Sales Journey Privacy Policy

Last updated: 04/08/2023

This Privacy Policy describes the practices and procedures adopted by SALES JOURNEY for the collection, storage, use, processing, sharing, and disposal of user information obtained through the SALES JOURNEY Platform.By using the platform, the user hereby declares that they have read this document and the Terms of Use in full and with attention, being fully aware and thus expressing their free and explicit agreement with the terms stipulated herein. If you do not agree with these Privacy Policies, you should discontinue your access to the Platform.

I. Information Collected

SALES JOURNEY will collect data that the user of the Platform voluntarily provides for their access to the Platform and records of information generated when the user or a visitor accesses or uses the SALES JOURNEY Platform.

SALES JOURNEY declares that it collects and processes data through the channels listed below:

(a) Data voluntarily provided by the data subject or their representative for Account registration and Service contracting: SALES JOURNEY promotes the collection and processing of personal data from users as necessary for their registration on the Platform, such as name, email address, telephone contact, and financial data, such as those related to the payment methods used to contract a service plan;

(b) Information collected during the use of the Platform: SALES JOURNEY also collects and processes data related to:

(i) Access and usage data: SALES JOURNEY may collect and process user data related to their access and usage of the Platform and Services, such as: type of plan contracted; user information with the Services, as well as the date and time of any access, including the Services used, the Content published in the Client's Account, the configuration and change in the configuration of the Services, and may include information related to or resulting from the use of Third-Party Software.

(ii) Technical data: SALES JOURNEY may collect and process certain technical data from the user and their interaction with the Platform, such as URL information, cookie data, the user's IP address, geolocation, the type of device used to access or connect to the Platform, device identification, device attributes, network connection type (e.g., Wi-Fi, 3G, LTE, Bluetooth) and network provider, network and device performance, browser type, language, information enabling the management of digital rights, operating system, and SALES JOURNEY version.

SALES JOURNEY is not responsible for the accuracy, truthfulness, or lack thereof in the information that the user provides to SALES JOURNEY or for its updating, and it is the user's responsibility to provide them accurately or update them.

II. Purpose

The SALES JOURNEY will process the data collected in accordance with item I above, in compliance with Brazilian data protection legislation and strictly for the following purposes:

• Provide, personalize, and improve the user experience with the Services offered by the Platform, and with other services and products provided by SALES JOURNEY (for example, by providing personalized, individualized, or tailored services based on their location or interests, recommendations, and functionalities);

• Understand how the user accesses the Services to ensure their technical functionality, develop new products and services, and analyze the user's use of the Platform, including their interaction with applications, products, and services that are made available, offered, or connected through the Platform;

• Allow the execution of contractual obligations established by SALES JOURNEY with the user, including the provision of customer service, support, training, data hosting, report generation, etc...;

• Process billing and other matters related to contract management;

• Provide user authentication and other measures to prevent fraud against the user, the Platform, and third parties;

• Send notifications and alerts about the Services;

• Send communications to the user, directly or through partners, for purposes of marketing, research, participation in contests, quizzes, promotions via emails, notifications, or other messages, according to any authorizations eventually transmitted by the user (for example, through the user's account settings page);

• Provide the user with functionalities, updates, pricing and hiring policies, advertising, or other content based on the user's location and specific interests.The consent that the user provides for the purposes of data use is collected individually, clearly, specifically, and legitimately.

III. Information Security

The SALES JOURNEY will store the collected information on the Platform on its own servers or those contracted by it, with the commitment to comply with confidentiality provisions in this regard:

a) The SALES JOURNEY adopts appropriate technological measures to meet legally required standards for preserving the privacy of data collected on its Platform, such as:

(i) The SALES JOURNEY has protection against unauthorized access by third parties to its systems;

(ii) The SALES JOURNEY controls access to the collected information by employees and third-party professionals who have formally committed to maintaining its confidentiality, and their access is guided by the principles of proportionality, necessity, and relevance, aiming to preserve privacy in accordance with this Policy;

b) The SALES JOURNEY will make its best efforts to preserve the privacy of user data. However, no solution is entirely secure, and the SALES JOURNEY cannot guarantee fully that all information traveling on the Platform will not be subject to unauthorized access perpetrated through methods developed to obtain information improperly. For this reason, the user should also take appropriate measures to protect their information, including, but not limited to, maintaining the confidentiality of all Access Data.

