SEO has a serious commitment to privacy and the protection of personal data of people impacted by its activities. Therefore, we created this Privacy Notice (the “Notice”) to inform you how we collect, use, process, and share, when strictly necessary, personal data when you run and use the SEO Module.
The SEO Module is a Software as a Service that allows its Users to optimize communication with leads and clients through a multi-service platform for managing activities and messages via the WhatsApp Platform, during the use of the license for the period contracted in the Subscription Plan acquired, in accordance with the SEO Terms and Conditions of Use.
To ensure our relationship is transparent and compliant with the General Personal Data Protection Law (the “LGPD”), we created this PRIVACY NOTICE (the “Notice”), through which we will inform you how we collect, use, process, and disclose your information and personal data when accessing and using the SEO Software as a Service, our Site, and our landing pages.
As you will notice, we collect the minimum possible Personal Data in the provision of our services and we choose not to have access to any Personal Data that we do not effectively need to access to fulfill our activities.
Read this document carefully and, if you have any questions, wish to express any non-conformity regarding the processing of personal data we perform, or wish to exercise your data subject rights, do not use our Software as a Service, our Site, and our landing pages, and speak to us immediately through our Service Channel | lordproducoes.com or contato@propix.com.br.
This Privacy Notice is an inseparable part of the Terms and Conditions of Use, which define the conditions for using the Site, so be sure to read that document as well.
WHAT INFORMATION YOU WILL FIND IN THIS NOTICE
- IMPORTANT CONCEPTS FOR THIS NOTICE
- TO WHOM DOES THIS NOTICE APPLY?
- ROLES AND RESPONSIBILITIES IN PERSONAL DATA PROCESSING
3.1. HOW PERSONAL DATA OF THOSE WHO USE THE SEO MODULE AND OUR SITE ARE TREATED
3.1.3. Data collected when you interact with our social networks - SHARING OF PERSONAL DATA
- LINK TO THIRD-PARTY SITES/PLATFORMS
- HOW WE PROTECT YOUR DATA
- KNOW YOUR RIGHTS AND HOW TO EXERCISE THEM
- HOW LONG DO WE STORE YOUR DATA?
- GENERAL PROVISIONS
- COMMUNICATION CHANNEL
1. IMPORTANT CONCEPTS FOR THIS NOTICE
Some concepts to help understand this Notice:
- Anonymization: Process by which collected personal data becomes files stored by the Controller, making it impossible to identify the person to whom such data refers.
- ANPD: National Data Protection Authority (Brazil), the public administration body responsible for overseeing, implementing, and supervising compliance with the LGPD throughout the national territory.
- Client: Person who pays for the SEO use license and determines who the Users registered in their dashboard are.
- Controller: The party responsible for decisions regarding the data processing of the subjects affected by an activity.
- Personal Data: Information that identifies a natural person, such as: email, Tax ID (CPF), phone number, and address.
- Sensitive Personal Data: Personal data regarding racial or ethnic origin, religious belief, opinion, union affiliation or organization of a religious, philosophical, or political nature, data regarding health or sexual life, genetic or biometric data.
- IP: The IP address is the code assigned to a terminal of a network to allow its identification, defined according to international parameters.
- LGPD: General Personal Data Protection Law (Lei n° 13.709/2018), which provides for the processing and protection of data in Brazil.
- Processor (Operator): Who performs the data processing according to the Controller’s instructions.
- SEO Platform: Platform that offers 24h self-service solutions through chatbots, service management, and message sending via WhatsApp Platform and Telegram Platform to your target audience.
- Subscription Plan: Contracting plan adhered to by click by the Client, directly on partner Purchasing Platforms, in accordance with their terms of use, privacy notices, and purchase conditions.
- WhatsApp Platform: Platform owned by WhatsApp LLC, on which the SEO Software as a Service may be executed, according to the contracted Subscription Plan and the platform’s terms of use, at the link https://www.whatsapp.com/legal/.
