Updated on January 25, 2022

CyberLabs Produtos e Serviços Tecnológicos S.A., registered with CNPJ no. 28.487.683/0001-72 (“CyberLabs”, “we”), respects your privacy, and considers data protection a top priority.

We have created this privacy policy (“Privacy Policy”) to inform you about the types of information we collect, how we may use and share such information, and to provide details about your privacy rights.

This Privacy Policy should be read carefully to understand our policies and practices relating to the information we collect about individuals or entities that license the use of our Services (as defined below) in connection with their own products and services (“Licensees”), users of our Licensees’ products and/or services (“Licensee Users”), and other individuals that interact with our websites or Services. We refer collectively to all types of users of our Services herein as “you” or “your.”

This Privacy Policy applies to the https://getperse.com website (and its subdomains), and all other features of the websites, mobile applications or online services owned or controlled by CyberLabs and which contain a link to this Privacy Policy, as well as to all products, programs, software and services offered by each of them (collectively, the “Services”), and is an integral part of the License and Services Agreement applicable to Licensee users of the Services.

By visiting any part of our Services or providing/sharing information to CyberLabs by any means, you agree to the practices and conditions described in this Privacy Policy. Use of the Services (following the publication of this Privacy Policy), set out below, means that you accept and agree to the terms of this Privacy Policy, so please check this Privacy Policy periodically for updates. This Privacy Policy applies only to users of the Services that are located outside of Brazil. If you are located in Brazil, please see our Brazilian Privacy Policy by clicking here.

TABLE OF CONTENTS:
I. IMPORTANT INFORMATION AND WHO WE ARE
II. INFORMATION WE COLLECT
III. THE SOURCES FROM WHICH WE COLLECT YOUR INFORMATION
IV. USE OF INFORMATION BY CYBERLABS
V. HOW WE DISCLOSE INFORMATION
VI. YOUR CHOICES RELATED TO YOUR INFORMATION
VII. PROTECTING YOUR INFORMATION
VIII. INFORMATION FOR INTERNATIONAL USERS
IX. PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS
X. CONTACT INFORMATION

I. IMPORTANT INFORMATION AND WHO WE ARE

A. APPLICATION OF THIS PRIVACY POLICY
This Privacy Policy applies exclusively to CyberLabs’ Services related to the Perse product, accessed via computer, mobile device, or other means by individuals outside of Brazil. Therefore, this Privacy Policy does not apply to the use of any other unaffiliated sites that link to and/or contain links to the Services.

B. OBJECT OF THIS PRIVACY POLICY
This Privacy Policy is intended to provide information about how CyberLabs collects and treats the information it collects, including any information you may provide through the Services by registering to receive information or communications, or to use Perse.

It is important that you read and understand this Privacy Policy in conjunction with any other privacy or data processing notice that we may provide in connection with use of the Services. This Privacy Policy supplements other notices and documents and does not replace them.

C. CHILDREN AND ADOLESCENTS
The Services are not designed or directed to minors under the age of 18, and CyberLabs does not knowingly collect information from such minors. If CyberLabs determines that we have inadvertently collected information in identifiable form from minors under the age of 18, measures will be taken to delete such information, as well as to prevent such users from using the Services.

If you are under the age of 18, please do not access or use the Services or provide us with any information. If you believe that we may have information from any minor under the age of 18, please contact us at suporte@cyberlabs.com.br.

D. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM ABOUT CHANGES
This Privacy Policy has been last updated on the date indicated at the top of the Privacy Policy, and you can obtain previous versions by contacting us.

We reserve the right, at any time and without notice, to add, change, update or modify this Privacy Policy by posting such change, update, or modification on the Services. Continued use of the Services following such changes will indicate your agreement to such changes. However, if we make any material changes to this Privacy Policy, we will provide notice and comply with any other obligations in accordance with applicable law. Please review this Privacy Policy regularly.

E. THIRD PARTY CONTENT, LINKS TO OTHER PLATFORMS, AND CYBERLABS CONTENT FOUND OUTSIDE THE SERVICES
This Privacy Policy covers only our use and disclosure of information collected through the Services. If a Licensee uses or discloses information in a manner other than that covered by this Privacy Policy, the provisions of this Privacy Policy will not apply, as we do not control the privacy practices of third parties, including Licensees. Licensee Users are responsible for reviewing the privacy policies of Licensees to understand more about their practices.

