1. Introduction

We take your privacy seriously and this Privacy Policy (“Policy”) sets out how LogAp Sistemas collects and uses personal information from customers and others (collectively, “you”) who access or use our websites, mobile applications, systems and/or any of our other websites, services or products (“Services”) linked to this Privacy Policy. By using our Services, you understand that we will collect and use your personal information as described in this Policy.

Your personal data (“Data”) are valuable assets and we at LogAp Sistemas know that they must be kept securely. Therefore, in this Policy, we will endeavor to make it very clear how and why we use your data.

We encourage you to read this entire Privacy Policy to ensure that you are fully informed.

2. Main concepts

2.1 What is the LGPD?
LGPD stands for the Brazilian General Data Protection Law (Law Nº. 13.709/2018). This Law provides for the processing of personal data, including in digital media, by a natural person or by a legal entity governed by public or private law, in order to protect the fundamental rights of freedom and privacy and the free development of the natural person’s personality.

2.2 What is personal data?
Personal Data is information that allows the identification, directly or indirectly, of an individual who is alive, for example: name, ID number, gender, date and place of birth and telephone number. Personal data on racial or ethnic origin, religious conviction, political opinion, affiliation to a union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a natural person are considered Sensitive Personal Data.

2.3 What are cookies?
Cookies are small files created by websites visited that are saved on the user’s computer, through the browser, and map their behavior. They serve to identify the user and their preferences, adjust the language once chosen by you, measure and analyze activity on the website for navigation improvements, display ads according to the profile specified by the user, among other functions.

3. How and what data do we collect?

Our website collects and uses some of your personal data, in order to enable the provision of services and improve the user experience.

3.1 By browsing the site
We automatically collect Data each time you browse our main domain (www.logap.com.br), subdomains or any other site that is part of our Services, fill out forms, post comments, participate in events or perform other interactions. The Data we collect in this case are: your approximate location (latitude and longitude), your IP address, your access device information (operating system type, device model), your internet connection information; type of your browser and the pages and content you access on our Services.

3.2 By registering in the form
We collect Data provided by you each time you register in any form available on our Services. The Data that we may request in this case are: full name, e-mail address, ID number, physical address and telephone number.

3.3 Through third parties
We may also automatically collect and use some of your Data through publicly available sources, service providers and our partners.

3.4 Through cookies
We may, through the use of cookies, automatically collect and identify Data such as: your visiting habits, your preferences, ad delivery and audience analysis.

– Which Data categories do we automatically collect?

Essential Cookies
Essential cookies are necessary for our Services to function, allowing you to browse our websites, platforms and use their services and features. Without these absolutely necessary cookies, the Services will not function as well as we would like, and we may not be able to provide certain Services or associated features. Examples of these cookies are: session, load balancing, user identification, security.

Preferences Cookies
Preference cookies collect information about your choices and preferences, enabling us to remember your language or other local settings, and customize the Services accordingly. Examples of these cookies are: language, location, mobile, referring website, last visit and activity, page history.

Marketing Cookies
Advertising and targeting cookies collect information about your activities on our Services and other websites to deliver targeted advertising. We may also allow our third party service providers to use cookies on our website for the same purposes identified above. Third party service providers that generate these cookies, such as: Google, Facebook, among others, have their own privacy policies and may use their cookies to target advertising for you on other websites based on your visit to our platform.

Analytical Cookies
Analytical cookies collect information about the use of the Services, enabling us to improve the way they work. For example, analytical cookies show us which pages are most visited on the websites, help us to record any difficulties users experience in navigating the Website, and show us whether our advertising is effective or not. This makes it possible to see global patterns of usage of the Services rather than a single person usage. Examples of these cookies are: Google Analytics, Google Optimize, Google Tag Manager.

– Use of third-party cookies

“Third Party Cookies” are cookies that third parties place on your device through our platform, with the purpose of helping us measure and improve the effectiveness of our communications. Service providers, with our permission, may use their own cookies on the Services. Such cookies will collect your Data on our properties for the purposes set out in this policy.

For more information on how these companies collect and use information on our behalf, see their respective privacy policies at: Google and Facebook.

– What cookies do we use?

