Introduction

This Privacy Policy (“Policy”) is effective as of October 1, 2020 and explains what information we collect about you and why we collect it, what we do with this information, how we share it, and how we handle personal information created, entered, submitted, posted, transmitted, stored or displayed by you, your Agents and End Users when you access and use our Services.

If there are any changes to this Policy, you will be notified by e-mail. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of our Services or Sites signifies your agreement to be bound by changes to this Policy. Your only recourse, if you do not accept the terms of this Policy, is to discontinue use of the Service and the Sites.

Information Covered by this Policy

We respect and protect the privacy of visitors to our Sites and of our users. This Policy explains the what, how, and why of personal information we collect when you visit our Sites or use our Services.

Personal information collected and used by ChatSac is limited to the purpose for which subscribers engage with any ChatSac member and other purposes explicitly described in this Policy.

What this policy covers:

What does Personal Information mean?

In this Policy, personal information means information relating to an identified or identifiable natural person. An identifiable person is a person who can be identified, directly or indirectly, specifically by an identification number or one or more factors specific to his or her physical, physiological, mental, economic, cultural, or social identity. Except as described in this Policy, ChatSac does not provide, sell, rent or lend any personal information to third parties.

Personal information you tell us or that we collect

Account Information

When you register, we ask you for personal information such as your name, address, telephone number, e-mail address, instant messenger ID, and credit card information, as well as certain information related to your company name and Web site.

We also collect personal information such as e-mail address and name or alias of any individual authorized to enter and use your Account as an Agent and/or Administrator or End User who is authorized by you to enter and use your Account.

A third-party intermediary is used to manage the credit card processing. This intermediary is not permitted to store, retain, or use your billing information for any purpose other than credit card processing on our behalf. For the purposes of this Policy, we refer to all the information described above as “Account Information”.

By voluntarily giving Account Information, you affirm that you are the owner of this personal information or are authorized to give it to us.

Data Collection

We collect and store information created, entered, submitted, posted, transmitted, stored or displayed by you, your Agents and End Users during use. This information may include personal information or other confidential information that you, your Agents or End Users choose to include. We refer to any information described above as “Service Data” for purposes of this Policy. All Service Data is subject to our technical protections, as described in more detail in our Terms of Service.

Cookies/usage tracking technologies

Our software and Sites use cookies for various purposes. These cookies may provide us with information, including personal information, other information about devices and networks that you use to access our Sites and Services, as well as information about your interactions with and on our Sites and Services.

Web beacons, tags, and scripts may be used in our Sites, Services or emails. They help us deliver cookies, count visits made to our Sites, understand campaign usage and effectiveness, as well as determine whether an e-mail has been opened and something has been done about it. We may receive reports based on the use of these technologies by our service providers on an individual and aggregate basis.

We use Local Storage Objects (LSOs), such as HTML5, to store content information and preferences. Various browsers may offer their own management tools for removing HTML5 LSOs.

Log Files

As with most web sites and services, we collect certain information automatically and store it in log files. This information includes internet protocol addresses, browser, internet service provider, exit/reference pages, operating system, time/date stamp and click stream data, as well as certain personal information such as user name, user e-mail address, and other information that may be included in the open text fields. We do this to improve the Services we offer you, as well as to improve the marketing, analysis or functionality of the Site.

Usage Analysis Information

We collect analytical information when you use our Sites and our Service to help us improve them.

Analysis information may consist of the feature and function being used, the domain name associated with it, the username and End User (which may include personal information if it has been incorporated into the username) and additional information required to detail the operation of the function and what parts of the Service are being affected. The analytics information we collect may include Service Data elements related to the function that the Agent or End User is performing. Thus, the analysis information may include personal information or confidential corporate information.

Communication with us

When you send email or other communication to us, including support requests we may collect the personal information you provide and may use it to process inquiries, respond to requests, and improve services.

Subscriber testimonials/comments/reviews/feedback:

We periodically post customer testimonials on our Sites that may contain personal information. We obtain clients’ consent to publish names next to testimonials. If the client wishes to update or delete the testimonial, simply contact us at [email protected]

Indications

If you choose to use our referral service to tell a friend about our Services, we will ask you for your friend’s name and email address. We will automatically send your friend an e-mail with an invitation to visit the Site and will store this information for sending this initial e-mail and also for tracking the success of the referral program and other advertising activities. Your friend can contact us at [email protected] to request removal of information from the database.

Other shipments

We collect other information, including personal information that you submit to our Sites or when you participate in certain interactive features, enter a survey, contest, promotion, prize, activity or event, apply for a job, request customer service, communicate with us through third party social networking sites or otherwise contact us. Any information, including personal information that you submit through the Sites may be visible to the public unless it is sent to a secure area of the Sites.

Social Networking Widgets

Our Sites include Social Networking Features like the Facebook Like button and widgets like the “Share” button. These Features may collect your internet protocol address, the page on our Sites that you are accessing, and may set a cookie in order for the Feature to function properly. Widgets and Social Networking Resources are hosted directly on our Sites.

Personal information from third-party services

Any access we may have to this information from a social network or third party authentication service is in accordance with the authorization procedures determined by the service in question. By authorizing us to connect with a third party service, you authorize us to access and store your name, email address(es), city where you live, profile picture URL, and other personal information that the third party service makes available to us, and to use and disclose it in accordance with this Policy. You should check your privacy settings at these third party services to understand and change the information these services send us. For example, you can log into our Sites using logon services such as Facebook Connect or an Open ID provider. These third party services will authenticate your identity and give you the option to share certain personal information with us, such as your name and email address to pre-fill our registration form. Facebook Connect (and other similar services) gives you the option of posting information about your activities on our Sites on your profile page to share with people in your network.

