anonymous and statistical information to allow Dedalus to measure, optimize and improve the content, quality and performance of its websites.

We use our own automatic data collection tools and / or third parties to see how you use our sites and services to improve your performance and develop them according to the preferences of our customers and visitors. For example, Automatic Data Collection Tools can be used to: test different designs and ensure that we maintain a consistent look and feel on our sites; track and provide trend analysis of how our users interact with our websites and communications; track errors and measure the effectiveness of our promotional campaigns. We use Google Analytics, administered by Google Inc., for example, to track site usage and activity.

The data collected will generally be aggregated to provide trends and usage patterns for business analysis, site / platform improvement and performance metrics. Our automatic data collection tools or the resulting analysis can also be shared with our business partners. The type of information we collect includes how many users visit our sites, how many customers log in, when they visited, for how long and which areas of our sites and services, but are generally not used to identify you individually. We may also receive similar information about visitors to partner sites.

Customization Tools

These allow us to remember the choices you make on our sites (such as your preferred language or the region you are in) and provide enhanced and personalized features. They can also be used to remember changes made to text size, fonts, and other parts of web pages that you can customize. They can also be used to provide services you have requested, such as watching a video or commenting on a blog. The information collected can be anonymized and cannot track your browsing activity on other websites.

We also use automatic data collection tools to change the way our sites behave or seek to personalize your experience from information we infer from your behavior on our sites or information you may already know, because, for example, you are a registered customer. These can be used to personalize the services you receive from us or the content, appearance and behavior you receive in subsequent sessions on our sites.

For example, if you personalize web pages or register for products or services, Automatic Data Collection Tools will help our web page server to retrieve your specific information. When you visit our sites, the information previously provided may be retrieved so that you can easily use the features of the site you have previously chosen.

If you use more than one device or computer on a regular basis, we can link the Automatic Data Collection Tools so that you still receive a personalized online experience. We can also customize the information you see based on what we already know about you, so you spend less time looking for things. Using Automatic Data Collection Tools, each visitor to our site and you can have a web experience that is unique to them.

Targeting Tools

They are defined by Dedalus and other third parties (such as selected retail or advertising partners) and used to create a profile to provide targeted advertising, both on and off the Dedalus websites, that is most relevant and useful to you. This data may reflect demographic or other unidentified data, linked to data that you voluntarily submitted to us (for example, your email address).

They also allow us to collect data related to the Dedalus website and page you visited and your activities on the Dedalus website. For example, if you visited one of our product pages, through the use of cookies, we may redirect you to partner sites with additional offers and promotions for a specified period.

If you are a registered user, the information collected from our sites is not anonymous and we may use that information in conjunction with other information that we know or infer about you, including your preferences, to personalize content, services, advertising and offers for you, for purposes presented in that Privacy Statement.

When you share information using a social media sharing button on Dedalus websites, the social network will record that you did it. This information may be linked to targeting / advertising activities. The types of tools used by these third parties and how they use the information generated by them will be governed by the privacy policies of those companies.

OTHER AUTOMATIC DATA COLLECTION TOOLS

We may use Automatic Data Collection Tools, such as web beacons, which are usually a transparent graphic image (usually 1 pixel x 1 pixel), to compile information about your interaction with e-mail or other communications. A web beacon can be incorporated into Dedalus’ subscription or marketing communications to determine whether our messages have been opened or put into action and whether our correspondence tools are working correctly.

IX. Choosing your privacy preferences

You can make or change your choices regarding Automatic Data Collection Tools, as well as receive signatures or general communications at the data collection point or using other methods, described in the following sections. These options do not apply to communications primarily for the purpose of managing order fulfillment, contracts, support, product security notices, driver updates or other administrative and transactional notices where the primary purpose of such communications is not of a promotional nature.

MARKETING AND SUBSCRIPTION COMMUNICATIONS

Dedalus marketing communications provide information about products, services and / or support and you can select how these communications are delivered – for example, by mail, email, phone, fax or mobile device.

