Version: March 2023
The Policy clarifies the general conditions of collection, use, storage and other forms of treatment and protection of personal data in our Sitrad Pro software (“App”), in accordance with the Brazilian legislation currently in force regarding privacy and protection of personal data, including, but not limited to, Law No. 12,965, of April 23, 2014 and Decree No. 8,771, from May 11, 2016 (“Marco Civil da Internet”), to Law No. 13,709, of August 14, 2018 (“General Data Protection Law” or “LGPD”).
In order to maintain direct contact with you, Full Gauge has appointed a Personal Data Controller to administer a communication channel:
In charge: Gabriela Coelho
By using our App, you freely express, informed, unequivocal, express and complete your agreement with this Policy. We recommend that you read it carefully.
Download the Sitrad Pro software;
Register to use the Sitrad Pro software.
The processing of personal data (or processing data), means anyoperation carried out with such data:
Collection of your data
Personal data is information related to an identified or identifiable human person. The data relating to you, our Full Gauge customer, is a personal data.
When you download our software, Full Gauge plays the role of controller of the processing of your personal data, acting in accordance with applicable legislation and as described in this Policy.
Important: You are not obliged to provide us with your information, however, without granting certain information when it is requested, you will not be allowed access to some features. In addition to the data you provide to us, whenever you interact with our software, information will be collected automatically. Such information is generally not identifiable, however, when combined with other data generating the ability to associate with you, it will be treated by Full Gauge as personal data.
To the extent permitted by applicable law, Full Gauge may process the following personal data that you have informed us:
Purpose of the processing
Connection by ID
IP addresses of the computer and the public internet access network.
Allow remote connection by unique ID to the software.
Consent, Article 7, I and Legitimate Interest Article 7, IX; and article 10 I of Law 13.709/18.
Registration information: full name, e-mail, telephone, company where you work, country, state, city and origin of the contact.
Automatically collected: Operating system version and language, .Net version, Sitrod version, UUID, screen resolution, processor, amount of memory, available disk space, and registry key.
Perform the registration of the user to use the software.
Article 7, V of Law 13.709/18
Please note that the personal data listed above is collected by Full Gauge and subsequently processed only as necessary to achieve the purposes set forth herein.
We do not knowingly collect, store or otherwise process excessive or unnecessary personal data for the purpose for which it was collected, as well as data considered sensitive (those relating to your racial or ethnic origin, religious belief, political opinion, membership of a trade union or organization of a religious, philosophical or political nature, health or sexual orientation, as well as genetic data) and data of children and adolescents. As a result, we ask that you refrain from sharing such data with us. If we become aware that there has been an inadvertent collection and processing of this data, it will be deleted from our records.
The classification of the legal basis of the data stored and processed by Full Gauge has been listed in Section 4 according to the specific context in which we collect it.
In summary, the data handled by Full Gauge tends to be collected only:
Art. 7, I of Brazilian Law No. 13,709
With your consent.
Art. 7, II of Brazilian Law No. 13,709
To comply with legal or regulatory obligation.
Art. 7, IX of Brazilian Law No. 13,709
When the processing of personal data is in accordance with the legitimate interests of Full Gauge, always with attention to its interests related to data protection or fundamental freedoms and rights. There will also be a need to process your data to protect your interests or those of third parties.
Art. 7, V of Brazilian Law No. 13,709
When necessary for the execution of the contract or preliminary procedures related to the contract.
When necessary to achieve the purposes described in Section 2, Full Gauge may share your personal data with third parties listed below, aiming at the correct provision of the services offered, the security of storage of your personal data and a better experience with Full Gauge. Whenever carried out, the sharing of data will be carried out within the limits and purposes of our business, in accordance with the purpose of the processing of personal data and in accordance with what the applicable legislation authorizes. In this way, your data can be shared with:
Software hosting company
Third party company responsible for hosting the software.
Security service providers
Company responsible for ensuring the security of the information handled by Full Gauge.
Response to complaints, investigations, judicial measures and judicial proceedings, if requested, as well as comply with legal, regulatory and tax obligations.
