Privacy Policy

At OSA IT Solutions, privacy protection and data security are fundamental to us. We are committed to transparency about how we use the personal information of our data subjects. This Privacy Policy therefore describes how we collect, use and transfer the data of clients and other people who access or use our services.

By using our services, you agree to the collection and use of your personal information as described in this Policy, under the Brazilian General Data Protection Law (LGPD, Federal Law No. 13,709/2018), the consumer protection provisions of Federal Law No. 8,078/1990 and other applicable rules of Brazilian law.

Accordingly, OSA IT GLOBAL SERVICES LTDA, hereinafter referred to simply as "OSA IT Solutions", registered under Brazilian corporate taxpayer ID (CNPJ/MF) No. 02.502.098/0001-00, acting as Data Controller, is bound by the provisions of this Privacy Policy.

This English version is provided for convenience. In the event of any discrepancy between this version and the original Portuguese version, the Portuguese version shall prevail.

1. What data do we collect about you and for what purpose?

1.1. Personal data provided by the data subject for drawing up service agreements.

2. How do we collect your data?

Your personal data is collected through online forms or messaging apps.

2.1. Consent

We process your personal data based on your consent. Consent is the free, informed and unambiguous expression by which you authorize OSA IT Solutions to process your data.

Accordingly, in line with the General Data Protection Law, your data will only be collected, processed and stored with your prior and express consent.

Your consent will be obtained specifically for each purpose described above, demonstrating the commitment to transparency and good faith of OSA IT Solutions toward its users/clients, in accordance with the relevant legal regulations.

By using the services of OSA IT Solutions and providing your personal data, you are aware of and consent to the provisions of this Privacy Policy, and you know your rights and how to exercise them.

You may revoke your consent at any time, free of charge.

Please note that revoking consent to data processing may make it impossible for some features of our services that depend on it to work properly. You will be informed of such consequences in advance.

3. What are your rights?

OSA IT Solutions guarantees its users/clients the data subject rights set out in Article 18 of the General Data Protection Law. Accordingly, you may, free of charge and at any time:

• Confirm whether your data is being processed, in a simplified form or in a clear and complete format.
• Access your data, and request a legible copy in printed form or by secure and reliable electronic means.
• Correct your data, by requesting that it be edited, corrected or updated.
• Restrict your data when it is unnecessary, excessive or processed in breach of the law, through anonymization, blocking or deletion.
• Request the portability of your data, through a report of the registration data that OSA IT Solutions holds about you.
• Delete data processed on the basis of your consent, except in the cases provided for by law.
• Revoke your consent, withdrawing authorization for the processing of your data.
• Be informed about the possibility of not giving your consent and about the consequences of refusing.

4. How can you exercise your rights as a data subject?

To exercise your rights as a data subject, please contact OSA IT Solutions through the following channel:

Email: [email protected]

To ensure that you are correctly identified as the data subject of the request, we may ask for documents or other evidence of your identity. In that case, you will be informed in advance.

5. How and for how long will your data be stored?

Your personal data collected by OSA IT Solutions will be used and stored for as long as necessary to provide the service or to achieve the purposes listed in this Privacy Policy, taking into account the rights of data subjects and controllers.

In general, your data will be kept for as long as the contractual relationship between you and OSA IT Solutions lasts. Once the storage period ends, your personal data will be deleted from our databases or anonymized, except in the cases provided for in Article 16 of the General Data Protection Law, namely:

I – Compliance with a legal or regulatory obligation by the controller;

II – Study by a research body, ensuring the anonymization of personal data whenever possible;

III – Transfer to a third party, provided that the data processing requirements set out in this Law are met; or

IV – Exclusive use by the controller, with access by third parties prohibited, provided the data is anonymized.

In other words, personal information about you that is essential for complying with legal, judicial and administrative determinations and/or for exercising the right of defense in judicial and administrative proceedings will be kept, notwithstanding the deletion of other data.

The storage of data collected by OSA IT Solutions reflects our commitment to the security and privacy of your data. We use technical protection measures and solutions capable of ensuring the confidentiality, integrity and inviolability of your data. We also have security measures appropriate to the risks and access control over the stored information.

6. What do we do to keep your data secure?

To keep your personal information secure, we use encryption for storage and data, as well as physical, electronic and managerial tools aimed at protecting your privacy.

