Privacy policy

Find out how we treat your data while navigating on our website.

Pismo Soluções Tecnologicas Ltda. (“Pismo”) is committed to respecting your privacy and has prepared this privacy policy (“Policy”) to explain what Data is collected and how it is processed by Pismo.

PLEASE READ THE POLICY BELOW CAREFULLY. IT DESCRIBES HOW WE PROCESS THE PERSONAL DATA PROVIDED BY YOU OR COLLECTED BY PISMO WHEN YOU ACCESS OR USE THE WEBSITES, PRODUCTS, AND SERVICES. For this Policy’s purposes, “Users” are all individuals that use Pismo Website in any way.

The website (“Website”) may be accessed at https://pismo.io

We do not collect or knowingly request data from minors under the age of 18 (eighteen), except when hiring trainees under this age. Users under the age of 18 (eighteen) must not send us data through our Website. If we learn that we collected data from an individual under the age of 18 (eighteen) other than a candidate for the trainee program, we will disregard the data provided and will not keep it on our database.

For proper use of the Website, we need to have access to certain personal data about you (collectively, the “Data”).

This Policy explains, in a simple, objective, and transparent manner, which Data are collected and processed by Pismo, its purposes, with whom it may be shared, and what resources are available for users to manage the Data.

What this Policy covers:

1. What Data do we collect and process
2. Why do we collect and process these Data
3. When we delete your Data
4. Who else has access to the Data and why
5. What are your rights with respect to these Data
6. How we store and protect your Data
7. Do you need to provide your consent for Pismo to use your Data as described
in this Policy?
8. Website of third parties
9. Changes to this Policy
10. How to make a complaint

According to Law No. 13,709 of 2018, Pismo is considered the “Controller”

According to Law No. 13,709 of 2018, Pismo is considered the “Controller” of your Data. After
reading this Policy, if you still have any questions or, for any reason, need to contact us for matters – 3 –
involving your Data, please, use the channel below:
Data Protection Officer (“DPO”): Thiago Nunes Lopes
DPO’s email address: dpo@pismo.io
Data subject Portal: https://portaldotitular.pismo.io

  1. What Data we collect and process
    Pismo receives or collects only the following types of information related to the Users: (1) data for
    registration purposes of prospective customers who wish to use the products and/or services of
    Pismo; (2) data of job applicants; and (3) data of visitors or users of our website.

    1.1. Data for registration purposes:
    Data provided by Users on the Website for contact purposes,
    before using the services:
    full name;
    • email address;
    • telephone number;
    • company; and
    • position in the company.

    1.2 Data of job applicants

• name;
• email address;
• telephone number;
• birth date;
• gender;
• parents’ names;
• RG and CPF number;
• address;
• profession and expertise;
• education;
• professional experience; and
• salary expectations

1.3. Data of Device:
Data collected through technologies such as cookies, pixels, and beacons when Users interact with the Website, such as:

• technical data, such as URL information;
• cookie data;
• your IP address;
• browser type;
• browser language;
• date and time of request;
• device attributes;- 4 –
• type of network connection;
• data that allows the management of digital copyrights;
• the operating system; and
• geolocation

  1. Why we collect and process these Data
    We use User Data for the following purposes:

Data for Registration Purposes
• Respond to customer service requests;
• Conduct research and analysis;
• Comply with legal and/or regulatory requirements;
• Respond to questions and concerns;
• To contact the User (by email, mail, text messages and/or telephone) about several matters, including the use of the Website and/or to carry out customer satisfaction surveys;
• To send messages with information and offers about products or services that may be interesting for the User;
• For advertising and marketing; and
• To generate knowledge, innovate, and/or develop new products.

Data of Job Applicants
• To process job applications;
• To carry out the selection process; and
• To communicate with applicants or potential job applicants selected for vacancies.

Data of Device
• To ensure the correct functioning of our services to support our customers’ analytical efforts.
• Manage and improve our Website, our web resources, as well as simplify the interaction with User.
• To comply with legal obligations;
• To help us understand your patterns of use of our Website and improve it;
• To recommend to User services or features of the Website, and even third-party services, which may be interesting to User.

We do not use User Data for any purposes other than those described above.

  1. When we delete your Data
    We structure the Website and our activities to avoid that your Data be retained in an identified
    manner for longer than necessary. In other words, we keep your Data only during the time
    necessary for the accomplishment of the purposes described above, for compliance with the
    requirements set forth by law or for the regular exercise of our rights.
    We may keep Data anonymously, that is, without it being related to a User, for longer periods.
    The data we collect about the IP address of Users of the page and about the logs of access of
    the registered Users is stored for at least six (6) months, as established by article 15 of Law No.
    12,965 of 2014 (Brazilian Internet Law ).

  2. Who else has access to the Data and why
    We do not sell or market your Data. However, we may from time to time share your Data with the
    third parties identified below.
    Some of these third parties may be located abroad. If your Data is transferred to another country,
    we will take the measures required by law to ensure its protection, but please keep in mind that
    when using our Website and providing us with your Data such Data may be sent to other
    countries
Third-PartyType of Data SharedSharing Purpose
Other Pismo Group companies• Data for registration purposes
• Data of Device
• Marketing, prospecting, researches of market, opinion, and promotion of our products and services;
• Prevention and resolution of technical or security problems; and
• Compliance with legal or regulatory obligation
Pismo Service Providers• Data for registration
purposes
• Data of Job Applicants
• Data of Devic
• Improvement of our services, website and application and operation of new products or services
• Processing and analysis of job applications; and
• Prevention and resolution of technical or security issues
Judicial, police or governmental authorities or other third parties with
whom we are required by law, rule, or court order to share Data
• Data for registration
purposes
• Receivables Data
• Data of Device
• Compliance with a court order, competent authority or supervision
body; and
• Compliance with a legal or regulatory obligation
In case of sale or transfer of part or the entire business, operation, or services provided by us to a third party, in case of corporate restructuring, we reserve the right to disclose your Personal Data to the potential purchaser before or after the sale.• Data for registration purposes
• Receivables Data
• Data of Device
• For purposes of due diligence or carrying out of the transaction.
  1. What are your rights with respect to these Data
    Pursuant to the General Data Protection Law (Law 13,709 of 2018 – “LGPD”), you have the right to:

