Privacy Policy – Last Updated: February 1, 2023
At ContratosDigitais.com, privacy is a priority. This Privacy Policy sets out how ContratosDigitais.com, and its group of companies (“we”, “our”, “us” or “us”) collect and use information from customers and other individuals who access or use our websites, including ContratosDigitais.com and our applications, our web client or professional client, and/or any of our other sites, products, or services that reference this Privacy Policy (the “Services”). By using our Services, you understand that we will collect and use your information as described in this Privacy Policy (collectively, “you”, “your” or “yours”).
If you or your organization has a contract with us and/or has accepted our terms of use, that contract or terms may have privacy terms that also apply to information you provide to us under the contract. Please review the terms of that contract as they may be different or more restrictive than the terms in this Privacy Policy.
This Privacy Policy does not apply to any third-party websites and applications you may use, including any that are linked from our Services. You should review the terms and policies for third-party websites and applications before clicking on any links.
ContratosDigitais.com’s main products and Services help users generate or upload documents, register signatories and/or users, send documents via the web to collect signatures, with ICP-Brasil certificate, TOKEN and/or with CPF via WhatsApp, collect data from digital or electronic transactions, such as electronically signing a contract or documents of any nature, and/or including a digital signature. As part of our Services, users ask us to collect and record information that helps the parties prove the validity of transactions. This information includes the people who are involved in the transactions and/or signatures, as well as WhatsApp number data of users and/or signatories.
We recommend that you read this Privacy Policy in its entirety to ensure that you are fully informed. All rules contained in this policy are intended to help ensure the security of your data and its use, complying with the legal requirements of the BRAZILIAN GENERAL DATA PROTECTION LAW (LGPD) – Law No. 13,709/2018.
How We Collect Information
To provide and improve our Services and support advertising and marketing, we collect information about visitors to our websites, users of our Services, the devices they use, and sometimes their locations.
We collect certain information directly from you when you fill out forms such as your name, email address, industry, phone number, and/or how you heard about us. We collect other information, typically about devices, web browsers, or locations, automatically (without you having to provide it to us on a form). We may also collect information about you from other sources, such as referrals from friends, about our services, in the belief that you may be interested in our Services.
You may choose to visit our websites, take a free trial, create a free account and/or provide information to us. However, if you do not provide us with certain information, you will not be able to use some parts of our Services. For example, if you do not provide your CPF and/or CNPJ, you will not be able to contract our solutions or even inform who will be the people authorized to access the system and view the respective documents.
Information We Collect from You. You provide us with information about yourself when you:
Register or log in to your account
Create, sign, or review an electronic document
Create or edit your user profile
Contact customer support
Comment on our blogs or community forums
Examples of information you provide are: name, email address, mailing address, telephone number, billing information, or electronic signature.
You also provide us with information about others when you use parts of our Services, for example when you:
Creates or participates in an electronic transaction, as a signatory on a document
Add others as members of an existing account
Refer friends
Information We Collect Automatically. We automatically collect information from you and your devices when you use our Services, even when you visit our websites or apps without logging in. About the choices you have about what information we collect automatically.
The information we collect automatically includes:
Device, Usage and Transactional Information. We collect information about how you use our Services and the computers or other devices, such as mobile phones or tablets, you use to access our Services. Some examples include:
IP Address
We may use applications to collect precise geolocation that you allow our applications to access (typically from your mobile device)
Unique device identifiers and device attributes such as operating system and browser type
Usage Data, such as: web log data indicating entry and exit pages, platform type, number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the time spent on particular pages, the date and time you used our Services, the frequency of your use of our Services, error logs, and other similar information
Transactional data, such as: names and email addresses, CPF, WhatsApp number of the parties to a transaction, subject, history of actions that individuals take with the transaction (e.g., review, sign, enable features) and information about those individuals or their devices, such as name, email address, IP address, and authentication methods.
Cookies and Related Technologies. We may use cookies, which are text files containing small amounts of information that are saved on your device (“Cookies”), or related technologies, local shared objects and tracking pixels to store and collect information. We also allow others to use Cookies in connection with the Services as described below. Cookies may store your preferences, your username and assist in personalizing advertising.
Analytics. We use services such as Google Analytics. These services use Cookies to collect usage data and help us understand how people use our Services, such as the pages they visit and for how long and the website or page they were on before coming to the ContratosDigitais.com website.
Personalized Advertising.
Advertisements for Other Products & Services. Third parties whose products or services are offered on our Services may place or read Cookies on your computer or other device to collect information. They do this to (i) personalize and serve ads based on information such as your past visits to our Services and other websites; and (ii) report the number of ads you see and your responses to those ads;
Information We Collect from Other Sources. We may collect information about you from other places, such as:
Third Party Sources. Examples of third party sources include merchants, partners, researchers, affiliates (such as companies affiliated with ContratosDigitais.com), service providers, and others who are authorized by you to share your information with us. For example, if you register for our Services on another website, that website may provide us with information that you authorized for viewing by its business partners.
