1. Introduction
We at Bemobi ("Bemobi") take your privacy very seriously. This privacy statement, which also includes our cookie policy, applies to the websites bemobi.com, ri.bemobi.com, the ethics channel, and other websites of Bemobi and its controlled companies ("websites"). This privacy statement explains what data we collect, why we collect it, and how we use it. It also provides information about the rights of the subjects of the personal data we collect. Bemobi is the controller of the processing of personal data on the websites. Bemobi owns or operates different services that may also process personal data, and specific privacy statements apply to those services. We always respect your decisions about how your data is used. We adopt safeguards to protect your data against loss, misuse, unauthorized access, disclosure, alteration, or destruction. When we publish changes to this privacy statement, we will indicate the date the update was made.
2. What data we collect and why we collect it
When you visit the website, we collect certain information from the device you use and information about how you use the website. The information collected from the device includes: • IP address and device ID; • how long you stay on the website; • which content you read; • scrolling behavior, etc. We use this information in aggregate form to obtain data that allows us to develop and improve the website. Although you can use the website without revealing your identity, you may also choose to send us additional information through web forms, applications, or by contacting us as made available on the website, such as: • your name; • address; • company name; • phone number; • email; • files containing personal data, such as your resume. Any information you send us is used solely to fulfill the purpose of your request. The legal basis for processing your data will, in most cases, be Bemobi's legitimate interest in improving the website or processing your information to fulfill your request. In addition, we may process your personal data based on the following legal bases: (a) when necessary to comply with legal and regulatory obligations; (b) when necessary to enter into or perform the terms of your contract (for example, to provide contractual payments and benefits); (c) your consent for the specific purposes that require such consent; and/or (d) for the regular exercise of rights in judicial, administrative, or arbitration proceedings.
3. Cookies
4. How do we protect your data?
We process your personal data in accordance with the applicable local Data Protection legislation, using the European GDPR as a reference. We implement appropriate technical and organizational measures to protect your personal data against unauthorized disclosure, misuse, and modification. We require our suppliers to adopt security measures and comply with the same laws and industry standards. Only Bemobi employees with specific needs have access to the data we collect. Our working procedures and internal compliance policies are designed to ensure that applicable regulations are strictly followed, maintaining your privacy in accordance with applicable law.
5. How and when do we share your data?
The personal data provided by you, or collected by our website, is not shared with third parties and is used exclusively to serve the legitimate interests of your request or to compile anonymous statistics about our products and services. However, we may be required to share such data in the following cases: • With government bodies and law enforcement authorities, to comply with legislation, for example, in judicial proceedings, by court order, or through another legal process. • With third parties, where such sharing complies with data protection legislation. • As may be described elsewhere in this statement; and/or • As permitted by applicable law or regulation. As we are an international company with data centers around the world, if you are accessing a website from the European Union (EU) or the European Economic Area (EEA), your data may be transferred to countries that have the same level of data protection as the EU/EEA. When this occurs, there will be an agreement in place to ensure that the recipient protects the data to standards similar to those of the EU/EEA or transfers it to Privacy Shield organizations (in the case of transfers between the US and EU countries). You can learn more about data protection on the European Commission's Justice website. Likewise, personal data may be transferred outside your country to countries that have the same level of data protection laws as provided for in the LGPD. When this occurs, we will use the legal bases provided for in the LGPD, such as standard contractual clauses, or transfers to countries recognized as adequate by the National Data Protection Authority. In the absence of instructions from the National Authority, we may use the standard contractual clauses of the European Union or of another jurisdiction.
6. Your rights
In Brazil, you have the following guaranteed rights: • Right of confirmation and access. You have the right, upon request, to be informed whether any processing of personal data exists and, if so, you may request information about the processing of your personal data and a copy of the personal data processed, provided that such copy does not harm or affect the rights and freedoms of third parties. • Right of rectification. You may request the correction of your personal data that is incorrect and/or the completion of incomplete data. We encourage you to update or correct your personal data if it changes or if you believe that the personal data we hold about you is incorrect, inaccurate, or outdated. • Right to anonymization, blocking, or deletion. You may request the anonymization, blocking, or deletion of your personal data, in particular when (i) the personal data is no longer necessary in relation to the purposes for which it was collected or processed, (ii) you object to the processing and there are no legitimate interests supporting it, (iii) your personal data has been processed unlawfully, or (iv) your personal data needs to be deleted to comply with a legal obligation to which we are subject. The right to deletion, however, does not apply, in particular, when the processing of your personal data is necessary to comply with a legal obligation or for the establishment, exercise, or defense of legal claims. • Right to data portability. You have the right to have your personal data transmitted to another service or product provider, limited by trade and industrial secrets. • Right to grant and withdraw consent. You have the right to grant your informed consent for the specific purpose and retention period, and you may withdraw your consent at any time using an opt-out function or by contacting us as provided in this privacy statement. Withdrawal will not affect the lawfulness of processing based on consent before its withdrawal. You may also request the deletion of your personal data processed with the data subject's consent, except in the situations provided for by law. • Right to object. You also have the right to object to processing carried out based on one of the legal bases other than your consent, in the event of non-compliance with the provisions of the LGPD. • Right to review. You have the right to request the review of decisions made solely on the basis of automated processing of personal data that affects your interests, including decisions intended to define your personal, professional, or consumer profile and/or aspects of your personality, where applicable. • Right to information. You have the right to information about the public and private entities with which we share your data. • Right to petition. You have the right to petition, in relation to your data, against the controller before the National Data Protection Authority ("ANPD"), as well as before consumer protection bodies. To exercise your rights, except the right to petition, or if you have any questions about the processing of your personal data, contact us as indicated below.
7. How long is my data stored?
We keep personal data only for as long as necessary to process it in accordance with the purposes described in this statement or as required to comply with applicable laws. When your data is no longer necessary or relevant for our purposes, or required by applicable law, we take steps to delete, aggregate, or anonymize it.
8. Privacy Committee
Bemobi has a Privacy Committee dedicated to ensuring the implementation of appropriate protections in the processing of the personal information of our customers, employees, and business partners. The committee is responsible for monitoring and reviewing our privacy policies and procedures and for ensuring that we comply with applicable data privacy laws.
9. Effective date and updates
This Privacy Statement is effective as of its original publication on 03/31/2023 and may be updated periodically. When that happens, we will publish the new version and include the date of the last update.
10. Contact information