Definitions

User: every private individual who uses or visits websites provided by Coaktion and its brands declare to be over 18 (eighteen) years old, to be emancipated and fully capable for civilian acts, or if they are entirely or partially incapable, they must be properly represented or assisted.

Personal Data: any information provided to and/or collected by Coaktion and/or its brands, by any means which:

• identify or, when used in combination with other data, identifies an individual; or
• it can be derived into a personal individual’s identification or contact information.

Personal data might exist in any media or format, including electronic or computerized records and physical files. Personal data, however, does not include business phone, business mobile number, business address, generic business e-mail (that is, one that does not use as its prefix or suffix the user’s name).

Purpose: the goal which Coaktion aims to reach by collecting and processing your personal information.

Requirement: the justification (according to the Brazilian Law nº 13.709/18) of why collecting personal data is strictly necessary to reach Co. Aktion’s purpose, avoiding excessive collection.

Legal Bases: legal reasoning (aligned with Purpose and Requirement) which makes legit the treatment of personal data for a given purpose previously defined and specified by Coaktion.

Agreement: definite and unequivocal authorization given by the user, owner of the personal data, to Coaktion to treat their personal data following a previous described purpose, using the necessary legal bases if there is a demand of definite authorization by the entitled.

Collection and use of personal information

This policy applies to every user and potential user of services provided by Coaktion, including users of websites or other media operated by Coaktion. It summarizes how information can be collected, produced, received, classified, used, accessed, reproduced, transmitted, distributed, processed, filed, stored, eliminated or controlled; how the data collected can be modified, communicated, transferred, diffused or extracted, also including information of personal identification, based on the applicable legal bases and on every existing privacy law and laws of data protection.

When accessing and/or using our website, the user declares to be at least 18 (eighteen) years old and to be fully capable to accept terms and conditions of this Privacy Policy and of the Consent Form for all legal purposes. In case the user does not fit the description above and/or does not agree, even partially, with terms and conditions in this Privacy Policy, they cannot have access and/or use the services provided by Coaktion, neither the website(s), products and services provided.

Updating and supplying correct data to our websites when subscribing bears in user’s sole responsibility. If you wish, you (the user) can update and correct data, or cancel your subscription by sending us an e-mail to privacidade@coaktion.com.

The user is aware that they consciously and voluntarily supply personal data and other information. When the user subscribes and/or fills out forms provided by Co. Aktion, including the websites it operates, certain personal data requested are kept secret and will be used solely for the purpose that motivated the subscription, as described below:

If we identify any violation of data, we will report the fact, up to 48 hours, to the local organs of controls (being Brazilian organs of control, or organs of control of the European Union, in case of European Users, and the United States, in case of American users), as well as provide immediate notice, without any delay (sending by e-mail with return receipt), to the affected individuals (Users).

Users might request copies of the personal data being stored and processed by us in a usable format, as well as information on the storage and processing of their data: retention time, contact information of the responsible for the organization’s personal data, justification for keeping personal data stored. Requests might be made to DPO – Data Protection Officer by sending an e-mail to privacidade@coaktion.com.

You (User) might request, at the end of the relationship between you (User) and Coaktion, or at any time, to remove your consent for the treatment of your personal data or for the final exclusion of the data you might have provided, by sending an e-mail to Coaktion, except in the hypothesis of mandatory guard of information, in accordance to the Brazilian Law nº13.709/18 (LGPD – Lei Geral de Proteção de Dados Pessoais – General Law of Personal Data Protection).

Information security

To keep the security and the protection of Users’ information on our websites, we use the Communication Protocol (https) and the SSL method to encrypt all kinds of communication between you (User) and our applications and database.

Applications and databases of our websites are hosted in an external environment, in AWS Cloud Architecture, which follows the best practices of the market in information protection and security. We will never send an electronic message requesting the installation of software in our Users’ computers or on any mobile device.

