Privacy Policy

When the USER accepts this Privacy Policy, he gives his free and express agreement to the terms stipulated herein.


  1. Glossary


1.1. For the purposes of this document, the following definitions and descriptions should be considered for your better understanding:


Account: It is the way in which the USER is represented when accessing certain restricted areas, exclusive features of the sites, applications and services offered by, usually corresponding to a set of data that represents the USER (such as registration data) and other relevant data for ensure SMARTCONN CORPORATE SOLUTIONS ‘most appropriate and complete relationship with the USER (as a record of activities performed by the USER on the websites, applications and services offered by SMARTCONN CORPORATE SOLUTIONS).

Cookies: Small files or data packages sent by SMARTCONN CORPORATE SOLUTIONS to the USER’s device to identify him and collect information that will help SMARTCONN CORPORATE SOLUTIONS to improve the services provided to the USER.


Credentials: It is the data set that the USER uses to authenticate himself when accessing certain restricted areas and / or exclusive features of the sites, applications and services offered by SMARTCONN CORPORATE SOLUTIONS. Generally, such data is login and password, but may include additional data to assist in the authentication process.

Data: Anonymous Data Set and Personal Data.


Anonymous Data: Information that, alone or in conjunction with other Anonymous Data, does not allow the identification of a person, considering the use of reasonable and available technical means at the time of treatment. They may include gender, age and geolocation (such as the city you are in) and statistical data.


Personal Data: This is information related to the identified or identifiable natural person. They may include, for example, name, address, e-mail, telephone, debit / credit card number, IP address and geolocation data.

Data Protection Officer (DPO): Person (natural or legal) appointed by SMARTCONN CORPORATE SOLUTIONS responsible for acting as a communication channel between SMARTCONN CORPORATE SOLUTIONS, the USER and government authorities in matters related to this Privacy Policy and use, data collection and treatment by SMARTCONN CORPORATE SOLUTIONS.

IP Address: Internet Protocol address associated with the device used by the USER. Each IP Address corresponds to an alphanumeric set that, together with other information, helps to uniquely identify the device that the USER is using to access the internet and, therefore, to access websites, applications and services offered by SMARTCONN CORPORATE SOLUTIONS.


Applicable Legislation: Means the legislation applicable to the relationship between SMARTCONN CORPORATE SOLUTIONS and the USER, which may vary due to (i) the place where the services are provided; (ii) place of residence or residence of one of the Parties, including the USER itself; (iii) other factors pointed out in specific legislation.

Logs: Records of USERS ‘activities carried out on the websites, applications and services provided by SMARTCONN CORPORATE SOLUTIONS.


  1. Data Collection

We collect USER Data as it provides us, directly or indirectly, in accessing and using the sites, applications and services offered by SMARTCONN CORPORATE SOLUTIONS or by partners who have been duly authorized by SMARTCONN CORPORATE SOLUTIONS (and who follow the guidelines of data privacy of SMARTCONN CORPORATE SOLUTIONS in accordance with this policy).

2.1. Data will be collected:

(i) when inserted or submitted voluntarily by USERS on the websites, applications and services offered by SMARTCONN CORPORATE SOLUTIONS, such as creating an Account, browsing, interacting with content and purchasing services;

(ii) when the USER submits Data from third parties to SMARTCONN CORPORATE SOLUTIONS (such as friend data), SMARTCONN CORPORATE SOLUTIONS may use it in accordance with this Privacy Policy, declaring the USER that it has obtained the necessary consent and authorization from concerned third parties to submit this Data for knowledge and registration by SMARTCONN CORPORATE SOLUTIONS, maintaining SMARTCONN CORPORATE SOLUTIONS indene;

(iii) when the Data is submitted automatically and without the need for any action on the part of the USERS, such as through Cookies; or

(iv) from partners who have obtained authorization to share them with SMARTCONN CORPORATE SOLUTIONS.

2.2. The information that SMARTCONN CORPORATE SOLUTIONS collects may include, but is not limited to:

(i) name;

(ii) CPF;

(iii) e-mail address;

(iv) postal address;

(v) telephone number and recordings (in contact with the USER);

(vi) date of birth;

(vii) payment information;

(viii) information about the device’s browser and operating system;

(ix) IP address;

(x) pages visited;

(xi) clicked links and buttons;

(xii) contact list;

(xiii) biometric data;

(xiv) gender.

2.3. SMARTCONN CORPORATE SOLUTIONS is not responsible for the veracity, inaccuracy or outdated information and data provided by the USER, and it is the responsibility of the USER to provide them with accuracy and to update them. SMARTCONN CORPORATE SOLUTIONS may request, from time to time, that the USER update the information provided and the Data provided.

