Privacy Policy

The Mignow, a software from the Essence IT Group, was created with the objective and commitment of bringing digital transformation to companies, through an automatically updated software that uses Artificial Intelligence. 

And it is with this same commitment that we treat the privacy and protection of the personal data of the data subjects to whom we have access. 

We hereby make it clear how we process the data of our clients and users when they browse our website. 

Attention! Before continuing browsing or registering for any feature of our website or platforms, please read all the terms of this document carefully. If you have any questions, please contact us under the terms of the item 8.  

1. GDPR 

The General Data Protection Law - LGPD (Law Nº 13.709/2018) came into force in September 2020 and aims to protect the personal data of a person who is in Brazil, also known as the data subject. 

In summary, the LGPD will apply when: 

  • The data processing operation is carried out in Brazil; 
  • The purpose of the data processing activity is to offer or provide services to people located in Brazil; 
  • The personal data has been collected in Brazil. 

There are two categories of data provided for in the law, "personal data" and "sensitive personal data", as shown below: 

"Personal data" is any data that identifies or makes identifiable a natural person. 
“Personal Sensitive Data" is that which, by its nature, concerns information that deserves greater care, mainly to protect against discrimination, such as data on racial or ethnic origin, religious conviction and political opinion.

Those responsible for processing personal data are the processing agents, known as: "controller", "operator" and we can also have the figure of the "suboperator". 

  • The "controller" is the natural or legal person responsible for deciding on the processing of personal data in their possession.  
  • The "operator" is a natural or legal person who processes personal data on behalf of and in accordance with the instructions of the controller. 
  • The "sub-operator", in the same line, it is any person who assists the operator in carrying out the processing of personal data on behalf of the controller. 

In addition to these essential concepts, so that you understand this document correctly, we have listed other important definitions below: 

Term Concept 
Data owner It's you: the natural person to whom the personal data refers, who may be a client (representative of a particular company) or a user of our platforms. 
DPO (Data Protection Officer) or EPD (Data Protection Officer) It is the DPO, the person we have appointed to act as a communication channel between us, the data subjects, who are you, and the National Data Protection Authority (ANPD). 
Treatment This refers to all the activities we carry out in relation to personal data, including, but not limited to, the following activities: collection, storage, consultation, use and sharing. 
Legal basis These are the legal hypotheses that authorize us to process personal data: it could be your consent, compliance with a legal obligation, performance of a contract, among others. 
ANPD It is the National Data Protection Authority, a federal public administration body, which has powers related to the protection of personal data and privacy and, above all, must monitor compliance with the LGPD. 

2. DATA FLOW DYNAMICS 

We will only be responsible for the processing of your personal data, i.e. controller of this data in the following situations: 

  • When necessary to formalize the contracting of our services; 
  • When they are entered via the website; 
  • In the context of our partnerships; 
  • Prospecting for new clients; 
  • In the relationship with our employees; 

This means that in the above cases, it will be our responsibility to adequately choose the legal bases consistent with the purposes set out in this Policy, to make decisions regarding the nature and length of data storage, as well as to respond directly to requests from data subjects regarding the rights set out in the LGPD. 

3. DATA WE COLLECT 

We may collect your data when you browse our website, contact us, or to formalize the contracting of our services. 

Below are the types of data we can collect directly from you: 

Data set  Personal data 
Registration and hiring data Full name, e-mail address, cell/commercial telephone number, address and CPF. 
Contact details Name, telephone number, e-mail address and company you work for; 

Here are the types of data we can collect indirectly while you browse our website: 

Data set  Personal data 
Navigation data Data collected through cookies, pages visited on our website, information you search for, duration of your visit, geographical location, browser type, duration of visit and pages visited. 
Identification data Identifiers of your electronic devices, such as the IP (Internet Protocol) address of your computer or the MAC address of your cell phone, as well as model, manufacturer, operating system, telephone operator, browser type and connection speed. 

