Privacy Policy
Updated on October 27, 2023

1. General Information

This Policy aims to describe how your privacy is protected when we collect, transmit, share, store, and delete your personal data. Additionally, this policy informs user rights and clarifies when and how they can exercise them.

This Policy applies to all users and potential users of ACRIE’s Services, including the website, landing pages, and blog.

This Policy does not apply to Third-Party Sites, even if you access them through links on our site, as they are not hosted in our environment or under our responsibility. The user should carefully read the policies of these Third-Party Sites to assess whether they agree with them or not.

By agreeing to this Policy, the user declares that any provision of Personal Data for our services is done consciously and freely.

By accessing our services, the user declares to be at least 18 (eighteen) years old and fully able to accept this Policy and any Terms of Use. Our services were not developed to offer services to minors. Therefore, we do not intentionally collect Personal Data from minors, and in specific cases, we always obtain express consent from their guardians.

ACRIE recommends that you carefully read this Policy in its entirety to ensure that you are fully informed.

2. What data we collect

By using our website, we collect some important information that can identify you as an individual (“Personal Data”) so that we can provide appropriate assistance.

In general, we collect your Personal Data when:

a) You provide us directly

    1. When registering to hire one of our services, we may collect important information such as your name, email, phone number, company you work for, date of birth, billing information, and credit card information to process your order, among other details.
    2. When using a third-party service (e.g., Google or Facebook) to register for one of our services, we will receive personal data through this third party, but only if you have authorized their platform to share your data with us.
    3. When registering to receive information about our services and products, initiatives (e.g., materials, events, training, etc.), or updates that we consider relevant to you, we may collect: name, email, company you work for, position, among other details.
    4. When you make contact with our team (e.g., sales, technical, or administrative), to request assistance or information, during events or training, among other similar situations, we may collect: name, email, company you work for, position, phone number, etc.

b) When interacting with our services

    1. When you access our services (websites, portals, applications, etc.), we may collect data such as: IP address, browser type, operating system, characteristics of the accessing device, location, carrier, language, clicks during navigation, pages accessed, time and duration of access, among others. To perform these collections, we may use technologies such as cookies, pixel tags, beacons, local shared objects, among others.

c) Other people provide us

    1. We collect Personal Data occasionally through Third Parties we trust and who provide us, such as marketing partners or other services, clients recommending companies that may be interested in our services, etc. In these situations, we may collect information such as: name, email, company you work for, phone number, position, age, professional and educational information, etc.

d) We search in Public Sources

    1. We may collect publicly available data from social networks such as LinkedIn, for example. In these cases, we may collect data such as: name, current or past employer, job titles, professional and educational history, publications, etc.

3. How we use your Personal Data

ACRIE uses your Personal Data in situations as described below:

    • When you provide us with your data through registrations to receive information about our company, our services, or relevant information from our business partners.
    • When we observe your interactions with our services to improve your experience, including performance, usability, preferences, among other similar aspects.
    • When we send information that we consider relevant to you, such as updates to this Policy, Terms of Use, news, improvements, or changes to our services, among others.
    • When we manage the relationship with our clients and partners, always within our responsibilities and duties, as well as to meet the expectations of this relationship.
    • When we manage our business operations, analyzing and improving our services through the observation of usage, including evaluating the performance of our actions, services, and products.
    • When we conduct financial transactions, for example, when you make a payment for a contracted service or product, or when we pay someone for a debt owed by our company.
    • When we communicate with you on matters that we consider in good faith to be relevant and of interest to you, such as technical, commercial, or administrative information, invitations, reminders, confirmations, thanks, satisfaction surveys, among others.
    • When we manage our relationship with you as a potential or active customer, based on participation in training, events, promotional actions, or other initiatives.
    • When we manage the relationship with our employees, job candidates, service providers, and suppliers.
    • To manage risks, we need to ensure the security of information in our services, monitoring our operations, either through our internal team or third parties, internal or external audits, always in combating ethical deviations, inefficiency of processes and services, fraud prevention, inhibition of illegal and/or inappropriate activities, or violations of this Policy or Terms of Use.
    • To protect the assets and rights of ACRIE and our employees, clients, and partners.
    • To protect and defend the legitimate interests of ACRIE.
    • When we fulfill contractual agreements between ACRIE and your company. To comply with applicable legislation, collaborate with a court order, as well as occasionally meet the obligation to report specific activities to the competent

4. Sharing of Personal Data

ACRIE will not sell your Personal Data under any circumstances.