2.4. SMARTCONN CORPORATE SOLUTIONS uses Cookies and anonymous identifiers for audience control, navigation, security and advertising, and the USER agrees to this use by accepting this Privacy Policy.

2.5. SMARTCONN CORPORATE SOLUTIONS will also record the activities performed by the USER on the websites, applications and services provided by SMARTCONN CORPORATE SOLUTIONS by creating logs that may include, but are not limited to:

(i) USER’s IP address;

(ii) Actions performed by the USER on the websites, applications and services provided by SMARTCONN CORPORATE SOLUTIONS;

(iii) Addresses of the pages and screens accessed by the USER on the websites, applications and services provided by SMARTCONN CORPORATE SOLUTIONS;

(iv) Dates and times of each USER action on the websites, applications and services provided by SMARTCONN CORPORATE SOLUTIONS, in addition to the access you make to the pages and screens and the tools and features you use;

(v) Information about the device used by the USER, operating system version, browser, among other installed applications and software;

(vi) Session and User ID, when available;

(vii) USER connection type, such as Wi-Fi or cellular networks (EDGE, 3G and 4G, for example);

(viii) Geolocation.

2.6. Other technologies may be used to obtain navigation data from the USER. However, they will always respect the terms of this Privacy Policy and the USER’s options regarding its collection and storage, and the USER will be informed in advance in case of any changes. If data other than those previously listed starts to be collected, the USER will be previously informed. The information collected by SMARTCONN CORPORATE SOLUTIONS may be combined with information collected by other sources (including third party partners) or from other technologies.






  1. Use of Data

The Data may be accessed only by SMARTCONN CORPORATE SOLUTIONS, partners, subcontractors and authorities. However, if the USER accesses partner sites or features, he will be subject to the practices and policies of those partners. We also list the uses we will make of the Data collected from USERS.

3.1. Data collected from USERS may be used for the following purposes:

(i) Identification, authentication and authorization;

(ii) To adequately attend to requests and doubts, as well as provide support to USERS;

(iii) Keep records updated for purposes of contact by telephone, electronic mail, SMS, direct mail or other means of communication;

(iv) Improve the use and interactive experience when browsing the websites, applications and services provided by SMARTCONN CORPORATE SOLUTIONS;

(v) Carry out statistics, studies, research, project planning and surveys relevant to the activities and behaviors of the USER when using the sites, applications and services provided by SMARTCONN CORPORATE SOLUTIONS, carrying out such operations in an anonymous way with Anonymous Data;

(vi) Promote the services of SMARTCONN CORPORATE SOLUTIONS and its partners, in addition to informing about news, features, content, news and other information relevant to maintaining the relationship with SMARTCONN CORPORATE SOLUTIONS;

(vii) Safeguard SMARTCONN CORPORATE SOLUTIONS from rights and obligations related to the use of the websites, applications and services provided by SMARTCONN CORPORATE SOLUTIONS;

(viii) Collaborate and / or comply with a court order or request by an administrative authority, as well as meet obligations to report certain activities preventively to competent authorities;

(ix) Proceed with payment requests made by USERS;

(x) Send newsletters and emails that the USER has expressly agreed to receive;

(xi) Manage risks and detect, prevent and / or remedy fraud or other potentially illegal or prohibited activities, in addition to violations of applicable policies or terms of use;

(xii) Share payment information between SMARTCONN CORPORATE SOLUTIONS companies, in order to facilitate the experience of USERS when using the sites, applications and services offered by SMARTCONN CORPORATE SOLUTIONS; and

(xiii) Consult the Data in private and public bureaus to check if they are correct, update them or request additional data.

3.2. The use, access and sharing of the database formed under the terms of this Privacy Policy will be made within the limits and purposes of SMARTCONN CORPORATE SOLUTIONS activities, and may be provided and made available for access and / or consultation for SMARTCONN CORPORATE SOLUTIONS companies in addition to business partners, suppliers, service providers, subcontractors, authorities or third parties in general, provided that the provisions of this Privacy Policy, the Applicable Legislation or by court order are obeyed. USER sensitive data, such as personal data about racial or ethnic origin, religious belief, political opinion, union membership or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a natural person, will be shared exclusively with the consent of the USER.

3.2.1. USERS ‘Data may be shared with entities located outside the USER’s country of residence (such as countries in the European Economic Area, South America or North America). In such cases, the processing, treatment, use and sharing of the Data will be done in accordance with the Applicable Legislation and the present Privacy Policy. In particular, when data originating from the European Economic Area is transferred to countries that have not been recognized by the competent authorities as offering an adequate level of protection, SMARTCONN CORPORATE SOLUTIONS will guarantee the use of the appropriate tools and measures (such as the Standard Contractual Clauses European Commission).

