PRIVACY NOTICE

UBIMINDS IT SERVICES LTD., the private legal entity having its principal place of business at Rodovia José Carlos Daux 4150 Sala A3 – ACATE – Saco Grande, Florianópolis/SC – Brazil, and UBIMINDS LLC, having its principal place of business at 16192 Coastal Highway, Lewes, Delaware, 19958, USA (“UBIMINDS”), take your privacy and data protection seriously.

In this regard, this Privacy Notice has been developed to inform UBIMINDS’ users and business partners about the collection and processing of your personal data, what your rights are, and how you can exercise them.

It is expected this information will support your understanding of how your data is handled and present UBIMINDS’ commitment to privacy, data protection, and information security.

Knowledge of the existence and understanding of this Privacy Notice is essential for the user (you) to access the website, contact us, register on platforms used by UBIMINDS when applicable, and make use of our services. If you disagree with the terms herein, please refrain from the mentioned actions and send an email to the Data Protection Officer (DPO), as established in item 9 of this document.

1. BASICS: WHAT YOU MUST KNOW TO FULLY UNDERSTAND THIS POLICY

To simplify your reading of this document, here are some valuable definitions from Law No. 13.709/18, also known as the Brazilian General Data Protection Law or “LGPD”:

Personal data	Information that allows direct or indirect identification of a natural person. Examples of personal data include name, Individual Taxpayer Registration Number, passport or personal ID, voter ID, work permit, phone number, email, profession, geolocation, age, gender, etc.
Sensitive personal data	Personal data regarding racial or ethnic origin, religious beliefs, political opinions, union membership, philosophical or political organization affiliation, health, sexual and reproductive life data, and genetic or biometric data linked to a natural person.
Processing	Any activity that can be performed with your personal data, including collection, storage, consultation, sharing, deletion, etc.
Data subject	You, the individual to whom the personal data refers to, or the company which you represent.
Company	That’s us, UBIMINDS.

 

2. WHAT DATA DO WE PROCESS AND WHY?

The types of personal data and its uses by UBIMINDS depend on the nature and reason of your relationship. In this context, here are some situations in which personal data may be processed:

 

Purposes	Types of personal data used
Service contracting	Registration data: name, taxpayer ID, address, e-mail, phone number Company registration data: corporate name, trade name, General Taxpayers’ Registry number, email, and telephone Banking data: bank institution, branch, and account number, including SWIFT/IBAN when applicable Company and product information: available budget, product roadmap, programming methodologies and techniques, and possibly information from respective customers, users, and service providers
Website visits	Device data: operational system type and version Navigation data: IP, location, access date and time, visited pages, access duration, language preferences
Marketing initiatives	Contact data: name, email, phone number, city, company, position, and common contacts, if applicable Information consumption data: topics of interest, access data, navigation history, language preferences, relationships, and associations
I want to apply/I want to hire	Contact data: name, email, company, LinkedIn, Github, phone number
International career information	Contact data: name, email, and previous companies and educational institutions
Contact	Contact data: name, email, and company

 

3. WITH WHOM DOES UBIMINDS SHARE DATA?

UBIMINDS collaborates with various organizations to enable its activities, making it indispensable to share some data with trustworthy third parties to fulfill intended purposes.

UBIMINDS may share personal data collected under the following circumstances:

1. Service providers acting on behalf of UBIMINDS;
2. Business partners;
3. Web analytics providers;
4. Advertising campaigns;
5. Public entities and authorities;
6. General authorities for legal or regulatory compliance;
7. Companies within the same economic group;
8. Other scenarios are to be determined with the client.

4. DATA STORAGE

UBIMINDS has established a data retention policy aligned with current American and Brazilian law. This means your data will be stored only for the period necessary to fulfill the intended purpose for which they were collected, unless there are other reasons for retention, such as legal, regulatory, contractual obligations, or legitimate rights.

Please note that you, as the data subject, can exercise your right to object by requesting the deletion of personal data or withdrawing your consent. In such cases, UBIMINDS will evaluate the request and delete the data if they are no longer necessary for the stated purpose, unless there’s a reason for continued storage, as mentioned above.

5. HOW DO WE PROTECT YOUR DATA?

To ensure your privacy and the protection of your personal data, UBIMINDS employs technical and organizational measures, including restricted access, the use of individual logins and passwords for server access, access log recording, backups, antivirus software, firewalls, confidentiality agreements with employees and service providers, and other measures to ensure the integrity and confidentiality of information.

6. DATA SUBJECT RIGHTS

The LGPD grants data subjects rights to be exercised with data controllers. In this regard, UBIMINDS, committed to complying with the law, outlines these rights and how they can be exercised:

Confirmation and Access	You can request confirmation from UBIMINDS about the processing of your personal data and, if confirmed, request copies of the records related to you and your online activities within our platforms.
Correction	You can request the correction of your personal data if they are incomplete, inaccurate, or outdated.
Anonymization, Blocking, or Deletion	You can request (a) the anonymization of your personal data, making them no longer identifiable and thus no longer considered personal data; (b) the blocking of your personal data, temporarily suspending processing for specific purposes; and (c) the deletion of your personal data, in which case all your personal data will be erased without the possibility of reversal. Please note that UBIMINDS may not fulfill the request if necessary to safeguard your rights and/or comply with legal or regulatory obligations.
Portability	You can request that UBIMINDS provide your personal data in a structured format to a third party, as long as this transfer does not violate UBIMINDS’ intellectual property or business secrets.
Information about Sharing	You have the right to know which public and private entities UBIMINDS shares your personal data with. Section 3 of this Policy will provide information about relationships with third parties that may involve personal data sharing. Depending on the case, the information provided may be limited if the disclosure could violate UBIMINDS’ intellectual property or business secrets.
Information about Non-Consent	You have the right to receive clear, complete, and unambiguous information about the possibility and consequences of not providing consent. You are aware that the refusal to provide consent may result in the inability to provide certain services, but you will be informed when this occurs.
Revocation of Consent	If you have given consent for the processing of your personal data for a specific purpose, you can always withdraw your consent. However, this will not affect the legality of any processing carried out before the revocation. If you withdraw your consent, UBIMINDS may be unable to provide certain services, but you will be informed if this happens.
Objection	The law permits the processing of personal data without consent. In such cases, your personal data will only be processed if there is a legal basis other than consent.

 

If you have any questions about these matters or about exercising your rights, feel free to contact UBIMINDS‘ Data Protection Officer through the channels provided at the end of this Policy.

7. INTERNATIONAL DATA TRANSFER

International transfer of personal data to foreign companies may occur when a data subject applies for a position offered by UBIMINDS or when information is stored on third-party servers (Cloud).

In these cases, it is ensured that your personal data will be sent to countries that provide an adequate level of personal data protection and that the guidelines of the LGPD will be observed.

8. COLLECTION AND USE OF PERSONAL INFORMATION REGARDING MINORS

Platforms used by UBIMINDS are not intended for users under 18 years of age.

9. COMMUNICATION CHANNEL

UBIMINDS makes available the dpo@ubiminds.com email for data subjects. Upon receiving your message, our Data Protection Officer (DPO) may request additional information to confirm your identity before verifying the nature of your request.

The provided channel can also be used for troubleshooting, as well as forwarding comments and suggestions related solely to the processing of personal data.

10. UPDATES TO THE PRIVACY NOTICE 

This Privacy Notice may be updated at any time by UBIMINDS to mirror improvements. Therefore, we recommend regular visits to this page to stay up-to-date on updates and keep track of versions as signaled at the end of this document.

UBIMINDS

Update History
V1	August/2023