Privacy Policy
INTRODUCTION
This Privacy Policy clearly, transparently and in detail establishes the rules governing the processing of personal data carried out by ADDON Intelligence, Software and Automation, in accordance with Brazilian law and best practices in privacy protection, information security and digital governance.
All processes, systems, platforms, applications, websites, APIs, software, mobile applications, automations, Artificial Intelligence solutions and other technology services developed or made available by ADDON will observe, whenever technically applicable, the principles of privacy by design and privacy by default.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
IDENTIFICATION OF THE DATA CONTROLLER
For the purposes of the Brazilian General Data Protection Law (LGPD), ADDON may act as Controller, Processor or, depending on the specific circumstances, in both capacities provided for by law.
When acting as Controller, ADDON will be responsible for decisions concerning the processing of personal data. When acting as Processor, it will process data in accordance with its clients’ instructions, respecting the contracts entered into and applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
SCOPE
This section governs scope within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
APPLICABLE LAW
This section governs applicable law within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Law No. 13,709/2018
- Law No. 12,965/2014
- Decree No. 8,771/2016
- Brazilian Civil Code
- Brazilian Consumer Protection Code
- Rules of the Brazilian National Data Protection Authority
- Applicable international standards
- Information security best practices
PRINCIPLES OBSERVED
This section governs principles observed in mobile applications, systems and platforms developed, maintained or made available by ADDON.
The permissions requested will depend on the specific purpose of the application and the features actually implemented, and may be managed by the user through the device settings.
The following points, among others, may be observed:
- Good faith
- Lawfulness
- Transparency
- Necessity
- Adequacy
- Purpose
- Free access
- Data quality
- Security
- Prevention
- Accountability
- Non-discrimination
TERMS AND CONCEPTS USED
This section governs terms and concepts used within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
DATA COLLECTED
This section governs data collected within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Registration data
- Contact data
- Technical data
- Browsing data
- Authentication data
- Data provided voluntarily
- Documents submitted by the user
- Information generated by systems and automations
METHODS OF DATA COLLECTION
This section governs methods of data collection within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
LEGAL BASES FOR PROCESSING
This section governs legal bases for processing within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Performance of a contract
- Pre-contractual procedures
- Compliance with a legal or regulatory obligation
- Regular exercise of rights
- Legitimate interest
- Data subject consent when required
- Credit protection where applicable
- Compliance with requests from competent authorities
PURPOSES OF PROCESSING
This section governs purposes of processing within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- User identification
- Access authentication
- Provision of technical support
- Performance of contracts
- Systems development
- Platform integration
- Sending technical communications
- Fraud prevention
- Information security
- Compliance with legal obligations
- Service improvement
- Operational continuity
BROWSING DATA
This section governs browsing data within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
COOKIES
This section governs cookies within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
WEB BEACONS
This section governs web beacons within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
PIXEL TAGS
This section governs pixel tags within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
LOCAL STORAGE
This section governs local storage within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
APPLICATION LOGS
This section governs application logs within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
DATA SHARING
This section governs data sharing within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
PROCESSORS AND SUBPROCESSORS
This section governs processors and subprocessors within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
HOSTING AND CLOUD INFRASTRUCTURE
This section governs hosting and cloud infrastructure within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
INTERNATIONAL DATA TRANSFERS
This section governs international data transfers within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
THIRD-PARTY SERVICES
This section governs third-party services within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
INTEGRATIONS WITH EXTERNAL PLATFORMS
This section governs integrations with external platforms within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Key- or token-based authentication
- Call logging
- Technical usage limits
- Permission validation
- Dependency on third parties
- Failure monitoring
- Adjustments in the event of external changes
- Responsibility for authorized use
ELECTRONIC COMMUNICATIONS
This section governs electronic communications within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Operational communications
- Security notices
- Contractual messages
- Technical support
- Service updates
- Authorized corporate communications
- Opt-out from promotional communications
- Keeping contact details up to date
ARTIFICIAL INTELLIGENCE INTEGRATIONS
This section governs artificial intelligence integrations in the context of ADDON's products, systems, automations and digital services.
The use of Artificial Intelligence may expand functionality and automate processes, but it does not eliminate the need for human review when the nature of the activity requires technical, legal, administrative or professional validation.