The use and transfer of information received from the Google API to any other App will adhere to the Google API Services User Data Policy, including the requirements of the “Limited Use” item.
In the manner and within the limits of the applicable legislation, you, as the holder of personal data, may contact us to exercise your rights in order to request:
Confirmation and access
It allows you to confirm the existence of processing of personal data and, if so, request access to a copy of this data.
Allows you to request the correction of data that is incomplete, inaccurate, or outdated.
Anonymization, blocking, or deletion
It allows you to request the anonymization of your data (so that it can no longer be related to you), the blocking of your data (temporarily suspending our use) or deletion of your data (so that we can no longer be related to you), without reversal).
It allows us, upon express request, to deliver your personal data to another service or product provider, in a structured and interoperable format.
It allows you to know with which public and private entities we share your personal data.
Information about the possibility of not consenting
It allows you to have clear and complete information about the consequences of not providing your consent, i.e. you are free to deny consent, even though we may limit our deliveries to you.
Revocation of consent
It allows you to revoke your given consent, at any time, without affecting the lawfulness of the processing previously carried out.
It allows you to object to the processing of your personal data if you do not agree to the treatment.
Your request can be made free of charge through the e-mail email@example.com. We will review your request and attend to it as soon as possible, considering the deadlines and terms provided for in the applicable legislation. If it is not possible to immediately meet your request, we will indicate the reasons of fact and law that prevent us.
Full Gauge is not responsible for the correctness, veracity, authenticity, completeness and updating of the data provided by the Holder. It is the sole responsibility of the Owner to provide only correct, true, authentic, complete and up-to-date information.
Full Gauge adopts security, technical and administrative measures to keep all stored data secure, through internal guidelines, confidentiality clauses and with strict access control, with our employees having access to the data strictly necessary to meet the specific purposes, as exposed in Section 2. Specifically with respect to data collected through our software, it is stored, processed and protected through the best practices of hosting and processing.
Even so, the Owner must be aware that no Internet security system is guaranteed against unwanted intrusions, and Full Gauge’s commitment is limited to the adoption of recommended protection measures according to the current state of the art.
Full Gauge will carry out the international transfer of your data to other countries or international organizations only when strictly necessary to achieve the purpose that gave rise to the processing of your personal data, prioritizing, whenever possible, the storage on servers located in the Federative Republic of Brazil. When your personal data is transferred outside of Brazil by Full Gauge, we will take appropriate measures to ensure adequate protection of your personal data in accordance with the requirements of applicable data protection legislation, including through the conclusion of appropriate data transfer agreements with third parties where necessary.
We store and maintain your information: (i) for as long as required by law; (ii) until the end of the processing of personal data, as mentioned below; (iii) for the time necessary to preserve Full Gauge’s legitimate interest, as the case may be; (iv) for the time necessary to safeguard the regular exercise of Full Gauge’s rights in judicial, administrative or arbitral proceedings. Thus, we will process your data, for example, during the applicable limitation periods or as long as necessary to comply with a legal or regulatory obligation.
The termination of the processing of personal data will occur in the following cases:
Observing the principle of necessity, some data forwarded through the software can be deleted from our records through routine record keeping. We have no obligation to store personal data indefinitely and we disclaim any liability arising out of or related to the destruction of such personal data.
We seek to prevent the sending of unsolicited emails by restricting communications with you to matters that are relevant or of specific interest to you.
If you prefer not to receive further information from us, you can request your unsubscribe through the unsubscribe link contained in the email itself or in the message received (opt out), or request through our Site.
You should be aware that many fraudsters try to use recognized brands to obtain personal information such as passwords and financial data. Full Gauge WILL NEVER REQUEST YOUR FINANCIAL DATA THROUGH EMAIL OR TELEPHONE CONTACT. IN CASE OF ANY OTHER SUSPICIOUS ATTITUDE, FORWARD YOUR QUESTION OR ALERT BY EMAIL TO firstname.lastname@example.org.