Diversitrack Platform Privacy Policy

Our privacy policy was created to provide transparency to our responding users and corporate clients about the type of data we collect, how we store it, under what conditions it is shared, as well as its purpose in our work process and especially your rights regarding these data.

To access the tool and its features, the user must read and agree to Diversitera's Privacy Policy, as well as our “Terms of Use and Consent”, available at https://diversitera.com/terms, together with the registering with Diversitrack.

The Privacy Policy and Terms of Use state that individuals agree to provide the data requested in the research and they, aware of the clauses presented, decide to proceed with the Research. Both documents, in addition to the privacy notice, which occurs before the start of the Survey, exempt the participating organization referred to as “corporate client” from any responsibility for providing identifiable and sensitive personal data of responding individuals.

1. Introduction

By accepting the terms of this Privacy Policy, you are aware that the controller of your personal data, that is, the company responsible for making decisions about the processing of your personal data provided, will be DIVERSITERA CONSULTORIA LTDA, registered with CNPJ 34.943 .012/0001-71, with headquarters at Avenida Presidente Altino, blc 5 cj36, Jaguaré, in the city of São Paulo, State of São Paulo, CEP 05323-002.

After reading this Privacy Policy, if you have questions, complaints, suggestions, want to exercise your rights related to your personal data or communicate with Diversitera about this matter, you can contact us by email contato@diversitera. with .

2. Definitions

Diversitera's Privacy Policy is based on the terms and definitions used in Law No. 13,709/2018 (General Data Protection Law, or “LGPD”). It was developed to explain in an understandable, simple and objective way our practices, how your data is processed and why we ask for it.

Whenever there is mention of the terms “Diversitera”, “we” or “our”, we are referring to Diversitera; Likewise, every time there is mention of the terms “you”, “your”, “your”, we are referring to You. Every time there is mention of the terms “platform”, “system” or “Diversitrack” we are referring to referring to the website owned by Diversitera for data collection and analysis through organizational climate and opinion surveys.

In this Policy, we use, among others, the following terms:

2.1. Personal data

Information related to an identified or identifiable natural person.

2.2. Sensitive personal data

Self-declared personal data on racial or ethnic identity, gender, religious belief, sexual affective orientation, political opinion, membership of a trade union or organization of a religious, philosophical or political nature, data relating to health, genetic or biometric data, when linked to a person Natural.

2.3. Titular

Natural person to whom the personal data that is subject to processing refers.

2.4. Controller

Natural or legal person, governed by public or private law, who is responsible for decisions regarding the processing of personal data.

2.5. Operator

Natural or legal person, governed by public or private law, who processes personal data on behalf of the controller.

2.6. Treatment

Any operation carried out with personal data, such as those relating to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer , diffusion or extraction.

2.7. Anonymization

Use of reasonable technical means available at the time of processing, through which data loses the possibility of association, directly or indirectly, with an individual.

2.8. Consent

Free, informed and unequivocal expression by which the holder agrees to the processing of their personal data for a specific purpose.

2.9. Elimination

Deletion of data or set of data stored in a database, regardless of the procedure used.

3. Application

This Privacy Policy is applicable to all users of the Diversitrack platform.

This Privacy Policy is also applicable to other forms of personal data collection by Diversitera, which allow the provision or improvement of our services and products. All forms of collection and use of your personal data are described in this Privacy Policy.

4. What personal data do we collect

To provide the Diversitera Products, we collect and process certain personal data about you. The types of data we collect depend on what and how you use our Products and are divided into the categories below.

4.1. Personal data provided by the holder

4.1.1. Registration data, such as name, identification documents, sex, gender, sexual orientation, color or race identity, whether or not you are a person with a disability, age, level of education.

4.1.2. Contact data, such as email.

4.1.3. Research data, such as organization, sector and area in which it operates, type of relationship with the organization evaluated, date of admission, opinion on issues related to the organizational climate as well as Diversity and Inclusion in the corporate environment.

4.2. Browsing and device data

4.2.1. Internet protocol (IP) address of the device used for access.

4.2.2. URL, network connection, provider, and device information.

4.2.3. Navigation cookies.

4.2.4. Device attributes such as ID, operating system, browser, and model.

4.2.5. Date and time of access on the platform.

4.2.6. The type and version of the browser used may be collected.

By accepting the terms of this Privacy Policy, you expressly agree to provide only true, current and accurate personal data and not to change your identity or personal data in any way when accessing and using our products or services. You will be solely responsible for false, outdated or inaccurate information that you provide directly to Diversitera.

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5. How we use the personal data collected

We use your personal data to provide a quality service to you and your employer, supply and enable the operation of Diversitera products and analyzes in terms of scientific research. Such data is stored in our server's log files. See how below.