- Telegram Platform: Platform owned by Telegram Messenger Inc., on which the SEO Software as a Service may be executed, according to the contracted Subscription Plan and the platform’s terms of use, at the link https://telegram.org/tos/br.
- Site: The SEO website.
- Data Processing: Any operation carried out with personal data, such as those referring to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, diffusion, or extraction.
- Data Subjects: Natural person to whom the personal data that is the object of Processing by Controllers and Processors refers.
- User: Person indicated by the Client to use the SEO license, which may be:
- Administrator User (the “Admin”): Person with visibility over team management features.
- Internal User: Natural person registered by the Admin to access and use the SEO System.
- Site User: Natural person who uses the SEO Site but does not interact with the platform.
- SEO Module: Module that provides a Software as a Service (SaaS), accessible in the web environment, which provides the optimization of lead and client service for the Client and Users on the WhatsApp Platform and Telegram Platform, through its various features.
2. TO WHOM DOES THIS NOTICE APPLY?
This Privacy Notice (Notice) applies to Users of the SEO Module and the Site.
3. ROLES AND RESPONSIBILITIES IN PERSONAL DATA PROCESSING
People responsible for the processing of personal data of Data Subjects
SEO is responsible for the processing of personal data of Users of the SEO Module and the Site, acting as Controller of this data.
However, when a SEO Client uses their license, they also act as a Joint Controller over this data, being indispensable that they maintain their own policies and technical and administrative measures for control and protection of personal data. It is fundamental that the Client and their Users, for example, fully assume the obligation to include operations performed by SEO in the necessary privacy notices, as well as obtain all applicable consents, with the maintenance of Data Processing in accordance with the legislation being the responsibility of the Client and their Users.
To contract a Subscription Plan, the client must purchase the use license for a determined time on the Partner Payment Platform. This Payment Platform is also a Controller of the data, to the extent that it processes the personal data of subjects for its due purposes.
SEO is not and will not be responsible for Data Processing performed by third parties, inside or outside its Software as a Service.
3.1. HOW PERSONAL DATA OF THOSE WHO USE THE SEO MODULE AND OUR SITE ARE TREATED
Data collected for access to SEO
For registration and User creation, the following data are collected:
- Name
- Phone
- IP
- Password
- Acceptance of Terms and Conditions of Use
Data collected for communication with Users
For communication with the Data Subject, the following data are collected:
- Name
- Phone
Data collected when you interact with our social networks
We collect the data necessary to contact you, such as name, email, and phone number.
The personal data that may be accessed are:
- Name
- Phone
- WhatsApp Photo
Data collected indirectly and cookies
Our company may collect indirectly during the User’s utilization of SEO, such as IP address, session, date and time logs of actions, acceptance of Terms and Conditions of Use, activities in our Software as a Service, etc., through webhooks and cookies, which will be treated in a specific item.
Application Logs
Access records are collected, a set of information referring to the date and time of use of a certain internet application from a certain IP address, under the terms of Law No. 12.965/2014 (Brazilian Civil Rights Framework for the Internet).
This record can only be accessed through a court order.
Cookies
On our Site, we have a cookies banner that can be accessed whenever you want to access and set privacy settings in our activities and change settings related to your consent on what can be changed.1
This banner is divided into two screens; on the first screen, you can decide if you want to:2
- Accept all our cookies3
- Reject non-necessary cookies
- Configure your acceptance, according to your preferences.
If you choose to configure your acceptance, you can see that our Site uses various types of cookies to enhance your experience and customize your navigation, which can be divided into 5 large “families”, they are:
- Necessary cookies: Essential for the site’s operation; without them, the site would not function correctly (e.g., access to secure areas of the site, security, legislation).
- Performance cookies: Allow the site to behave according to the visitor, adjusting to their location, preferred language, etc.
- Functional cookies: Adjust the site to third-party services, such as links to your profile on social networks, comments, chatbots, etc.
- Marketing cookies: Track visitor navigation and collect data so that the company can provide more relevant ads according to such behavior.