IV. Sharing

(a) SALES JOURNEY will not share user data with third parties without the user's consent, except (i) as necessary to comply with user instructions and requests; (ii) to the extent necessary to enable the functionality of the contracted SALES JOURNEY services, subject to items
(b) and (c) below; (iii) to comply with court orders under applicable law, or in legal proceedings to establish or exercise legal rights or defend against legal actions; (iv) when it believes in good faith that sharing information is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violation of SALES JOURNEY's Terms and Conditions of Use; (v) in the event of sale of SALES JOURNEY's assets, change in its control, or preparation for any of these events (where the acquirers will have the right to continue using the information in accordance with this Privacy Policy); or (vi) for other purposes, through specified and authorized procedures by law.

(b) SALES JOURNEY Platform and its Services may: (i) be accessed through various applications, operating systems, and platforms (e.g., Windows, iOS, etc.), which have their own independent privacy policies and information handling practices, and therefore must be evaluated and accepted by the user at their own discretion; (ii) offer some Services that may be accessed through Third-Party Software in national or foreign territory, governed by their own terms of use and privacy policy, which the user must evaluate before contracting the respective Service. Notwithstanding the provisions of item (d) below, SALES JOURNEY shall have no direct or indirect responsibility for the privacy policies and terms of use of these third parties, nor for any damages or losses that the user may suffer as a result of the fault or intent of said Third-Party Software providers. If the user does not agree with the privacy policy practiced by Third-Party Software providers, it is up to the user to refrain from hiring or using the Services provided by them.

(c) SALES JOURNEY may also share collected information with service providers contracted by SALES JOURNEY, such as data processing companies (operators), processing systems (cloud computing services), IT consulting, telecommunications services, delivery services, advertising and marketing services, event organization, and credit billing services (financial).

(d) In the cases provided for in items (b) and (c) above, SALES JOURNEY undertakes to require Third-Party Software providers and service providers contracted by it to commit to confidentiality and compliance obligations, in accordance with the laws of data protection in force, especially with Law No. 13,709/2018, through a contractual instrument or in a specific declaration with binding force.

(e) In the event that SALES JOURNEY is required to share users' personal data as a result of an order issued by a judicial, police, or administrative authority, SALES JOURNEY ensures that it will only disclose such data after validation of the order issued by the competent authorities.

V. Retention, Alteration, and Deletion of Information.

Except for the scenarios provided here, the data collected by SALES JOURNEY through the Platform will be automatically deleted from SALES JOURNEY's servers after being used for the purposes for which they were collected.

In the event of an Account closure, upon termination of the Terms of Use of SALES JOURNEY, it will remove from its database all data related to the closed account's users, keeping only the data necessary to comply with SALES JOURNEY's legal obligations, to meet regulatory requirements, resolve disputes with the user, prevent fraud and misuse of the Platform and data, and/or to ensure compliance with this Privacy Policy and the Terms of Use of SALES JOURNEY.

VI. Privacy Policy Amendment

SALES JOURNEY reserves the right to occasionally amend this Privacy Policy. SALES JOURNEY will inform the user of the amendment by publishing the new version on the SALES JOURNEY Platform or by another reasonable means selected by SALES JOURNEY before its respective validity. The use of the SALES JOURNEY Platform and/or its Services after the validity of the new version will constitute the user's acceptance of the changes made and the consolidated and updated version of the Privacy Policy.

VII. Contact

If you need any assistance to exercise your rights, you can contact SALES JOURNEY, as instructed in this Policy.

Some of these rights may be exercised directly by the user, through the management of information about their own Account on the Platform. Other changes will require the submission of a request for further evaluation and adoption of additional measures by SALES JOURNEY.

Any communications, inquiries, and requests of any kind related to the processing of personal data and the terms of this privacy policy can be sent to the email.

The user is aware that deleting essential information for managing their account with SALES JOURNEY will result in the termination of their registration, with the consequent cancellation of the services provided.

VIII. General Provisions

If any provision of this Privacy Policy is deemed illegal or illegitimate by an authority in the jurisdiction where you reside or access the Internet, the remaining conditions shall remain in full force and effect.

This Privacy Policy shall be governed and construed in accordance with Brazilian law, especially Law No. 13,709/2018, regardless of the laws of other states or countries, with the jurisdiction of the domicile of the user being elected to settle any disputes or controversies involving this document, except for specific reservation of personal, territorial, or functional competence by the applicable law.

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