Privacy Notice | Cortex Website

  1. 1. INTRODUCTION

    1.1. We at Cortex care about the privacy of your data. For this reason, we closely monitor the development and progress of data protection legislation in Brazil, especially through Law No. 13,709/2018 ("General Data Protection Law" or "LGPD"), which regulates the subject in the country and guarantees rights to data subjects. This is an essential law, responsible for placing Brazil within the global scope of data protection and specifically providing for the rights and duties of all those who perform personal data processing activities.

    1.2. As a leading company in the development of data intelligence solutions to boost communication, marketing, and sales sectors, we are committed to adopting the best market measures and practices to ensure our activities comply with the LGPD regarding privacy, data protection, and information security, so that all data processed by us or our partners is properly maintained.

    1.3. To this end, we have undergone a comprehensive process of adapting our activities to the LGPD, identifying all activities involving the processing of personal data, conducting assessments, and adjusting our terms with suppliers and partners. We include data protection as a key theme in our relationships, ensuring, to the extent possible, that we establish relationships with companies that adopt the highest standards of diligence and compliance under the LGPD.

    1.4. Finally, we emphasize that for our software solutions, we adopt robust measures to ensure integrity and quality during the processing of personal data.

    2. ABOUT CORTEX

    2.1. Cortex is a company that offers intelligent data-based solutions for marketing, communication, and sales intended for our partners. We value the quality of our services, using the most robust techniques for evaluation and solution creation. Among the solutions offered, our central objective is to boost the sales of contracting companies through marketing and communication strategies, especially through Cortex solutions. Furthermore, we are constantly seeking innovations to offer high-standard efficiency services that keep pace with market needs.

    3. APPLICATION OF THIS PRIVACY NOTICE

    3.1. Through this document ("Privacy Notice" or "Notice"), data subjects will have access to all possibilities for the processing of their personal data by Cortex when using the Cortex website and related services. Therefore, we recommend that you read this Privacy Notice carefully. If you do not agree with the provisions of this Notice, we recommend that you do not use the Cortex website or its services, as usage in these cases will constitute acceptance of the terms described herein.

    3.2. This Notice describes what information is collected by Cortex Intelligence Tecnologia Ltda., a limited liability company, domiciled in the city and State of São Paulo, at Avenida Paulo VI, No. 621, Sumaré, ZIP 01262-010, registered with the CNPJ/MF under No. 06.068.735/0002-14, holder of municipal registration No. 4.626.712-3, but exempt from state registration, owner of intellectual property over software, website, applications, content, and other digital or non-digital assets related to Cortex products and services.

    4. HOW CORTEX ACCESSES YOUR DATA AND FOR WHAT PURPOSES THEY ARE PROCESSED

    4.1. As a controller, Cortex obtains your data through your interactions with the Cortex website, as well as from data made public. There are three central ways through which Cortex obtains your personal data:

    • 4.1.1. Browsing data: data about access to the Cortex website and other data collected while the subject uses the said site, such as IP address data and other means, technical data such as computers and devices used, data related to communication tools available on the Cortex website, the latitude/longitude data of the subject's smartphone, network connection type, and the performance of the provider, network, and device used.
    • 4.1.2. Data provided by the subject: provided in forms intended for communication between subjects and Cortex, such as for receiving newsletters and downloading materials provided by Cortex, scheduling a conversation with Cortex or the Cortex chatbot, and those provided by the subject when participating in events organized by Cortex with partners. In these situations, we may collect data such as: first name; last name; professional email; mobile phone; name of the company where the subject works, its respective area and sector; and the hierarchical position held by the subject.
    • 4.1.3. Reputation Analysis: performing analysis regarding reputation, the impact of actions, products, brand, and other elements, as well as verifying impressions about Partners, especially on social media; any processing performed by Cortex is done only according to Partner instructions.
    • 4.1.4. Publicly available data: always respecting applicable legislation, personal data to which access is public or which has been made manifestly public by its subject, including any sensitive data in the public domain, emphasizing that the processing of such data will always consider the purpose, good faith, and public interest that justified its availability.