Attention!!! It is important that you understand that if you find links to third-party pages on our website, you should check the Privacy Policy of that third party, as we are not responsible for the data processing carried out by such pages. 

4. COLLECTION PURPOSES 

We will only collect your personal data for specific purposes, avoiding over-collection and the processing of data in a generic manner and without legitimate purposes. 

Below, we list the purposes for which we may collect and process your personal data: 

Purposes 
Contact and prospecting: we ask for your registration details in order to contact you, inform you about our services and answer any questions you may have;  
Hiring: to enable the provision of services; 
Support: preventing and resolving technical or security problems and monitoring the use and performance of services; 
Marketing: we will inform you about other services available, as well as news, features, content, news and promotions relevant to maintaining our relationship with you, always guaranteeing your right to easy access to unsubscribe at any time; 
Market intelligence: we carry out research, studies, statistics and surveys relating to the use of our Platforms; 
Judicial determinations: to comply with legal or regulatory obligations that fall upon the company, as well as for legitimate company purposes that are authorized by the LGPD or other applicable rules; 
ANPD request: where appropriate, respond to requests from the ANPD or other public and government authorities; 

5. SHARING YOUR DATA 

In certain situations, we may share your personal data, such as: 

  • To enable the development of our business activity, or; 
  • To comply with judicial orders. 

Below, we clarify the objectives of the shares: 

Sharing Goal 
Suppliers and partners We may share your data with suppliers who help us carry out our business activity as a whole, and may involve responsible companies: a) the structuring of database and e-mail management tools; b) internal and user service flows; c) our recruitment and selection; d) statistical analysis of customer experience with our services. 

In the cases mentioned above, we assume all responsibilities and guarantee the quality of the contracting of our suppliers and partners, always prioritizing those who keep their business compatible with data protection laws and similar security standards.  

Where applicable, we also ensure that we provide objective and lawful instructions for the processing of shared data. 

6. INTERNATIONAL DATA TRANSFER 

It is possible that some of our systems are hosted on servers located in other countries. international transfer of personal data.  

In these cases, or in any situations where there may be an international transfer, we reinforce our total commitment to only contracting suppliers that adopt security measures and good practices compatible with the level of protection established by Brazilian legislation, as regulated by the ANPD.  

In the absence of regulation, we assure you that we will only carry out international transfers in accordance with art. 33, IX, of the LGPD, and only with companies that adhere to other data protection regulations, such as the European GDPR, the American CCPA and CDPA and the Australian Privacy Act. 

7. RIGHTS OF THE DATA SUBJECT 

Our priority is to maintain an accessible communication channel to facilitate the exercise of your rights as a data subject.  

According to the LGPD, the holder has several rights that can be exercised. Here we list the main rights regarding the processing of your personal data: 

Rights How to exercise them 
Confirmation and access to your data You have the right to request confirmation on whether your personal data is being processed and if so, you can access and verify details about this processing, as well as request copies of this information. 
Correction of your data Once the processing of your data is confirmed, the LGPD ensures that you can correct or delete any of your data that may be incomplete, inaccurate, or outdated. 
Right to information about the sharing of your data You have the right to know the types of public and private entities with which we share your data. We include in item 5 of this Policy an indication of our relationships with third parties that may involve the sharing of personal data.  
Information on the possibility of not consenting to data processing You have the right to receive clear and complete information about the possibility and consequences of not providing consent, where this legal basis is appropriate. 
Withdrawal of consent to data processing If you have consented to any purpose in which your data is processed, you can always choose to revoke your consent. However, this will not affect the legality of sharing data made prior to the revocation request.  
Opposition to the treatment of Data We may also process your data if we have legitimate reasons to do so, such as when necessary to ensure the security of our applications and available resources. In these cases, you may oppose the treatment, if you believe that it does not comply with any legal standard.  
Refuse marketing and advertising You can request to stop receiving marketing materials and announcements through the unsubscribe link provided in the body of the marketing email sent to you.  

To exercise the rights provided for in the LGPD and listed here, read the topic below. 