Name: Facebook Ads
Provider: Facebook
Purpose: Announcements
Validity: We do not have individual data
Type: Marketing

Name: Google Ads
Provider: Google
Purpose: Announcements
Validity: We do not have individual data
Type: Marketing

Name: Google Analytics
Provider: Google
Purpose: Statistics
Validity: We do not have individual data
Type: Analytical

Name: Google Optimize
Provider: Google
Purpose: Statistics
Validity: We do not have individual data
Type: Analytical

Name: Google Tag Manager
Provider: Google
Purpose: Statistics
Validity: We do not have individual data
Type: Analytical

– How do I change or block cookies?

You are free to change your browser’s cookie settings at any time, choosing to block or be alerted when a cookie is being sent to your device.

You can block cookies from a specific website, block third-party cookies in relation to a website, or block all cookies. But beware: blocking all cookies will affect your experience on various services, as it will not be possible to identify your preferences on the platform, nor recommend relevant content and advertising.

To learn more about cookie settings, see your browser instructions: Internet Explorer, Edge, Chrome, Safari, Firefox and Opera.

4. For what purpose do we collect and use your data?.

We collect your Data to: provide personalized services to you, communicate with you in a personalized way, improve and develop our Services, and comply with legal obligations.

It is through this Data that we deliver differentiated content, direct our Services, prevent suspicious activities, improve our technical and operational service as quickly as possible.

4.1. Consent
It is from your consent that we process your Data. Consent is the free, informed and unambiguous expression by which you authorize LogAp Sistemas to process your data.

Thus, in accordance with the LGPD (Lei Geral de Proteção de Dados), your data will only be collected, processed and stored with prior and express consent. Your consent will be specifically obtained for each purpose described above, evidencing LogAp Sistemas’ commitment to transparency and good faith towards its users/clients, following the relevant legislative regulations.

By using our Services and providing your Data, you are aware of and consent to the provisions of this Privacy Policy, in addition to knowing your rights and how to exercise them.

At any time and at no cost, you may revoke your consent.

It is important to highlight that the revocation of consent for data processing may imply the impossibility of the proper performance of some functionality of the website that depends on the operation. Such consequences will be informed in advance.

5. What are your rights?

LogAp Sistemas assures its users/clients their rights as holders provided for in article 18 of the LGPD, the Brazilian General Data Protection Law. This way, you can, for free and at any time:

– Confirm the existence of data processing, in a simplified way or in a clear and complete format.
– Access your data, being able to request them in a legible copy in printed form or electronically, secure and reputable.
– Correct your data, when requesting the editing, correction or update of these.
– Limit your data when unnecessary, excessive or treated in violation of the law through anonymization, blocking or deletion.
– Request the portability of your data, through a report of registration data that LogAp Sistemas handles about you.
– Delete your processed data with your consent, except as provided by law.
– Revoke your consent, disallowing the processing of your data.
– Inform yourself about the possibility of not giving your consent and about the consequences of denial.

To exercise your rights as a holder, you must contact LogAp Sistemas via e-mail: [email protected]

In order to guarantee your correct identification as the holder of the personal data that are the object of the request, we may request documents or other proof that may prove your identity. In this case, you will be informed in advance.

6. How and for how long will your data be stored?

Your personal data collected by LogAp Sistemas will be used and stored for the time necessary to provide the service or for the purposes listed in this Privacy Policy to be achieved, considering the rights of data subjects and controllers.

In general, your data will be kept for as long as the contractual relationship between you and LogAp Sistemas lasts. Once the Data storage period ends, they will be deleted from our databases or anonymized, except in the cases legally provided for in Article 16 of LGPD (Brazilian General Data Protection Law), namely:

I – compliance with a legal or regulatory obligation by the controller;
II – study by a research body, ensuring, whenever possible, the anonymization of personal data;
III – transfer to a third party, provided that the data processing requirements set out in this Law are respected; or
IV – exclusive use of the controller, its access by a third party being prohibited, and provided that the data is anonymized.

Personal information about you that is essential for the fulfillment of legal, judicial and administrative determinations and/or for the exercise of the right of defense in judicial and administrative proceedings will be kept, despite the exclusion of other data.

If you request the update, correction or even the deletion of your Data, LogAp Sistemas will respond to the request within 15 days.

The storage of data collected by LogAp Sistemas reflects our commitment to the security and privacy of your data. We employ technical protection measures and solutions capable of guaranteeing the confidentiality, integrity and inviolability of your data. In addition, we also have security measures appropriate to the risks and access control to stored information.