5.1. Personal data provided by the holder

5.1.1. Providing personalized content on the platform.

5.1.2. User identification, verification and authentication to access correct content on Diversitrack.

5.1.3. Guarantee of the user's real identity.

5.1.4. Contact via email or other means of communication, including sending notifications and reminders.

5.1.5. Allow real-time monitoring of user review status.

5.1.6. Preparation of a report on the applied Product. When this is done through the organization assessment instrument, the data will be anonymized.

5.1.7. Sending Products (such as individual reviews) as gifts after contact and registration with Diversitrack.

5.1.8. Responding to requests and queries.

5.1.9. Prevention and resolution of technical or security problems.

5.1.10. Improvement of services provided by Diversitera.

5.1.11. Collaboration with or compliance with a court order, competent authority or supervisory body.

5.1.12. Compliance with legal or regulatory obligation.

5.1.13. Ensure the long-term viability of our information technology systems and platform.

5.2. Browsing and device data

5.2.1. Provision of services, offering of contracted Products and improvement of use and experience with Diversitrack.

5.2.2. Generation of statistics on engagement in surveys contracted by corporate clients with their employees and project monitoring

5.2.3. Operationalization of new products and services.

5.2.4. Generation of statistics, studies, research and surveys relevant to activities and behavior in the use of products or services.

5.2.5. Prevention and resolution of technical or security problems.

5.2.6. Collaboration with or compliance with a court order, competent authority or supervisory body.

5.2.7. Compliance with legal or regulatory obligation.

6. How personal data is shared

Diversitera may share your data if you request it. Your data may also be shared with third-party partners and with authorities and regulatory bodies for different purposes, when necessary. Whenever carried out, data sharing will be carried out within the limits and purposes of our business and in accordance with what is authorized by applicable legislation.

We describe below with whom and for what purpose we may share your personal data.

6.1. Contracting company for Diversitrack platform products

6.1.1. Allow the execution of point 5.1.5. of this document.

6.1.2. For Products that use individual assessment instruments.

6.1.2.1. Individual responses to the evaluation and their respective report will be shared, in addition to information on name, surname, organization, sector and area.

6.1.3. For products related to CENSUS RESEARCH, CLIMATE, DIAGNOSIS OF DIVERSITY AND INCLUSION, PERCEPTION or any projects that use organization assessment instruments:

6.1.3.1. Individual assessment responses and sensitive data are completely anonymous and confidential, therefore, there will only be access to the individual's assessment status and information on name, surname, organization, sector and area, for the purpose of monitoring engagement numbers for each specific project.

6.1.3.2. The results and deliverables of the evaluation projects are reported to the employing companies, in a grouped manner. The anonymized responses are grouped into a sufficient number of individuals and with a safety margin so that there is no possibility of identifying the respondent.

6.1.3.3. The objective of research carried out through the Diversitrack platform is to support organizations and individuals to create more inclusive and welcoming environments for everyone. Through knowledge of the composition of its population, the company can improve the effectiveness of its communication and its people management policies, adjust its benefits policy, guide development and career plans, among others.

6.1.3.4. The use of any information from our studies for any punitive or persecutory nature is prohibited. In addition to the anonymization of any data reported to companies, the contractor's commitment is always required at the beginning of each project.

6.2. Upon your request

6.2.1. As the holder and owner of your data, you can request all data relevant to your identity contained on the platform. The request must be sent to contato@diversitera.com and the response time is up to 7 working days.

6.3. Authorities and regulatory bodies

6.3.1. Regular exercise of Diversitera's rights, including presenting documents in judicial and administrative proceedings, if necessary.

6.3.2. Compliance with a court order, compliance with a request from a competent authority or supervisory body.

6.3.3. Compliance with legal or regulatory obligation.

Furthermore, when using our platform (diversitrack.online), you may be redirected to third-party websites or applications. Once you are redirected to a third-party website or application, its privacy practices will be governed by that third party's privacy policies and terms of use. We cannot control or be responsible for the privacy practices and content of third parties. Please read the applicable privacy policies carefully to understand how they collect and process your data.

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7. Updating, correcting, retaining and deleting personal data

During the use of our products and services and for the entire period in which Diversitera stores your personal data, it will be kept in a secure and controlled environment. We grant you the ability to access, correct or update your personal data directly on our platform. Furthermore, you have the right to request, at any time, that Diversitera deletes your personal data.

To delete your data or if you have any questions about correction or updating, please contact us via email: contato@diversitera.com

When applicable, even after a deletion request, we may retain your personal data for an additional period to comply with legal obligations, resolve disputes or enforce our agreements. Meanwhile, your data will be inactivated in the system and database.