Sharing information

Security and confidentiality of our Users’ information are very important to us. Subscription information provided by Users on our websites is protected by this Privacy Policy and we are committed to keep secrecy of our Users’ information, except in situations in accordance to the law, or in certain circumstances in which sharing information is mandatory. Below, we give examples of situations of sharing information:

Judicial Order: Coaktion might share information if there is a judicial order issued in notices, notifications, or judicial letters.
With Customer/User authorization: If information must be shared, we will send the User a notification by email requesting their approval.
Sharing data for statistical purposes: Data collected from the Users might be used to create statistic reports without any identification or
individualization of its origins.
Information collected might be share by Coaktion:

With partner companies, when the information is needed for suitable service provision to the customer, the object of its activities;
To protect Co. Aktion’s interest in any kind of conflict;
If there is a judicial decision or request by the competent authority.
However, we elucidate that your information might be shared with companies providing the technological and operational infrastructure needed for Coaktion’s operations, such as payment intermediates and Cloud storage providers.

YOUR RIGHTS

In compliance with the applicable regulation regarding personal data treatment, Coaktion respects and guarantees to the User the possibility of presenting requests based on the following rights:

• Confirmation of treatment existence;
• Access to data;
• Correction of incomplete, incorrect, or outdated data;
• Anonymization, blocking, or elimination of unnecessary, excessive data or data treated in disagreement;
• Portability of your data into other service or product providers, followed by a definite request of the User;
• Elimination of data treated with the User’s consent;
• Obtaining information on public or private entities with which Coaktion has shared your data;
• Information on the possibility of not consenting, as well as being informed about consequences, in case of negative;
• Revocation of consent.

If you have any request, complaint, or want to get in touch with our DPO – Data Protection Officer, send an e-mail to privacidade@coaktion.com. 

Privacy policy amendment and update

As we are constantly evolving our business model, Coaktion reserves the right to modify this Privacy Policy at any time by publishing the updated version at www.coaktion.com/politica-de-privacidade. 

Cookies

Our website uses cookies. Cookies are text files with data that a website sends to the Web browser of your computer while you navigate through it. Cookies have distinct functions that allow you to browse more easily through the webpages recording your preferences and optimizing the user’s experience. Those cookies might be stored in your device to help identify your computer. Cookies used at Co. Aktion’s website have a maximum expire date of 12 months.

Cookies used in this website might be set by our website or by third-part websites. Those cookies might be “session” or “persistent”:

• Session cookieis are temporary, and it is automatically deleted when the user closes the browser.
• Persistent cookieis are stored in the User’s terminal until a certain date.

We might also collect specific information from mobile devices which access our websites. Besides, we store some information automatically received whenever you (User) interact with our website. Internet Protocol (IP), the kind of browser, and the pages seen in our websites are some examples of such collection, which happen by means of cookies. All information collected in our websites are stored and protected by us.

We do not include third-party publicity on our website. We use segment cookies only for our own analytical means. We use third-party cookies to gather and collect information on our website’s audience and to offer advertising for the target audience on third-party websites. We might use personal data collected by our cookies to identify the User’s behavior and to show content and offers according to their profile. Performance cookies used in this website do not collect personal data.

Third-party social media websites might record some information (your IP address, the kind of browser, language, time of the access) if you access those while navigating through our website. They might also link information collected to your profile information on this website. We cannot control that tracking technology by third parts. Therefore, we recommend you read the terms of use and the privacy policy of those websites before accessing them.

Use of Cookies

Other cookies might collect personal data (including information of cookies inserted in our ads in third-party websites):

• When the user is subscribed.
• When we send e-mails to segmented target audiences with web beacons, cookies, or tracking technologies, we know if you opened, read, or deleted a message.
• When you click on a link in an e-mail marketing sent by Co. Aktion with log cookies of visualized pages and content downloaded from our websites, the same happens even if you did not subscribe to our website.

