Privacy Policy

This privacy policy (“Policy”) describes information that we process to enable operating our digital platform (“WDC Networks Platform”) and is integral part of Terms of Use (“Terms”) that rule the access and use of WDC Networks Platform, a available and maintained by Livetech da Bahia Indústria e Comércio S.A., registered as Corporate Taxpayer CNPJ/ME under no. 05.917.486/0001-40, located at Rodovia BA 262, Rodovia Ilhéus x Urucuca, S/N, complemento Km 2,8, Bairro Iguape, CEP 45658–335, municipality of Ilhéus, State of Bahia (hereinafter referred to as “WDC Networks” or “we/us”).  

WDC Networks is commited to protect, under terms of applicaple legislation, especially as provided on Law no. 12.965, of April 23, 2014 (“Civil Rights Framework for the Internet”) and Law no. 13.709, of August 14, 2018 (Brazilian “GDPR”), the privacy of personal data of its employees, customers, business partners and other identifiable people. In this context, WDC Networks implemented a program for privacy and data protection to establish and maintain higher standards to collect, use, publish, storage, protect, access, transfer, and/or process personal data of WDC Networks Platform users (“User”). 

The Policy herein describes the approach adopted by WDC Networks to process personal data that allow the feasibility and development of its operation (“Services”). The objetive is to clarify to interested parties about collected data, reasons to collect and how the User can update, manage or delete these information.  

For purpose of the Policy herein, the expression “data treatment” means: all operation performed using personal data, such as those related to collection, production, reception, sorting, utilization, access, reproduction, transmission, distribution, processing, filing, storage, exclusion, evaluation or information control, modification, communication, transference, broadcast or extraction. 

Upon accessing the WDC Networks Platform and its contents, the inteacting with available contents, the User also grants his free and expressed consent to let us collect and treat his personal data, according to the purposes, conditions and form exposed herein, and ensures the accuracy of the provided information. The acceptance by the User of this Policy occurs expressly, freely and spontaneously. 

WDC Networks Platform is in constant development, to meet demands of its Users and to comply with the applicable legislation. Thus, WDC Networks may chance this Policy, it is fundamental to refer to this document on regular basis, notwithstanding sending of notice by us whenever this Policy is changed. 

User’s personal data are collected by WDC Networks Platform as follows: 

(i) The User must create an account in the WDC Networks Platform, and all personal data provided for registration, required to use our Services, are stored by us and associated to the respective User account (“Account”). Upon creating an Account, we can identify the User.  

(ii) When the User accesses the WDC Networks Platforma, the information on interaction and access are collected by WDC Networks to assure the best experience to the user and visitor. These data can be about keywords used for search, sharing a specifica document, comments, page views, profiles, URL from where the user and visitor come from, browser and access IP, and others that can be saved and retained. 

(iii) Intermediated by third party: WDC Networks Platform receive data from third party, when an user log in to his profile of these websites. The user authorize in advance the use of these data with the subject third party. 

All collected information is properly treated, following the most rigorous norms of data protection, and in accordance with the principles highlited below:  

(i) The User’s Personal data is processed in a licit, loyal and transparent way; 

(ii) The User’s Personal data is collected only for defined, explicit and legitimate purposes, and may not be treated further in a way incompatible with these purposes; 

(iii) The User’s personal data is collected in a proper way, pertinent and limited to the needs of the objective to which they are processed; 

(iv) The User’s personal data is updated whenever necessary, in order to delete or rectify inaccurate data, as possible; 

(v) The User’s personal data is kept in a way that allows to identify the data subjects only during the required time for purposes to which it is treated. 

 

The collected information is:  

• Data provided by the User: We collect information provided by the User upon registration to create an Account (e.g., User name, password, name, e-mail address, contact information, address information, Corporate or Individual Taxpayer Registry Number, and location). 

• Automatically collected data by WDC Networks Platform: Our Services automatically collect some technical information, including but not limited to, device type used to access Services, connection IP (with access date and time), approximate geographical location, unique identification number of his device (such as MAC Address or IMEI), information on use of Services, software or browser used to access Services, operational system and version of used device  and so on. 

• Cookies: WDC Networks may also use standard technology to collect User information, such as cookies, to improve his browsing experience. The persistent cookie remains in the user’s and visitor’s hard disk after the browser is closed and is used by browser in further visits to the website. The persistent cookies can be removed by following instruction of the browser. The session cookie is temporary and disappears after the browser is closed. It is possible to redefine in the User’s web browser to reject all cookies, but some features of WDC Networks Platform may not correctly work and accept cookies when disabled. 

