Privacy and Cookies Policy
Document contents
Mogi das Cruzes/SP, Brazil — ZIP 08763-150
01Who we are and who this Policy applies to
Solvers Solution Factory LTDA, registered under Brazilian CNPJ No. 04.647.925/0001-80, headquartered at Rua São Camilo de Lelis, 46, Cjto. Santo Ângelo, Mogi das Cruzes/SP, Brazil, ZIP 08763-150 ("Solvers", "we", or "us"), develops technology solutions and provides consulting and software development services to its clients. This Privacy and Cookies Policy ("Policy") clearly and transparently describes how we collect, use, store, share, and protect the personal data of data subjects who interact with our website, platforms, products, and service channels (collectively, the "Services").
This Policy is a translation provided for the convenience of English-speaking visitors. It was prepared in accordance with Brazil's General Personal Data Protection Law — Law No. 13,709/2018 ("LGPD") — and other applicable Brazilian regulations, including the Brazilian Internet Civil Rights Framework (Law No. 12,965/2014) and, where applicable, the Brazilian Consumer Protection Code.
It applies to visitors of our website, customers and users of our products, job applicants, suppliers, and business partners, whenever their personal data is processed by Solvers.
02Definitions
To make this Policy easier to read, some of the terms used here carry the meaning assigned to them by the LGPD:
- Personal data: information related to an identified or identifiable natural person.
- Sensitive personal data: data concerning racial or ethnic origin, religious belief, political opinion, union membership or membership in a religious, philosophical, or political organization, data concerning health or sexual life, genetic or biometric data.
- Data subject: the natural person to whom the processed personal data relates.
- Controller: the party responsible for decisions regarding the processing of personal data — in this Policy, Solvers.
- Processor: the party that processes personal data on behalf of the controller.
- Processing: any operation carried out with personal data, such as collection, use, access, storage, sharing, and deletion.
- ANPD: Brazil's National Data Protection Authority (Autoridade Nacional de Proteção de Dados), the government body responsible for enforcing the LGPD.
- Cookies: small text files stored on a user's device when they access a website, described in detail in Section 12.
03What data we collect
We only collect the data necessary for the purposes described in this Policy. The main categories are:
- Identification and contact data: name, email, phone number, company, and job title.
- Browsing data: IP address, device and browser type, pages visited, time spent, and traffic source.
- Voluntarily provided data: content of contact forms, sign-ups, résumés, and support requests.
- Contractual and business data: information necessary to enter into and perform contracts with clients, suppliers, and partners.
- Cookie and similar technology data: as detailed in Section 12.
04How and when we collect data
- Directly from the data subject: when you fill out a form, contact us, apply for a job opening, or hire our Services.
- Automatically: through cookies and tracking technologies while browsing our website (Section 12).
- From public sources or business partners: where applicable, always observing the stated purpose and the corresponding legal basis.
05Purposes of processing
We use the personal data we collect to:
- Enable access to, browsing of, and use of the website and Services;
- Respond to requests, questions, and business inquiries;
- Provide technical support and customer service;
- Comply with contractual, legal, and regulatory obligations;
- Send marketing and commercial communications, always based on consent or legitimate interest, respecting the right to object;
- Carry out statistical analysis to improve our products and website performance;
- Conduct recruitment and hiring processes;
- Prevent fraud and ensure the security of our systems and information.
06Applicable legal bases
The processing of personal data by Solvers is always supported by one of the legal bases set out in Article 7 of the LGPD, including:
| Legal basis | When it applies |
|---|---|
| Consent | Sending marketing communications and using non-essential cookies. |
| Contract performance | Processing necessary to provide the contracted Services. |
| Compliance with a legal or regulatory obligation | Tax, accounting, labor, and regulatory obligations. |
| Legitimate interest | Improving the Services, information security, and fraud prevention, always weighed against the data subject's rights. |
| Regular exercise of rights | Defense in administrative, judicial, or arbitration proceedings. |
07Data sharing
We may share personal data with:
- Service providers that help us with hosting, email marketing, data analysis, and payment processing, always under contracts with confidentiality and security obligations;
- Public authorities, when required by law, court order, or regulatory request;
- Business partners, strictly to the extent necessary to provide the contracted Services.