Here there is a list of the kinds of cookies used on our website:

If you do not want to get cookies from our website, you may disable them at our consent management banner, when accessing the website for the first time. You can modify our consent at any time, following the same path, that is accessing our website’s Preference Center.

You can also set your browser to refuse or to be notified when receiving any cookies, and you will be able to accept or reject them. There is also the possibility of setting your browser to deactivate cookies To do so, follow the instructions according to your browser:

• If you use Internet Explorer <https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d#:~:text=In%20Internet%20Explorer%2C%20select%20the,box%2C%20and%20then%20select%20Delete.>
• If you use Mozilla Firefox <https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox>
• If you use Apple Safari <https://www.apple.com/legal/privacy/en-ww/cookies/>
• If you use Google Chrome <https://support.google.com/accounts/answer/32050?hl=en&co=GENIE.Platform%3DAndroid>

Questions and contact

You (User) can ask any questions about our Privacy Policy at any time, by sending us an e-mail to: privacidade@coaktion.com.

Contact data of data protection officer (DPO)

According to the Brazilian General Law of Personal Data Protection (LGPD), the person responsible for this function, must be a channel of communication between Coaktion, the personal data holders and the supervisory authorities (the main one is ANPD – Brazilian National Authority for Data Protection). It is of their full responsibility to provide mapping, register and adequacy of every Coaktion business processes, ensuring compliance with principles, rights, and other guidelines and standards according to Brazilian Law nº 13.709/18 and according to other applicable laws.

Annex I

Company’s Qualification

AKTIE PARTICIPAÇÕES LTDA. (Coaktion)limited company based at Rua Manoel Coelho, nº 676, sala 710, Centro, in São Caetano do Sul, São Paulo – Brazil, Zip code: 09510-101, under Brazilian National Legal Entity Register CNPJ/ME nº 33.108.579/0001-60, with its articles of incorporation duly filed at Board of Trade of São Paulo (JUCESP) under Business Registration Identification Number NIRE 35231427106 (“Society”).
AKTIE NOW SERVIÇOS TECNOLÓGICOS E EMPRESARIAIS LTDA., limited company based at Rua Manoel Coelho, nº 676, sala 710, Centro, in São Caetano do Sul, São Paulo – Brazil, Zip code: 09510-101, under Brazilian National Legal Entity Register of the Ministry of Economy (“CNPJ/ME”) nº 24.552.976/0001-35, with its articles of incorporation duly filed at Board of Trade of São Paulo (“JUCESP”) under Business Registration Identification Number (NIRE) 3522978790 (“AKTIE NOW”).

DROZ TECNOLOGIA DA INFORMAÇÃO LTDA.limited company based at Rua Manoel Coelho, nº 676, sala 710, Centro, São Caetano do Sul, São Paulo – Brazil, Zip code: 09510-101, under Brazilian National Legal Entity Register CNPJ/ME nº 30.488.257/0001-03, with its articles of incorporation duly filed at Board of Trade of São Paulo JUCESP under Business Registration Identification Number NIRE 35230962628 (“DROZ”).

MYPBX SERVIÇOS E TECNOLOGIA LTDA.limited company based at Rua Manoel Coelho, nº 676, sala 710, Centro, São Caetano do Sul, São Paulo – Brazil, Zip code: 09510-101, under Brazilian National Legal Entity Register CNPJ/ME nº 10.717.581/0001-30, with its articles of incorporation duly filed at Board of Trade of São Paulo JUCESP under Business Registration Identification Number NIRE 35223070113 (“MYPBX”).

2LISTEN TECNOLOGIA DA INFORMAÇÃO LTDA.limited company based at Rua Manoel Coelho, nº 676, sala 710, Centro, São Caetano do Sul, São Paulo – Brazil, Zip code: 09510-101, under Brazilian National Legal Entity Register CNPJ/ME nº 33.943.115/0001-79, with its articles of incorporation duly filed at Board of Trade of São Paulo JUCESP under Business Registration Identification Number NIRE 35231667859 (“2LISTEN”).