Data Protection Policy

Privacy is very important to us. Therefore, we have developed this data protection policy to help you understand how we collect, use, store, share, transmit, transfer, delete, or process personal data. This policy explains the measures we take to ensure the protection of personal data and how you can reach out to us with any questions about data protection.

SCOPE

This data protection policy applies to the Creare Systems Group (hereinafter referred to as "Creare") and GoAwake, covering all dimensions and activities across all regions where we operate.

This policy pertains to the processing of personal data collected by Creare/GoAwake, either directly or indirectly, from all individuals, including but not limited to current, future, or potential job applicants, employees, clients, suppliers, contractors, subcontractors, shareholders, or any third parties. "Personal data" in this context refers to any information related to an identified or identifiable individual or a person who can be reasonably identified through the data.

COLLECTION AND PROCESSING OF YOUR PERSONAL DATA

Compliance with General Data Protection Laws and Other Applicable Local Data Protection Regulations

We commit to complying with all relevant legislation concerning personal data and ensuring that personal data is collected and processed in accordance with legal provisions.

Loyalty, Fairness, and Transparency

We do not collect or process personal data without a lawful reason to do so. We may need to collect and process personal data when necessary for contract execution, compliance with legal obligations, or legitimate interests pursued by Creare/GoAwake, unless these interests are overridden by fundamental rights and freedoms.

When collecting and processing personal data, we will provide clear and complete information about the data processing, including the responsible data processor, the purposes of processing, recipients of data, data subject rights, and how to exercise them, unless it is impossible or requires disproportionate effort.

Where required by applicable law, we will seek prior consent (e.g., before collecting any sensitive personal data).

Legitimate Purpose, Data Limitation, and Minimization

Personal data is collected for specific, explicit, and legitimate purposes and is not processed in a manner incompatible with those purposes.

When Creare/GoAwake processes data for its own purposes, personal data is mainly processed for purposes such as recruitment management, human resources management, financial accounting and management, treasury and tax management, risk management, personnel security management, provision of IT tools or internal websites, and any other digital solutions or collaborative platforms, IT support management, health and safety management, information security management, customer relationship management, tendering, sales and marketing management, supply management, internal and external communication, event management, compliance with anti-money laundering obligations or any other legal requirements, data analysis operations, legal corporate management, and compliance process implementation.

When providing services for our clients or among our entities, we may also process personal data on behalf of a data controller (whether a client or another Creare/GoAwake entity) to effectively operate, manage, perform, and deliver our services. We ensure that the processed personal data is relevant, limited, and necessary for the intended purposes.

Data Accuracy and Storage Limitation

Creare/GoAwake will maintain accurately processed personal data and update it when necessary. Additionally, we retain personal data only for the time necessary to fulfill the purposes for which it was processed (in accordance with our Data Retention Policy). Creare/GoAwake will follow client instructions to aid them in fulfilling this obligation.

Security of Personal Data

We implement appropriate technical and organizational measures to protect data (personal or otherwise) against unauthorized access, alteration, loss, or illegal use or disclosure, in accordance with our Internal Information Security Policy.

We take, where appropriate, all reasonable privacy-by-design and privacy-by-default measures to implement necessary safeguards and protect the processing of personal data. Depending on the level of risk posed by processing, we conduct internal privacy impact assessments to adopt suitable safeguards and ensure the protection of personal data. Additional security protections are provided for data deemed confidential.

Disclosure of Personal Data

In the course of our business and for processing purposes, we may share personal data with relevant personnel within the Creare/GoAwake Group or with duly authorized employees, contractors, or subcontractors. This ensures consistency in our activities, maximizes the quality and efficiency of our services and operations.

We may also be obligated to disclose personal data to regulatory authorities, courts, and government agencies as required by law, regulation, legal process, or to protect the interests, rights, or property of Creare/GoAwake or related third parties.

Otherwise, we will not share personal data with other parties unless we have prior approval for such sharing.

International Transfer of Personal Data

We may transfer some personal data to service providers located abroad, including cloud service providers. When this occurs, Creare/GoAwake will take appropriate measures to ensure adequate protection in accordance with applicable legal requirements.

COOKIES AND OTHER TRACKING TECHNOLOGIES

Like many companies, some of our websites may use cookies and other tracking technologies.

What are cookies? They are small files downloaded to your computer to enhance your experience. You can prevent this by adjusting your browser settings (see your browser's help for instructions). However, in most cases, there are no default options to disable cookies without completely impacting the functionality and features they add to the site. Therefore, it is recommended that you leave all cookies enabled if you are unsure whether you need them, especially if they are used to provide a service you use.

Account-related Cookies: If you create an account with us, we use cookies for managing the registration process and general administration. These cookies are usually deleted when you log out. However, in some cases, they may remain to remember your site preferences upon leaving.

Login-related Cookies: We use cookies when you are logged in to remember this action, preventing you from needing to log in each time you visit a new page. These cookies are usually removed or cleared when you log out, ensuring you can only access restricted resources and areas after logging in.

Email Newsletter-related Cookies: Our site offers newsletter or email subscription services, and cookies may be used to remember if you are already registered and whether certain notifications should be displayed only to subscribed/non-subscribed users.

Survey-related Cookies: Periodically, we conduct surveys and questionnaires to provide interesting information, useful tools, or to better understand our user base. These surveys may use cookies to remember who has already participated or to provide accurate results after page changes.

Form-related Cookies: When you submit data through a form, such as those found on contact pages or comment forms, cookies may be set to remember user details for future correspondence.

Site Preference Cookies: To provide an optimal experience on our site, we offer functionality to set your preferences for how it operates when you use it. To remember your preferences, we need to set cookies so this information can be recalled whenever you interact with a page affected by your preferences.

Google Analytics Cookies: These may track things like how long you spend on the site and the pages you visit, helping us produce engaging content. For more information about these cookies, refer to the official Google Analytics page.

Cookies for Testing and Performance Improvement: Periodically, we test new features and make subtle changes to the site's presentation. While testing new features, these cookies may be used to ensure you receive a consistent experience on our site as we seek to understand the optimizations our users appreciate most.

Cookies and Communication Statistics: As we sell custom fleet solutions, it's important to understand statistics about how many site visitors actually contact us and acquire our solutions. This is the

kind of data these cookies will track. This is important for you, as it means we can accurately forecast business, allowing us to analyze our advertising costs and product prices to ensure the best possible rates.

CONTACT INFORMATION

The Creare/GoAwake Group has appointed a Data Protection Officer (DPO). To exercise your rights regarding personal data, you can send your requests or complaints to the email address: This email address is being protected from spambots. You need JavaScript enabled to view it..

In case of an incident involving personal data, you should contact the Creare/GoAwake DPO at the above email address.

LEGAL BASIS

Law 12.965 / 2014 (Internet Civil Rights Framework)

Law 13.709 / 2018 (General Data Protection Law)

MP 959 / 2020 (amendments to LGPD)

General Data Protection Regulation (GDPR)

  • +55 (51) 30949090
  • This email address is being protected from spambots. You need JavaScript enabled to view it.
  • Av. Farroupilha, 8001 – ULBRATECH – Prédio 16

  • Canoas – RS
  • +55 (51) 30949090
  • This email address is being protected from spambots. You need JavaScript enabled to view it.
  • Av. Farroupilha, 8001 – ULBRATECH – Prédio 16

  • Canoas – RS

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