Privacy Policy

Please carefully review this document so that You understand our policies and practices on Personal Data and how such data are handled at Conductor Tecnologia S.A.

This Policy applies to data subjects (natural persons), henceforth referred as “You” associated with Personal Data that is or may be an object handled by Conductor Tecnologia S. A., referred as “Conductor” in this policy. It also provides information on how You can access and update Personal Data and make decisions on how your Personal Data will be used, always backed by the applicable law.

This Policy details our data collection activity both online and offline regarding Personal Data collected by Conductor through a variety of channels, including, but not limited to, Websites, Apps, third-party Social Media, Customer Service, Points of Sale, Research and Events. Please note that Conductor can aggregate Personal Data combined from different sources—such as our website and offline events—or from Conductor’s partners and customers. For more information about opting out, see the section “About your rights on Personal Data”.

In certain cases, if You decide not to provide your Personal Data that is flagged as necessary (Conductor will flag it if that’s the case, such as explicitly showing that information in our registration forms), we might not be able to provide You with the products/services that are associated with your providing data.

This Privacy Policy was written in compliance with the Federal Act 12.965 of April 23rd, 2014 (Brazilian Civil Rights Framework for the Internet), and the Federal Act 13.709 of August 14th, 2018 (General Data Protection Regulation).

1.Agents handling Personal Data

According to the Brazilian law, agents handling personal data include the Data Controller, which is responsible for making decisions regarding handling Personal Data, and the Data Operator, which handles Personal Data on Conductor’s behalf.

When Conductor handles Personal Data on its customers’ behalf (contractor companies) through its solutions in means of payment, it is considered a Data Operator according to LGPD, and Personal Data will be handled according instructions provided by these contractors (our customers) as Data Controllers, as defined by the law.

When Conductor handles Personal Data related to its own operation involving the types of Data Subjects listed below, it is considered a Data Controller according to LGPD, and the data handling will take place according to all the guidelines mentioned in this policy and other rules or procedures adopted by Conductor. In this case, Conductor will apply the rules in this policy:

  1. To its employees when handling Personal Data in order to fulfill their legal and contracting obligations;
  2. When You apply for job opportunities at Conductor;
  3. If You subscribe to one of our channels for receiving news from Conductor;
  4. When You directly contact Conductor and provide your Personal Data.

2.Personal Data Sources

As a Data Operator, Conductor will not directly collect Personal Data when handling it as requested by its customers (contractor companies), which are Data Controllers. In this context, Conductor is only making available services and applications so that companies (its customers) are able to submit their data, which was previously collected by any other application.

As defined in item 2 above, when handling your Personal Data as a Data Controller, Conductor will collect your Personal Data through the following sources:

  • Conductor’s websites: All our websites may be used for collecting Personal Data. It includes both the website where we directly operate via our domains and IP addresses and websites, or pages that Conductor manages in third-party platforms, such as Facebook, LinkedIn and other third-parties providing this type of service.
  • Email and instant messaging: Services used for electronic communication between You and Conductor, including those made available directly by Conductor, or third-party services such as WhatsApp, Telegram, SMS (short message service) and more.
  • Conductor’s mobile apps: Mobile apps provided by Conductor or via third-party services such as Google or Apple.
  • Online forms, advertising and ads: Engagements using any type of ad, advertising and form.
  • Offline registrations: Registration forms filled out offline, distributed during events and other engagements with Conductor.
  • Data from third-parties: Including, but not limited to, social media and third-party websites such as Facebook, Instagram, LinkedIn and more, data aggregation services, Conductor’s partners and customers, public sources and data received when acquiring other companies.

