Release updated on 08/31/2022

Before reading our Privacy Policy, we affirm our commitment based on five (5) key principles regarding Data Privacy:

Control: You will have control over your privacy at any time, upon request, which will be processed within a maximum period of 48 (forty-eight) hours.
Transparency: We are transparent in the collection and use of data so that you can make informed decisions.
Security: Your data is protected through cryptographic mechanisms and excellent security measures.
Strong Legal Protections: We respect the laws of the countries in which we operate and international agreements on data protection for individuals and companies.
No Content-Based Targeting: You will not receive any emails, text messages, files, chats, or other personal content that has not been previously requested through our service channels.

Summary Table

Data Controller:
The Enlighten Company S/A – CNPJ. 28.386.215/0001-01

Role in Data Processing:
Predominantly Controller

Nature of Processed Data:
Personal data provided by the Data Subject and/or automatically collected

Main Purposes

• To use personal data to contact, respond, or maintain communication before, during, or after a contractual relationship with the Data Subject, as well as to fulfill the contract.
  Legal basis: Execution of a contract with the Data Subject. Fulfillment of legal or regulatory obligations.

• To use personal data for data processing and sanitization purposes as instructed by the client.
  Legal basis: Consent from the Data Subject.

Data Sharing

Operators and service providers essential to our activities; authorities and government bodies due to legal or regulatory obligations.

Data Protection

Appropriate security, technical, and administrative measures.

Your Rights

Confirmation of data processing, access, correction, and more.

Your privacy is important to us. This privacy policy explains Enlighten’s personal data processes, how Enlighten processes them, and for what purposes.
Enlighten offers a wide variety of products and services. References to Enlighten’s products and services in this document include Enlighten websites, applications, software, servers, devices, and services.

This policy applies to Enlighten’s interactions with you and to the products listed below, as well as other products that display this policy.

Personal Data

Enlighten collects data from you through our interactions with you and through our products and services. You provide some of this data directly, while some of it is obtained by collecting data about your interactions, use, and experiences with our products and services. The data we collect depends on the context of your interactions with Enlighten and the options you choose, including your privacy settings and the products and features you use. We also obtain data about you from third parties.

If you represent an organization, such as a company, and use enterprise products, this rule also applies to your organization.

There are options when it comes to the technology you use and the data you share. When we ask you to provide your personal data, you may decline. Many of our products require certain personal data to offer the service. If you choose not to provide the necessary data for a product or feature, you may not be able to use that product or feature.

Similarly, when we need to collect personal data required by law or to enter into or perform a contract with you and you do not provide the data, it will not be possible to enter into the contract; or, if it relates to an existing product you are using, we may have to suspend or cancel it. You will be notified if that is the case at the time. Where the provision of data is optional and you choose not to share personal data, features that use this data, such as personalization, will not work for you.

Use of Collected Personal Data

• Enlighten uses the data we collect to provide sophisticated and interactive experiences. Specifically, we use data to:
  • Provide our products, including updates, security, and troubleshooting, as well as customer support. This also includes sharing data when necessary to provide the service or carry out transactions you request.
  • Improve and develop our products.
  • Personalize our products and make recommendations.
  • Advertise and market to you, including sending promotional communications, targeting ads, and presenting relevant offers to you.

We also use the data to operate our business, including analyzing our performance, fulfilling our legal obligations, developing our workforce, and conducting research.

Our processing of personal data for these purposes includes both automated and manual (human) methods of processing. Our automated methods are often related to and supported by our manual methods.

Sharing of Personal Data

We share your personal data with your consent or to complete transactions or provide a specific product that you have requested or authorized.

We may also share data with affiliates and subsidiaries controlled by Enlighten, with authorized vendors, when required by law or to respond to legal processes, to protect our customers, safeguard lives, maintain the security of our products, and protect the rights or property of Enlighten and its customers.

How to Control Your Personal Data

Enlighten guarantees the possibility for users of our products and services to submit requests as listed below:

i) Confirmation of the existence of data processing.
ii) Access to the data.
iii) Correction of incomplete, inaccurate, or outdated data.
iv) Anonymization, blocking, or deletion of unnecessary, excessive, or non-compliant data.
v) Portability of your data to another service or product provider upon the Data Subject’s explicit request.
vi) Deletion of data processed with the Data Subject’s consent.
vii) Obtaining information about public or private entities with which Enlighten has shared your data.
viii) Information about the possibility of not providing consent and being informed of the consequences in case of refusal.
ix) Revocation of consent.

You Can Also Make Choices About the Collection and Use of Your Data

You can control the personal data obtained by Enlighten and exercise your data protection rights by contacting us or using one of the various tools we provide.

In some cases, your ability to access or control your personal data may be limited as required or permitted by applicable law. Access to or control of your personal data also depends on the products used.

The personal data processed by Enlighten can be accessed upon request via the email contato@enlightenbrasil.com.br or communication channels available on the website https://www.be-enlighten.com.

If you wish to access or control processed personal data, you can always contact Enlighten at the address provided on the website https://www.be-enlighten.com.

What Are Cookies and Their Technology

Cookies are small text files placed on your device to store data that can be remembered by a web server within the domain that placed the cookie.