3.2.2. SMARTCONN CORPORATE SOLUTIONS is committed to safeguarding the financial and banking secrecy of its customers and USERS by not sharing this information with companies with which the USER has not agreed. The USER acknowledges that SMARTCONN CORPORATE SOLUTIONS is obliged to comply with a series of legal obligations due to the Applicable Legislation related to the identity of its customers and the origin of the funds it operates. Accordingly, SMARTCONN CORPORATE SOLUTIONS is authorized to request, and the USER is obliged to provide, additional documents and information, including for carrying out know-your-client procedures and preventing money laundering. The information obtained by SMARTCONN CORPORATE SOLUTIONS in response to the questions raised will be treated as confidential information. SMARTCONN CORPORATE SOLUTIONS is authorized to share data required by Applicable Law with the competent authorities and with third parties who need access to the Data to prepare / validate reports on the activities of SMARTCONN CORPORATE SOLUTIONS under said legislation.

3.2.3. The USER is responsible for the confidentiality, use and all acts in the use of Credentials (such as, but not limited to, login, password and authentication token). If the USER identifies or suspects that a third party has access to his password, he must change it directly in the systems or services. The sharing of Credentials resulting from the action of the USER constitutes a violation of this Privacy Policy.

3.3. The USER is now aware that SMARTCONN CORPORATE SOLUTIONS may perform (i) the anonymization of Personal Data, making it anonymous data; (ii) the enrichment of its database, adding information from other legitimate sources; and (iii) treatment of Personal Data based on the legitimate interest of SMARTCONN CORPORATE SOLUTIONS, as provided for in the Applicable Legislation. The USER expresses express consent to such activities by agreeing to the terms of this Privacy Policy.

3.3.1. The USER acknowledges and agrees that SMARTCONN CORPORATE SOLUTIONS may use the Data to profile the USER, in order to improve its services or comply with Applicable Law, including, but not limited to, obligations to know-your-client . The USER’s profile will be shared exclusively under the terms of this Privacy Policy or the Applicable Legislation.

3.4. Internally, the Data will only be accessed by professionals duly authorized by SMARTCONN CORPORATE SOLUTIONS, respecting the principles of purpose, adequacy and necessity, among others foreseen in the Applicable Legislation, for the objectives of SMARTCONN CORPORATE SOLUTIONS, in addition to the commitment to confidentiality and preservation of privacy under this Privacy Policy.

3.5. Anonymous Data may be collected, processed, stored, used, transferred and disclosed for any purpose, regardless of the USER’s authorization.


3.6. SMARTCONN CORPORATE SOLUTIONS has business partners that can offer services through features or websites accessed from the websites, applications and services provided by SMARTCONN CORPORATE SOLUTIONS. The Data provided by the USER to these partners will be the responsibility of the partners, thus being subject to their own practices of obtaining and using Data, without any burden being placed on SMARTCONN CORPORATE SOLUTIONS with respect to such Data.

3.7. . SMARTCONN CORPORATE SOLUTIONS values ​​the security and inviolability of the USER Credentials. For this reason, it constantly searches and monitors the internet in its various layers in order to identify, collect and process for purposes of validation (authentication tests) logins and passwords potentially belonging to USERS that have been improperly published on the internet by third parties.

3.7.1. If through authentication tests SMARTCONN CORPORATE SOLUTIONS finds that the USER Credentials have been compromised (made accessible to third parties), SMARTCONN CORPORATE SOLUTIONS – for security and in order to prevent inappropriate third party access to the USER Account and Data – preventively block USER Credentials. If there are any doubts – including how to unlock the Credentials – the USER can consult the terms of use on the websites, applications and services provided by SMARTCONN CORPORATE SOLUTIONS, or contact the SMARTCONN CORPORATE SOLUTIONS NOC.

  1. Data Storage

The collected data is stored in a safe place. At any time, the USER may request the display, correction or deletion of his Data. Except in specific cases, we may keep the Data collected for legal compliance, auditing and preservation of rights, for the period necessary to fulfill these responsibilities.

4.1. The collected data will be stored in a safe and controlled environment. However, considering that no security system is foolproof, SMARTCONN CORPORATE SOLUTIONS disclaims any liability for any damages and / or losses arising from failures, viruses or invasions in the database of the websites, applications and services offered by SMARTCONN CORPORATE SOLUTIONS, except in cases where it is intentional or guilt. However, if SMARTCONN CORPORATE SOLUTIONS identifies that any of these situations occurred, it will notify the affected USERS informing that there was a violation of their Data and indicating that they take the appropriate measures.