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8. Rights of the holder

The Holder has the right to obtain from the Controller, in relation to the data processed by him, at any time and upon request: I - confirmation of the existence of processing; II - access to data; III - correction of incomplete, inaccurate or outdated data; IV - anonymization, blocking or elimination of unnecessary, excessive or processed data that does not comply with the provisions of Law No. 13,709; V - portability of data to another service or product provider, upon express request and in compliance with commercial and industrial secrets, in accordance with the regulations of the controlling body; VI - deletion of personal data processed with the holder's consent, except in the cases provided for in art. 16 of Law No. 13,709; VII - information on public and private entities with which the Controller shared data use; VIII - information about the possibility of not providing consent and the consequences of refusal; IX - revocation of consent, pursuant to § 5 of art. 8th of Law No. 13,709.

Right to revoke consent

This Terms of Consent may be revoked by the Holder, at any time, upon request via email or correspondence to the Controller, without prejudice to anonymized data, which may be kept for an indefinite period, at the discretion of the Controller, in accordance with art. 12, combined with art. 5th, III and XI, of the General Personal Data Protection Law.

If you wish to exercise any of these rights, please contact us directly with our data operator at contato@diversitera.com. To enforce your rights, we may request proof of your identity, as a security measure.

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9. Activity Log

When you register, access and use our platform we create logs (records of activities carried out) that will contain: the IP address, actions carried out by you, date and time of each action carried out and information about the device used, such as the system version operating system and browser.

We may also use certain technologies such as:

9.1. Cookies

Internet files that temporarily store what you are visiting on the network. Diversitera has cookies on its platform. Cookies can be used for a variety of purposes, including remembering you and your preferences, persisting information related to your activities on Diversitrack, or collecting information that can be used to deliver content in a personalized way.

We may have third-party cookies enabled on our platform. Privacy practices will be governed by the privacy policies and terms of use of these third parties, so we cannot control or be responsible for the privacy practices and content of third parties. Therefore, we highlight that you can, at any time, block the use of cookies by activating a setting on your internet browser and your ability to limit cookies will be subject to the settings and limitations of your browser. You can also delete existing cookies using the same settings as your internet browser. If you choose to disable cookies, you will be able to continue using our platform, but some parts of the pages may no longer work.

9.2. Web beacon

It is a technique that allows you to map who is visiting a given web page, identifying their behavior with different websites or web servers.

9.3. Analytics tools

Tools that may collect information such as how you visit a website, including which pages and when you visit such pages, as well as other websites that have been visited before, among others.

All technologies used by us will always respect the terms of this Privacy Policy.

10. International transfer of personal data

Some or all of your personal data is stored by Diversitrack on secure cloud computing servers located in Brazil, belonging to multinational technology companies with a global presence, so it may be transferred abroad. To this end, Diversitrack observes all requirements established by current legislation and adopts the best security and privacy practices to guarantee the integrity and confidentiality of your personal data.

11. Security measures

We take security measures that seek to inhibit and prevent problems involving the processing of the data provided. Diversitrack uses encryption for data at rest, in transit and in use, to guarantee the integrity of information, in addition to servers with guaranteed layers of protection and all requests in HTTPS.

This data can also be stored using cloud computing technology and other technologies that may emerge in the future, always aiming to improve and improve our services and security.

There is still no 100% (one hundred percent) secure system of protection against the actions of hackers or third parties equipped with methods of obtaining information improperly. As a result, Diversitrack is not responsible for illicit access, as well as for acts of third parties who are successful in collecting or using, by any means, registration data and information made available on our platform by you.

12. Consent

Throughout this Privacy Policy, we inform you that some personal data will only be collected by the platform with your consent. Likewise, this personal data may only be processed with authorization.

By selecting the checkbox “I have read and agree to the Diversitrack Terms of Use and Privacy Policy.”, you consent to the processing of personal data in the ways indicated here.

The processing of your personal data is a necessary condition for us to provide our services and deliver our products. If you have questions about any of the terms explained here, we are available on our customer service channels to help you.

It is worth remembering that our business model has as its pillar of support the trust of individuals who are willing to register and use our platform, and the privacy of our users is the number 1 priority in our work.

13. Changes to this Privacy Policy

Diversitera may modify this Privacy Policy for the purpose of improving, adapting or updating it to comply with the law and jurisprudence.

We will notify you before making changes to this policy and give you the opportunity to review the revised policy before deciding to continue using our Products.

14. How to contact us

If you have questions about this Policy, you can contact the data operator directly by email at contato@diversitera.com.

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15. Forum

The Central Forum of the District of São Paulo, State of São Paulo is elected as competent to resolve any conflicts arising from this contract.