The following points, among others, may be observed:
- Key- or token-based authentication
- Call logging
- Technical usage limits
- Permission validation
- Dependency on third parties
- Failure monitoring
- Adjustments in the event of external changes
- Responsibility for authorized use
INFORMATION SECURITY
This section establishes measures and guidelines relating to information security, applicable to ADDON's technology environments, systems, applications, APIs, databases and digital services.
ADDON will adopt reasonable technical, administrative and organizational measures to protect personal data against unauthorized access, destruction, loss, alteration, improper disclosure, leakage, inappropriate processing or any form of unlawful use.
The following points, among others, may be observed:
- Access control
- User authentication
- Encryption where applicable
- Log monitoring
- Backups when contracted
- Incident response
- Permission review
- Continuous improvement
ENCRYPTION
This section establishes measures and guidelines relating to encryption, applicable to ADDON's technology environments, systems, applications, APIs, databases and digital services.
ADDON will adopt reasonable technical, administrative and organizational measures to protect personal data against unauthorized access, destruction, loss, alteration, improper disclosure, leakage, inappropriate processing or any form of unlawful use.
The following points, among others, may be observed:
- Access control
- User authentication
- Encryption where applicable
- Log monitoring
- Backups when contracted
- Incident response
- Permission review
- Continuous improvement
ACCESS CONTROL
This section governs access control within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
AUTHENTICATION AND CREDENTIAL MANAGEMENT
This section governs authentication and credential management within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
BACKUPS
This section governs backups within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
BUSINESS CONTINUITY
This section governs business continuity in mobile applications, systems and platforms developed, maintained or made available by ADDON.
The permissions requested will depend on the specific purpose of the application and the features actually implemented, and may be managed by the user through the device settings.
The following points, among others, may be observed:
- Device permissions
- Technical compatibility
- Publishing in an official app store
- Platform review
- Required updates
- Privacy policy
- Terms of use
- Operating system limitations
INCIDENT RESPONSE
This section establishes measures and guidelines relating to incident response, applicable to ADDON's technology environments, systems, applications, APIs, databases and digital services.
ADDON will adopt reasonable technical, administrative and organizational measures to protect personal data against unauthorized access, destruction, loss, alteration, improper disclosure, leakage, inappropriate processing or any form of unlawful use.
The following points, among others, may be observed:
- Access control
- User authentication
- Encryption where applicable
- Log monitoring
- Backups when contracted
- Incident response
- Permission review
- Continuous improvement
AUDITING AND TRACEABILITY
This section governs auditing and traceability within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
SYSTEM MONITORING
This section governs system monitoring within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
SECURITY GOVERNANCE
This section establishes measures and guidelines relating to security governance, applicable to ADDON's technology environments, systems, applications, APIs, databases and digital services.
ADDON will adopt reasonable technical, administrative and organizational measures to protect personal data against unauthorized access, destruction, loss, alteration, improper disclosure, leakage, inappropriate processing or any form of unlawful use.
The following points, among others, may be observed:
- Access control
- User authentication
- Encryption where applicable
- Log monitoring
- Backups when contracted
- Incident response
- Permission review
- Continuous improvement
SECURE DEVELOPMENT
This section governs secure development within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
DEVELOPMENT, TESTING AND PRODUCTION ENVIRONMENTS
This section governs development, testing and production environments within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
APIS AND INTEGRATIONS
This section governs apis and integrations within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Key- or token-based authentication
- Call logging
- Technical usage limits
- Permission validation
- Dependency on third parties
- Failure monitoring
- Adjustments in the event of external changes
- Responsibility for authorized use
CODE REPOSITORIES
This section governs code repositories in mobile applications, systems and platforms developed, maintained or made available by ADDON.
The permissions requested will depend on the specific purpose of the application and the features actually implemented, and may be managed by the user through the device settings.
The following points, among others, may be observed:
- Device permissions
- Technical compatibility
- Publishing in an official app store
- Platform review
- Required updates
- Privacy policy
- Terms of use
- Operating system limitations
SOURCE CODE AND DATA PROTECTION
This section governs source code and data protection within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
OPEN-SOURCE COMPONENTS
This section governs open-source components within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Source code
- Object code
- Layouts
- Interfaces
- Technical documentation
- Reusable components
- Third-party licenses
- Restrictions on unauthorized use
UPDATES, DEPENDENCIES AND VULNERABILITIES
This section governs updates, dependencies and vulnerabilities within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
DEVOPS, CI/CD AND DEPLOYMENT AUTOMATION
This section governs devops, ci/cd and deployment automation within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Content generation
- Information classification
- Data extraction
- Human review when necessary
- Technical limitations of the model
- Logging of relevant interactions
- Data minimization
- Responsible use by the user
ARTIFICIAL INTELLIGENCE AND DATA PROTECTION
This section governs artificial intelligence and data protection in the context of ADDON's products, systems, automations and digital services.