4.2. The data obtained from the USER may be stored on SMARTCONN CORPORATE SOLUTIONS ‘own server or from a third party hired for this purpose, whether they are located in Brazil or abroad, and may also be stored using cloud computing technology and / or others that may arise in the future. , always aiming at improving and improving the activities of SMARTCONN CORPORATE SOLUTIONS. SMARTCONN CORPORATE SOLUTIONS will ensure that third parties that eventually maintain the servers on which the Data is stored maintain security and control standards in accordance with applicable legal standards.

4.3. Through the service tools available on the websites, applications and services offered by SMARTCONN CORPORATE SOLUTIONS, it is provided to the USER (and may be subject to proving his identity):

(i) require access to the Data, including its display, rectification with the correction of incomplete, inaccurate or outdated data or the deletion / deletion of the Personal Data that pertains to it;

(ii) require the elimination / deletion of all of your Personal Data collected and registered by SMARTCONN CORPORATE SOLUTIONS, provided that the contract between the USER and SMARTCONN CORPORATE SOLUTIONS has ended, the Account has been canceled and the minimum legal term for the purposes of legal obligations from SMARTCONN CORPORATE SOLUTIONS has elapsed;

(iii) revoke consent for the future collection, treatment, use and processing of Personal Data that pertains to you or restrict the processing of Personal Data. This will not affect the legality of the processing and processing of Personal Data carried out prior to revocation, based on your consent or the legitimate interest of SMARTCONN CORPORATE SOLUTIONS. The revocation of consent may prevent the USER from using it to the full or even make it impossible to use the sites, applications and services offered by SMARTCONN CORPORATE SOLUTIONS;

(iv) request the portability of your Data; and

(v) request that SMARTCONN CORPORATE SOLUTIONS no longer use Personal Data for marketing purposes.

4.3.1. Although the USER has requested the deletion of his data and revoked his consent, in some specific cases SMARTCONN CORPORATE SOLUTIONS may be subject to Laws and regulations that make it impossible to delete / revoke the Data.

4.3.2. The USER’s Personal Data will also be deleted when they are no longer needed, except in the event of legal or contractual justification for their maintenance (for example, to comply with any legal obligation to retain data or the need to preserve these to preserve legitimate rights and interests one of the parties involved in the contract).

4.4. The privacy settings of the USERS and the products and resources that the USER uses influence the USER Data that will be obtained by SMARTCONN CORPORATE SOLUTIONS.

4.5. SMARTCONN CORPORATE SOLUTIONS may, for the purposes of auditing and preservation of rights, remain with the history of registration of USER Data, SMARTCONN CORPORATE SOLUTIONS having the ability to permanently exclude them at its convenience or in the cases in which the law or regulatory rule requires . SMARTCONN CORPORATE SOLUTIONS may also maintain the Anonymized Data and anonymized version of the Data for statistical and study purposes, even after the exclusion request by the USER or after the end of the legal term of custody.

  1. General Provisions:

We can update this document at any time. So, consult it frequently. If we outsource any activity, we will ensure that the contracted companies comply with all the provisions of this document.

5.1. The content of this Privacy Policy may be updated or modified at any time, according to the purpose or convenience of SMARTCONN CORPORATE SOLUTIONS, as for the adequacy and legal compliance of the provision of the law or standard that has equivalent legal force, and the USER is responsible for verifying it. whenever you access the sites, applications or services offered by SMARTCONN CORPORATE SOLUTIONS.

5.1.1. In the event of updates to this document, SMARTCONN CORPORATE SOLUTIONS will notify the USER through the tools available on the websites, applications and services provided by SMARTCONN CORPORATE SOLUTIONS and / or the contact means provided by the USER. The USER will be bound by the new terms of this document upon delivery of notification of updates.

5.2. If the USER considers SMARTCONN CORPORATE SOLUTIONS to have violated any legal provision or this Privacy Policy, the USER has the right to lodge a complaint with the appropriate supervisory authority, in addition to contact SMARTCONN CORPORATE SOLUTIONS directly.

5.3. If outsourced companies process any Data collected by SMARTCONN CORPORATE SOLUTIONS, they must comply with the conditions here stipulated and the SMARTCONN CORPORATE SOLUTIONS Information Security rules, mandatorily.

5.4. If any provision of this Privacy Policy is considered illegal or illegitimate by the authority of the location in which the USER resides or of his internet connection, the other conditions will remain in full force and effect.


  1. Applicable Law and Jurisdiction

In case of legal action, Brazilian law and the jurisdiction of the city of São Paulo apply, unless specifically specified by the Applicable Law (such as the USER’s domicile).

6.1. This Privacy Policy will be interpreted in accordance with Brazilian law, in the Portuguese language, being elected the forum of the city of São Paulo to settle any litigation or controversy involving this document, unless specific proviso of personal, territorial or functional competence by the Applicable Legislation.