Other Customers. Other customers may provide us with their information. For example, if a customer expects you to sign an electronic document on our Services, he or she will provide us with your name and email address.
Combining Information from Different Sources. We may combine information we receive from other sources with information we collect from you (or your device) and use it in the ways described in this Privacy Policy.
Information We Collect and Process on Behalf of Customers. When our customers use our Services, we process and store certain information on their behalf as a data processor. For example, when a customer (or the customer’s Authorized Users) submits contracts or other documents for review or signature, we act as a data processor and process the documents on the customer’s behalf and in accordance with their instructions. In such cases, the customer is a data controller and is responsible for most aspects of the processing of the information. If you have any questions or concerns about how information is processed in such cases, including how to exercise your rights as a data subject, we encourage you to contact the customer and obtain the appropriate authorizations.
Use of Information and Access
In general, we collect, use, store, and process your information to provide our Services, to service and improve them, to develop new Services, and to promote our companies and their products and Services. Below are some examples of how we use the information we process:
Provide you with the Services and products you have requested and bill you for them
Send you records of our relationship, including for purchases or other events
Offer you special features, products, or events via email or telephone, or send you advertisements about third-party products and services we believe may be of interest to you, given your consent
Record details about what happens to electronic documents, such as who viewed and/or signed, the devices used, and when these events occurred
Create and review data about our users and how they use our Services
Test changes to our Services and develop new features and products
Fix problems you may have with our Services, including answering support questions or resolving disputes
Manage the Services platform, including support and security systems (Each user’s information is restricted to each sector and/or user according to the permissions granted by the digital contracts / TXR solutions security manager, in addition to using judicious and robust access methods. We also emphasize that all security criteria used in the organization, whether in the digital and/or physical environment, are limited by physical security barriers, whether with hexadecimal passwords, protected rooms and in addition to individual contracts that govern the responsibilities and confidentiality of each employee according to the area of activity.
Prevent, investigate, and respond to: fraud, unauthorized access to or use of our Services, violations of terms and policies, or other malicious behavior
Comply with legal obligations
Comply with legal retention periods
Other Uses.
We may combine the information we collect (“aggregate”) or remove portions of the information (“de-identify”) to limit or avoid identifying any particular user or device in order to assist with research and advertising purposes. This Privacy Policy does not apply to our use of such aggregated or de-identified information.
We will normally collect or use information about you or others only where we have your consent to do so, where we need the information to perform our functions relating to our contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may have a legal obligation to collect or retain personal information or need the personal information to protect your vital interests or those of another person. For example, where we:
We use information to create and manage a Thing, we need the information to provide the related Services.
We collect and record data associated with the use of a digital certificate or digital signature, we do this to comply with regulations.
We use your name and email address for email marketing purposes, we do so with your consent (which you can withdraw at any time).
We collect usage data and analyze it to improve our Services, we do so based on our legitimate interest in protecting and improving our Services.
If you have questions or require further information regarding the legal basis on which we collect and use your personal information, please contact us using the contact information provided in Section 10 of this Privacy Policy.
Information Sharing
We share information as follows:
Service Providers. We share your information with other companies that we use to support our Services. These companies provide services such as intelligent search technology, intelligent analytics, advertising, authentication systems, billing, fraud detection, and customer support. We have contracts with our service providers to protect and use your personal information appropriately.
Affiliates and/or independent consultants. We may share your information with other people and/or companies under common ownership or control of ContratosDigitais.com. These companies and/or people use your information in the manner described in this Privacy Policy.
Advertising Partners. We may share your information with sponsors of events, webinars or sweepstakes for which you have registered and previously authorized, or other parties with whom we may engage in joint marketing activities.
Government or Public Authorities. We may share your information to comply with applicable laws, or to respond to legal process (such as a court order). We may also share your information when there is a threat to the physical safety of any person, violation of this Privacy Policy or other agreements, or to protect the legal rights of third parties, including our employees, users, or the public.
Business Transactions. We may share your information in connection with a corporate transaction, such as a merger or sale of our assets, or as part of due diligence for such contemplated transactions. If a corporate transaction occurs, we will notify you of any changes in control of your information, as well as the choices you may have.
Consent. We may share your information in other ways if you have asked us to do so or if you have given us your consent. For example, with your consent, we may publish user testimonials that may identify you.
Partners via API integration. We may share your information with API partners. These companies and/or individuals use your information in the ways described in this Privacy Policy.
Your information may also be shared as described below:
Other users. When you authorize others to access, use, or edit content in your account, we share that content with them. For example, if you send a contract to others for review or signature, we make the content of that document available to them.
Third Parties. When you make a payment to another user through our Services, we share your payment method details with the third party that will process the payment chosen by you or the other user.
Public Information.
User Generated Content. When you comment on our blogs or in our community forums, that information may also be read, collected, and used by others.
