Better Traduções Ltda. is committed to complying with the laws that protect the privacy of customer and general public data.  This page explains how we comply with data protection regulations, what information we collect while you browse our communication channels, and how we collect, use, and protect this information in accordance with Act No. 13,709/2018 (General Data Protection Act – “LGPD”). In order to use our products and services, as well as our platforms, and other means of interaction that we may make available, you must accept this Privacy Policy, including with respect to our employees.

1. Sources of Personal Data

Better Traduções Ltda. will have access to personal data in the following situations:

• By Interacting with a Customer:  When the Customer provides and assigns the personal data necessary for the provision of the services and the use of the products provided by Better Traduções Ltda.
• Interaction with your Employees: When your employees and associates of any nature use your systems and platforms to fulfill their contractual duties and obligations.

2. Types of Personal Data and Sensitive Personal Data Collected

Better Traduções Ltda. may also collect, without prejudice to the data of your employees that are commonly collected and processed for the purposes of the legal relationship they have, the following personal data:

• Names and contact data, such as first and last names, e-mail address, postal address, telephone number, and other similar types of contact data, such as bank data;Device information, such as information about your device, such as IP address, location, or provider;
• Browsing use and history information, such as information about how the User browses our services, their browsing history, and Better Traduções Ltda. services elements used most;
• The purpose for which Better Traduções Ltda. may collect sensitive personal data will be explained separately to the User, who must consent to Better Traduções Ltda. use of such data, and, if the User does not agree with it, such data will be automatically excluded from Better Traduções Ltda. databases.

Better Traduções Ltda. does not collect data from minors, unless authorized by their parents or guardians; if they are collected without authorization, as soon as Better Traduções Ltda. realizes this, it will immediately delete the data that were collected, in accordance with the rules of the Terms of Use and of this Privacy Policy.

3. Use of the Personal Data that are Collected

When collected, Better Traduções Ltda. will use personal data:

• To provide and improve the contracted services;
• To comply with a legal or regulatory obligation;
• To manage the relationship with the Users;
• To setup and manage User accounts;
• To provide technical assistance, support, and training to the User;
• To contact Users;
• For internal research and development purposes, and to improve, test, and perfect the features and functions of Better Traduções Ltda. services.
• To provide marketing, advertising, and propaganda to Users, including from Better Traduções Ltda. Partner companies, as permitted by law;
• To meet internal and external audit requirements, including Better Traduções Ltda. information security obligations;
• To send e-mail messages in order to: a) confirm or cancel requests through the use of the platform; b) communicate future changes that this policy may undergo, and c) disclose updates, changes, additions of new data sources, and improvements to the platform.
• To exercise Better Traduções Ltda. rights, including but not limited to the privacy, security, networks, systems, and property of Better Traduções Ltda. and/or third parties; 
• To comply with requests from the courts, law enforcement authorities, regulatory bodies, and other public institutions and government authorities, including, but not limited to any rules in force outside the user’s country of residence;
• To exercise Better Traduções Ltda. rights and to defend it against any legal actions, as well as to comply with any legislation or regulation applicable to Better Traduções Ltda. or third parties with whom we work, as well as to properly fulfill contracts signed between Better Traduções Ltda. and its users;

4. Sharing of Personal Data with Third Parties

The User accepts and agrees that Better Traduções Ltda.share their personal data with the following recipient categories:

• Companies that provide access to or are responsible for the registration the user depends on; 
• Partner companies, such as third party service providers and other companies that assist us in providing our services or who may act on our behalf, protecting our rights, users, systems, and services;
• Third parties to whom Better Traduções Ltda. is accountable or is authorized to disclose information of by law (e.g., government agencies, regulatory agencies, the judiciary, and other public authorities);
• Third parties in order to participate in the sale, merger, acquisition, restructuring, joint venture, assignment, transfer of part or all of the business of Better Traduções Ltda. , in which case the User's data will be considered an asset and transferred in a possible negotiation;
• Third parties who need the data to protect Better Traduções Ltda. rights;
• Any natural or legal person to whom the User requests the portability of their data. 

5. International Transfer of Personal Data 

Better Traduções Ltda. does not intend to transfer any of the personal data it collects from the User outside of Brazil, provided that if the hypotheses listed below are not met, the User will be notified by e-mail, at which point the User may or may not accept such transfer, and if the User disagrees, Better Traduções Ltda. may suspend their access rights. 

The international transfer of data described in the General Data Protection Law (LGPD) does not specify guidelines to be set by the National Authority for the Protection of Personal Data (ANPD), but Better Traduções Ltda. undertakes to abide by them fully when they are defined.