3.What Personal Data needs to be collected and how

During your engagement with Conductor as a Data Controller under the terms shown in item 2 in this policy, when using one of the collection sources aforementioned in item 3, we can collect a variety of types of Personal Data about You, such as the following:

  • Contact information: It includes any type of information that may facilitate our contact with You, such as your mailing address, phone numbers, email addresses, websites and profile pages on social media.
  • Login information: It includes information used for identifying yourself and authenticating in services provided by Conductor, such as your registered name (login), password in unrecoverable formats (encryption) and security questions.
  • Demographics and your interests: Any information that may describe your demographics, habits or personal behavioral features, such as date of birth, age or age group, sex, geography, favorite products, hobbies and other interests and information about family or lifestyle.
  • Technical information about computing equipment or mobile devices: Details about your computer or mobile device that was used for accessing one of our websites, services or apps, including the registered IP address that is used for connecting your computer or mobile device to the Internet, such as your geography, the type or version of the operational system and the Web browser. If You access a Conductor’s website or app by using a mobile device, such as a smartphone or tablet, the collected information will also include, if permitted, the unique ID for your phone, geography and other similar data on the mobile device.
  • Information about how You use our websites and services. During your engagement with our websites and services, Conductor will use automatic data collection technology for capturing information about your actions. It may include details such as the links You click on, pages and content You view and for how long, and other similar information and statistics about your engagements, such as content response time, download errors, and visit duration to certain pages. This information is captured by automated technology such as Cookies (Browser Cookies, Flash Cookies and others) and Web beacons and also by third-party tracking. For information about how to opt out of such technology at any time, see the details in the section “About your rights on Personal Data”.
  • Market research and consumer feedback: This is information You willingly share with Conductor about your experience when using our products and services.
  • Content provided by Personal Data Subjects: It includes any content You build and share with Conductor on third-party social media or by uploading it to one of our websites, apps and other online and offline services, such as Facebook, Instagram, LinkedIn and others. This information includes text, comments, articles, pictures, video, personal stories and other similar content and media. When permitted, Conducts collects and publishes content provided by Data Subjects related to a variety of activities, such as communications of products and services by Conductor, contests, awards and other special offers, website community resources, Data Subject engagements and third-party social media.
  • Information from third-party social media: It involves any data You publicly share on third-party social media or information that is part of your profile page on third-party social media (such as Facebook, Instagram, LinkedIn and others) and You allow third-party social media to share with us. This data may include details such as personal information for account (name, email address, sex, date of birth, current city, profile picture, user ID, contact list and more) and any other additional activity or information You allow third-party social media to share with us. Conductor will receive all the information (or part of it) from your profile page on third-party social media every time You download an item or engage with a Conductor’s Web service or app on third-party social media, use a social media resource that is integrated with a Conductor’s website or engage with us through third-party social media. For more information about how your information is collected by Conductor from third-party social media or opt out of sharing this social media information, visit the third-party social media website that is providing the data.
  • Contacts with our Customer Service: Your engagements with our Customer Service may be recorded or heard in compliance with the applicable law for operational purposes by Conductor, as a Data Operator and Controller. Payment and financial details are not recorded. When required by the law, You will be informed of such recording at the beginning of the call.
  • Sensitive Personal Data: Conductor handles Personal Data that is considered sensitive by following the applicable law and exempting in situations defined by the applicable law. Thus, we don’t intent to collect or process sensitive Personal Data during normal course of actions in your engagements with our products or services. If we do process your sensitive Personal Data by account and order of a third-party, as a Data Operator, Conductor will be backed by the following legal bases: (i) crime detection and prevention; and (ii) the applicable law.

4.On Children’s and Teenager’s Personal Data

Conductor does not request, collect, process, store or share children’s and teenagers’ Personal Data, exempting when defined by the law or an explicit consent from parents or legal guardians, according to the applicable law.

If we find such type of Personal Data being handled unintentionally, we’ll remove that child’s or teenager’s Personal Data from our systems immediately after being aware of it.

5.About using Cookies, log files and similar technologies

Cookies are small text files that may be stored in your computer or mobile device by websites and Web services You use. They’re used for ensuring a smooth operation on websites and other online services, as well as providing information to websites’ or online services’ owners.

Cookies make it easy to tailor Conductor websites to your personal needs—thus assisting your use whenever possible—and to receive feedback from customers on how happy they are with the service.