 

Complying with strict terms of the Brazilian GDPR, the User’s rights for Services on WDC Networks Platform is as follows:  

1. Right to confirmation and access: the User has the right to obtain from WDC Networks Platform the confirmation that  his personal data are ou not subject to treatment and, if it is the case, has the right to access his personal data; 
2. Right to rectification: the User has the right to obtain from WDC Networks Platform a rectification of innacurate personal data; 
3. Right to data elimination: the User has the right to have his data deleted from WDC Networks Platform; 
4. Right to limit data treatment: the Right has the right to limit the treatment of his personal data, and can obtain upon claiming data accuracy, when a treatment is illicit, when the WDC Networks Platform does not require the data anymore for the proposed purposes and when opposing to data treatment in case of unnecessary data treatment; 
5. Right to data portability: the User has the right to receive his data, provided to WDC Networks Platform, in a structured format, for current use and automatic reading, and right to transmit these data to other application, safeguarding commercial and industrial secret data of WDC Networks; and 
6. Right to information: right to request to us to provide additional information on use of personal data, as well as to provide a copy of personal data given to us.

The use of these rights is subject to defined exceptions in order to safeguard public interest (crime prevention or detection) or our interest (maintenance of professional secrecy).  

When using one of these rights, we proceed to analyze and answer within the term provided on Brazilian GDPR. 

The User has the right to remove his consent at any time, not compromising the legality of his personal data treatment before its removal. The consent removal can be performed by e-mail: marketing@wdcnet.com.br.  

WDC Networks Platform will notify, in case of reticfying or excluding User data. 

When using Services of WDC Networks Platform, the User consents with the Policy herein. WDC Networks Platform only treats personal data only in legally authorized situations or upon expressed and inequivocal consent by the User.  

Information shared by User with the WDC Networks Platform has purpose of Service management, administration, provision, expansion and improvement.  

Therefore, the legal bases include his consent and ligitimate interests on WDC Networks Platform for Service availability, development and improvement, since its processing does not harm the User’s rights and freedom. In other words, the legitimate interest is toward developing and improving WDC Networks Platform Services, always complying with this Policy for data protection, strictly with the terms of applicable legislation.   

We are obliged by law to keep some basic access record data of Services, including, but not limited to, IP address of connection origin with date and time. Such data area kept for a minimum period of 6 (six) months. Eventually, other data can also be stored to comply with legal obligations. 

Also, we may use, for example, technical information collected from his device to make easier support and provision of technical assistance in case of “bug” or Service failure, by adding functions or improving other Service aspects and its browsing capacity. 

We may also use collected data to direct offers and advertising to the User, that we think of his interest. Such offers and ads are, whenever possible, related to WDC Networks Platform or WDC Networks.  

At last, WDC Networks may also use collected data for secondary purposes not in conflict or excessive, related to the purposes listed above, including selling data bases to third parties, always complying with the Brazilian legislation, based on his legitimate interest, except in cases when legal rights and warranties of the User prevail. 

The personal data treatment for purposes that are not provided in this Policy occurs only upon communication in advance to the User, and upon acceptance of the new information given, and in any case, the rights and obligations provided in this Policy remains applicable.

WDC Networks may share data collected through WDC Networks Platform with third parties in situations as described below: 

(a) To protect interests of WDC Networks in any type of conflict, including lawsuit; 

(b) In case of transations and alterations of incorporation documents involving WDC Networks, hipothesis of information transference is required for service continuity and products delivery; 

(c) Upon court order or requisition from administrative authority with legal competence for requisition;  

(d) When data are necessary for information delivery process, they are sent to a WDC Networks authorized reseller in order to return the original demand requested by the User, such as price estimations or other information related products, prices, proposals, payment conditions, inventories, and so on. The reseller has obligation to use information provided by WDC Networks only and exclusively for purpose of attending the request sent by the User, and may not use the informed data for any other purpose without autorization; 

(e) With WDC Networks partner companies, for promotion, advertising and statistics purposes, as provided in this Policy. 

 

WDC Networks may share data collected through the WDC Networks Platform with service providers, subcontrators or other suppliers that work, directed by WDC Networks, for treatment of personal data collected on WDC Networks Platform, in condition of treatment operators in order to allow the correct provision of the WDC Networks Platform to the Users. 

WDC Networks may use data sharing with public organizations, upon their request, for projects of interest of WDC Networks and/or public interest, and WDC Networks commits to provide all the subject information to the User, as provided on Brazilian GDPR, whenever such shared use occurs. 

The collected data treatment is performed by WDC Networks, or by third parties guided by WDC Networks, which is responsible for project compliance as a whole, as Controller, except in hypothesis of responsibility exemption as provided on this Policy or Terms of Use.  

WDC Networks is committed to apply technical and organizational measures to protect personal data against unauthorized access and situation of data destruction, loss, change, communication and broadcast of such data. 

We implement the following measures, among others: 

• Restrict personal access to personal data based on “needs” criteria only within the range of communicated purposes;
• Transference of collected data as encrypted data only;
• Information technology systems protection by firewalls, in order to prevent unauthorized access to personal data;
• Permanent monitoring on accesssing information technology systems regarding to prevent, detect, and block unduly use of personal data.