To achieve the purposes mentioned in this Policy, we may share with our employees for the execution of their legitimate responsibilities within our company, as well as service providers, government, among others. Always within the limits of the law.

See below with whom we may share your Personal Data:

    • With companies and individuals hired by ACRIE to perform certain activities essential to our business, such as providing support for our technologies, cloud technology service providers, accounting services, marketing, partner companies in the development of commercial activities, and partners in providing employee benefits, among others.
    • Financial institutions, for due transactions, including payment gateway companies, at the moment you make any payment for our services, which will be exclusively processed to facilitate the purchase you have made.
    • With the general public, whenever you post comments on our blogs, publications, or other resources available through our services, including through social media.
    • To third parties for the purpose of detecting and protecting against fraud, or any technical or security vulnerabilities.
    • To judicial or administrative entities, upon court order or as required by authorities with legal competence to do so.

5. Data Retention

The Personal Data we process is kept for the time necessary to achieve the purposes described in this Policy.

If you wish, we will make our best technical effort to delete or anonymize your Personal Data, unless we are authorized or obligated to keep them.

Instances where Personal Data may be retained for a longer period:

    • To fulfill legal obligations.
    • To serve our legitimate interests, such as fraud prevention or ensuring the security of information or the privacy of data subjects.

6. Your Rights

ACRIE respects and guarantees your rights. In particular, you have the following rights:

    • Confirmation of the existence of processing.
    • Access to the data.
    • Correction of incomplete, inaccurate, or outdated data.
    • Anonymization, blocking, or deletion of unnecessary, excessive, or data processed in violation of the Brazilian Data Protection Law.
    • Data portability to another service or product provider, upon express request, in accordance with the regulations of the national authority, while respecting trade and industrial secrets.
    • Deletion of Personal Data processed with the consent of the data subject.
    • Information about public and private entities with which the controller has shared data.
    • Information about the possibility of not providing consent and the consequences of refusal.
    • Revocation of consent.

If you wish to exercise your rights or have any questions regarding the processing of your Personal Data, please contact us through the communication channels on our institutional website or via email at dpo@acrie.com.br. Requests will be received, analyzed by our team, and appropriate measures will be taken.

ACRIE will make every effort to respond to requests as quickly as possible.

7. How We Protect Your Information

ACRIE makes every effort to respect and protect your personal information.

We strive to adopt reasonable technical and organizational measures for data protection. While there is a strong commitment to ensuring the confidentiality, integrity, and availability of information, please note that no system is completely secure, as the internet’s security structure is continuously evolving.

If you have reason to believe that the protection of your Personal Data and privacy has been compromised in your relationship with ACRIE, please contact us immediately through the channels outlined in this Privacy Policy.

8. Who Controls Your Data

The controller is the entity responsible for making decisions about the processing of personal data. For the purposes of this policy, ACRIE is the Data Controller.

Below are the details:

a) Controller’s Information

Name: A Crie LTDA
CNPJ: 32.325.850/0001-56
Address: Rua Juliano Marques Duarte, 194 – Ilha Gama Cerqueira | Além Paraíba – MG
Phone: (32) 99843-3593

b) Data Protection Officer (DPO)

The Data Protection Officer (DPO) appointed by ACRIE is Erica Grellert, and can be contacted via email at dpo@acrie.com.br.

If you have any questions or concerns about this Privacy Policy or the data processing, please contact us, and we will be happy to clarify and/or address your request.

When we receive a privacy-related question or request, our team conducts a review and responds to the presented issue. If it is of a more specific nature, we will work on gathering more information to respond, always taking the necessary measures according to the technical and operational feasibility of ACRIE.

If you have received any communication from ACRIE and would prefer not to have received it, please let us know through the “unsubscribe” link usually present in the respective message, depending on its nature, or send us an email to dpo@acrie.com.br.

9. Modification of this Privacy Policy

ACRIE may occasionally change or update, in whole or in part, this Privacy Policy to comply with the law or meet operational, technical, administrative, or business requirements of the organization. When we update or change, we will take steps to inform you. We may notify you by changing the revision date of this document on our institutional website, through notices in systems, applications, emails, or other means. Please make sure to carefully read any such notices.

We encourage you to periodically review the update date and/or this Policy to stay informed about our practices and how we are protecting your privacy and information.

10. Legislation and Jurisdiction

This Privacy Policy and the relationship arising from the actions covered herein, as well as any disputes arising therefrom, will be exclusively governed by Brazilian law.

The Court of Além Paraíba-MG is hereby elected to settle any issues related to this document, with the parties waiving any other, no matter how privileged it may be or become, ACRIE.