Conductor can use the following types of Cookies on its relevant websites and services:

  • Session Cookies: They’re cookies for temporary use, which can be removed when You close your browser. When You run your browser again and go back to the websites that created the Cookie, this website treats You as a new visitor.
  • Persistent Cookies: They’re Cookies that remain in your computer until You remove them manually or until your browser removes them according to the period of time set by the Cookie. These Cookies will recognize You as a returning visitor to a Conductor website or service.
  • Necessary Cookies: They’re Cookies that are strictly necessary for a Conductor-supported website or service to operate. They allow You to browse the website and use our resources.
  • Cookies providing us with information about You: Conductor inserts this type of Cookies on a Conductor-supported website or service, and this type of Cookies can only be read by our supported websites and services.
  • Cookies on Conductor ads: We use Cookies in ads shown on third-party-supported websites and services. We get information from these Cookies when You click or engage with ads. In this case, Conductor is using a “third-party” Cookie. We can use the data received from the third-party Cookies to send You other ads that might be relevant or interesting for You, according to your past behavior.
  • Cookies sharing your information with third-parties: They’re Cookies used in a Conductor’s website by our partner companies, such as online advertising services. They can use data collected by these Cookies to anonymously send You targeted ads from other websites based on your visit to Conductor-supported websites or services.

Conductor-supported websites and services can also use other tracking technologies that are similar to Cookies, capable of collecting information such as IP, log files, Web flags and more. Such data is also used for helping us tailor Conductor-supported websites and other services to our personal needs.

See more details below:

  • IP Addresses: An IP address is a number used on the Internet or a network for identifying your computer. Your computer gets an IP assigned to your Internet service provider every time You connect to the Internet. We may log IP addresses for the following purposes:
    • Handling technical issues;
    • Maintaining protection and security on our websites and other online services;
    • Understanding more deeply how our websites and other online services are used;
    • Tailoring our content to your needs, depending on your geography.
  • Log Files: Conductor or a third-party working on our behalf will be able to collect information through log files which detail the activities on the website and collect statistics about the users’ browsing habits. These logs are usually generated anonymously and help us understand details, such as:
    • Our users’ type of browser and system used on our websites and online services;
    • Details on the user’s session, including the source URL, date, time, pages the user visited on our supported websites and services and duration of the user’s visit or use;
    • Other details on browsing or counting clicks, including reports about website traffic, unique visitor counting and more.
  • Web Flags (Web beacons): Conductor may use Web flags (or transparent GIFs) on websites or electronic communications at Conductor. The Web flags (also known as Web bugs or Web beacons) are short code sequences that enable delivering a graphic image on a Web page, aiming to transfer data back to Conductor. We use the information provided by Web flags for several purposes, including:
    • Understanding how the user responds to email campaigns;
    • Reporting traffic on our supported websites and services;
    • Counting unique users, auditing and reporting advertising and email and customizing our supported websites and other services.

It is important to keep in mind that You are responsible for ensuring your computer or mobile device settings reflect whether You agree with Cookies.

Most of the browsers allow You to set rules so that You’re notified before agreeing with Cookies or simply opt out. You don’t need to have Cookies enabled in order to use or browse most part of Conductor websites and online services. However, in this case, we cannot assure You will be able to access all resources. We recommend that You check how to set up this type of configuration through the “Help” button on your browser. Remember that if You use browsers, or even different computers and/or mobile devices in different locations, You will need to ensure each device and browser is adjusted to your personal Cookies preferences.

Since out Web flags (Web beacons) may be part of a Web page, You can’t remove (“opt-out”) this type of resource, but You can make it 100% non-functional by enabling the resource “opt-out” for Cookies placed by this flag.

6.About using your Personal Data

When a Conductor customer (contractor company), which is a Data Controller, uses the services we provide, the purposes for which your Personal Data is collected will be described in those companies’ policies, and You will need to access and validate its use directly with our customers, the Data Controllers. As a Data Operator, Conductor will follow the applicable Data Protection laws and rules shown in the contract with the Controller.

According to the terms in item 2 above, the following describes the purposes for which Conductor, as a Data Controller, collects your Personal Data and the different types of Personal Data for each purpose. Please note that not all uses below will be relevant to You and might only be applicable to specific situations.

  • Services for Data Subject: Your Personal Data will be used for providing the Data Subject with services, including helping with your questions, issues and suggestions. In general, it requires certain personal contact details and information on the reason for your question, issue or suggestion, such as the request or question and if there’s a technical issue, question or complaint about the product.
  • Reason for using your personal data in this situation:
    • Fulfilling contractual obligations;
    • Legal obligations;
    • Our legitimate interests;
    • Consent has been received (when necessary).
  • Our legitimate interest in this situation:
    • Improving and developing new products and services;
    • Being more efficient when fulfilling your requests;
    • Protecting our systems, networks and employees;
    • Fulfilling legal obligations in their entirety.
  • Special offers and other marketing campaigns: With your consent (when necessary, according to the applicable law), Conductor will use your Personal Data to provide information about products or services, such as marketing communications, special offers or ad campaigns. You can do it through a variety of communication means, including email, ads, SMS messages, phone calls, and mailing (as permitted by the applicable law), as well as our own websites and/or third-party social media and/or websites. In this situation, using your Personal Data is 100% optional, which means You can oppose to it or even opt out of having your Personal Data handled for these purposes at any time. For more details about changing your preferences about marketing communications, see the section “About your rights on Personal Data” in this policy. For more information about our special offers, see the rules or details posted about each offer.
  • Reason for using your personal data in this situation:
    • Fulfilling contractual obligations;
    • Our legitimate interests;
    • Consent has been received (when necessary).
  • Our legitimate interest in this situation:
    • Understanding our products and services that might interest You and provide information on them;
    • Determining consumers for new products and services.
  • Third-party websites and social media: We will use your Personal Data when You engage with features in third-party websites and social media, such as providing exclusive content (ebooks, video and webinars) and engaging with You on third-party social media. For information about how those engagements work, what profile information Conductor retains about You and how to opt out, see the privacy policies directly on the relevant third-party websites and social media.
  • Reason for using your personal data in this situation:
    • Our legitimate interests;
    • Consent has been received (when necessary).
  • Our legitimate interest in this scenario:
    • Understanding our products and services that might interest You and provide information on them;
    • Determining consumers for new products and services.
  • Customization (offline and online): Based on your consent (when required by the applicable law), Conductor will use your Personal Data for (i) understanding your preferences and habits; (ii) anticipating your needs based on our understanding of your profile; (iii) improving and customizing your experience on our websites and apps; (iv) ensuring the content on our websites and apps is optimized for You and your computer or device; (v) sending You targeted advertising and content and (vi) enabling You to take part in interactive features whenever You decide to. In this situation, using your Personal Data is optional, which means You can always oppose to it or even opt out of handling your Personal Data for those purposes. For more details, see the section “About your rights on Personal Data” in this policy.
  • Reason for using your personal data in this situation:
    • Our legitimate interests;
    • Consent has been received (when necessary).
  • Our legitimate interest in this situation:
    • Understanding our products and services that might interest You and provide information on them;
    • Determining consumers for new products and services.
  • Legal reasons or merging/acquisition: In case Conductor or its assets are acquired or merged with another company, including for bankruptcy, we will share your Personal Data with our legal successors while respecting legal requirements in place. We will also disclose your Personal Data to third-parties (i) when required by applicable law; (ii) in response to legal procedures; (iii) in response to a request by a competent legal authority; (iv) to protect our rights, privacy or property; or (v) to comply with the terms in any agreement on our website, products and services according to the applicable law.
  • Reason for using your personal data in this situation:
    • Fulfilling contractual obligations;
    • Our legitimate interests;
  • Our legitimate interest in this situation:
    • Fulfilling legal obligations in their entirety;
    • Protecting our systems, assets and employees.

7.About disclosing your Personal Data

In addition to entities that are part of Conductor, we can share your Personal Data with the following types of third-party organizations:

  • Service providers: They include partner companies that are used by Conductor as Data Operators for operating our business. Select service providers and their employees are only allowed to access your Personal Data on behalf of Conductor and the Data Controller for specific tasks required from them, based on our direct instructions. Our service providers must contractually keep your Personal Data secure and confidential and, in case of violation, respond in solidarity according to the applicable law.
  • Third-party companies using Personal Data for their marketing purposes: Except when You’ve provided your specific consent, Conduct doesn’t license or sell your Personal Data to third-party companies for their marketing purposes. In case this type of sharing occurs, those third-party companies’ identity will be informed before the Data Controller receives your consent.
  • Third-parties using your Personal Data for legal reasons or for merging/acquisition: We will disclose your Personal Data to third-parties for legal reasons or for merger or acquisition at Conductor or the Data Controller.