The use of Artificial Intelligence may expand functionality and automate processes, but it does not eliminate the need for human review when the nature of the activity requires technical, legal, administrative or professional validation.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
LIMITATIONS OF ARTIFICIAL INTELLIGENCE SYSTEMS
This section governs limitations of artificial intelligence systems in the context of ADDON's products, systems, automations and digital services.
The use of Artificial Intelligence may expand functionality and automate processes, but it does not eliminate the need for human review when the nature of the activity requires technical, legal, administrative or professional validation.
The following points, among others, may be observed:
- Content generation
- Information classification
- Data extraction
- Human review when necessary
- Technical limitations of the model
- Logging of relevant interactions
- Data minimization
- Responsible use by the user
SENSITIVE PERSONAL DATA
This section governs sensitive personal data within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Data concerning racial or ethnic origin
- Data concerning religious beliefs
- Data concerning political opinions
- Data concerning trade union membership
- Health data
- Data concerning sex life
- Genetic data
- Biometric data
- Other information legally classified as sensitive
PROCESSING OF SENSITIVE DATA IN SYSTEMS DEVELOPED FOR CLIENTS
This section addresses processing of sensitive data in systems developed for clients in the context of services provided by ADDON and information entered, submitted, imported or made available by clients and users.
The client or user is responsible for the truthfulness, lawfulness, accuracy and adequacy of the information provided, as well as for having a lawful basis for processing third-party data where applicable.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
CHILDREN'S AND ADOLESCENTS' DATA
This section governs children's and adolescents' data within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
DATA RETENTION
This section governs data retention within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
The application of this provision must take into account the specific purpose of the processing, the nature of the data involved, existing legal and contractual obligations, the rights of data subjects and the technical limitations of the environment used.
DATA DELETION
This section governs data deletion within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
The application of this provision must take into account the specific purpose of the processing, the nature of the data involved, existing legal and contractual obligations, the rights of data subjects and the technical limitations of the environment used.
ANONYMIZATION AND PSEUDONYMIZATION
This section governs anonymization and pseudonymization within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
The application of this provision must take into account the specific purpose of the processing, the nature of the data involved, existing legal and contractual obligations, the rights of data subjects and the technical limitations of the environment used.
DATA SUBJECT RIGHTS
This section governs data subject rights in accordance with the Brazilian General Data Protection Law (LGPD) and other applicable rules.
ADDON may request additional information to confirm the identity of the requester or the authority of a legal representative, in order to prevent fraud, improper exposure of data or the handling of fraudulent requests.
The following points, among others, may be observed:
- Confirmation of whether processing exists
- Access to data
- Correction of incomplete, inaccurate or outdated data
- Anonymization of unnecessary data
- Blocking of excessive data
- Deletion of data processed in violation of the law
- Data portability where applicable
- Information about data sharing
- Withdrawal of consent
- Review of automated decisions where applicable
- Petitioning the Brazilian National Data Protection Authority
The application of this provision must take into account the specific purpose of the processing, the nature of the data involved, existing legal and contractual obligations, the rights of data subjects and the technical limitations of the environment used.
LGPD CONTACT CHANNEL
This section governs lgpd contact channel in accordance with the Brazilian General Data Protection Law (LGPD) and other applicable rules.
ADDON may request additional information to confirm the identity of the requester or the authority of a legal representative, in order to prevent fraud, improper exposure of data or the handling of fraudulent requests.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
The application of this provision must take into account the specific purpose of the processing, the nature of the data involved, existing legal and contractual obligations, the rights of data subjects and the technical limitations of the environment used.
PROCEDURE FOR EXERCISING RIGHTS
This section governs procedure for exercising rights in accordance with the Brazilian General Data Protection Law (LGPD) and other applicable rules.