- Statistics cookies: Translate visitor interactions into detailed behavior reports, anonymously.
You can check how each cookie behaves directly on our banner.
Different cookie functionalities bring different legal bases for data processing, which is why the Data Subject can modulate their acceptance on the settings screen, actively opting for those data they consent to collect. They come disabled by default, so if you did not accept or reject all on the quick button of the first screen, you can select the ones you consent to accept on this second screen.
On the denial of client data processing
SEO does not have access to the data that Users operate within the system.
SEO does not have access to the phone contacts of SEO Users.
SEO does not have access to the conversations of SEO Users.
Purposes and legal bases for personal data processing
The personal data processed for access and use of SEO will be used only to meet the following purposes:
| Collected Data | Purpose | Legal Basis |
| Client Registration Information | For contract formation and identification of the User acquiring the right to use the SEO License and its features. | Execution of Contract and preliminary procedures (Art. 7, V, LGPD) |
| User Registration Information | For identification of the User acquiring the right to use the SEO License and its features. | Execution of Contract and preliminary procedures (Art. 7, V, LGPD) |
| User Interactions with SEO in communication and/or service channels | To make SEO service more efficient and improve User experience. | Legitimate interest (Art. 7, IX, LGPD) |
| IP Address, User session, date and time logs of actions, device/browser, User activities on the site | Collect information to identify and protect Users, as well as comply with legal obligations. | Legal or regulatory obligation of the Controller (Art. 7, II, LGPD) – Comply with the Civil Rights Framework for the Internet (Art. 15) Legitimate interest of the Controller (Art. 7, IX, LGPD) |
| Necessary Cookies | To record the action of acceptance, modulation, or rejection of cookies by the Data Subject during navigation on the Site. | Legitimate interest of the Controller (Art. 10, LGPD) |
| Functional, Statistical, Performance, and Marketing Cookies | For personalization of the User experience, improving our features, and directing advertising to Users according to their interest. | Consent (Art. 7, I, LGPD) |
Veracity of data
The User is responsible for the veracity of their personal data. The SEO use license does not cover liability for checking the authenticity of Client/User data and/or other data confirmation or validation actions during the use of the system.
The SEO use license does not include the obligation to process or Treat Data provided by the Client or User if there is a motivated suspicion to believe that carrying out the activity may cause an infringement of any applicable law, as well as regarding the misuse of SEO by the Client/User, such as for illegal, illicit purposes or contrary to this Notice or the Terms and Conditions of Use.
4. SHARING OF PERSONAL DATA
SEO may share the data necessary to maintain its operations efficiently. That is, data may be shared with contracted companies so that SEO features are available and/or to provide a better experience for the Client and Users.
Specialized outsourced agents for providing specific and punctual services for our Software as a Service will have access to personal data collected for the operation of SEO, as Data Processors, such as:
- Hetzner Cloud Platform – cloud servers – https://www.hetzner.com/legal/privacy-policy/
- WhatsApp Platform – instant messaging services – https://www.whatsapp.com/legal/
- Telegram Platform – instant messaging services – https://telegram.org/tos/br
However, it may be that, to use SEO, the Client has to share personal data with other Data Controllers, such as our partners:
- Hotmart Payment Platform – https://hotmart.com/pt-br/legal/privacidade-de-dados
- Greenn Payment Platform – https://greenn.com.br/politica-de-privacidade-greenn/
In this case, you need to understand that these platforms may request personal data that is not stored in SEO to fulfill their own obligations related to Data Processing. Before accepting any type of term or privacy policy, be well informed.
All our hirings value the secure treatment of Client/User information.
From the moment these third parties have access to the shared data, they will be responsible for its secure treatment, being limited to the purposes related to the contracted service and having to respect the applicable Law.
International Data Transfer
To the limit permitted by the LGPD, there may be data sharing outside of Brazil.
This international transfer occurs when we use cloud services for processing or storing data, to make it possible to execute our services in the best way, in a secure environment.