We use cookies and similar technologies to store and respect your preferences and settings, enable you to log in, provide interest-based advertising, combat fraud, analyze the performance of our products, and serve other legitimate purposes.

We also use “web beacons” to help deliver cookies and gather performance data. Our websites may include web beacons, cookies, or similar technologies from third-party service providers.

You have a variety of tools to control the data collected by cookies, web beacons, and similar technologies.
For example, you can use the controls in your internet browser to limit how the websites you visit use cookies and withdraw your consent by clearing or blocking cookies.

Enterprise Products

If you use an Enlighten product or service through an organization you are affiliated with, the organization may:

• Control and manage your access to Enlighten products, including controlling privacy settings related to the product or account.
• Access and process your data, including interaction and diagnostic data and the content of your communications and associated files.

If you lose access to your account, you may lose access to the products and content associated with those products, including those purchased in your own name.

If your organization grants you access to Enlighten products, your use of the products will be subject to your organization’s policies, if any.

You should direct your privacy questions, including any request to exercise your data protection rights, to your organization’s administrator.

Enlighten is not responsible for the privacy or security practices of our clients, which may differ from those set forth in this privacy policy.

When you use an Enlighten product provided by your organization, the processing of personal data in connection with that product is governed by a contract between Enlighten and your organization.

Enlighten processes your personal data to provide the product to your organization and to you.

As mentioned above, if you have questions about the processing of data for your organization, please contact the organization directly.

How We Keep Your Data Secure

ENLIGHTEN uses reasonable market measures and those legally required to protect the privacy of the personal data it collects. Accordingly, ENLIGHTEN adopts several precautions in compliance with security standards set forth in legislation, such as:

1. ENLIGHTEN uses market-standard methods to encrypt and anonymize the collected data.
2. ENLIGHTEN has protection against unauthorized access to its systems.
3. ENLIGHTEN only authorizes access to the storage location of collected information to previously authorized individuals.
4. Individuals who come into contact with personal data must commit to maintaining absolute confidentiality. A breach of confidentiality will result in civil liability, and the individual responsible will be held accountable under Brazilian law.
5. Maintenance of an inventory indicating the time, duration, identity of the employee or person responsible for access, and the specific file accessed, based on connection and application access logs, as required by law.

In addition to technical efforts, ENLIGHTEN also adopts institutional measures aimed at protecting personal data, such as maintaining a privacy governance program applied to its activities and governance structure, which is continuously updated.

VII. Although ENLIGHTEN makes every effort to preserve privacy and protect Data Subjects’ data, no information transmission is completely secure. Therefore, ENLIGHTEN cannot fully guarantee that all information it receives or sends will not be subject to unauthorized access by methods developed to obtain information improperly.
VIII. For this reason, we encourage Data Subjects to take appropriate measures to protect themselves, such as keeping their usernames and passwords confidential, as this information is personal, non-transferable, and solely the responsibility of the Data Subjects.

Data Deletion

ENLIGHTEN uses reasonable market measures and those legally required to protect the privacy of the personal data it collects. Accordingly, ENLIGHTEN adopts several precautions in compliance with security standards set forth in legislation, such as:

1. ENLIGHTEN uses market-standard methods to encrypt and anonymize the collected data.
2. ENLIGHTEN has protection against unauthorized access to its systems.
3. ENLIGHTEN only authorizes access to the storage location of collected information to previously authorized individuals.
4. Individuals who come into contact with personal data must commit to maintaining absolute confidentiality. A breach of confidentiality will result in civil liability, and the individual responsible will be held accountable under Brazilian law.
5. Maintenance of an inventory indicating the time, duration, identity of the employee or person responsible for access, and the specific file accessed, based on connection and application access logs, as required by law.

In addition to technical efforts, ENLIGHTEN also adopts institutional measures aimed at protecting personal data, such as maintaining a privacy governance program applied to its activities and governance structure, which is continuously updated.

VII. Although ENLIGHTEN makes every effort to preserve privacy and protect Data Subjects’ data, no information transmission is completely secure. Therefore, ENLIGHTEN cannot fully guarantee that all information it receives or sends will not be subject to unauthorized access by methods developed to obtain information improperly.
VIII. For this reason, we encourage Data Subjects to take appropriate measures to protect themselves, such as keeping their usernames and passwords confidential, as this information is personal, non-transferable, and solely the responsibility of the Data Subjects.

To protect the Data Subjects’ privacy, personal data processed by ENLIGHTEN will be automatically deleted when they are no longer useful for the purposes for which they were collected or when the Data Subject requests their deletion, except when their retention is expressly authorized by law or applicable regulation to support ENLIGHTEN in future legal or administrative actions where it needs to defend its rights or prove compliance with legal or contractual obligations.

However, the information may be retained to comply with legal or regulatory obligations, transfer to third parties – provided that data processing requirements are respected – and for the exclusive use of ENLIGHTEN, including the exercise of its rights in legal or administrative proceedings.

Standards

Enlighten adheres to the principles of the Privacy Protection framework of the European Union, the United States, and Brazil.

Contact Us

If you are concerned about your privacy, have a complaint, or have a question for the Privacy Officer (DPO), contact us using our form at https://www.be-enlighten.com or send us an email at dpo@be-enlighten.com.

The Enlighten Company
Felipe Rodriguez Alvarez
CEO

Annex 1 – Glossary