We apply these tools taking into account the nature of the personal data collected, the context and purpose of the processing, and the risks that any breach would pose to the rights and freedoms of the data subject whose data is collected and processed.

Among the measures we adopt, we highlight the following:

• Only authorized people have access to your personal data.
• Access to your personal data is granted only after a confidentiality commitment.
• Your personal data is stored in a secure and reliable environment.
• OSA IT Solutions is committed to adopting best practices to prevent security incidents. However, it must be noted that no website, software or hardware is entirely secure and risk-free. Despite all our security protocols, problems caused solely by third parties may occur, such as cyberattacks by hackers, or as a result of negligence or recklessness on the part of the user/client.

In the event of security incidents that may create a relevant risk or harm to you or any of our users/clients, we will notify those affected and the National Data Protection Authority (ANPD) of the occurrence, in accordance with the provisions of the General Data Protection Law.

7. With whom may your data be shared?

To preserve your privacy, OSA IT Solutions will not share your personal data with any unauthorized third party.

Your data may be shared with our business partners.

There are also other cases in which your data may be shared, namely:

I – Legal requirement, request, demand or court order, with the competent judicial, administrative or governmental authorities.

II – Corporate transactions, such as mergers, acquisitions and incorporations, automatically.

III – Protection of the rights of OSA IT Solutions in any type of dispute, including legal proceedings.

7.1. International data transfer

Some of the third parties with whom we share your data may be located, or have facilities located, in other countries. In such cases, your personal data will in any event remain subject to the General Data Protection Law and other Brazilian data protection laws.

In this regard, OSA IT Solutions is committed to always adopting effective cybersecurity and data protection standards, using its best efforts to ensure compliance with legal requirements.

By agreeing to this Privacy Policy, you agree to this sharing, which will take place in accordance with the purposes described in this document.

8. Cookies or browsing data

OSA IT Solutions uses Cookies, which are text files sent by the platform to your computer and stored on it, containing information related to your browsing on the site. In short, Cookies are used to improve the user experience.

By accessing our website and consenting to the use of Cookies, you acknowledge and accept the use of a browsing data collection system that uses Cookies on your device.

You may, at any time and free of charge, change permissions, block or refuse Cookies. However, revoking consent for certain Cookies may prevent some features of the platform from working properly. For more details, see our Cookie Policy.

9. Changes to this Privacy Policy

The current version of this Privacy Policy was drafted and last updated on: November 2, 2024.

We reserve the right to modify this Privacy Policy at any time, mainly to adapt it to any changes made to our website or in legislation. We recommend that you review it frequently.

Any changes will take effect upon publication on our website, and we will always notify you of the changes made.

By using our services and providing your personal data after such changes, you consent to them.

10. Liability

OSA IT Solutions provides for the liability of the agents involved in data processing, in accordance with Articles 42 to 45 of the General Data Protection Law.

We are committed to keeping this Privacy Policy up to date, observing its provisions and ensuring compliance with it.

We are also committed to seeking technical and organizational conditions reliably capable of protecting the entire data processing process.

Should the National Data Protection Authority (ANPD) require measures regarding the data processing carried out by OSA IT Solutions, we undertake to follow them.

10.1. Disclaimer

As mentioned in Section 6, although we adopt high security standards to prevent incidents, no platform is entirely risk-free. Accordingly, OSA IT Solutions is not responsible for:

I – Any consequences arising from users' negligence, recklessness or lack of skill regarding their individual data. We guarantee and are responsible only for the security of the data processing processes and for fulfilling the purposes described in this document. Please note that users are responsible for the confidentiality of their access credentials.

II – Malicious actions by third parties, including but not limited to hackers and/or crackers. In the event of security incidents that may create a relevant risk or harm to you or any of our data subjects, we will notify those affected and the National Data Protection Authority (ANPD) and take the necessary measures.

III – Inaccuracy of the information entered by data subjects in the records required to use the services of OSA IT Solutions; any consequences arising from false information or information entered in bad faith are the sole responsibility of the data subject.

11. Data Protection Officer (DPO)

If you have any questions about this Privacy Policy or the personal data we process, you can contact our Data Protection Officer through the following channels: