Privacy Policy of Actio Software

At Actio, privacy and security are priorities, and we are committed to transparency in the treatment of our users’ and clients’ personal data. This Privacy Policy outlines how we collect, use, and transfer information from clients and others who access or use our system. 

By using our services, you understand that we will collect and use your personal information as described in this Policy, in accordance with data protection laws (LGPD, Federal Law 13.709/2018), consumer protection regulations (Federal Law 8078/1990), and other applicable Brazilian legal provisions. 

Thus, Actio, registered under CNPJ/MF nº 32783967/000183, as the Data Controller, adheres to the terms set forth in this Privacy Policy. 

1. What data do we collect about you, and for what purpose?

Our system collects and uses some of your personal data to enable the provision of services and enhance the user experience. 

2. How do we collect your data?

Your personal data is collected in the following ways: 

When registering an employee/user in the system, personal goals, bonus calculations, or performance evaluations, the data is saved in our database, which is stored in the Amazon Web Services (AWS) cloud. 

2.1. Consent 

We process your personal data based on your consent. Consent is the free, informed, and unequivocal expression by which you authorize Actio to process your data. 

In accordance with the General Data Protection Law, your data will only be collected, processed, and stored with your prior and explicit consent. 

Your consent will be obtained specifically for the purposes described above, demonstrating Actio’s commitment to transparency and good faith with its users/clients, following relevant legislative regulations. 

By using Actio’s services and providing your personal data, you are aware and consent to the provisions of this Privacy Policy, and you understand your rights and how to exercise them. 

At any time and at no cost, you may revoke your consent. 

Refusing to consent to this Policy will result in the blocking of registration fields related to your personal data, such as photo, mobile number, email, LinkedIn, date of birth, gender, social name, race, academic qualifications, languages, previous professional experiences, extracurricular courses, academic training, availability for relocation, and interest in other areas. 

Revoking consent will result in the permanent deletion and blocking of fields related to your personal data. If you consent to this Policy again, it will be necessary to re-register them. 

In any case, you will still be able to use the software. 

It is important to note that regarding the Lift Module – Performance Management, evaluations in your name will continue to be generated and used for performance analyses, regardless of your acceptance of this Policy, as they are considered corporate data, not personal data. 

Moreover, refusal to consent to data processing may affect the proper performance of some system features that depend on the operation. 

3. What are your rights?

Actio ensures its users/clients the rights of data subjects as provided in Article 18 of the Brazilian General Data Protection Law. Thus, you may, free of charge and at any time: 

• Confirm the existence of data processing in a simplified manner or in a clear and complete format. 

• You can access your data and request a readable copy in print or by secure and suitable electronic means. 

• Correct your data by requesting its editing, correction, or updating. 

• Limit your data when unnecessary, excessive, or processed in non-compliance with the law through anonymization, blocking, or deletion. 

• Delete your data processed with your consent, except in cases provided by law. 

• Revoke your consent, disallowing the processing of your data. 

• Be informed about the possibility of not providing consent and the consequences of refusal. 

4. How can you exercise your rights as a data subject?

To exercise your rights as a data subject, you must contact Actio through the following available means: 

• Support contact phone, available on our website. 

• Support contact email available on our website. 

To ensure your correct identification as the data subject of the personal data object of the request, we may ask for documents or other evidence that can prove your identity. In this case, you will be informed beforehand. 

5. How and for how long will your data be stored?

Your personal data collected by Actio will be used and stored during the time necessary for the provision of the service or for the improvement of the user experience, according to the purposes listed in this Privacy Policy, considering the rights of the data subjects and the controller. 

In general, your data will be maintained while the contractual relationship between you and Actio persists. Once the personal data storage period expires, they will be deleted from our databases or anonymized, except in cases legally provided for in Article 16 of the  Brazilian General Data Protection Law, namely: 

I – Compliance with a legal or regulatory obligation by the controller;  

II – Study by a research body, guaranteeing, whenever possible, the anonymization of personal data;  

III – Transfer to a third party, provided the data processing requirements set forth in this Law are respected; 

IV – Exclusive use of the controller, with no access by a third party, and provided the data is anonymized. 

In other words, personal information about you that is essential for compliance with legal, judicial, and administrative determinations and/or for the exercise of the right of defense in judicial and administrative processes will be maintained. 

6. What do we do to keep your data secure?

The data collected by Actio reflects our commitment to the security and privacy of your data. We employ technical protection measures and solutions to ensure the confidentiality, integrity, and inviolability of your data. Additionally, we also have appropriate security measures for the risks and control access to the stored information. 

To keep your personal information secure, we use physical, electronic, and managerial tools designed to protect your privacy. 

We apply these tools considering the nature of the personal data collected, the context and purpose of the processing, and the risks that potential breaches would generate for the rights and freedoms of the data subject whose data is collected and processed. 

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 made after a confidentiality commitment. 

• Your personal data is stored in a secure and suitable environment. 

Actio is committed to adopting best practices to avoid security incidents. However, it is necessary to highlight that no virtual application is entirely secure and risk-free. It is possible that, despite all our security protocols, issues caused solely by third parties, such as cyber-attacks by hackers, or also due to the negligence or imprudence of the user/client, may occur. 

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

7. With whom can your data be shared?

To preserve your privacy, Actio will not share your personal data with any third party. 

8. Changes to this privacy policy

The current version of the Privacy Policy was formulated and last updated on 03/20/2024. 

We reserve the right to modify this Privacy Policy at any time, especially in the event of adjustments to our software or changes in legislation. We recommend that you review it frequently. 

Any changes will take effect from their publication on our website. 

9. Responsibility

Actio provides for the responsibility of agents acting in data processing processes in accordance with Articles 42 to 45 of the Brazilian General Data Protection Law. 

We are committed to keeping this Privacy Policy updated, observing its provisions, and ensuring its compliance. 

Additionally, we are committed to seeking technical and organizational conditions that securely protect the entire data processing process. 

If the Brazilian National Data Protection Authority requires measures regarding Actio’s data processing, we commit to following them. 

9.1 Disclaimer 

As mentioned in Section 6 (What do we do to keep your data secure?), although we adopt high-security standards to prevent incidents, no virtual application is entirely free of risks. In this sense, Actio is not responsible for: 

I – Any consequences arising from the negligence, imprudence, or malpractice of users regarding their individual data. We guarantee and are responsible only for the security of data processing processes and the fulfillment of the purposes described in this document. 

It is noteworthy that the responsibility for the confidentiality of access data lies with the user. 

II – Malicious actions of third parties, such as hacker attacks, except if proven to be due to Actio’s fault or deliberate conduct. We emphasize that in the event of security incidents that may pose significant risk or damage to you or any of our users/clients, we will notify those affected and the Brazilian National Data Protection Authority about the incident and will take necessary measures. 

III – The inaccuracy of the information entered by the user/client in the records necessary for the use of Actio’s services; any consequences arising from false or entered-in-bad-faith information are the sole responsibility of the user/client. 

10. Data protection officer

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

Luis Gustavo Bordon 

• DPO contact email: [email protected] 

• Support contact phone, available on our website 

11. Actio cookies policy

This website and Actio software use cookies. Some cookies are necessary to enable basic functions without which the applications cannot function properly. Other cookies are optional and may be placed on your device to improve your experience, collect statistics, optimize application features, and offer tailored content. 

IMPORTANT: Cookies do not allow any files or information to be extracted from the user’s hard drive, nor do they allow access to personal information that did not come from the user or the way they.