    • Obtain confirmation that we process your Data. In response to this request, we will
    inform you if we process your Data or not. Note that, if you are our customer (User), we
    necessarily process your Data, as explained in this Policy.
    • Access your Data. If you are interested, you can receive a report in which we present the
    Data held by you that are processed by us.
    • Rectify incomplete, inaccurate or outdated Data. If you consider that your Data are
    incorrect, you can request the rectification, indicating what needs to be changed and why.
    It is possible that we request a proof to make this change.

• Request the anonymization, blocking or erasure of Data deemed unnecessary,
excessive or processed in breach of the LGPD. If you consider that we are processing
your Data in an unnecessary and excessive manner or in breach of the LGPD, you can
request that the Data be anonymized, blocked or erased.
• Request portability of your Data to another service or product supplier, with due
regard for our trade and industrial secrets, according to the regulation to be issued
by the National Data Protection Authority (“ANPD”). You are the owner of your own
Data. Therefore, you can request that these Data be transferred to another service or
product supplier, according to ANPD’s regulation, provided that the trade and industrial
secrets are respected.
• Request erasure of Data processed on the basis of your consent, except in the
events of retention of Data prescribed by law. If your Data are processed based on
consent, you may request the erasure of these data. However, the LGPD authorizes the
preservation of data for fulfillment of legal or regulatory obligations; studies conducted by
research bodies, ensuring, if possible, the anonymization; transfer to a third party and
exclusive use by the controller, to the extent that the data be anonymized.
• Obtain information about the entities with whom we share your Data. You can
request that we inform with which entities we share your Data.
• Obtain information about the possibility of refusing consent and the respective
consequences. When the consent is used as legal basis for the processing of personal
data, you are entitled to be informed about the possibility of refusing consent and the
consequence of such refusal.
• Withdraw your consent to the processing of your Data. If your Data are processed
based on consent, you can withdraw this consent. With that, any processing of your Data
that is made based on consent will be interrupted.
• Object the processing that violates the LGPD. If you consider that we are processing
your Data in violation of the LGPD, you can object this processing. The request will be
carefully reviewed and, if we agree, the processing of your Data that is in breach of the
LGPD will be interrupted.
• Request the revision of decisions taken solely based on the automated processing
of your Data. It is possible that decisions are taken based in the automated processing
of your Data. If this happens, you can request the revision of these decisions.
• File a petition regarding your Data with the National Data Protection Authority. If you
consider it necessary, you can file a petition regarding your Data with the ANPD.

You can exercise any of the above rights through our data subject portal
https://portaldotitular.pismo.io, or by sending an e-mail to dpo@pismo.io.
Before answering a request for exercise of the abovementioned rights, we can request that you
provide us with some information to confirm your identity.

  1. How we store and protect your Data
    We store your Data in a secure manner in third-party data centers located in Brazil, in the United
    States and Europe. We currently contract data center services provided by cloud computing
    service operators. Before sending your Data for storage in other countries, we adopt the measures required by law to ensure that they will be protected accordingly.

The security of your information is of utmost importance to us. We have in place the best technical
and administrative practices to protect the Data against unauthorized access, destruction, loss,
alteration, communication or any inadequate or unlawful processing.
Nevertheless, no platform is completely secure. If you have any concern or suspicion that your
Data are at risk, for example, if someone had access to your password, please contact us
immediately.

  1. Do you need to provide your consent for Pismo to use your Data as described in this Policy?
    LGPD establishes several situations in which processing of personal Data is allowed regardless
    of the consent of the data subject. These are the so-called “legal bases for processing of Data.”
    This means that, if you choose to use our resources, in some cases we may collect and process
    your Data without your consent (if there is a legal basis provided for in LGPD that allows us to do
    so), such as, for example, to perform measures prior to contracting or signing an agreement with
    you, to comply with legal and regulatory obligations, to exercise rights established in an
    agreement or required by judicial, administrative and arbitration proceedings, credit protection, to
    guarantee protection against fraud and security of the data subject, in the identification and
    authentication processes of registration in electronic systems, for the legitimate interests of Pismo
    or third parties, among others.
    In other cases, we may ask for your consent to use your Data. Please note that the revocation of
    your consent will obligate us to cease the processing of Data done exclusively based on your
    consent.
  1. Websites of third parties
    We may provide links to other websites on the Internet as a resource for our Users. Pismo is not
    responsible for these websites and content, and does not share, subscribe, monitor, validate or
    accept the way used for these websites or content storage tools to collect, process, and transfer
    your personal and private data. The data or content of such other websites are governed by the
    privacy statements of such other websites. We encourage you to check the privacy policies of
    said websites to be properly informed on how your personal data is used by other websites or
    other tools.
  2. Changes to this Policy
    We may change the provisions of this Policy at our discretion and at any time.
    Whenever this Policy is changed substantially, such changes will be valid, effective and binding
    after: (1) they are posted on Pismo website; (2) they are emailed to Users; and/or (3) they are
    informed to Users by any other means

Users must check the updated version of this Policy every time they visit our Website.

  1. How to make a complaint
    You may file a complaint through Pismo’s channel provided above.
    You may also send a message to the National Data Protection Authority.