ADDON may request additional information to confirm the identity of the requester or the authority of a legal representative, in order to prevent fraud, improper exposure of data or the handling of fraudulent requests.
The following points, among others, may be observed:
- Full name
- Identification document
- Contact email
- Telephone number when necessary
- Service used
- Related system or application
- Description of the request
- Approximate processing period
- Information that helps locate the data
- Documents proving the legitimacy of the request when necessary
The application of this provision must take into account the specific purpose of the processing, the nature of the data involved, existing legal and contractual obligations, the rights of data subjects and the technical limitations of the environment used.
LIMITATIONS ON FULFILLING REQUESTS
This section governs limitations on fulfilling requests within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Compliance with a legal or regulatory obligation
- Need to preserve rights
- Existence of an active contract
- Defense in judicial, administrative or arbitration proceedings
- Fraud prevention
- Systems security
- Data stored in backups
- Necessary technical records
- Inability to confirm the requester's identity
- Abusive, generic, disproportionate or legally incompatible request
The application of this provision must take into account the specific purpose of the processing, the nature of the data involved, existing legal and contractual obligations, the rights of data subjects and the technical limitations of the environment used.
MARKETING AND CORPORATE COMMUNICATIONS
This section governs marketing and corporate communications within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Operational communications
- Security notices
- Contractual messages
- Technical support
- Service updates
- Authorized corporate communications
- Opt-out from promotional communications
- Keeping contact details up to date
NEWSLETTER
This section governs newsletter within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Operational communications
- Security notices
- Contractual messages
- Technical support
- Service updates
- Authorized corporate communications
- Opt-out from promotional communications
- Keeping contact details up to date
SENDING EMAILS
This section governs sending emails within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Operational communications
- Security notices
- Contractual messages
- Technical support
- Service updates
- Authorized corporate communications
- Opt-out from promotional communications
- Keeping contact details up to date
SENDING SMS
This section governs sending sms within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Operational communications
- Security notices
- Contractual messages
- Technical support
- Service updates
- Authorized corporate communications
- Opt-out from promotional communications
- Keeping contact details up to date
WHATSAPP AND MESSAGING APPLICATIONS
This section governs whatsapp and messaging applications in mobile applications, systems and platforms developed, maintained or made available by ADDON.
The permissions requested will depend on the specific purpose of the application and the features actually implemented, and may be managed by the user through the device settings.
The following points, among others, may be observed:
- Device permissions
- Technical compatibility
- Publishing in an official app store
- Platform review
- Required updates
- Privacy policy
- Terms of use
- Operating system limitations
PUSH NOTIFICATIONS
This section governs push notifications within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Operational communications
- Security notices
- Contractual messages
- Technical support
- Service updates
- Authorized corporate communications
- Opt-out from promotional communications
- Keeping contact details up to date
ANDROID APPLICATIONS
This section governs android applications in mobile applications, systems and platforms developed, maintained or made available by ADDON.
The permissions requested will depend on the specific purpose of the application and the features actually implemented, and may be managed by the user through the device settings.
The following points, among others, may be observed:
- Internet access
- Notifications
- Camera
- Photo gallery
- Files
- Microphone
- Location
- Contacts
- Bluetooth
- Storage
- Device identifiers
- Background execution
IOS APPLICATIONS
This section governs ios applications in mobile applications, systems and platforms developed, maintained or made available by ADDON.
The permissions requested will depend on the specific purpose of the application and the features actually implemented, and may be managed by the user through the device settings.
The following points, among others, may be observed:
- Internet access
- Notifications
- Camera
- Photos
- Files
- Microphone
- Location
- Contacts
- Bluetooth
- Device identifiers
- Background execution
- Device security features
DEVICE PERMISSIONS
This section governs device permissions in mobile applications, systems and platforms developed, maintained or made available by ADDON.
The permissions requested will depend on the specific purpose of the application and the features actually implemented, and may be managed by the user through the device settings.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
APP STORES
This section governs app stores in mobile applications, systems and platforms developed, maintained or made available by ADDON.
The permissions requested will depend on the specific purpose of the application and the features actually implemented, and may be managed by the user through the device settings.
The following points, among others, may be observed:
- Device permissions
- Technical compatibility
- Publishing in an official app store
- Platform review
- Required updates
- Privacy policy
- Terms of use
- Operating system limitations
DATA PROCESSED IN CLIENT SYSTEMS
This section addresses data processed in client systems in the context of services provided by ADDON and information entered, submitted, imported or made available by clients and users.