The collected data provided when using WDC Networks Platform and its features, including those voluntarily provided by the User, are kept while the relationship between the User and WDC Networks exists, therefore, without maintenance, it is not possible to provide the WDC Networks Platform and its features. 

The collected data that allows improving WDC Networks Platform for technical support service are kept during the time required for implementation or provision of specific assistance requested by the User, and can be definetely deleted or made anonimous added to data base for statistics purpose, upon request by the User. 

The collected data kept with purpose to comply with legal obligations by WDC Networks are maintained as provided on Section I of Article 15 of the Brazilian GDPR. 

Eventually certain relevant data, always considering the minimum required, may be stored beyong the term described above, with purpose of: 

(i) defense of WDC Networks rights by court or out-of-court procedures; 

(ii) compliance with legal or regulatory obligation by the controller; 

(iii) study by research organization, assuring whenever possible, to make personal data anonimous; 

(iv) transference to third party, complying with the requirements for data treatment as provided on Brazilian GDPR;  

(v) exclusive use by the controller, prohibiting the access by third party, since data is made anonimous. 

WDC Networks Platform may have links with other websites that are not owned by the company. WDC Networks does not assume any liability related to contents and/or norms and privacy prctices of such third party websites. We recommend that Users read the privacy statements of linked websites, because their practices on privacy may differ from ours.  

At last, WDC Networks is committed to treat User’s personal data with confidentiality, within the legal limits.  

WDC Networks Platform can be accessed by adderess [=], which has Digital Certification SSL (Secure Socket Layer), encryption technology for all transmitted data between the User’s device and our website. With this feature, the Usuário sends his/her data with total security and privacy. Anyway, is is important that the User is aware about the security measures related to internet are not fully failure-proof. 

However, WDC Networks is exempt, despite always performing at maximum and best efforts to prevent, for the exclusive action of third parties, as in case of cyberatack by hackers or crackers, or exclusive action of the User, as when he transfers his data to third parties. WDC Networks is also committed to communicate to the User, in timely manner, if any kind of security breach on personal data occurs that can pose high risk to its rights and personal freedom. 

Personal data breach is a security infringiment that causes, accidentally or illicitly, destruction, loss, change, release or unauthorized access to transmitted personal data, maintained ou subject to any other type of treatment.

The exclusion of data stored by WDC Networks may be requested, under conditions established by GDPR, through WDC Networks Platform tools or by e-mail marketing@wdcnet.com.br . WDC Networks declares to be committed to make its best efforts to perform all requests for exclution, when applicable, as soon as possible. Such exclusion, when including data required for Service functions, also results in termination of Terms of Use and exclusion of the User’s Account. Even in such case, WDC Networks may keep personal data stored, and shall not be subject to active treatment, in order to comply with its legal obligations for data storage. 

We share information globally, both internally and externally with our partners in accordance with this Policy. On hypothesis of personal data communication to third parties, by speakers or not, in case of international transferences, WDC Networks assures that all entities that may receive such data are subject by specific contractual clauses or confidentiality and data security agreements, with purpose of imposing such third parties or foreign data recipients to the same obligations on security, integrity and confidentiality as described in this Policy. In addition, in cases of international data transference, WDC Networks certifies that such transference occurs within the acceptable legal hypothesis for personal data protection standards to be required from the recipiente of such data.  

Personal data collected while using the WDC Networks Platform can be processed by us or by affiliates or subcontractors. Our company is established in Brazil, but our affiliates, subcontractors or partners may be located or perform data treatment abroad. Therefore, upon agreeing with this Policy and with the associated Terms of Use, the User also agrees that his/her data are subject to international transferences to affiliates or subcontractors, and declares to be aware of all applicable warranties for foreign data treatmento, according to this Policy and related Terms of Use. 

We will notify the User about any change in this Policy, as highlighted, in order to make the User fully aware of the changed contents. 

Any request by User related to his/her data – information, change request, cancel, and so on, as well as if there are doubts concerning to this Policy – contact us at customer relationship channel, e-mail: marketing@wdcnet.com.br . 

All and any request. claim, information request ou use of data subject rights can be made by written message to the above e-mail address, containing at least, the following  information and documents: 

1. Full name of the requesting party; 

(b) ID card (RG) and Taxpayer Registry (CPF) numbers; 

(c) E-mail address used for registration on WDC Networks Platform; 

(d) Copy of D card (RG) and Taxpayer Registry (CPF); 

(e) Request description. 

 

Eventually, other information and documents may be requested to proceed with the requisition, and in case of any doubt concerning to the accuracy of of provided information or identity of the requesting party. 

Any controversies arisen from this Policy shall be fully governed by the Brazilian Law. 

Eventual lawsuits shall be presented before the Civil District Court of São Paulo, State of São Paulo. 

 Date of latest revision: August 2020.