7. What do we do to keep your data safe?

To keep your personal information secure, we use physical, electronic and management tools aimed at protecting your privacy.

We apply these tools taking into account the nature of the personal data collected, the context and purpose of the processing and the risks that any violations would generate for the rights and freedoms of the holder of the data collected and processed.

Among the measures we have adopted, we highlight the following:

– Only authorized people have access to your personal data.
– Access to your personal data is only made after the commitment to confidentiality.
– Your personal data is stored in a safe and sound environment.

LogAp Sistemas is committed to adopting the best postures to avoid security incidents. However, it is necessary to emphasize that no virtual page is entirely safe and risk-free. It is possible that, despite all our security protocols, problems that are exclusively of third parties may occur, such as cyber attacks by hackers, or also due to the negligence or recklessness of the user/customer.

In the event of security incidents that may generate relevant risk or damage for you or any of our users/customers, we will communicate to those affected and the National Data Protection Authority about what happened, in accordance with the provisions of the LGPD (Brazilian General Law for the Protection of Data).

8. Who can your data be shared with?

In order to preserve your privacy, LogAp Sistemas will not share your personal data with any unauthorized third party.

They receive their Data only to the extent necessary for the provision of the contracted Services and our contracts are guided by the data protection rules of the Brazilian legal system.

In addition, there are also other hypotheses in which your data can be shared, which are:

I – Legal determination, application, requisition or court order, with competent judicial, administrative or governmental authorities.
II – Case of corporate changes, such as mergers, acquisitions and incorporations, automatically.
III – Protection of LogAp Sistemas’ rights in any type of conflict, including those of a judicial nature.

8.1 International Data Transfer
Some of the third parties with whom we share your Data may be located or have facilities located in foreign countries. Under these conditions, in any case, your personal data will be subject to the LGPD (Brazilian General Data Protection Law) and other Brazilian data protection legislation.

In this sense, LogAp Sistemas is committed to always adopting efficient cybersecurity and data protection standards, in the best efforts to guarantee and comply with legislative requirements.

By agreeing to this Privacy Policy, you agree to this sharing, which will take place in accordance with the purposes described in this instrument.

9. Changes to this Privacy Policy

The current version of the Privacy Policy was formulated and last updated on: May 8, 2021.

We reserve the right to modify this Privacy Policy at any time, mainly depending on the adequacy of any changes made to our website or in the legislative framework. We recommend that you review it frequently.

Any changes will take effect as of their publication on our website and we will always notify you of any changes that have occurred.

By using our services and providing your personal data after such modifications, you consent to them.

10. Responsibility

LogAp Sistemas provides for the responsibility of agents who work in the Data processing processes, in accordance with Articles 42 to 45 of the LGPD (Brazilian General Data Protection Law).

We are committed to keeping this Privacy Policy updated, observing its provisions and ensuring compliance with it.

In addition, we are also committed to seeking technical and organizational conditions that are surely able to protect the entire Data processing process.

If the National Data Protection Authority requires the adoption of measures in relation to the processing of Data carried out by LogAp Sistemas, we undertake to follow them.

10.1 Disclaimer
As mentioned in Topic 6, although we adopt high security standards in order to avoid incidents, there is no virtual page that is entirely risk-free. In this sense, LogAp Sistemas is not responsible for:

I – Any consequences arising from the negligence, recklessness or malpractice of users in relation to their individual data. We guarantee and are only responsible for the security of the data processing processes and the fulfillment of the purposes described in this instrument.

We emphasize that the user is responsible for the confidentiality of access data.

II – Malicious third-party actions, such as hacker attacks, unless proven guilty or deliberate conduct by LogAp Sistemas.

We emphasize that in case of security incidents that may generate relevant risk or damage to you or any of our users/customers, we will communicate to those affected and the National Data Protection Authority about what happened and we will take the necessary steps.

III – Inaccuracy of the information entered by the user/client in the records necessary for the use of LogAp Sistemas’ services; any consequences arising from false information or entered in bad faith are entirely the responsibility of the user/customer.

11. Our contact

LogAp Sistemas provides the following means for you to contact us to exercise your rights as a holder: [email protected].

If you have any questions about this Privacy Policy or about the personal data we handle, you can contact our Personal Data Protection Officer, through the following channels:

LogAp Sistemas support team: [email protected]