08International data transfer
Some service providers used by Solvers (for example, cloud providers and analytics tools) may store or process data on servers located outside Brazil. In such cases, we adopt the safeguards required by Article 33 of the LGPD, such as specific data protection contractual clauses and verification of the level of protection offered by the destination country.
09Data retention and deletion
We keep personal data for as long as necessary to fulfill the purposes for which it was collected, to comply with legal or regulatory obligations, or to allow the regular exercise of rights in administrative or judicial proceedings. Once these periods end, the data is securely deleted or anonymized, except where the law requires mandatory retention — for example, tax and accounting records, whose retention period is set by applicable legislation.
10Information security
We adopt technical and administrative measures to protect the personal data under our responsibility, including access control, encryption, system monitoring, internal information security policies, and ongoing team training.
No system is entirely free of risk. Should a security incident occur that could pose a relevant risk or harm to data subjects, Solvers will notify the ANPD and the affected data subjects under the terms of Article 48 of the LGPD.
11Data subject rights
Under Article 18 of the LGPD, you may request, at any time:
- Confirmation that your data is being processed;
- Access to the personal data processed;
- Correction of incomplete, inaccurate, or outdated data;
- Anonymization, blocking, or deletion of unnecessary data or data processed in violation of the LGPD;
- Portability of data to another service or product provider;
- Deletion of data processed based on consent;
- Information about the public and private entities with which we share data;
- Information about the possibility of not giving consent and the consequences of doing so;
- Withdrawal of consent, at any time;
- Review of decisions made solely based on automated processing of data.
To exercise any of these rights, please contact us at [email protected]. We may request additional information to confirm your identity before responding to your request, and we will respond within a reasonable time.
12Cookies and tracking technologies
Cookies are small text files stored on your device when you visit our website. They help us recognize your browser, remember preferences, and understand how our website is used, allowing us to continuously improve the experience we offer.
| Category | Purpose | Can be disabled |
|---|---|---|
| Strictly necessary | Ensure the website's basic operation (security, navigation, load balancing). | No |
| Performance and analytics | Measure website usage (e.g., most visited pages) to guide improvements, in aggregate and statistical form. | Yes |
| Functionality | Remember preferences, such as language or region, to personalize your next visit. | Yes |
| Marketing and advertising | Used by us or by partners to display more relevant content and ads. | Yes |
Strictly necessary cookies are processed based on legitimate interest and the need for the website to function; the other categories depend on your consent, collected through a banner displayed on your first visit to the website.
13How to manage your cookie preferences
You can manage or withdraw your consent at any time through:
- The cookie preferences panel displayed on our website;
- Your browser settings, which allow you to block or delete cookies already stored;
- Specific opt-out tools offered by analytics and advertising partners (for example, the Google Analytics opt-out add-on).
14Data of children and teenagers
Our Services are business-to-business (B2B) in nature and are not directed at children or teenagers. If we identify that personal data of minors was inadvertently collected without the specific, prominent consent of their legal guardians, such data will be deleted from our records.
15Changes to this Policy
This Policy may be updated periodically to reflect changes in our data processing practices or in applicable legislation. The date of the last update is always indicated at the top of this document. Material changes will be communicated by email or by a notice displayed on our website.
16Data Protection Officer (DPO) and contact channel
In compliance with Article 41 of the LGPD, Solvers maintains a dedicated channel for questions, requests, and complaints related to the processing of personal data.
Use this channel to exercise your rights as a data subject, clarify questions about this Policy, or report any privacy-related concern.
17Governing law and jurisdiction
This Policy is governed by the laws of the Federative Republic of Brazil, in particular the General Personal Data Protection Law (Law No. 13,709/2018) and the Brazilian Internet Civil Rights Framework (Law No. 12,965/2014). The courts of the judicial district of Mogi das Cruzes/SP, Brazil, the headquarters of Solvers Solution Factory LTDA, are elected to settle any disputes arising from this Policy, except as otherwise required by law, particularly consumer protection rules, where applicable.