8. DATA PROTECTION OFFICER ("DPO") - DATA PROTECTION OFFICER ("EPD") 

It has always been our priority to comply with data protection legislation and other sectoral laws, as well as to follow serious conduct that is in line with good market practice. 

Therefore, as required by law, the company has a Data Protection Officer (DPO). For the activities inherent to the DPO, we have appointed the consultancy firm Assis e Mendes Advogados. In compliance with Resolution CD/ANPD No. 18, we inform that the individual responsible for our DPO as a service is the partner Adriano Mendes.

If you have any specific questions about data protection that have not yet been clarified by our Privacy Policy, they can be sent directly to the person in charge via email: dpoaas@assisemendes.com.br.

9. ABOUT THE CUSTOMER SERVICE CHANNEL  

We have a team of professionals dedicated to data protection and privacy who support the DPO in serving data subjects, whether for exercising rights or general queries. If you have any specific questions that have not been clarified by our Privacy Policy or if you wish to exercise any of the rights provided for in the LGPD, you can contact us via email: privacy@mig-now.com.

10. SECURITY OF YOUR DATA 

We use appropriate technologies and procedures according to the level of risk and the service provided to guarantee the security and protection of your data.

We even have a specialized team responsible for managing our security methods in accordance with legal provisions, regulatory requirements, changes in technology and other relevant factors that may influence data protection. 

However, although we take all precautions and appropriate measures to guarantee and ensure the protection of our platforms, we also rely on the participation of our users. 

You, as a user, must ensure that your computer or mobile device, when using our services, is adequately protected against software harmful, such as viruses, spyware, adware, unauthorized remote access, among other activities and malicious programs in the digital environment.  

We therefore urge you to follow the basic rules of digital security, keeping your computer and your data safe. 

If, by any chance, you identify or become aware of any type of situation that could compromise the security of your data, please contact our data protection and privacy team directly, as indicated in the item 9.  

Finally, we clarify that if we identify and prove any intrusion, attempt, or activity that violates or contravenes intellectual property right laws, among others, and/or the provisions stipulated in this Policy, we will spare no effort to ensure that the person responsible is held accountable under the terms of the applicable legislation, and must therefore pay compensation for any damage caused. 

11. PERIOD OF STORAGE OF YOUR DATA 

We have a strict policy regarding the period for which we store personal data.  

To better clarify, we follow the respective parameters to determine the retention and storage period of your personal data: 

Deadlines for data retention 
Period required to fulfill the purpose of the collection; 
The moment the user stops using the site; 
Until the revocation of consent or request for deletion of data by the data subject, only if and when the legal basis for data processing is consent; 
Period required to prove compliance with specific legal duties and obligations;  
Legal deadlines, regulatory deadlines, deadlines contained in court decisions or deadlines determined by the competent authorities; 
Deadlines for compliance with legal or regulatory obligations; 
Period during which the contract continues to run; 
Period necessary for the regular exercise of rights in judicial, administrative and arbitration proceedings; 
Exclusive use by us, with no access by third parties, and provided that the data is anonymized. 

12. REGULAR CHANGES TO THIS PRIVACY POLICY 

This Policy is our sole responsibility,  and can be altered or modified at any time, as long as there is a need for further restructuring or adaptation to new techniques and procedures, always maintaining the degree of reliability and safety. 

It is therefore important that you consult the document regularly to check if continues to agree with its terms before continuing browsing or filling in any of our site's features. 

13. FINAL NOTICES 

The use of the name MIGNOW, of the domain <https://mig-now.com/> (and branches), as well as the contents of the site's screens are the property of the Essence Group and are protected by international intellectual property laws and treaties.  

You must not misuse or reproduce such content, in whole or in part, unless expressly authorized to do so. 

This Privacy Policy complies with and shall be interpreted on the basis of Data Protection Laws.  

To settle any doubts or questions relating thereto, the parties elect the Courts of the District of São Paulo/SP, to the exclusion of any other. 

Last updated: August 2024.