6. Personal Data Protection

Better Traduções Ltda. uses appropriate technologies and procedures to protect any personal data it collects (including administrative, technical, and physical protections) in accordance with the level of risk and service provided, and it has a team of professionals that are legally responsible for dealing with the secure management of the data in accordance with the legal and regulatory requirements, technological advancements, and other relevant factors that may impact how personal data are protected.

Better Traduções Ltda. employs all reasonable measures to ensure the security of its systems and of the data collected, this includes using highly qualified and reputable Internet services and database and storage servers, in addition to security certificates (SSL) and access protection software to prevent unauthorized access to systems, as well as standard methods for encrypting and anonymizing the collected data.

This Policy represents Better Traduções Ltda. efforts to protect the User’s information. However, due to the very nature of the Internet, it is not possible to guarantee that malicious third parties will not succeed in improperly accessing the stored information, which is why, if this occurs,

Better Traduções Ltda. shall be liable within the limits provided for by law.

Within a reasonable period to be determined by the National Data Protection Authority (“ANPD”), Better Traduções Ltda. shall notify the ANPD and the affected User of the occurrence of a security incident that may cause significant risk or damage to the affected User, mentioning at least:

• A description of the nature of the personal data affected;
• Information about the holders involved;
• An indication of the technical and security measures used for data protection, observing commercial and industrial secrets;
• The risks related to the incident;
• The reasons for the delay if the communication was not immediate.
• The measures that have been or will be adopted to reverse or mitigate the effects of the loss.

7. Better Traduções Ltda. Data Processing and Responsibility

Better Traduções Ltda. will be responsible for processing, as follows:

• With respect to personal data provided directly by its Customers, Better Traduções Ltda. will be the Operator, and will not interfere with the processing approach the Controller indicates, but shall do so under the terms of the LGPD;
• Better Traduções Ltda. will be the Controller of its employees’ Personal Data, processing them based on the Execution of Contracts, in Compliance with legal or regulatory obligations, and, also, in specific and determined situations, on Consent.

Better Traduções Ltda. may adopt different legal bases for different processing of personal data.

8. Term for Processing Personal Data

Better Traduções Ltda. calculates the personal data retention period according to these criteria:

• The period necessary to fulfill the purpose of the collection;
• The moment the Customer/User ceases to use Better Traduções Ltda. services;
• The moment when the Holder of the data revokes consent or requests the deletion of the personal data;
• The time needed to demonstrate compliance with Better Traduções Ltda. duties and obligations;
• The period required by law, regulations, court decisions, etc.;
• As determined by the National Data Protection Authority;
• Compliance with a legal or regulatory obligation by the Controller;
• The perfect execution of the contract;
• Needs related to compliance with the system of laws, as well as for any legal disputes;
• Transference to a third party, provided that the data processing requirements set forth by law are adhered to, or
• The exclusive use of the data by the controller, with access by third parties being prohibited, and provided that the data are anonymized.

9. User Rights

The User has the following rights in regard to the handling of their personal data under the Brazilian General Data Protection Law:

• Right of Confirmation: The User may confirm whether Better Traduções Ltda.processes their personal data;
• Right of Access: The User may make a written request to get details on how their information is being used, as well as to get a copy of said information;
• Right to Correction: The User may correct or remove any data that is incomplete, inaccurate, or outdated;
• Right to anonymization, blocking or deletion: The User may request the anonymization, blocking or deletion of unnecessary, excessive or data processed for purposes in conflict with consent given, observing, for that purpose, other rules of the system of laws;
• Right of Deletion: The User may request the deletion of some data, except those that are required by law to be retained;
• Right to Information: The User has the right to request information about public and private entities with which Better Traduções Ltda.shared their data, as well as the consequences of choosing not to consent to the collection and processing of their personal data;
• Right to Refuse Marketing: By clicking the link contained within the marketing e-mail that was sent, the User may opt out of receiving advertisements and other materials at any time. 
• Right to Portability: Unless Better Traduções Ltda.has already anonymized and deleted the User's data, the User can request that their data be transferred to themselves or third parties.
• Right to Withdraw Consent: The User may cancel any consent given in advance for Better Traduções Ltda. to use their personal data. The User is aware that such cancellation will not affect the use and sharing of data that occurred prior to the request to withdraw consent.

The rights provided for in this chapter are not absolute, and the User must, whenever they want to exercise them, contact Better Traduções Ltda.at Este endereço para e-mail está protegido contra spambots. Você precisa habilitar o JavaScript para visualizá-lo..