The Services may contain content or links to other platforms that are not owned or controlled by CyberLabs. CyberLabs has no control over, does not review, and is not responsible for the privacy policies or content displayed on other platforms. By clicking on certain links, you will leave the Services and be directed to another platform. During this process, another entity that owns such platform may collect information from you. You are responsible for reviewing the privacy policies of such other platforms.

In addition, CyberLabs content (such as but not limited to advertising) may be included on platforms and websites not associated with CyberLabs, over which CyberLabs has no control. Such third parties may collect data through the use of their own cookies, pixel tags or other technologies. They may also collect information independently or request your information, as well as track the use of Licensee’s platforms, and CyberLabs is not and will not be responsible for the privacy practices of any third-party content.

II. INFORMATION WE COLLECT
We and our third-party service providers may collect, use, store and transfer different types of information depending on how you use the Services as follows:

  • Identity Information including, if you register for the Services or otherwise contact us using a webform or otherwise, real name, email address, or similar identifier;
  • Contact Information including, for Licensees that registered with us, business name, DBA if applicable, contact name, company ID or Tax ID, billing or company address (including zip code and country), phone number, and contact email address (used to log in to the service or contact us);
  • Financial Information including, for Licensees that registered with us, payment-related information such as, if applicable, bank account or payment card details (including cardholder name and billing address);
  • Transaction Information including, for Licensees that registered with us, details about payments to and from such Licensees, as applicable, and other details of products or services Licensees have purchased from us;
  • Facial Biometrics – images and biometrics of the face or voice of Licensee Users, as well as of Licensees that use biometric solutions to access the Services;
  • Technical Information – internet protocol (IP) address, uniform resource locator (“URL”), operating system/version/language, browser, and time zone during a login attempt;
  • Online identifiers, including identifiers that can be used to recognize a user or device over time and across different services, including, but not limited to, an internal customer/ID number, unique alias, or user alias;
  • Profile Information including the email address used to log in to the Services or contact us, feedback (if you choose to share with us), consent data such as records of your agreement to our terms (date, time and IP address relating to acceptance of the Privacy Policy, License Agreement, DPA, and Terms of Use), and responses to surveys (if any);
  • Usage Data including information about your use of our Services, including areas visited and/or parts of our Services used, among other usage information;
  • Inference Data, which is data we derive about your personal characteristics, such as demographics, to improve our Services and associated algorithms; and
  • Marketing and communications information including your preferences to receive communications, including third-party marketing and communication preferences.

III. THE SOURCES FROM WHICH WE COLLECT YOUR INFORMATION
We and our third-party service providers use different methods to collect information from and about you as you access or use the Services, including:

Direct Interactions. You will provide us with identity, demographic, contact, financial, profile or marketing and communications information if you engage in the following activities:

  • purchase or subscribe to our Services;
  • create an account through the Services;
  • subscribe to emails, newsletters, or newsletters;
  • requests services (including demos) or other information;
  • participates in a competition, contest, promotion, or research;
  • register for an event or participate in an event in which we participate; or
  • provide feedback about the Services.

Automatic Collection of Information Through Technologies and Use of the Services. When interacting with the Services, we may automatically collect Technical Information, Online Identifiers, and Usage Information as described above. We collect this information using cookies, pixel tags, embedded scripts, and other similar technologies.

Cookies are small data files that a website sends that are stored on your browser while you are viewing a website. Cookies can be used for many purposes, including to monitor website usage, customize content specific to your interests, ensure that you do not see the same ad repeatedly, speed up your searches and purchases, and recognize a user when they return to the website in the future. You can choose to refuse, block, and/or delete cookies through your browser settings. However, if you choose to disable cookies on your device, some features of our Services may not work correctly.

Please note that this Privacy Policy only applies to cookies and similar technologies that are placed by CyberLabs and any service providers performing services on our behalf. This Privacy Policy does not cover the placement of cookies by third-party advertising networks or other third-party services.

IV. USE OF INFORMATION BY CYBERLABS
We use the information we collect to provide services and features that may be tailored to the needs of our users and to customize the Services. We (and our third-party service providers performing services on our behalf) use the information we collect, as follows:

Provision of services:

  • to provide and make available access to and use of the Services to you;
  • to process and register the creation of an account with the Services, including verification of active and valid contact information (provided in an account registration);
  • to identify users on our system;
  • to provide information, products, or services that you have requested or agreed to receive;
  • to provide and improve the administration of our Services;
  • to process transactions and/or payments, where applicable.

Compliance and operations:

  • to send administrative notifications by email, such as order confirmations, order status updates, security, or support and maintenance notices;
  • for fraud prevention and security, including the application and compliance with our Terms of Use and this Privacy Policy, protecting our rights, security, or property and/or rights of you or others, protecting against or investigating fraudulent, harmful, unauthorized, unethical or illegal activities;
  • to fulfill our obligations and enforce our rights arising from any contracts entered into between us;
  • to notify you of changes to our Services;
  • to comply with applicable laws, requests, and legal processes, such as responding to subpoenas or requests from government authorities;
  • to contact you with respect to your use of the Services, and at our discretion, changes to the policies or functionality of our Services;
  • to process a request or perform other functions, as described at the time of collection, with your consent, as described in this Privacy Policy.

Marketing:

  • in accordance with applicable legal obligations, to submit newsletters, surveys, offers and other promotional materials related to our Services, including for CyberLabs’ marketing purposes;
  • to promote our products or services, including recommending products or services that may be of interest to you.

Research and Development:

  • to improve our Services;
  • to present the content of our Services appropriately and effectively to you and your device; and
  • to improve the quality of experience in interacting with our Services.

In addition to the foregoing, we may also use the information we receive from and about you to create de-identified information that can no longer be linked directly to you or your device. Our use and disclosure of such de-identified information is not subject to this Privacy Policy and we retain the right to use and disclose such information for any purposes in our sole discretion.

Our Legal Bases for processing your information. The laws in some jurisdictions require companies to tell you about the legal grounds they rely on to process your information. Our legal bases for processing your information as described in this Privacy Policy are as follows:

  • Where use of your information is necessary to perform our obligations under a contract or commitment to you. For example, to provide the services you’ve requested from us, or to comply with our Terms of Use or the License.
  • Where use of your information furthers our legitimate interests or the legitimate interests of others. For example, to provide security for our Services, operate the Services, make and receive payments, defend our legal rights, and prevent fraud.
  • Where we use your information to comply with applicable legal obligations. For example, keeping track of purchases for tax and auditing purposes.
  • Where you have consented to our processing of your information for a particular purpose.

V. HOW WE DISCLOSE INFORMATION
CyberLabs may disclose your information for the following purposes:

A. CYBERLABS AFFILIATES
We may share the information we collect with affiliated companies, subsidiaries, joint ventures or other companies under common ownership or control with CyberLabs, either now or in the future, for a variety of purposes, including for commercial, operational, and marketing purposes.

B. EXTERNAL THIRD PARTIES FOR LEGAL PURPOSES
CyberLabs cooperates with competent authorities and third parties as reasonably necessary to ensure compliance with the law, for example in areas such as protection of intellectual property rights, data protection, and fraud prevention. Specifically, we transfer and disclosure information in order to:

  • comply, in good faith, with a valid government investigation or legal process, such as a warrant, subpoena, court order, or if, in our discretion, such disclosure is otherwise required by law;
  • obtain or maintain insurance coverage, manage risks, obtain professional advice or establish, exercise or defend our rights in legal proceedings;
  • protect the security, interests, rights, property or security of CyberLabs, you or any third party; or
  • to defend or assert our legal rights in accordance with the terms and policies applicable to the Services or any other agreement you may have with CyberLabs.

C. Third Party Service Providers
We may share information with service providers that perform services on our behalf to improve or facilitate our operations if commercially necessary for the operation of the Services. Such service providers may include, but not be limited to, provides of web hosting services, legal or consulting services, marketing, online advertising, payment processing, and data analytics.

D. FEEDBACK
If you choose to provide us with feedback about CyberLabs or the Services, we may use and disclose such feedback in accordance with our applicable terms with you either with your consent or if shared in a de-identified manner.

E. PUBLICLY DISCLOSED INFORMATION
The Services may contain areas that allow for public access and posting, such as blogs or comment functionality. This includes, but is not limited to, comments to the CyberLabs blog. You should be aware that any information you provide in these areas may be read, collected, accessed, and used by others who access it, including third parties.

F. SHARING BETWEEN CYBERLABS COMPANIES; BUSINESS TRANSFERS
We may share and disclose the information we collect in connection with or during the negotiation of any merger, financing, acquisition or dissolution, transaction or process involving the sale, transfer, disposal or disclosure of all or a part of our business or assets. In the event of insolvency, bankruptcy or recovery, your information may also be transferred as a business asset. If another company acquires our company, business or assets, that company will own the information collected by us and assume the rights and obligations relating to processing of that information as described in this Privacy Policy. We will comply with applicable legal requirements in the event of such transfers.

