Privacy Policy

This Privacy Policy and Data Protection Policy (the “Policy”) establishes the terms and conditions under which the Sementes application (the “Sementes” or “Application”) collects, uses, stores, processes, shares, and protects the personal data of its users in compliance with applicable legislation, particularly the Brazilian General Data Protection Law (LGPD – Law No. 13.709/2018), as well as other relevant regulations.

1. PRELIMINARY PROVISIONS

1.1 Purpose and Scope

The purpose of this Policy is to provide clear, precise, and accessible information regarding the procedures adopted by Sementes for the processing of users’ personal data. This includes both data provided voluntarily and information automatically collected during the use of the Application, as well as the security measures implemented to safeguard such data.

1.2 Definitions

For the purposes of this Policy, the following definitions apply:

• Data Subject: The natural person to whom the personal data relates.
• Personal Data: Any information related to an identified or identifiable natural person.
• Sensitive Data: Personal data that reveals racial or ethnic origin, religious beliefs, political opinions, health information, or other sensitive information as provided by law.
• Controller: The person or entity responsible for determining the purposes and means of the processing of personal data.
• Processor: The person or entity that processes personal data on behalf of the Controller.
• Processing: Any operation performed with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, storage, deletion, or evaluation.

2. DATA COLLECTION

2.1 Data Provided Directly by the User

During registration and use of the Application, the Data Subject may provide the following information:

• Identification Data: Full name, email address, date of birth, profile picture, and other registration details.
• Contact Information: Telephone number and address, when explicitly requested for specific purposes.

2.2 Data Generated Through Application Usage

Data generated as a result of user interaction with the Application includes:

• Information related to participation in challenges, scores, rankings, and historical records of activities.
• Usage data such as connection duration, accessed functionalities, and user preferences.

2.3 Location Data

With the explicit consent of the Data Subject, location data may be collected to offer personalized challenges and suggestions. This collection is subject to technical and legal limitations.

2.4 Technical and Access Data

Automatically collected information includes details about the device used (e.g., model, operating system, unique identifiers) and connection data (e.g., IP address, browser type). Such data is used for security purposes, performance analysis, and continuous improvement of the Application.

3. PURPOSES OF DATA PROCESSING

3.1 Personalization and Enhancement of User Experience

Collected data is used to provide a personalized experience by tailoring challenges, notifications, and content according to the Data Subject’s preferences and behavior.

3.2 Management and Operation of the Application

Data processing facilitates the internal administration of the Application, including:

• Performance monitoring and usage analytics;
• Technical support and customer service;
• Statistical analysis for ongoing enhancement of the Application’s functionalities.

3.3 Communication and Marketing

Based on the Data Subject’s consent, Sementes may use personal data to:

• Send communications, newsletters, offers, and invitations to participate in new challenges;
• Conduct marketing campaigns and promotional activities.
  Such communications can be opted out of at any time through the Application’s settings.

3.4 Compliance with Legal and Regulatory Obligations

The Application may process and retain personal data in order to comply with legal and regulatory obligations, as well as to prevent and investigate any illegal activities.

4. LEGAL BASIS FOR PROCESSING

The processing of personal data by Sementes is based on the legal grounds provided by the LGPD, including:

• Consent: When the Data Subject freely, explicitly, and informedly consents to the processing of their data for specific purposes.
• Performance of a Contract: When necessary for the execution of a contract or pre-contractual measures related to the use of the Application.
• Legal or Regulatory Obligation: To comply with legal or regulatory requirements imposed on Sementes.
• Legitimate Interests: When the processing is necessary to fulfill the legitimate interests of Sementes, provided that such interests do not override the fundamental rights and freedoms of the Data Subject.

5. DATA SHARING AND TRANSFER

5.1 Sharing with Third Parties

Personal data may be shared with:

• Service Providers: Companies and partners engaged to provide essential services (e.g., hosting, data analysis, notification delivery), under contractual agreements that ensure security and confidentiality.
• Competent Authorities: In compliance with legal obligations, regulatory requirements, or upon requests from public authorities, judicial bodies, or oversight agencies.