Better Traduções Ltda. undertakes to respond as soon as possible to such requests free of charge and within 15 (fifteen) days of receipt, unless a longer period is required due to complexity, for reasons of fact or law, which will be communicated to the User.

Better Traduções Ltda. will immediately inform the processing agents with whom it has shared User data that the data has been corrected, eliminated, anonymized, or blocked, so that they can repeat that procedure.

The existence of or access to the User's personal data will be confirmed, electronically or expressly, in a simplified format or by means of a clear and complete statement of the origin of the data, the absence of registration, the criteria used, and the purpose of the treatment, always observing Better Traduções Ltda. trade and industrial secrets.

10. Cookies

Better Traduções Ltda. and possible partners may use cookies and other similar technologies to store and manage User preferences, offer targeted advertising, enable content, and collect analytical and usage data, for example. Cookies and other tracking technologies are a standard on websites and platforms, allowing information about a User’s activities on those platforms, websites, or other services to be collected.

A cookie is a small text file placed on a computer or other device that is used to identify the User, identify the device used, and to collect information, and it can perform these functions:

• Necessary Cookies: These cookies are essential to allow the user to browse a platform and use its features. 
• Performance Cookies: These cookies collect information about how the User uses Better Traduções Ltda. platform and are used to improve the User’s browsing and enhance their experience. The information collected includes, for example, Internet browsers and operating systems that are used, the URL of the website previously visited, the number of visits, the average duration of the visit, and the pages viewed.
• Functional Cookies: These cookies enable the platform to remember choices the User makes (such as their username or ID, language preference or the area or region the User is in) and to provide enhanced and more personalized features.
• Advertising Cookies: These cookies track the User’s browsing habits and are used to deliver targeted advertising. They also limit the number of times you see an ad and measure the effectiveness of advertising campaigns. Additionally, they also remember that the User has already visited a website, and this information is shared with other organizations, such as advertisers.

Better Traduções Ltda. uses necessary and performance cookies. 

Users may disable Cookies at any time through their browser settings, installing plug-ins available on the market, or even using other technologies that they deem necessary.

In addition to cookies, Better Traduções Ltda. uses other tracking technologies, such as:

Web Server and Platform Records: Better Traduções Ltda. servers automatically collect certain information to assist, manage, and protect the services offered, as well as to analyze usage and improve the User’s experience. The information collected includes:

• IP address and browser type;
• Device Information, including the Unique Device Identifier (UDID), MAC address, Identifier for Advertisers (IFA), and similar identifiers assigned by us or a third party;
• The device’s operating system and other technical data;
• The city, state, and country from where you are accessing the BRASIL RISK platform, including for fraud prevention;
• Information or texts that were typed;
• Links and buttons clicked;

Connections via Social Networks: Some of Better Traduções Ltda. services may include social networking features, such as Facebook “Like” buttons and widgets; “Share” button, and interactive mini-programs.

Some of the services offered by Better Traduções Ltda. can be accessed using the login credentials of the User's own social networks, in which case Better Traduções Ltda. may receive and store authentication information from these services.

11. Contact Information

The User may send questions, comments, suggestions and/or complaints regarding this Privacy Policy, as well as any need for information, alteration, or deletion of personal data directly to Better Traduções Ltda. by e-mail, at Este endereço para e-mail está protegido contra spambots. Você precisa habilitar o JavaScript para visualizá-lo.

12. Amendments

In order to provide users with better service and protection, Better Traduções Ltda. will update this Privacy Policy from time to time.
In the event of changes affecting the purpose and duration of the processing of the User’s personal data, the User will be informed through the e-mail address registered in our services or through the platform itself 30 (thirty) days in advance. If the User disagrees with such amendments, the User may revoke the consent provided, being unable to use Better Traduções Ltda. services.

If, in the future, Better Traduções Ltda. changes its policy in order to share data with third parties, it will send a notice 30 (thirty) days in advance to the user through the user’s registered e-mail, and, if the user disagrees with the sharing, at which time he will continue to use Better

Traduções Ltda. services.
The User is advised to periodically read this policy in order to keep up-to-date with its content.

13. Legislation and Venue

This Policy will be governed, interpreted, and executed in accordance with the laws of the Federative Republic of Brazil, regardless of the conflicts of these laws with the laws of other states or countries, and the Courts of São Paulo is competent to resolve any issues arising from this instrument, waiving any other, however privileged.

All rights reserved.