This PRIVACY POLICY applies to the use of the ORÇA AÍ services offered by S&S TECNOLOGIA EM INTERNET LTDA, a company duly registered under CNPJ No. 07.518.001/0001-71, located at Rua Maria Giraldi Cavallari, No. 150 – Apt. 1-204, Jardim Cavallari, Marília/SP, Brazil, hereinafter referred to as AELIAN.

Our PRIVACY POLICY is based on Brazilian legislation, especially the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados – LGPD, Law No. 13,709/2018), and explains what information we collect and why we collect it; how we use that information and the choices we offer, including how to access and update information.

We try to keep everything as simple as possible, but if you are not familiar with terms such as cookies, IP addresses, pixel tags, and browsers, please read about these key terms first. Your privacy is important to AELIAN, so whether you are a new or long-time user, please take the time to get to know our practices. And if you have any questions, contact us.

Scope

This Policy applies to all services of the ORÇA AÍ App and applies to everyone who in any way comes into contact with the services, whether they are customers, companies, or users of websites, apps, or other service delivery resources of ORÇA AÍ. All of these individuals will hereinafter be referred to as USERS.

Information we collect

We collect the following personal and usage information to identify USERS and improve their experience in the application:

  • Personal information: Name, e-mail, telephone number, CNPJ or CPF (provided by the user).
  • Location data: To personalize results or features based on your region.
  • Device information: Model, Brand, Operating System, IP Address, and unique identifiers for analysis and security purposes.

Data is collected automatically or provided directly by the user when requested by the application.

Third-party information provided by the User

Given the nature of the ORÇA AÍ services, Users may provide third-party information for the performance of the services. In such cases, the User is responsible for the information provided and for the corresponding legal authorization, with ORÇA AÍ acting as the processor of such data.

The third-party information that may be provided by Users consists of general customer data, such as name, e-mail, telephone number, address, CPF or CNPJ, among others.

Log information

When you use our services or view content provided by ORÇA AÍ, we may automatically collect and store certain information in server logs. This may include details of how you used our service, such as your search queries; Internet Protocol (IP) address; device event information such as issues, system activity, hardware settings, the date and time of your request, and referral URL.

Local storage

We may collect and store information (including personal information) locally on your device using mechanisms such as file storage, databases, and application data caches.

Cookies and anonymous identifiers

We use various technologies to collect and store information when you visit an ORÇA AÍ or AELIAN website, and this may include sending one or more cookies or anonymous identifiers to your device. We also use cookies and anonymous identifiers when you interact with services we offer to our partners, such as advertising services or features that may appear on other websites.

How we use the information we collect

We use the information we collect across all our services to:

  • Provide, maintain, protect, and improve those services;
  • Develop new products;
  • Protect our systems and users;
  • We also use statistics for commercial and scientific purposes.

When you contact ORÇA AÍ, we may keep a record of your communication to help resolve any issues you may have. We may use your e-mail address to inform you about our services, such as notices about upcoming changes or improvements.

We will ask for your authorization before using information for purposes other than those set forth in this PRIVACY POLICY.

Transparency and choice

You may also configure your browser to block all cookies, including cookies associated with our services, or to indicate when a cookie is being set by us. However, it is important to remember that many of our services may not function properly if your cookies are disabled.

Accessing and updating your personal information

Whenever you use our services, our goal is to provide you with access to your personal information. If that information is incorrect, we strive to offer you quick ways to update or delete it – except when we must keep it for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request.

We may decline requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or are extremely impractical.

Where we can provide access to and correction of information, we will do so free of charge, except where doing so would require disproportionate effort. Our goal is to maintain our services in a way that protects information from accidental or malicious destruction. Therefore, after information is deleted from our services, we may not immediately delete residual copies from our active servers, and it may not be possible to remove information from our backup systems.

Information we share

We do not share personal information with companies, organizations, or individuals outside of ORÇA AÍ, except in one of the following circumstances:

  • With your authorization: We will share personal information with companies, organizations, or individuals outside of ORÇA AÍ when we have your authorization to do so. We require (“opt-in”) authorization for the sharing of any sensitive personal information.
  • For external processing: We provide personal information to our affiliates or other trusted companies or persons to process it for us, based on our instructions and in compliance with our PRIVACY POLICY and any other appropriate security and confidentiality measures.
  • For legal reasons: We will share personal information with companies, organizations, or individuals outside of ORÇA AÍ if we believe, in good faith, that access, use, preservation, or disclosure of the information is reasonably necessary to: comply with any applicable law, regulation, legal process, or governmental request; enforce applicable Terms of Service, including investigation of potential violations; detect, prevent, or otherwise address fraud, security, or technical issues; protect against harm to the rights, property, or safety of ORÇA AÍ, our users, or the public, as required or permitted by law.
  • We may share aggregated, non-personally identifiable information publicly and with our partners – such as publisher websites, advertisers, or related sites. For example, we may share information publicly to show trends about the general use of our services.

If ORÇA AÍ is involved in a merger, acquisition, or asset sale, we will continue to ensure the confidentiality of any personal information and will notify affected users before personal information is transferred or becomes subject to a different privacy policy.

Information security

We work hard to protect ORÇA AÍ and our Users from unauthorized access to, or unauthorized alteration, disclosure, or destruction of, the information we hold. Specifically: we encrypt personal information; we review our information collection, storage, and processing practices, including physical security measures, to guard against unauthorized access to systems; and we restrict access to personal information to ORÇA AÍ employees, contractors, and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be prosecuted or terminated if they fail to meet those obligations.

Both our website, through which you access ORÇA AÍ, and our data backups are hosted on Amazon Web Services, the largest and most reliable data center in the world. For more information, visit: https://aws.amazon.com/

Data retention

Depending on the circumstances, we will retain Users’ information for the retention period required, considering the situation that justifies the processing: if for compliance with a legal or regulatory obligation, for the period indicated in the applicable rule; if for the performance of a contract, until the objectives of the contractual relationship are achieved; and if based on legitimate interest — which will always be preceded by a privacy impact assessment and carried out within the limits of the purpose that justifies it — until that interest ceases.

We may also retain your personal information, regardless of your request for deletion and consent, pursuant to Article 16 of the Brazilian General Data Protection Law (LGPD), in the following situations and for the following purposes: compliance with a legal or regulatory obligation; study by a research body, ensuring, whenever possible, the anonymization of the data; transfer to a third party, provided that the data subject’s rights and the requirements of data protection and privacy laws are respected; and our exclusive use, provided that third-party access is prohibited and the data is anonymized.

Contact and incident reports

To exercise your rights or for any necessary communication with ORÇA AÍ regarding the use of the services or this Privacy Policy, you may use the contact form available at: https://orcaai.app.br/en/#contact.

Communications will be received by the responsible party (DPO/Data Protection Officer), who will review the matter and apply the incident response procedure as necessary.

Changes

Our PRIVACY POLICY may change from time to time. We will not reduce your rights under this PRIVACY POLICY without your explicit consent. We will post any changes to the PRIVACY POLICY on this page and, if the changes are significant, we will provide a more prominent notice (including, for some services, e-mail notification of PRIVACY POLICY changes).

Version 1.0, dated November 26, 2024.