The client or user is responsible for the truthfulness, lawfulness, accuracy and adequacy of the information provided, as well as for having a lawful basis for processing third-party data where applicable.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
RESPONSIBILITY OF THE CLIENT AS CONTROLLER
This section addresses responsibility of the client as controller in the context of services provided by ADDON and information entered, submitted, imported or made available by clients and users.
The client or user is responsible for the truthfulness, lawfulness, accuracy and adequacy of the information provided, as well as for having a lawful basis for processing third-party data where applicable.
The following points, among others, may be observed:
- Provide truthful information
- Keep data up to date
- Use the services lawfully
- Respect third-party rights
- Protect credentials
- Report relevant failures
- Validate functionality
- Comply with contractual obligations
DOCUMENTS SUBMITTED BY THE CLIENT OR USER
This section addresses documents submitted by the client or user in the context of services provided by ADDON and information entered, submitted, imported or made available by clients and users.
The client or user is responsible for the truthfulness, lawfulness, accuracy and adequacy of the information provided, as well as for having a lawful basis for processing third-party data where applicable.
The following points, among others, may be observed:
- Provide truthful information
- Keep data up to date
- Use the services lawfully
- Respect third-party rights
- Protect credentials
- Report relevant failures
- Validate functionality
- Comply with contractual obligations
DATABASES
This section governs databases within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
DATA IMPORT
This section governs data import within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
DATA EXPORT
This section governs data export within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
TECHNICAL SUPPORT
This section governs technical support within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
REMOTE ACCESS
This section governs remote access within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
CREDENTIALS, KEYS AND ACCESS PROVIDED BY THE CLIENT
This section addresses credentials, keys and access provided by the client in the context of services provided by ADDON and information entered, submitted, imported or made available by clients and users.
The client or user is responsible for the truthfulness, lawfulness, accuracy and adequacy of the information provided, as well as for having a lawful basis for processing third-party data where applicable.
The following points, among others, may be observed:
- Provide truthful information
- Keep data up to date
- Use the services lawfully
- Respect third-party rights
- Protect credentials
- Report relevant failures
- Validate functionality
- Comply with contractual obligations
CLIENT'S EXTERNAL ENVIRONMENTS
This section addresses client's external environments in the context of services provided by ADDON and information entered, submitted, imported or made available by clients and users.
The client or user is responsible for the truthfulness, lawfulness, accuracy and adequacy of the information provided, as well as for having a lawful basis for processing third-party data where applicable.
The following points, among others, may be observed:
- Provide truthful information
- Keep data up to date
- Use the services lawfully
- Respect third-party rights
- Protect credentials
- Report relevant failures
- Validate functionality
- Comply with contractual obligations
INTELLECTUAL PROPERTY AND PERSONAL DATA
This section governs intellectual property and personal data within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
DATA IN SOFTWARE PROJECTS
This section governs data in software projects within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
SYSTEM ACCEPTANCE TESTING
This section governs system acceptance testing within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
CLIENT ACCEPTANCE
This section addresses client acceptance in the context of services provided by ADDON and information entered, submitted, imported or made available by clients and users.
The client or user is responsible for the truthfulness, lawfulness, accuracy and adequacy of the information provided, as well as for having a lawful basis for processing third-party data where applicable.
The following points, among others, may be observed:
- Provide truthful information
- Keep data up to date
- Use the services lawfully
- Respect third-party rights
- Protect credentials
- Report relevant failures
- Validate functionality
- Comply with contractual obligations
CORRECTIVE AND EVOLUTIONARY MAINTENANCE
This section governs corrective and evolutionary maintenance within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
DELETION OF USER ACCOUNTS
This section addresses deletion of user accounts in the context of services provided by ADDON and information entered, submitted, imported or made available by clients and users.
The client or user is responsible for the truthfulness, lawfulness, accuracy and adequacy of the information provided, as well as for having a lawful basis for processing third-party data where applicable.
The following points, among others, may be observed:
- Provide truthful information
- Keep data up to date
- Use the services lawfully
- Respect third-party rights
- Protect credentials
- Report relevant failures
- Validate functionality
- Comply with contractual obligations
The application of this provision must take into account the specific purpose of the processing, the nature of the data involved, existing legal and contractual obligations, the rights of data subjects and the technical limitations of the environment used.