VI. YOUR CHOICES RELATED TO YOUR INFORMATION
YOU CAN STOP THE FURTHER COLLECTION OF INFORMATION FROM YOU BY OUR SERVICES BY UNINSTALLING THE SERVICES AND CEASING USE OF THE SERVICES.

In addition, you have several options regarding how we process your information:

A. OPTING OUT OF MARKETING COMMUNICATIONS
As explained above, in accordance with applicable legal requirements, we may send you marketing communications regarding the Services and other topics we believe will be of interest to you. You can manage the frequency and/or opt out of receiving these communications by clicking the “Unsubscribe” link at the bottom of such emails. It may take some time, in accordance with applicable legal requirements, to process your request. Please note that even if you unsubscribe from these marketing communications or disable the Services, we may still send transactional communications related to the Services, including notices of any updates to our Terms of Use, License Agreement or Privacy Policy.

B. COOKIES
If you decide at any time that you no longer wish to accept cookies from the Services for any of the purposes described above, you may configure your browser to stop accepting cookies or warn you before accepting a cookie from the websites you visit. See your browser’s technical information for more information on how to do this. However, if you do not accept cookies, you may not be able to use all parts and/or features of the Services.

C. ACCESS, UPDATE, CORRECT OR DELETE INFORMATION
Depending on the applicable laws in your jurisdiction of residence, you may be able to request to review, access, modify, delete, or correct your information, or otherwise request more information about how we process your information. To make such a request, please contact us at dpo@cyberlabs.ai explaining the right you are requesting. Please note that we may be required to verify your identity before processing your request, and that we may not be able to comply fully with your request depending on applicable exceptions in your jurisdiction of residence. We may also retain an archived copy of your request for legal compliance purposes.

VII. PROTECTION OF YOUR INFORMATION
CyberLabs uses a variety of technical and organizational measures to help protect your information from accidental loss, or from being used, accessed, altered, or disclosed in an unauthorized manner. However, please note that no system can be completely secure and, while we implement a variety of measures to protect the integrity of your information, we cannot ensure or guarantee the security of any information we collect. Therefore, by using our Services, you provide your information at your sole risk.

The security and protection of your information also depends on you. By indicating an email to receive an access token, or by using an authentication/encryption key to create or access your account and/or certain parts of our Services, you are responsible for maintaining the security and confidentiality of your account information. If you have any indication of unauthorized use of your account or the Services, please contact us using the contact information below. Licensees are solely responsible for ensuring the security of Licensee User accounts in accordance with the terms of the License.

VIII. INFORMATION FOR INTERNATIONAL USERS
Please note that the Services involve the processing of your information in Brazil and the United States, which may have different data protection laws than your jurisdiction of residence. By accessing or using the Services, you acknowledge and agree that your information may be transferred to and processed in these locations, and in other locations by our service providers (e.g., AWS).

IX. PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS
If you are a California resident, California law requires us to provide you with additional information regarding how we collect, use, and share your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). For specific information about the categories of personal information we collect, the sources from which we collect it, and how we use and share it, please see Sections 2-5 of this Privacy Policy. Please note that the CCPA sets forth certain obligations for businesses that “sell” personal information to third parties, and considers some online advertising and analytics services to constitute “sales” of data. If you are a California resident and you would like to opt out of our “sale” of your information for these purposes, please click here. Please note that we do not and will not “sell” biometric information.

The CCPA further allows you to make certain requests about your personal information (e.g., requests for more information, access, or deletion). The CCPA also provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights. If you would like to exercise any of these rights, please see the information above in Section VI(c) or complete this form.

You can also request a list of all the third parties to which we have disclosed certain personal information (as defined by CA law) during the preceding year for those third parties’ direct marketing purposes by contacting us using the contact information below.

X. CONTACT INFORMATION
If you have any questions or concerns about this Privacy Policy or our data collection and/or processing practices, please contact us by email suporte@cyberlabs.com.br or by post by sending a letter to:

Cyberlabs Produtos e Serviços Tecnológicos S.A.
Rua Sorocaba, 240 – Botafogo, CEP 22271-110
Rio de Janeiro/RJ – Brazil

CyberLabs’ DPO is GEP Soluções em Compliance