User: all individuals who will use or visit the Website(s) and/or application(s), over 18 (eighteen) years of age or emancipated and fully capable of performing acts of civil life or those who are absolutely or relatively incapable and duly represented or assisted.

Personal Data: means any information provided and/or collected by the company, by any means, even if public, that:
(I) identify, or that, when used in combination with other information processed by the company, identifies an individual; or
(II) through which the identification or contact information of a natural person can be derived.

Personal Data may be in any media or format, including electronic or computerized records as well as paper-based files. Personal Data, however, does not include business telephone, business mobile number, business address, business email.

Purpose: the objective, the purpose that the company wishes to achieve through each act of processing personal information.

Need: justification for which it is strictly necessary to collect personal data, to achieve the purpose, avoiding excessive collection.

Legal bases: legal basis that makes the processing of personal data for a specific purpose by the company legitimate.

Consent: express and unequivocal authorization given by the User holding the personal data so that the Luctel Telephony and Information Technology process your personal data for a previously described purpose, in which the legal basis necessary for the act requires the express authorization of the holder.

This policy applies, in general, to all Users and potential Users of the services offered by Luctel Telephony and Information Technology and summarizes how the Luctel Telephony and Information Technology may collect, produce, receive, classify, use, access, reproduce, transmit, distribute, process, archive, store, eliminate, evaluate or control the information, modify, communicate, transfer, disseminate or extract the collected data, including personally identifiable information, in accordance with the applicable legal bases and all privacy and data protection laws in force.

If the User does not fit the description above and/or does not agree, even in part, with the terms and conditions contained in this Privacy Policy, he/she should not access and/or use the services offered by Luctel Telephony and Information Technology, as well as the websites and services operated by it.

In this sense, all personal data collected and their purposes are available in the company's General DP Map. Luctel Telephony and Information Technology and the holder of the personal data may request the available information at any time they deem necessary. The company has a period of 3 working days to provide all the information.

Personal data that does not fall within the legal bases defined in Chapter II, article 7 of Law 13,709 (General Data Protection Law), have the express consent of the holder for due processing.

To keep your personal information secure, we use physical, electronic and managerial tools designed to protect your privacy. We apply these tools taking into account the nature of the personal data collected, the context and purpose of the processing and the risks that any violations would generate for the rights and freedoms of the data subject of the collected and processed data. Among the measures we adopt, we highlight the following:

• Only authorized persons have access to your personal data;
• Access to your personal data is only granted after a commitment to confidentiality;
• Your personal data is stored in a safe and suitable environment.

THE Luctel Telephony and Information Technology is committed to adopting the best practices to avoid security incidents.

In the event of security incidents that may generate risk or relevant damage to you or any of our users/customers, we will notify those affected and the National Data Protection Authority about the incident, in accordance with the provisions of the General Data Protection Law.

THE Luctel Telephony and Information Technology provides the following means for you to contact us to exercise your rights as a data subject:

Phone / WhatsApp: (11) 2527-1091

If you have any questions about this Privacy Policy or the personal data we process, you can contact our Personal Data Protection Officer through the following channels:

Marcos Luciano Silva Siqueira 

luciano.siqueira@luctel.com.br

THE Luctel Telephony and Information Technology reserves the right to change this Privacy Policy at any time, without prior notice, at its sole discretion. Changes will be effective immediately upon posting of the updated version on this page.

If we make material changes to this Privacy Policy, we will notify you by means of a prominent notice on our website. We encourage you to periodically review this page to stay informed of changes, and if you have any questions or concerns, please contact us

By continuing to use the Website and/or Services after any changes to this Privacy Policy are posted, you agree to those changes and the terms of the updated Privacy Policy.