Information Retention and Security Criteria
We retain your personal information only for as long as it is necessary for the purposes for which we process it. The length of time we retain information depends on the purposes for which we collect and use it and/or as required to comply with applicable law. Where there are technical limitations preventing deletion or anonymization, we protect personal data and limit the active use of such data.
5. Your Choices
This section describes many of the steps you can take to change or limit the collection or use of your information.
Profile. You are not required to complete a profile. If you do, you can access and review that information. If any information is inaccurate or incomplete, you can make changes to it in your account settings.
Marketing Messages. You may opt out of receiving marketing email messages from us. You may opt out of receiving these messages by clicking the “unsubscribe” link in the email message, or unsubscribe. Please note that we may send you a message to confirm that you have opted out of receiving marketing messages. If you are a registered user of our Services, or have engaged in transactions with us, we may continue to send you transactional and relationship-related messages (e.g., subscription or account notifications) after you opt out of receiving marketing messages. If you would like to add your phone number to our Telemarketing Opt-Out Registry, please contact our call center. Please include your first name, last name, company, and phone number. You may also notify us during a telemarketing call that you no longer wish to receive telemarketing calls.
Cookies and Other Related Technologies. You can reject cookies in your internet browser settings. However, if you reject cookies, you may not be able to use some portions of our Services.
To exercise choices about personalized advertising, please visit the following sites (please note that you will still receive advertising, but it will no longer be personalized for you, and that ContratosDigitais.com does not control these services that are offered by third parties):
We do not recognize or respond to “Do Not Track” signals from web browsers.
Device and Usage Information. If you do not want us to see your device’s location, you can turn off location sharing on your device, change your device’s privacy settings, or decline location sharing in your web browser.
Closing Your Account. If you wish to close your account, please log in to your account and open a ticket requesting such action or for more information, contact our support center.
Complaints. We are committed to resolving all valid complaints about your privacy and our collection or use of your personal and/or business data. For questions or complaints about our data use practices or Privacy Policy, please contact us at: [email protected]
Children’s Privacy
Our Services are not designed for, and are not offered to, individuals under the age of 18. We do not knowingly collect or solicit information from minors. We do not knowingly allow minors to use our Services. If you are a minor, please do not use our Services or submit your information to us. We delete information that we become aware has been collected from a minor without verifiable parental consent.
Your Privacy Rights
By using our Services, you:
acknowledges that your information will be processed in the manner described in this Privacy Policy;
consent to having your information transferred to our affiliates and facilities throughout Brazil or elsewhere, to the facilities of the third parties with whom we share such information, as described in this Privacy Policy.
You may have certain rights in relation to your personal data, subject to local data protection laws. These rights may include:
You can also request the following information: how we collect and use your information and why; the categories of personal data concerned; the categories of recipients of your personal data; how we received your personal data; and how long we use or store your personal data or how we determine relevant retention periods.
You also have the right to correct your personal and/or business data. In certain situations, you can request the deletion or cessation of use of your information (and object to the use of your personal data) or the export of your data.
Where we rely on your consent to process your personal data, you have the right to refuse to give consent and/or where you have given consent, to withdraw your consent at any time. This will not affect the lawfulness of the processing before your consent was withdrawn. You can request that we stop using your information for direct marketing purposes at any time.
You may have the right to receive information regarding financial incentives we offer you. You also have the right not to be discriminated against for (as provided by applicable law) exercising certain rights. Please be aware that your rights and choices vary depending on your location. Certain information may be excluded from such requests under applicable law. We need certain types of information so that we can provide products and/or Services to you. If you ask us to delete it, you may no longer be able to access or use our products and/or Services. We will take reasonable steps to verify your identity.
How We Protect Your Information
To keep your information secure, we use physical, electronic, and administrative tools. We apply these tools based on the sensitivity of the information we collect, use, and store, and the current state of technology. We work to prevent unauthorized access or use of personal information. However, we cannot guarantee 100% that our systems are inviolable by criminals and malicious hackers. We store your data on several servers to prevent data and/or document loss. However, this scenario presents some risk, which is not associated with a lack of security criteria for digital contracts, but rather a result of the digital medium in question. For this reason, we cannot guarantee that the information we collect or store will always be protected from unauthorized access, or that it will only be used as described in this Privacy Policy. If any criminal activity is detected, where your data may be at risk, we will notify you through the contact channels registered on our platform, in addition to notifying the competent authorities, such as the National Agency for the Protection of Personal Data (ANPD).
Changes to this Policy
We may change this Privacy Policy to reflect changes in the law, our business, our Services, our data collection and use practices, or advances in technology. Our use of the information we collect is subject to the Privacy Policy in effect at the time such information is used. Depending on the type of change, we may notify you of the changes on this page or by email or request new consents. Please review this Privacy Policy periodically and carefully review any changes to this Privacy Policy.
How to Contact Us
For questions or complaints regarding our use of your information or the Privacy Policy, please contact us at [email protected] or at TXR Soluções’ address.