8.About retaining and final steps when handling your Personal Data

According to the applicable laws, Conductor will use your Personal Data for as long as it is necessary to fulfill the purposes for which your Personal Data was collected, as mentioned in this policy, or to meet applicable legal requirements or Data Controller’s definitions.

Personal Data used for providing You with a customized experience will be retained for a permitted period, according to the applicable laws and Data Controller’s definitions.

For more details on retaining your Personal Data, see the communication channels defined in this policy.

When your Personal Data handling comes to an end, your Personal Data will be removed in the scope and within the technical limits of the activities, while retaining is permitted in situations that are foreseen by the applicable law.

9.About disclosing, storing and transferring Personal Data

Conductor takes appropriate measures to ensure your Personal Data is retained securely and confidentially. However, such protections don’t apply to information You have chosen to share in public areas, such as third-party social media.

  • People allowed to access your Personal Data: Your Personal Data is handled by our authorized employees or agents as long as they have access to this information, while respecting the specific purposes for which your Personal Data was collected.
  • Measures to be taken in operating environments: We store your Personal Data in operating environments by using security measures, whether technical or administrative, that are capable of preventing any type of unauthorized access.
  • Measures Conductor expects You to take: It is also important for You to keep your Personal Data secure. When You create an online account, please make sure to choose a password that is strong enough to avoid unauthorized parties to guess it. We recommend that You never show or share your password with others. You’re responsible for keeping your password confidential and for any action taken through your account on Conductor-supported websites or services.

If You use a shared or public computer, You should never choose the option to remember your login, email address or password. You should always ensure You log out from your account when You leave the computer. You should also use settings and privacy controls enabled by Conductor on our website, services or apps, including those that are considered optional.

  • Personal Data transfer: Given the nature of our business, we might have to transfer your Personal Data that is stored at Conductor to other locations, including some out of Conductor’s direct control, according to the purposes defined in this Privacy Policy. That’s why we can transfer your Personal Data to other countries, as long as they have regulations corresponding to the ones applicable to Brazil.

10.About your rights on Personal Data

As a Data Operator, when Conductor handles your Personal Data as requested by their customers (contractor companies), your rights and requests will be referred through our customers, while respecting contractual terms agreed between ourselves and those companies. In this case, it will be important to refer your requests directly to the contractor companies, which are Data Controllers and the ones responsible for setting rules and forms of fulfill their Data Subjects’ requests (consumers) so that we can take action.

However, in case You refer to us a request for exercising your rights, and we identify a situation where Conductor is a Data Operator, if we have the information on who is the Data Controller, we will present it to You so that You can exercise your rights in their entirety.

When Conductor is considered a Data Controller and handles your Personal Data (see items 2 and 3 above), your rights may be exercised in their entirety, and we will fulfill your requests immediately, while respecting the terms in the law.

You have the right to confirm the existence, access, review, change and/or request an electronic copy of the information about your Personal Data that is handled by Conductor.

You also have the right to request details about your Personal Data source or sharing this data with third-parties.

You can always limit the usage and disclosure or revoke the consent to any of our activities involving your Personal Data handling, except in situations foreseen in the applicable law.

You can exercise these rights through the communication channels specified in this policy. You will also need to validate your identity by providing a copy of your ID, or equivalent identification documents according to the applicable law, through our communication channels provided in this policy in section 14 – How to contact us. For fulfilling your request, You will always need to provide your full name, email and contact phone.

If You submit a request without providing the evidence that is necessary to prove your Data Subject is legitimate, the request will be automatically rejected. We emphasize that any identification information provided for Conductor will only be processed according to and as permitted by the applicable law.

In certain cases, we emphasize that we can’t remove your Personal Data without also removing your user account. In addition, some situations require that your Personal Data is retained after You request the removal in order to fulfill contractual and legal obligations.

When available, our websites, apps and online services might have a dedicated feature, where You can review and edit your Personal Data. We emphasize that Conductor requests You to validate your identity by using, for instance, a login system with an access password or similar feature before authorizing your access or changing your Personal Data. Thus, we ensure there is no unauthorized access to your account and associated Personal Data.