Marketing communications may include information about new products or services, special offers, personalized content, targeted advertising or invitations to participate in market research or compliance reviews. Subscription communications include email newsletters, software updates, etc., which may be expressly requested by you or that you have consented to receive.

You can choose not to receive these general communications using one of the following methods:

  • Select the “Deactivate” or “Unsubscribe” link in the email or follow the instructions included with each email communication.
  • To unsubscribe from messages delivered on mobile devices, reply to the message with the words “STOP” or “END”.
  • Write to Dedalus. Be sure to provide your name, contact information and specific relevant information about your privacy preferences.

DEDALUS ANNOUNCEMENTS AND OFFERS ON THIRD PARTY WEBSITES

Simulate contracts with service providers to place ads on websites owned by third parties. This will sometimes be achieved by sharing some personal data, as described in the section on third party advertising cookies and social media cookies.

In addition, we use and allow ad networks and other third parties to use cookies and other Automatic Data Collection Tools to determine how you interact with our selected sites, communications and services and partner sites and to identify your interests, create profiles and business segments. interest in providing advertising that is most relevant and useful to you. For more information, see Section VIII – How We Use Automatic Data Collection Tools.

AUTOMATIC DATA COLLECTION TOOLS – ONLINE

When visiting Dedalus websites, you have the option to accept or adjust the cookies that allow us to place them on your browser. You can modify these settings at any time by visiting the cookie settings.

If you do not want to allow cookies, consult your browser settings. Please note that by disabling certain categories of cookies, you may be prevented from accessing some features of our websites or certain content or functionality may not be available. Some browsers allow you to browse websites anonymously or privately. After the browser session is closed, normally all cookies collected during the session are automatically destroyed.

In order not to be tracked by Google Analytics on our sites, visit http://tools.google.com/dlpage/gaoptout.

Some newer web browsers incorporate “Do not crawl” features. There is currently no industry standard for handling “Do Not Track” requests, so at this time, our websites may not respond to “Do Not Track” requests or headers from these browsers.

AUTOMATIC DATA COLLECTION TOOLS – DEDALUS COMMUNICATIONS

You can disable automatic data collection tools, such as web beacons, in e-mail messages, by not downloading images contained in received messages (this feature varies depending on the e-mail software used on your personal computer) . However, this may not always disable the Automatic Data Collection Tools in the email message due to specific features of the email software. For more information on this, refer to the information provided by your email software or service provider.

X. Exercising Your Rights and Our Contact

You have the right to ask us for a copy of the personal data that you have provided to us or that we keep about you and to request an explanation of the treatment. In addition, you have the right to withdraw any consent previously granted or request correction, alteration, restriction, anonymization or deletion of your personal data; and to obtain the personal data you provide with your consent or in connection with a contract in a structured, machine-readable format and ask us to transfer that data to another data controller.

You also have the right to object to the processing of your personal data in some circumstances, especially when we are using your data for direct marketing or to create a marketing profile. Please see Choosing Your Privacy Preferences for guidance on how to exercise your marketing rights.

In certain cases, these rights may be limited, for example, if the fulfillment of your request reveals personal data about another person or if you ask us to delete information that, by law, we must maintain or maintain legitimate interests to be maintained.

To obtain the rights, your questions and actions regarding our Privacy Statement, our collection and use of your data or an action violated of the privacy laws, you can contact Dedalus at dedalus@dedalusprime.com.br.

All communications will be treated confidentially. After receiving your communication, our representative will contact you within a reasonable time to answer your questions or concerns. Our goal is to ensure that your issues are resolved in a timely and appropriate manner.

If we are unable to resolve your issues or if you believe that data protection rules have been violated, you have the right to contact the Brazilian government authorities or seek legal remedy.

XI. Changes to the Privacy Statement

If we modify our Privacy Statement, we will post the revised statement here, with the updated revision date. If we incorporate significant changes to our Privacy Statement that materially modify our privacy practices, we may also notify you by other means, such as sending an email or posting a notice on our website and / or social media pages before the changes go into effect. in force.

Posting Date: March 30, 2021.