1. INTRODUCTION
1.1 We at Cortex care about the privacy of your data. That is precisely why we are closely following 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 the rights of data subjects. This is an essential law, responsible for inserting Brazil into the global data protection sphere and specifically providing for rights and duties for all those who carry out personal data processing activities.
1.2 Therefore, as a leading company in the development of data intelligence solutions to boost the communication, marketing and sales sectors, we are committed to adopting the best measures and market practices so that our activities comply with the LGPD with regard to issues such as 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 gone through a complete process of adapting our activities to the LGPD, identifying all activities that involve the processing of personal data, carrying out assessments and adjusting our terms with suppliers and partners, including data protection as a key issue in our relationships, ensuring, as far as we are able, that we establish relationships with companies that adopt the best standards of diligence and adequacy under the LGPD.
1.4 Finally, we emphasize that, for our software solutions, we have adopted robust measures in order to guarantee integrity and quality during the processing of personal data.
2. ABOUT CORTEX
2.1 Cortex is a company that offers intelligent data-driven solutions for marketing, communication and sales to our partners. We value the quality of our services, using the most robust techniques for evaluating and creating solutions. Among the solutions we offer, our main objective is to boost the sales of contracting companies through marketing and communication strategies, especially using Cortex solutions. In addition, we are always looking for innovations in order to offer services with a high standard of efficiency that keep pace with market needs.
3. APPLICATION OF THIS PRIVACY NOTICE
3.1 By means of this document ("Privacy Notice" or "Notice"), data subjects will have access to all the possibilities for the processing of their personal data by Cortex when using the Cortex website and related services. We therefore 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, since in such cases you are accepting 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, CEP 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, holder of intellectual property on software, website, applications, content and other digital assets or not, related to Cortex products and services.
4. HOW CORTEX ACCESSES YOUR DATA AND FOR WHAT PURPOSES IT IS PROCESSED BY CORTEX
4.1 As controller, Cortex obtains your data through your interactions with Cortex's own website, as well as data made public. There are three main ways in which Cortex obtains your personal data:
4.1.1. browsing data: data on access to the Cortex website and other data collected while the data subject is using said website, such as data on IP address and other means, technical data, such as the computers, devices and appliances used, data related to communication tools made available on the Cortex website, the latitude/longitude data of the data subject's smartphone, type of network connection and performance of the provider, network and device used.
4.1.2 Data filled in by the data subject: made available in forms aimed at communication between data subjects and Cortex, such as for receiving a newsletter and downloading materials made available by Cortex, scheduling a conversation with Cortex or Cortex's chatbot, and also those made available by the data subject when participating in events organized by Cortex with partners. In these situations, we may collect data such as: first name; last name; professional e-mail; cell phone; name of the company in which the data subject works, its respective area and the company's sector of activity; as well as the hierarchical position held by the data subject.
4.1.3 Data made public: always respecting the applicable legislation, personal data whose access is public or which has been made manifestly public by its owner, including any sensitive data of public access, emphasizing that the processing of this data will always take into account the purpose, good faith and public interest that justified its availability.
4.2. Personal data is also processed for the following purposes:
4.2.1. sending content by filling in a form, subscribing to a newsletter and/or participating 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 data subjects who have consented to this.
4.2.4. contacting interested parties who wish to schedule a conversation with Cortex or offer our services to holders who have consented to this purpose, according to the form available on the Cortex website.
4.2.5 Allowing the use of cookies on the Cortex website in order to guarantee the operation of basic functionalities of its services and to generate statistics on their use.
4.3 Cortex guarantees that, whenever there is a need to process sensitive personal data, it will strictly comply with the authorizations and requirements imposed by the 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. to assist in the operation of Cortex (e.g. storage of data 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. to allow Cortex to enter into partnerships, insofar as the personal data is necessary for these partnerships, always within the strict limits authorized by law, and in accordance with the processing purposes and other precautions informed in this Notice.
5.1.3 Generating data on the functionalities and use of Cortex's services, which will be made available to its economic group, always within the strict limits authorized by legislation, and in accordance with the purposes of processing and other precautions informed in this Notice.
5.1.4 Analyzing and solving technical and other problems related to fraud and security of Cortex and its services.
5.1.5 Events with partners. When organizing events with its partners, the personal data of the participants of the event may, always respecting the applicable legislation, be shared with the co-organizing partners.
5.1.6. Other purposes, in the form and within the limits of the consent granted by the data subject (where necessary), and within the limits of what is permitted or required by applicable law.
6. STORAGE AND SECURITY OF PERSONAL DATA
6.1 When processing your data, Cortex will always endeavor to keep it secure. For this reason, Cortex undertakes to continuously implement physical, technical and administrative information security measures when processing your personal data. In this way, we seek to protect your personal data against unauthorized access, accidental or unlawful destruction, loss, alteration, communication or any form of improper or unlawful processing.
6.1.1 Cortex allows its employees to access your personal data only to the extent strictly necessary to carry out 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 information security practices will be based on: applicable legislation, best practices adopted in the market, and other Cortex internal policies related to the subject.
6.2 Cortex will retain your personal data only for the period necessary to achieve the purposes described in this Notice or for the periods provided for in the applicable legislation.
7. INTERNATIONAL TRANSFER OF DATA
7.1 Cortex, as a company aligned with the latest practices and technologies, may carry out international transfers of your personal data in order 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 undertakes to carry out international transfers of your data only on the basis of mechanisms permitted by the applicable legislation.
8. RIGHTS OF DATA SUBJECTS
8.1. Cortex will adopt appropriate technical and organizational measures to comply with its obligations in relation to your rights as a data subject. To this end, Cortex undertakes to make your rights, as provided by law, possible in the best possible way.
9. GENERAL PROVISIONS
9.1 This Privacy Notice is the valid and effective version of the information on the processing of your personal data by Cortex. This version is responsible for governing all instances in which Cortex processes your personal data.
9.2 Cortex may make additional information available to you about its personal data processing practices relating to certain services. This information may supplement or clarify Cortex's privacy practices or provide you with additional choices about how Cortex processes personal data. In any case, Cortex undertakes to follow 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 for any form of termination, for whatever reason, and will continue to produce their effects on the parties for 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 at the following e-mail address: [dpo@cortex-intelligence.com].