For this, Hetzner cloud servers are used, which implies an international transfer of personal data to the country where this server is headquartered, in the United States of America/Germany. Other SEO servers are located in São Paulo/SP, Brazil.
By doing so, we take all appropriate measures to ensure that your data is treated and shared securely and in compliance with current legislation and this Privacy Notice.
5. LINK TO THIRD-PARTY SITES/PLATFORMS
Our Site may contain links to third-party sites/platforms, such as partners, advertisers, and social networks. When following a link, it is important to note that these sites/platforms have their own privacy notices and policies and that our company is not responsible for these notices or for the data collection performed. We recommend checking these notices and policies before sending any personal data to these third parties.
6. HOW WE PROTECT YOUR DATA
SEO is committed to the security of all its Users and, therefore, adopts physical, electronic, and administrative procedures that guarantee the privacy and security of your data, with technical measures compatible with expected standards and good information security practices.
Whenever possible, we do not collect data regarding your use of SEO.
Under no circumstances will we have access to your conversations.
All technologies used and employed in SEO will always respect current legislation and the terms of this Privacy Notice.
7. KNOW YOUR RIGHTS AND HOW TO EXERCISE THEM
- Access and confirmation of processing: You can request access to the complete list of data collected and processed, as well as confirmation of the processing of your personal data.
- Withdrawal of consent: You may withdraw your consent to the Processing of Personal Data at any time, when this is the appropriate legal basis for carrying out the processing of your personal data.
- Correction of personal data: You can request the correction of data that is incomplete, inaccurate, or outdated.
- Anonymization, blocking, or elimination: All data collected and processed by us aims at the provision of services and the good performance of the Software as a Service. If you believe that any of your data is being treated unnecessarily, in excess, or the processing is not in compliance with the LGPD, you may request anonymization, blocking, or elimination, if you prove that there was excess, unnecessity, or non-compliance with the LGPD.
- Information regarding sharing: You can request information about our partners and suppliers with whom we share data. All our partners are also concerned with User security and guarantee the adoption of appropriate measures for the protection of your data.
- Automated decisions: You can request a review of decisions made solely based on automated data processing and the criteria used in these decisions, always observing our company’s commercial and industrial secrets.
- Data portability: You may request the portability of your personal data to another service provider, in compliance with the provisions of the LGPD.
- Opposition or objection to Personal Data Processing: If you wish, you can object to the processing of some Personal Data we perform or present opposition to the processing completely. In this case, we may stop the processing or explain that we have an appropriate legal basis to carry out the questioned processing.
- Registering a complaint: You may contact the ANPD (National Data Protection Authority) at any time if you feel your rights have been violated.
To exercise any of your rights as a Data Subject, contact us through the Service Channel | lordproducoes.com or contato@propix.com.br.
8. HOW LONG DO WE STORE YOUR DATA?
Data provided by the Client/User will be stored and processed as long as their registration is active.
If the User wishes, they can request the deletion of their account and personal data through the Service Channel | lordproducoes.comcliogrow.com/#contact or contato@propix.com.br.
Upon the request for deletion or termination of the processing purpose, the User will have all their data permanently deleted, except for data whose maintenance is mandatory by law or regulation or regarding data necessary for the regular exercise of rights in judicial, administrative, or arbitral proceedings.
9. GENERAL PROVISIONS
At any time, strictly unilaterally, we may modify/update this Notice. If this happens, the Data Subject will be notified, and the updated version will be valid from its publication.4
The continued access or use by the Client/User after disclosure of the update will confirm awareness and validity of the new Notice.5
In addition to this Privacy Notice, we have Terms and Condition6s of Use, which define the conditions of use that will govern the use of SEO. The Terms inseparably cover the provisions of this Privacy Notice.
10. COMMUNICATION CHANNEL
We provide a communication channel to offer support to the personal data subject and any questions related to this Notice, at the Service Channel | lordproducoes.com/contact or contato@propix.com.br.