Conductor strives to address all issues and questions You might have on how we process your Personal Data. Nonetheless, if You have issues or questions that haven’t been addressed yet, You have the right to make a complaint to competent authorities regarding data protection or the Data Controller.

11.Your options on how we use and disclose your Personal Data

Conductor strives to give You freedom of choice on the Personal Data provided. The following mechanisms offer You control over your Personal Data handling:

  • Cookies/Similar technology: You can manage your consent by using:
    • Our solutions for consent management.
    • Your browser settings to deny some or all Cookies and similar technologies or to notify You when they’re used.
  • Advertising, marketing and special offers: You can consent so that your Personal Data is used by Conductor for promoting our products and services through email sent by Conductor according to this purpose.

If You choose not to receive such communications anymore, You can unsubscribe from communications related to marketing in the link provided on the Conductor email You received.

For unsubscribing from marketing communications sent through third-party social media, You can always choose to opt out by unsubscribing through the link provided on relevant third-party social media.

It is important to keep in mind that, even after unsubscribing from our marketing communications, You will keep receiving Conductor official communications, such as requests, transaction confirmations, notifications about your account activity on our supported websites and services and other important announcements non-related to marketing.

  • Customization (offline and online): When permitted by the law, if You want us to use your Personal Data for providing You with a customized experience and targeted ads and content, You can let us know by sending an email to [email protected]

If You decide not to benefit from this customization anymore, You can always choose to opt out by sending an email to [email protected]

  • Targeted ads: Conductor can partner with advertising networks and other advertising or service providers that show ads and other similar content on our behalf or on behalf of other companies that aren’t associated with Conductor. Some of these ads may be adjusted to your interests based on information collected on Conductor-supported websites and services or on websites owned by organizations that aren’t associated with Conductor.

It is important to emphasize that, in cases of targeted advertising mentioned in this topic, Conductor won’t have direct access to your Personal Data and won’t identify You directly nor carry out studies based on your profile in order to target ads. Conductor’s partner social media is exclusively responsible for these activities.

For more information on how to manage or opt out of targeted advertising, contact us by using the communication channels mentioned in this policy.

12.Changes in our Privacy Policy

This Policy will be updated whenever Conductor decides to change how we handle your Personal Data. We reserve the right to change our practices and this Policy at any moment, as long as it is still in compliance with the applicable law.

We recommend that You access this Policy on a regular basis or whenever questions arise so that You are aware of eventual updates or changes made in our Privacy Policy.

13.How to contact us

You can contact us for:

  • Asking questions and making comments on the Policy and our Personal Data protection and privacy practices;
  • Making a complaint;
  • Confirming that your Personal Data is being handled;
  • Requesting details on private and public entities we share your Personal Data with;
  • Getting information on whether to provide your consent and the consequences of opting out;
  • Other rights the Data Subject holds according to the applicable law.

Conductor may address your contact promptly in case it is the Data Controller for the following situations (see items 2 and 3 above):

  • Revoking your consent to your Personal Data handling, except in situations foreseen in the applicable law;
  • Getting information on how to access your Personal Data;
  • Correcting Personal Data that is incomplete, inaccurate or out to date;
  • Getting information on anonymizing, blocking or removing data that is unnecessary, excessive or handled, according to the applicable law;
  • Getting information about transferring your Personal Data to another product or service provider upon explicit request, according to the applicable law;
  • Requesting the removal of the Personal Data that is handled based on your consent, except in situations foreseen in the applicable law;

To that end, we ask You to contact us by using the following channels:

Employee responsible for Personal Data handling:

Thiago Cunha
[email protected]

Privacy Portal:
www.conductor.com.br/en/privacypolicy

Phone:
55 11 3889-1805

Mailing address:
Avenida Tamboré, 267, Alphaville, Barueri – SP – CEP: 06460-000

If the request is submitted by someone who isn’t You, without evidence showing that the request is legitimate on your behalf, it will be rejected. Note that any identification information we provide will be processed according to the applicable laws.

Within a reasonable waiting period, Conductor will receive, investigate and address any request or complaint on how Conductor, as a Data Operator, handles your Personal Data, including complaints on disrespecting your rights under the applicable Personal Data protection and privacy laws.

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