Privacy Policy

Able values the privacy and protection of personal data of its clients, suppliers, partners and employees. For this reason, it presents, in a clear and objective manner, information about the types of personal data collected and how they are processed by the company, complying with the data protection legislation in force in Brazil, namely Law No. 13,709/2018 – the General Data Protection Law (“LGPD”) and other rules and regulations applicable to the services offered.

Considering that Able's service provision is normally carried out on behalf of its clients, it acts as Data Processor under the terms of current legislation.

If you have any questions about this Privacy Policy or to exercise your rights as a data subject, please contact the Data Protection Officer (DPO):

CLRA Consultoria e Compliance – partner Maís Ritter
Contact email: lgpd@able.com.br
Link for data subject requests: https://app.podium.com.br/forms/da3b6236-ce02-4737-a1da-e74f17d89da6

1. Glossary

Personal Data: Refers to any information related to an identified or identifiable natural person, such as full name, personal and professional document numbers, telephone, address, email, among others.

Sensitive Personal Data: Refers to data on racial or ethnic origin, religious belief, political opinion, union membership or affiliation with a religious, philosophical or political organization, 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 relating to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

Data Subject: Refers to the natural person to whom the personal data being processed refers.

Data Protection Officer (DPO): 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, the Brazilian General Data Protection Law.

Anonymization: Refers to the use of technical means by which data loses the possibility of direct or indirect association 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 subjects in the following cases and for the purposes indicated below:

Where we collect	Data collected	Purpose
Website form - "Contact"	Name, email, telephone and subject to be addressed.	Serve website users seeking information about the company.
Telephone, Messaging applications, Email, Systems and Applications	Name, telephone, 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.	Serve the research and relationship demands of clients with data subjects.

3. Cookies

Cookies are small text files automatically downloaded to your device when you access and browse a website. They are used, basically, to make it possible to identify devices, activities and user preferences. Cookies do not allow any file or information to be extracted from the user's hard drive, nor is it possible, through them, to access personal information that did not come from the user or from the way they use the website's resources. Able uses only the cookies necessary for the proper functioning of the website.

4. Legal basis and use of personal data

The collection and processing of personal data meets one of the following legal requirements established 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 other cases that depend on prior authorization from the data subject or their Legal Representative for the processing of personal data.

Contract Execution (art. 7, V, LGPD) whenever Able contacts the data subject on behalf of and at the request of its clients. In these cases, Able will limit itself to collecting and processing personal data as determined by the client.

Legitimate interest of the company or third parties, including the Data Subject themselves (art. 7, IX, LGPD), since it seeks to meet the relationship needs between Able's client and the data subjects.

5. Storage and sharing

The personal data collected may be stored by the company or its clients, depending on the type of service provision contracted, always ensuring the protection and security of the information.

Sharing may occur:

With clients and suppliers, for the proper provision of the contracted service;

With third parties, at the client's request and in accordance with the signed contract;

With government authorities and entities for the fulfillment of legal obligations related to the type of service provided;

By judicial order or at the request of administrative authorities that have legal competence for such requisition, as well as for the protection of Able's interests in any type of conflict, including lawsuits and administrative proceedings;

In other cases, with the specific consent of the data subject.

6. Rights of data subjects

In compliance with the LGPD guidelines relating to the rights of Data Subjects (Art. 18), it is possible to request, at any time:

Information about the possibility of not providing consent and the consequences of refusal.
Withdrawal of consent — which may be in whole or in part, when applicable.
Access to personal data and confirmation of the existence of processing, as well as the correction thereof if incomplete or outdated.
Right to data portability to another service provider, safeguarding the company's trade secrets.
Information about entities with which the company has shared data or entities with which data has been shared, as well as for what purpose.
Request for anonymization, blocking and elimination of unnecessary or excessive data or data processed in non-compliance with the LGPD.

7. Response to security incidents

Able is concerned about the privacy of the personal data it processes and seeks to protect it from unauthorized access, destruction, loss, alteration, leakage or any other form of inappropriate or unlawful processing. Nevertheless, should a security breach involving personal data occur that may generate relevant risk or damage, the company undertakes to notify the affected data subjects and the National Data Protection Authority (ANPD) within the legal deadline, informing the measures adopted to repair damages and prevent new incidents.

8. Consent and changes to the privacy policy

Consent and agreement with this Privacy Policy is given through the acceptance of the specific terms on the website; therefore, by browsing the site and accepting the terms provided, you expressly authorize the company to process and use your personal data in accordance with the clauses of this document and current legislation.

In addition, by consenting to the collection of data during the execution of Able's services, you acknowledge the data processing described herein.

Able also reserves the right to modify this Privacy Policy whenever there are changes in its procedures or to comply with legislation, with no prior notice required when the changes do not cause relevant harm to its users and clients.

It is recommended that you periodically visit the site to stay updated on this Privacy Policy.

This document was updated on 04/03/2024.