1. Objective
This document presents the Data Privacy Policy processed by Blockbit Tecnologia Ltda, in compliance with Federal Law No. 13.709/2018 (General Personal Data Protection Law – LGPD).
2. About Blockbit data collection
This agreement aims to clarify how Blockbit uses personal data collected and stored. To offer its solutions and content, Blockbit collects various data and information, aiming above all to provide an increasingly better experience for its users and channels. We have a great responsibility and we commit ourselves to ensuring privacy.
Acceptance of our Policy is by legal means and through consent. To enjoy our solutions, even if for free, acceptance of this Policy is necessary, whether when using or installing any Blockbit technology – hardware, software, firmware, updates or any solution provided by Blockbit. Acceptance indicates science and total agreement with how personal information and data are used. If you do not agree with this Policy, please do not continue any procedure and do not use the available solutions.
Whenever you use or install any Blockbit technology – hardware, software, firmware, updates – it will be understood as voluntary acceptance of the terms of this Policy.
In addition, any individual who contacts us, visit any of our websites, portals or other resources of our ecosystem, apply for a job opening and/or voluntarily insert information into one of our online forms, will also be in accordance with the terms of this Policy.
3. Who uses our websites, portals and hardware/ software/ firmware/ updates
3.1 Websites
Our websites are public for access to any individual, but it is advisable to be accessed only by older than 16 years, and when used by minors, it will only be possible to collect data by consent of at least one of their parents or guardians.
3.2 Portals
Our portals can only be accessed by employees Blockbit, authorized channels and/or customers, upon signature of legal contracts. The logins and passwords provided for these accesses are individual and non-transferable, precisely so that Blockbit has control of the permissions according to the level of each user and the records of all actions performed on these systems. These users are over 18.
3.3 Software/ Hardware/ Firmware and updates
Blockbit solutions are accessed by the end users who have purchased our solution and they can grant access to a Blockbit contributor or contributor of a channel authorized by Blockbit, for support, deployment, configuration, analysis or any other reason, provided it is formally and legally consented by the organization and/or a legal representative who bought one of our products.
4. What data we collect and what we do with them
Blockbit uses appropriate technologies and procedures to protect all personal data. Our information security policies and procedures are strictly aligned with accepted standards and are regularly reviewed and updated as necessary to meet our business needs, technology changes and/or regulatory requirements.
Any data captured by Blockbit products is only used for analytical purposes and restricted to groups that need to know this information to process them, and are subject to strict contractual confidentiality obligations.
Whenever personal data is collected directly by cloud providers, or third-party services from which we may be subscribers, Blockbit is exempt from any responsibility for the security, storage and/or privacy of any information collected.
4.1 Blockbit as Data Controller
Blockbit may request that you share information such as, but not limited to: your name, company address, phone number, mobile number or email address. Eventually, the request for some information can be made through Blockbit direct contact with users via email or telephone. Whenever this data is processed for the benefit of our own business, Blockbit is considered a Data Controller.
As a controller, Blockbit can use data as follows:
– To provide products, services and other offers from our business;
– To promote events, training and certifications;
– To launch and optimize websites and manage web communities;
– for marketing, advertising and communication purposes;
– for human resources and recruitment;
– for sales and customer service purposes;
– To promote relationship with customers, partners, suppliers, leads etc.;
– To conduct market research;
– To comply with rules described in the law and market standards; and/or
– To ensure business continuity.
In addition, we can automatically collect information from any of our products for evaluation and optimization purposes. This may include, but is not limited to: IP address, device type, operating system details, unique device identification numbers, browser type, language, time zone, operating system, geographic location or other technical information.
Some data can be collected through Cookies on our websites. Now, our software does not use cookies. For a better understanding, see the cookie statement.
You can see the personal information, stored in our systems, only Blockbit employees, and among these, only people with the proper authorizations. No personal data shall be made public. All data collected is confidential and any use of this information will be in accordance with this Policy. Blockbit makes every effort to ensure the safety of our systems.
4.2 Blockbit as Data Operator
In certain cases, where disclosure is legally permitted or granted by the Holder, Blockbit may process data on behalf of our partners and customers. In such cases, Blockbit is considered the Data Operator.
As Operator, Blockbit can use data as follows:
– To provide products and services, technical support, deployment, maintenance, updates and evaluation;
– for sales and/or customer service purposes;
– To comply with rules described in the law and market standards; and/or
– To evaluate credit decisions.
4.3 Use of personal data
Blockbit undertakes not to transfer or disclose your personal data, except in the cases listed below:
– With Blockbit internal teams, for commercial purposes only, whenever processing information is necessary to provide a quality service;
– With suppliers, service providers, audit agencies, etc., where the processing of information is necessary to provide a quality service;
– With Blockbit shareholders;
– With Blockbit authorized channels, to process orders and manage sales, subscriptions, support etc.;
– with government bodies, always at official request, as a matter of applicable regulation and approved by law; and/or
– With a court, to defend our legal rights or to limit damages in litigation.
– For any necessary cases mentioned or other adverse situations, there will always be legal consent from the Holder.
We may use business and third party services to:
– Provide the product on behalf of Blockbit;
– Perform services related to Blockbit solutions; or
– To help us analyze how the Blockbit solution is used.
– These third parties may have access to personal information. The reason is to perform the tasks assigned to them on our behalf. However, -Blockbit is legally secured so that third parties cannot disclose or use the information for any other purpose.
