Privacy Policy
Able values the privacy and protection of the personal data of its customers, suppliers, partners and employees. Therefore, it clearly and objectively presents information about the types of personal data collected and the way in which they are treated by the company, complying with the data protection legislation in force in Brazil, namely Law No. 13,709/2018 – General Personal Data Protection Law (“LGPD”) and other rules and regulations applicable to the services offered.
Considering that Able's services are normally provided on behalf of its clients, it holds the position of Data Operator under current legislation.
If you have any questions about this Privacy Policy or to exercise your rights as a holder, please contact the Data Officer (DPO):
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CLRA Consultoria e Compliance – partner Maís Ritter
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Contact email: lgpd@able.com.br
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Link to holder requests: https://app.podium.com.br/forms/da3b6236-ce02-4737-a1da-e74f17d89da6
1. Glossary
Personal Data: Refers to any information related to the identified or identifiable natural person, such as full name, personal and professional document numbers, telephone number, address, email, among others.
Sensitive Personal Data: Refers to data concerning racial or ethnic origin, religious belief, political opinion, union membership or membership of organizations of a religious, philosophical, or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a natural person.
Processing of Personal Data: Refers to any operation carried out with personal data, such as those related to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
Data Holder: Refers to the natural person to whom the personal data that is subject to processing refers.
Data Officer or DPO (Data Protection Officer): Refers to the natural or legal person responsible for communication between data subjects, Able, and the ANPD (National Data Protection Authority).
LGPD: Refers to Law No. 13,709/2018, which is the General Personal Data Protection Law.
Anonymization: Refers to the use of technical means through which data loses the possibility of association, directly or indirectly, with an individual.
Services: Refers to the services offered and provided by Able, which may also include access to the website.
2. Collection of personal data and purposes
The company collects and accesses Personal Data from its holders in the following cases and for the purposes indicated below:
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Where we collect
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Data collected
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Purpose
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Website form - "Contact"
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Name, email, telephone number and subject to be discussed.
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Serve website users who are looking for company information.
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Telephone, Messaging App, Email, Systems and Applications
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Name, telephone number, address, CPF, ID, date of birth, email, position, remuneration, voice recording and any additional information sent by the Data Subject. Exceptionally, sensitive personal data is collected, such as photo, information about disability (PCD) and race.
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Meet the research and relationship demands of customers with data holders.
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3. Cookies
Cookies are small text files automatically downloaded to your device when you access and browse a website. They basically serve to identify devices, activities and user preferences. Cookies do not allow any file or information to be extracted from the user's hard drive, and it is not possible, through them, to access personal information that did not come from the user or the way in which they use the website's resources. Able only uses the cookies necessary for the website to function properly.
4. Legal provisions and use of personal data
The collection and processing of personal data meets one of the following legal requirements set out in article 7 of the LGPD:
Consent (art. 7, I, LGPD) will be used whenever there is a need to accept the terms of this Privacy Policy in the forms filled out on our website and in other cases that depend on prior authorization from the holder or their Legal Representative for the processing of personal data.
Execution of Contract (art. 7, V, LGPD) whenever Able contacts the holder on behalf and at the request of its customers. In these cases, Able will limit itself to collecting and processing personal data as determined by the customer.
Legitimate interest of the company or third parties, including the Holder himself, (art. 7, IX, LGPD), as it seeks to meet relationship needs between Able's client and data holders.
5. Storage and sharing
Personal data collected may be stored by the company or its clients, depending on the type of contracted service, always ensuring information protection and security.
Sharing may occur:
With customers and suppliers, for the proper provision of the contracted service;
With third parties, at the customer's request and in accordance with the signed contract;
With government authorities and entities to comply with legal obligations relating to the type of service provided;
By court order or request of competent administrative authorities, as well as to protect Able’s interests in conflicts;
In other cases with the specific consent of the data subject.
6. Data subject rights
In accordance with LGPD guidelines (Art. 18), data subjects may request at any time:
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Information about the possibility of not providing consent and the consequences of refusal.
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Revocation of consent — which may be in whole or in part, when applicable.
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Access to personal data and confirmation of the existence of processing, as well as their correction, if incomplete or outdated.
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Right to data portability to another service provider, safeguarding the company's commercial secrets.
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Information about entities with which the company shared data use or entities with which data was shared, as well as for what purpose.
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Request for anonymization, blocking and deletion of unnecessary, excessive or processed data that does not comply with the LGPD.
7. Security Incident Responses
Able cares deeply about the privacy of processed personal data and seeks to protect it against unauthorized access, destruction, loss, alteration, leakage, or any other inappropriate or illegal treatment. In case of a security breach involving personal data that poses a significant risk or damage, Able commits to notify affected data subjects and the National Data Protection Authority (ANPD) within the legal timeframe, informing measures taken to repair damages and prevent new incidents.
8. Consent and changes to the privacy policy
Consent and agreement with this Privacy Policy occurs through acceptance of the specific terms on the website, therefore, by browsing the website and accepting the terms set out, you expressly authorize the company to process and use your personal data in accordance with the clauses of this document and current legislation.
Furthermore, by consenting to the collection of data during the provision of services by Able, you are aware of the processing of data set out herein.
Able also reserves the right to modify this Privacy Policy whenever there are changes to its procedures or to adapt to legislation, with prior notice not being necessary when the changes do not cause material harm to its users and customers.
It is recommended that you periodically visit the website to stay updated on this Privacy Policy.
This document was updated on 04/03/2024.