5.2 International Data Transfers

When applicable, personal data may be transferred to countries that provide an adequate level of data protection or under specific contractual guarantees ensuring data protection in accordance with applicable laws.

5.3 Social Interaction and Selective Disclosure

Data that the Data Subject chooses to share publicly, such as achievements, challenge results, and community interactions, may be accessible to other users of the Application, in accordance with the user-defined privacy settings.

6. SECURITY AND PROTECTIVE MEASURES

6.1 Security Policies and Procedures

Sementes implements a comprehensive set of technical, administrative, and physical measures designed to protect personal data against unauthorized access, disclosure, alteration, loss, or any form of illicit processing.

6.2 Encryption and Restricted Access

The Application employs advanced encryption technologies and access control mechanisms to ensure that data is handled only by authorized and trained personnel who are bound by confidentiality obligations.

6.3 Audits and Continuous Monitoring

Regular audits and continuous system monitoring are conducted to ensure the effectiveness of the security measures and to identify areas for improvement in line with industry best practices.

7. RIGHTS OF THE DATA SUBJECT

In accordance with the LGPD, the Data Subject has the following rights:

• Confirmation and Access: To request confirmation of the existence of data processing and access to the personal data being processed.
• Correction and Updating: To request the correction of incomplete, inaccurate, or outdated data.
• Anonymization, Blocking, or Deletion: To request the anonymization, blocking, or deletion of data that is unnecessary, excessive, or processed in violation of legal provisions.
• Data Portability: To request the transfer of personal data to another service provider, subject to security and confidentiality guarantees.
• Deletion of Personal Data: To request the deletion of data processed based on consent, subject to any legal obligations that require retention of data.
• Information on Data Sharing: To obtain information about the public or private entities with which the data has been shared.
• Consent Revocation: To revoke consent at any time without affecting the lawfulness of processing based on prior consent.

To exercise these rights, Data Subjects should contact Sementes through the channels provided in the “Contact and Clarifications” section below.

8. USE OF COOKIES AND SIMILAR TECHNOLOGIES

8.1 Purpose of Cookies

Sementes utilizes cookies and similar tracking technologies to:

• Ensure the proper functioning of the Application;
• Personalize the user experience;
• Perform statistical analysis and monitor performance;
• Display targeted content and advertisements.

8.2 Management and Deletion

Data Subjects may manage their cookie preferences through the settings of their browser or within the Application. Please note that disabling cookies may limit access to certain functionalities.

9. POLICY AMENDMENTS

9.1 Updates and Revisions

This Policy may be updated periodically to reflect changes in internal processes, applicable legislation, or industry best practices. Significant modifications will be communicated to users via the Application and, if necessary, through additional official channels.

9.2 Effective Date

The most recent version of this Policy becomes effective as of its publication date, replacing all previous versions in their entirety.

10. CONTACT AND CLARIFICATIONS

For any questions, requests, or additional information regarding the processing of personal data, Data Subjects may contact us through the following channels:

• Email: privacy@sementes.app

11. GENERAL PROVISIONS

11.1 Non-Compliance with Legal Provisions

Failure to comply with the provisions set forth in this Policy may result in judicial and administrative measures, in accordance with the severity of the infraction.

11.2 Governing Law and Jurisdiction

This Policy is governed by the laws of the Federative Republic of Brazil, in particular by the LGPD. Any disputes arising from non-compliance with this Policy shall be resolved in the competent court of the jurisdiction where Sementes is headquartered, unless otherwise provided by law.

11.3 Transitional Provisions

In cases where special procedures are required for data transfer or deletion, such procedures will be transparently communicated to the Data Subject, ensuring the preservation of the rights guaranteed by applicable law.

By using the Sementes Application, the Data Subject acknowledges that they have read, understood, and accepted the terms of this Privacy Policy and Data Protection Policy, and agree to abide by the conditions set forth herein. Sementes reaffirms its commitment to transparency, security, and respect for the privacy of all its users.

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