Your privacy is important to us. This privacy statement explains how we collect, use, store, share, transmit, transfer, delete or process personal data. This policy describes the measures we take to ensure the protection of personal data. We also tell you how to contact us so that we can answer any questions you may have about data protection.
The data protection policy applies to Creare Sistemas Group (hereinafter called “Creare”) and GoAwake, covering all dimensions and activities in all regions where we operate.
This policy applies to the processing of personal data collected by GoAwake, directly or indirectly, from all individuals, including, but not limited to, current, future, or potential job applicants, workers, customers, suppliers, contractors or subcontractors, shareholders or any third parties. We define “personal data” as any data relating to an identified or identifiable individual or to a person who can be identified by means fairly likely to be used.
In compliance with General Data Protection Regulation (GDPR) and any other applicable local data protection laws or regulations
We commit to comply with all applicable laws regarding personal data and we will ensure that personal data is collected and processed in accordance with the provisions of the law.
Loyalty, Justice and Transparency
We do not collect nor process personal data without having a legal reason to do so. We hereby inform you that we may need to collect and process personal data when needed for the execution of an agreement or to comply with a legal obligation to which we are subject. We may also collect and process personal data for GoAwake legitimate interests, except when those interests are voided by fundamental interests or rights and freedoms.
When collecting and processing personal data, we will provide a fair and complete information notice or a privacy statement about who is responsible for the processing of such personal data, for what purposes personal data are processed, who are the recipients, what are the rights of the data owners and how to exercise them, unless it is impossible or demand disproportionate efforts to do so.
When required by applicable law, we will seek prior consent (for example, before collecting any sensitive personal data).
Legitimate Purpose, Data Limitation and Minimization
Personal data is collected for specific, explicit and legitimate purposes and it is not processed in a manner incompatible with those purposes.
When GoAwake acts for its own purposes, personal data is processed primarily for, but not limited to, the following purposes: recruitment management, human resource management, accounting and financial management, finance, treasury and tax management, risk management, personnel security management, provision of IT tools or internal websites and any other digital solutions or collaborative platforms, IT support management, health and safety management, information security management, customer relationship management, bidding, sales and marketing management, supply management, internal and external communication and event management, compliance with obligations against money laundering or any other legal requirements, data analysis operations, legal corporate management and compliance processes deployment.
On providing our services for the benefit of our customers or between us, we may also process personal data on behalf of a controller (whether a customer or any other entity of Creare/GoAwake acting as such) primarily for the effective operation, management, performance, and delivery of our services. We will ensure that the personal data processed is adequate, relevant and limited to what is necessary for the purposes for which it is processed.
Data Accuracy and Storage Limitation
Creare/GoAwake will keep personal data processed accurately and, when necessary, updated. In addition, we only keep personal data for as long as necessary for the purposes for which they are processed (in accordance with our Data Retention Policy). Creare/GoAwake will act in accordance with the instructions received from its customers, to assist them in fulfilling this obligation.
Security of Personal Data
We have deployed appropriate technical and organizational measures to protect data (personal or not) from accidental or illegal changes or loss, or from unauthorized use, disclosure, or access, in accordance with our Internal Information Security Policy.
When appropriate we take all reasonable measures based on privacy by design and privacy by standard principles to implement the necessary safeguards and to protect the processing of personal data. Depending on the level of risk raised by the processing, we also conduct internal privacy impact assessments in order to adopt the appropriate safeguards and to ensure the protection of personal data. We also provide additional security protections for data deemed confidential.
Disclosure of Personal Data
In the normal course of our business and for processing purposes, we may share personal data with relevant personnel within Creare/GoAwake Group, or with our duly authorized, contracted, or subcontracted employees, to ensure consistency in our activities, thus maximizing the quality and efficiency of our services and operations.
We may also be required to disclose personal data to regulatory authorities, courts and government agencies when required by law, regulation, or legal process, or to defend the interests, rights or property of Creare/GoAwake or related third parties.
Otherwise, we will not share personal data with other parties, unless we receive prior approval for such sharing.
Transfer of International Personal Data
We may transfer personal data to service providers located abroad, including cloud service providers. In such situations, Creare/GoAwake will take the appropriate measures to ensure adequate protection in accordance with the requirements of the applicable laws.
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Creare/GoAwake Group has appointed a Data Protection Officer. To exercise their rights as holders of their personal data, they can submit requests or complaints to the following email address: firstname.lastname@example.org .
In the event of an incident involving Personal Data, Creare/GoAwake DPO should be contacted at the aforementioned email address.
Law 12.965/2014 (Brazilian Civil Rights Framework for the Internet)
Law 13.853/2019 (General Data Protection Regulation)
MP 959/2020 (changes to GDPR)
General Data Protection Regulation (GDPR)