Privacy Policy: Website


Last update: September 23, 2020

The purpose of this Privacy Policy is to demonstrate the commitment of Incognia US, Inc, a Delaware Corporation, located in 2479 East Bayshore Road, Suite 150 - Palo Alto, CA 94303, USA with the privacy and protection of personal data collected through its technology in accordance with the applicable privacy laws and regulations, ensuring transparency and best practices for the protection of personal data.

 

About

The Website Privacy Policy deals with the collection and processing of personal data of website visitors (the "data subjects"). The contact data that will be detailed here are provided voluntarily by the data subjects themselves through the contact means available on our page.

In addition to the contact data detailed in this Policy, this website also stores cookies in your browser to customize your experience, correct errors and improve usability. You can set your preferences regarding the storage of cookies. To learn more, read our cookie policy.

Personal data processing

Data source

Our website collects personal data by filling out the forms "Fale com vendas", available at the top of the page, and "Contato", at the footer, and through the chat bot for available questions.

The data collected in the "Fale com vendas" form is used for registration and communication with potential customers; providing requested products and services; and, if authorized by the data subject, targeting and marketing campaigns.

The data from the "Contato" form is provided by subjects who want to contact us about a certain subject or with a certain sector of Inloco, either to clarify doubts about products, events, job opportunities, etc.; to establish partnerships; to produce journalistic articles; among other purposes. These data are not used for any purpose other than that intended by the subjects themselves at the time of contact.

Finally, the chat bot is available on our website for the data subject to ask general questions about Inloco or to direct the subject to a member of the Inloco team who can answer them. The bot collects contact information so that the communication continues in case of disconnection.

Categories of data and purposes of the processing

Inloco follows the principle of minimization established by the EU General Data Protection Regulation, which states that "personal data must be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed" (Art. 5, 1, (c), GDPR), as well as the principle of necessity of the Brazilian General Data Protection Law, defined as the "limitation of processing to the minimum necessary for the accomplishment of its purposes, with scope of the relevant, proportional and not excessive data in relation to the purposes of data processing" (Art. 6, III, Law No. 13.709/2018, Brazil). For this reason, and because Inloco has the commitment of being transparent, we detail all the data that are collected through our website and for which purposes below.

“Fale com vendas” Form

Category

Description

Purposes

Contact

Name

Lead registration

Product communication

Targeting [1]

Marketing campaigns [1]

Last name

Corporate email

Phone number

[1] Only if authorized by the data subject

“Contato” Form

Category

Description

Purposes

Contact

Name

Contact with a specific area or team at Inloco for the purposes intended by the subjects themselves, including: answering questions; establishing partnerships; producing journalistic articles; obtaining information about job opportunities, etc.  

Last name

Email

Phone number

Chatbot

Category

Description

Purposes

Contact

Name

Answer questions on general topics

Direct the data subject to a member of the Inloco team that can help them

Email

Sensitive data

We do not collect or treat sensitive data - information that reveals ethnicity, religion, political, religious, philosophical opinion or of union entities or data related to health, sexual life, genetics and biometry (Art. 5, II, Law No. 13.709/2018, Brazil).

Child data

As we do not collect data that allow us to know age information, it is not possible to detect whether the individual in contact with us is a child. However, we consider that our website is directed to the adult audience, especially with regard to the language used, which makes it unlikely that a child will have access to contact means and provide personal information.

Form and duration of the processing

Automated decision-making

There is no automated decision-making for any of the purposes of personal data processing detailed in this Privacy Policy. All the processing carried out with the data collected through the website contact means has human interference from members of our team.

Security measures

The data referred to in this Policy is collected directly from the data subject, who voluntarily provides it via form or chat, and is used only for the purposes intended and authorized by them. This data is stored in Hubspot and Google Drive cloud storage services, which apply physical, technical and organizational security measures, such as encryption in data transport and storage. In addition, such information is accessed by a restricted number of employees and is stored only for the time required for the purposes described in this Policy.

Data transfer

We only share data with processors, that is, agents who perform data processing on behalf of a controller (in this case Inloco) to facilitate the operation. These processos cannot use the information shared by Inloco for any purpose other than that intended by Inloco itself. They are: Hubspot, for lead registration, targeting, sending marketing campaigns, storage and communication with customers and partners; and Google Drive, for safe data storage.

Controller and processor responsibility

Inloco processes personal data as controller, which is the agent in charge of the decisions regarding the processing, in accordance with Article 5, VI of the Brazilian General Data Protection Law. We use processors Hubspot and Google Drive, as detailed in the "Transfer" section, to facilitate our operation.

According to Chapter VI, Section III of the Brazilian LGPD, the controller or processor who causes another person patrimonial, moral, individual or collective damage due to the processing of personal data is obliged to repair it. In addition, when the processor fails to comply with the obligations of the data protection legislation or when it has not followed the lawful instructions of the controller, the processor is jointly liable for the damage caused by the processing, as well as the controllers directly involved in this processing. Processing agents (controller and/or processor) will be held liable unless they prove that they have not carried out the processing of personal data assigned to them; that there has been no violation of data protection legislation; or that the damage is due to the exclusive fault of the data subject or third party.

Rights of the data subject

Inloco's mission is to respect your privacy and ensure the protection of your data. Therefore, we guarantee the exercise of the rights of the data subject as provided for in the Brazilian General Data Protection Law (LGPD) and the General Data Protection Regulation of the European Union (GDPR). Below is a simplified list of the rights of the data subject provided for in Chapter III of the LGPD and Chapter III of the GDPR, which can be requested via email 'dpo@incognia.com'.

  • Right to confirmation of the personal data processing
  • Right of access to data
  • Right to correction of incomplete, inaccurate or outdated data
  • Right to anonymization, blocking, deletion or restriction of unnecessary, excessive or processed data in breach of the law
  • Right to data portability
  • Revocation of consent ("opt-out")
  • Right to delete data processed with user consent
  • Information on refusing to consent and consequences
  • Right to review automated decisions
  • Right not to be subject to automated decision-making

In addition to the above rights, the data protection laws guarantee the right of access to information, which allows the subject to obtain certain information about the processing of data, and the right to information of the public and private entities with which Inloco performs shared use of data, both which are already duly detailed throughout this Policy.

Contact

If you have any questions, comments or suggestions, please contact our Data Protection Officer by sending an email to 'dpo@incognia.com'.