4.4 Withdrawal and deletion of personal data
Blockbit may retain your information for as long as is necessary for the purposes described in this Privacy Policy and to comply with applicable regulatory requirements, provided that we have legitimate commercial purposes and are permitted by law.
Once the periods of storage of personal data have expired, they are removed from our databases or anonymized, unless there is a possibility or need for storage due to legal or regulatory provision.
4.5 Sensitive data
No sensitive data will be collected from any user on our website, portals and/or systems, so understood to those defined in articles 11 et seq. of the General Data Protection Act. In other words, Blockbit will not collect any sensitive data related to racial or ethnic origin, religious conviction, political opinion, membership of the union or organization of religious, philosophical or political character, given regarding health or sexual life, genetic or biometric data, when linked to a natural person.
4.6 Legal Bases
4.6.1. Consent
Consent is defined as a clear and unequivocal declaration of will. This is the case where the person agrees to the use of his data for the purposes proposed by Blockbit. A practical example of the legal basis of consent, in the context of Digital Marketing, is the checkbox (opt-in) in our form fields, to request authorization for sending communications. See some of the requirements:
Consent is free: the person cannot be forced to provide consent. It's a choice. If you are interested in consenting to Blockbit data, you may choose to click if you accept or do not share your personal data for a given purpose;
Consent is informed: the user must understand with what he is consenting. Blockbit will make sure that it clearly explains exactly what the person is agreeing to;
Consent must be unequivocal: from the manifestation through a positive act of the individual. In other words, Blockbit will receive personal data if there is an action by the user indicating its acceptance, either by sending an email, electronic signature, or even by clicking on a given location. There will be no doubt as to whether consent has been provided or not;
Consent must be provided for specific and determined purposes: consent must be provided for a specific and determined purpose. It is part of the entire logic of LGPD to specify why a given personnel is used. Blockbit will not use the data for a purpose other than the one given consent.
4.6.2. Legitimate Interest
For certain personal data processing operations, we rely solely on our legitimate interest. To find out in which cases, specifically, Blockbit is worth this legal basis, or to get more information about the tests we do to make sure we can use the data, contact our data protection officer or the channels informed in this Privacy Policy, in the “How to Contact Blockbit” section.
4.6.3 Contracts
In the case of the legal basis of contracts, personal data may be processed by Blockbit in two cases: the first is to comply with an obligation provided for in the contract, and the second when the processing of data serves for the validation and start of validity of an agreement.
4.6.4. Too many legal bases
In addition to the above, there are other types of legal bases that may justify the processing of personal data:
Legal Obligation: In this case, the processing of personal data is justified by requirements of other laws. These are scenarios where Blockbit needs to use or store personal data to comply with legal obligations;
Execution of Public Policies: when the processing of personal data is protected by the public interest or by the need for an official authority exercising the role of controller of that data;
Research organ studies: Personal data can be processed for the purposes of officially accredited organ studies as research. In such a case, where possible the data shall be anonymised by Blockbit ensuring the privacy of the holders as far as possible;
Judicial proceedings: personal data may still be processed for the exercise of right in legal proceedings;
Protection of Life: it is possible to justify the processing of personal data when its use is of vital interest, either to the data subject or to another person;
Health Protection: when health professionals, health services or health authority need to treat personal data;
Credit Protection: For credit approval, reducing the risks of the transaction, it is possible for personal data to be consulted by evaluating the profile of citizen payer.
5. Rights of the Holder of personal data
As defined in LGPD, the data subject has the following rights:
Confirmation of the existence of treatment: whether or not your data is processed by Blockbit under the condition of Controller;
Access to data: If the processing is confirmed, the holder has the right to access it in a controlled manner in order to avoid access of his data by others;
Correction of incomplete, inaccurate or outdated data: respected the limitations by legal requirement to maintain history, your data can be corrected. According to the treatment given to them, it may be necessary to provide documentation to prove the update, completeness or correction performed by Blockbit;
Anonymisation: processing which prevents the identification of the holder where it is not necessary;
Limitation of processing: is the right of the holder to limit the processing of his personal data, which can be obtained when he contests the accuracy of the data, when the processing is unlawful, when Blockbit no longer needs the data for the purposes proposed and when it has opposed the processing of the data;
Elimination of unnecessary, excessive or processed data in breach of LGPD: is the right to exclude data, except under the conditions laid down in the same Law;
Data portability: at the time of publication of this policy was still pending regulation by the national authority;
Elimination of data or right to forgetfulness: represents the right to have your data deleted from Blockbit systems, except under the conditions laid down in the same Law;
Share information: be informed about sharing your data and with which entities;
Failure to consent: when consent is requested for data collection and processing, the consequences of non consent will be informed;
Revocation of consent: withdrawal may be requested at any time by the express manifestation of the holder. Revocation does not cancel previous treatments unless elimination is also formalised.
6. Changes in the Privacy Policy
This Privacy Policy may be updated and any change will be published on the Blockbit website as a means of confirming the privacy and protection of personal data.
If any purpose of data collection is different from that presented here, we will request new authorizations and immediately update this Policy.
7. How to contact Blockbit
At any time the data subject may contact the data protection officer in order to remove doubts or exercise the rights mentioned above. Just send an email to privacy@blockbit.com