    4.2. Furthermore, the processing of personal data is carried out for the following purposes:

    • 4.2.1. Sending content upon completion of a form, newsletter subscription, and/or participation in events organized by Cortex with partners.
    • 4.2.2. Carrying out marketing campaigns on social networks and targeted marketing campaigns.
    • 4.2.3. Presenting personalized content on the Cortex website to subjects who have consented to this purpose.
    • 4.2.4. Contacting interested parties who wish to schedule a conversation with Cortex or offering our services to subjects who have consented to this purpose, as per the form available on the Cortex website.
    • 4.2.5. Allowing the use of cookies on the Cortex website to ensure the functioning of basic service features and generate statistics on their use.

    4.3. Cortex ensures that whenever there is a need to process sensitive personal data, it will strictly comply with the authorizations and requirements imposed by applicable personal data protection legislation.

    5. WITH WHOM WE SHARE PERSONAL DATA

    5.1. In cases where it is necessary for the operation of our website or the provision of our services, within the limits of applicable legislation, Cortex may share your personal data with third parties. This sharing will seek to achieve the following purposes:

    • 5.1.1. Assisting in Cortex operations (e.g., data storage in third-party cloud services), always within the strict limits authorized by legislation, and according to the processing purposes and precautions informed in this Notice.
    • 5.1.2. Allowing Cortex to enter into partnerships, to the extent that personal data is necessary for the completion of these partnerships, always within the strict limits authorized by legislation, and in accordance with the processing purposes and other precautions informed in this Notice.
    • 5.1.3. Generating data regarding the features and use of Cortex services, which will be made available to its economic group, always within the strict limits authorized by legislation, and according to the processing purposes and other precautions informed in this Notice.
    • 5.1.4. Analyzing and solving technical problems and others related to fraud and the security of Cortex and its services.
    • 5.1.5. Events with partners: When organizing events with its partners, the personal data of event participants may, always respecting applicable legislation, be shared with co-organizing partners.
    • 5.1.6. Other purposes, in the form and within the limits of the consent granted by the subject (when necessary), and within the limits of what is permitted or required by applicable legislation.

    6. STORAGE AND SECURITY OF PERSONAL DATA

    6.1. When processing your data, Cortex will always strive to keep it secure. For this reason, Cortex commits to continuously implementing physical, technical, and administrative information security measures in the processing of your personal data. We thus seek to protect your personal data against unauthorized access, accidental or unlawful situations of destruction, loss, alteration, communication, or any form of inappropriate or unlawful processing.

    • 6.1.1. Cortex allows your personal data to be accessed by its employees only to the extent strictly necessary to perform their activities, in accordance with express instructions and under a contractual obligation of secrecy and confidentiality of the personal data processed.
    • 6.1.2. Cortex's practices regarding information security will be based on: applicable legislation, best market practices, and other internal Cortex policies related to the subject.

    6.2. Cortex will retain your personal data only for the period necessary to achieve the objectives described in this Notice or for the periods stipulated in applicable legislation.

    7. INTERNATIONAL DATA TRANSFER

    7.1. Cortex, as a company aligned with the most current practices and technologies, may perform international transfers of your personal data to enable the development of some of the activities indicated in this Notice (e.g., data storage in cloud services with servers located abroad). Cortex commits to performing international transfers of your data only based on mechanisms permitted by applicable legislation.

    8. DATA SUBJECT RIGHTS

    8.1. Cortex will adopt appropriate technical and organizational measures to fulfill its obligations regarding your rights as a personal data subject. In this regard, Cortex commits to facilitating your rights as provided by law in the best possible way.

    9. GENERAL PROVISIONS

    9.1. This Privacy Notice consists of the valid and effective version of the information about the processing of your personal data by Cortex. This version governs all instances in which Cortex processes your personal data.

    9.2. Cortex may provide additional information to you about its personal data processing practices related to certain services. This information may complement or clarify Cortex's privacy practices or provide you with additional choices about how Cortex processes personal data. In any case, Cortex commits to following the legal and regulatory obligations applicable to the processing of personal data, as well as the agreements entered into with its Partners and Suppliers.

    9.3. The clauses of this Privacy Notice will remain in force upon any form of termination, occurring for any reason, continuing to produce their effects on the parties as long as there are subsequent legal relationships.

    9.4. If you wish to exercise any of the rights provided for in this Privacy Notice or have any questions about this document and the practices described herein, you should contact Cortex via the following email: dpo@cortex-intelligence.com.