CONTRACT TERMINATION
This section governs contract termination within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
The application of this provision must take into account the specific purpose of the processing, the nature of the data involved, existing legal and contractual obligations, the rights of data subjects and the technical limitations of the environment used.
PRESERVATION OF DIGITAL EVIDENCE
This section governs preservation of digital evidence within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
The application of this provision must take into account the specific purpose of the processing, the nature of the data involved, existing legal and contractual obligations, the rights of data subjects and the technical limitations of the environment used.
CHANGES TO THIS POLICY
This section governs changes to this policy within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
The application of this provision must take into account the specific purpose of the processing, the nature of the data involved, existing legal and contractual obligations, the rights of data subjects and the technical limitations of the environment used.
CURRENT VERSION AND HISTORY
This section governs current version and history within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
The application of this provision must take into account the specific purpose of the processing, the nature of the data involved, existing legal and contractual obligations, the rights of data subjects and the technical limitations of the environment used.
DATA PROTECTION OFFICER
This section governs data protection officer in accordance with the Brazilian General Data Protection Law (LGPD) and other applicable rules.
ADDON may request additional information to confirm the identity of the requester or the authority of a legal representative, in order to prevent fraud, improper exposure of data or the handling of fraudulent requests.
The following points, among others, may be observed:
- Collection limited to what is necessary
- Legitimate purpose
- Appropriate legal basis
- Access control
- Information security
- Proportionate retention
- Deletion where appropriate
- Transparency toward the data subject
CONTACT CHANNELS
This section governs contact channels within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
COMMUNICATION WITH COMPETENT AUTHORITIES
This section governs communication with competent authorities within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Operational communications
- Security notices
- Contractual messages
- Technical support
- Service updates
- Authorized corporate communications
- Opt-out from promotional communications
- Keeping contact details up to date
RESPONSIBILITY FOR INFORMATION PROVIDED BY THE USER
This section addresses responsibility for information provided by the user in the context of services provided by ADDON and information entered, submitted, imported or made available by clients and users.
The client or user is responsible for the truthfulness, lawfulness, accuracy and adequacy of the information provided, as well as for having a lawful basis for processing third-party data where applicable.
The following points, among others, may be observed:
- Provide truthful information
- Keep data up to date
- Use the services lawfully
- Respect third-party rights
- Protect credentials
- Report relevant failures
- Validate functionality
- Comply with contractual obligations
LIMITATION OF LIABILITY REGARDING PRIVACY
This section governs limitation of liability regarding privacy within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
COMMITMENT TO PRIVACY AND SECURITY
This section establishes measures and guidelines relating to commitment to privacy and security, applicable to ADDON's technology environments, systems, applications, APIs, databases and digital services.
ADDON will adopt reasonable technical, administrative and organizational measures to protect personal data against unauthorized access, destruction, loss, alteration, improper disclosure, leakage, inappropriate processing or any form of unlawful use.
The following points, among others, may be observed:
- Access control
- User authentication
- Encryption where applicable
- Log monitoring
- Backups when contracted
- Incident response
- Permission review
- Continuous improvement
INTERPRETATION OF THIS POLICY
This section governs interpretation of this policy within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
The application of this provision must take into account the specific purpose of the processing, the nature of the data involved, existing legal and contractual obligations, the rights of data subjects and the technical limitations of the environment used.
APPLICABLE LAW AND JURISDICTION
This section governs applicable law and jurisdiction within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
The application of this provision must take into account the specific purpose of the processing, the nature of the data involved, existing legal and contractual obligations, the rights of data subjects and the technical limitations of the environment used.
FINAL PROVISIONS
This section governs final provisions within ADDON's websites, systems, applications, APIs, automations, platforms and technology services.
Where personal data is processed, the processing will observe legitimate purpose, necessity, adequacy, transparency, security, prevention, accountability and the other principles set out in applicable law.
The following points, among others, may be observed:
- Specific purpose
- Operational necessity
- Compatibility with the contract
- Good faith
- Transparency
- Security
- Responsibility of the parties
- Compliance with applicable law
The application of this provision must take into account the specific purpose of the processing, the nature of the data involved, existing legal and contractual obligations, the rights of data subjects and the technical limitations of the environment used.