Single Sign-On

You can access ChatSac using logon services, such as Facebook Connect or an Open ID provider. These services will authenticate your identity and give you the option to share certain personal information with us, such as your name and e-mail address to pre-fill our registration form. Services like Facebook Connect give you the option to post information about your ChatSac activity to your profile page to share with people in your network.

Other information you provide or that we collect

In addition to personal information, we collect data and other information from visitors to our Sites and from users. This includes, among other things, anonymous information or aggregate data, which ChatSac collects about a group or category of Services, resources or users while you visit our Site or access our Services. We define this information as Usage Data. Usage Data helps us understand usage trends of the Services so that we can better design new features or adapt our Services. In addition to collecting and using Usage Data, ChatSac may share it with third parties, including our customers, partners and service providers for various purposes, including to help us better understand our customers’ needs and improve our Services, as well as for advertising and marketing purposes. We may also publish Usage Data to present relevant information about our service provision and also for marketing purposes.

How We Use Personal Information

General Uses:

We use the personal information we collect for various purposes, including:

Site and Service Analysis:

As we have indicated above, we use the information we collect (including registration and configuration data) to understand how our Sites and Services are being configured and used, how they can be improved, and to develop new services, features and functionality.

Sharing of personal information

Outsourced service providers:

We share information, including personal information, with our third party service providers (such as credit card carriers, hosting providers, sub-processors of Service Data, and technology partners) to provide the necessary hardware, software, networking, storage, and other services that we use to operate our Services and maintain a high quality user experience. We do not allow our service providers to use the personal information shared by us for their own advertising purposes or for any other purpose that is unrelated to the services they provide to us.

Other services:

You can choose to use Other Services in conjunction with our tool. Other Services are third party products, applications, services, software, products, networks, systems, directories, websites, databases, and information that are linked to or may be connected by You including, without limitation, Other Services that may be directly integrated into Your Account and to which You grant access. When access is granted, certain information in your Account is shared with third parties, including personal information. ChatSac does not control the policies and procedures of these Other Services. This Policy does not cover the collection or use of information, including personal information, by Other Services and we encourage you to take into account the privacy policies governing those Other Services.

Compliance with laws and requests from legal authorities; protection of our rights:

We disclose personal information to comply with subpoenas, court orders, and legal process or to establish or exercise our legal rights or defend against legal claims. We may also share this information if we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential risks to the physical safety of any person, violations of our Terms of Service, or if required by law.

Sharing:

We may share information, including personal information, with any member of our company for the purposes explicitly described in this Policy.

Consent:

We may share information with these third party companies when we have your consent to do so.

Choices

If you do not wish to receive ChatSac advertising communications, please contact us at [email protected] or follow the unsubscribe instructions included in each advertising email.

Accessing and updating your information

Subscribers can access, update or change Account Information by providing additional information where applicable. If you are a subscriber and wish to obtain access to or request deletion of information collected by ChatSac, please contact us at [email protected] We will respond to such requests within thirty (30) business days.

Technical limitations may restrict or eliminate our ability to remove or delete certain Data on all systems. In that case, you will be informed.

Sovereignty of the Portuguese version

Translations of this Policy into languages other than Portuguese are provided for your convenience only. If there is any ambiguity or conflict between translations, the Portuguese version is official and sovereign.

Protection of Information

We are committed to ensuring the security of your personal information. We use robust precautions to protect the confidentiality and security of personal information on our Service by employing technological, physical, and administrative security safeguards such as firewalls and carefully designed security procedures.

For example, when entering sensitive information (such as login credentials or information sent from within the Service).

We encrypt the transmission of this information using Secure Socket Layer (SSL) technology.

These technologies, procedures, and other measures are used in an effort to ensure that your Data are protected, secure, and available only to you and to those authorized to access your Data.

However, no Internet, e-mail, or electronic transmission is ever fully protected or error-free. So choose carefully what information you send to us in this way.

Hosting, Data Transfer and Retention

Unless expressly agreed otherwise, ChatSac may host and process Data, including personal information, in Brazil and other countries through ChatSac and third parties used to operate and manage our Service. Wherever we process personal information outside the European Economic Area on behalf of our subscribers located in the EEA or Switzerland, we will continue to afford them adequate protection in accordance with the requirements of the European Data Protection Directive 95/46/EC.

We may retain and use other personal information, including personal information we collect as “data controllers” as necessary to comply with legal obligations, maintain accurate accounting, keep financial and operational records, resolve disputes, and fulfill our contracts, as described above. Our policy for deletion of Data following termination or cancellation of the contract by a subscriber can be obtained by sending a request to [email protected]

Personal Information of Minors

ChatSac does not knowingly collect personal information from children under the age of 13. If you are under 13 years of age, please do not submit personal information.

We encourage parents and legal guardians to monitor children’s Internet use and help comply with our Policy by instructing their children never to provide personal information without their permission.

If you have reason to believe that children under the age of 13 are sending us personal information through our Services, please contact us and we will use commercially reasonable efforts to delete this information.

Subscribers are responsible for establishing policies and complying with applicable laws for the collection of personal information in connection with the use of our Services.

Business Transactions

ChatSac may assign or transfer this Policy and your Account and related information and data, including any personal information, to any person or entity that acquires all or part of the company, its stock or assets, or in the event of a merger with us.

Contact Us

If you have questions or complaints regarding this Policy or the ChatSac Group’s privacy practices, please contact us at [email protected]

Personal information collected, stored, used and/or processed by ChatSac as described in this Policy is collected, stored, used and/or processed in accordance with Brazil’s Law No. 12,965/2014. By using our services, you explicitly agree to our collection, use, storage and processing of your personal information as described here.