XCOM by Atrevia – Privacy Policy

Table of Contents

1. Initial Considerations
2. Data Collected and Processed
3. Marketing
4. Sharing with Third Parties
5. Retention Time and Information Security
6. Data Subject Rights
7. Exercise of Data Subject Rights
8. Privacy Policy Review

1. Initial Considerations

XCOM values transparency, ethics, privacy, responsibility, and absolute respect for personal data processed – whether from our clients, suppliers, employees, or business partners.

We recommend that you read our Privacy Notice. Through it, you will understand how personal data is processed by us and for what purpose.

2. Data Collected and Processed

Your data is provided directly by you (data subject) through electronic contact (email), telephone, or social media. The collected data is used solely and exclusively for sending email marketing and contact regarding contracted services.

The collected data includes name, email, telephone, and in some cases, information from the social media you use.

The information provided will be treated as confidential and stored securely. All required information will be used for the development of XCOM’s activities and to provide the best service to our clients.

It is important to state that XCOM does not collect any type of sensitive personal data, namely: racial or ethnic origin, religious conviction, political opinion, union membership or membership in religious, philosophical or political organizations, health or sexual life data, genetic or biometric data.

3. Marketing

XCOM will use your data to better target commercial, advertising, or sponsored content to you on its pages.

In all mailings directed by XCOM, the data subject may configure not to receive any messages. Our registry includes a mechanism (“do not authorize” option or opt-out) that allows data subjects to stop receiving any email.

4. Sharing with Third Parties

XCOM may disclose collected personal data to third parties in the following circumstances and within the limits required and authorized by law: (i) With its clients and partners when:

(i) Necessary and/or appropriate for the provision of related services; (ii) With companies and individuals contracted for the execution of certain activities and services on behalf of XCOM; (iii) With suppliers and partners for the achievement of services contracted with our company (such as information technology, accounting, among others); (iv) When necessary due to legal obligation, determination by competent authority, or judicial decision;

In the event of sharing, we have contracts requiring full observance of the purpose and objective for which they were collected, fully observing compliance with this Privacy Notice and all applicable data protection laws.

XCOM under no circumstances commercializes personal data or shares it with third parties without a legitimate purpose or in non-compliance with Applicable Laws.

5. Retention Time and Information Security

Collected personal data remains stored for the time necessary for legitimate purposes and is securely discarded when the data subject requests mailing cancellation, in accordance with Applicable Laws.

We adopt technical and administrative measures to protect personal data from unauthorized access and accidental or unlawful situations of destruction, loss, alteration, disclosure, or any form of inadequate or unlawful processing.

6. Data Subject Rights

The data subject has the right to:

• Request confirmation of the existence of processing of their personal data;
• Have access to processed data;
• Correct incomplete, inaccurate, or outdated data;
• Demand anonymization, blocking, or elimination of personal data that proves unnecessary or whose processing, for any reason, comes to be considered irregular;
• Request data deletion;
• Request data portability to another service or product provider;
• Know with which entities personal data has been shared.

7. Exercise of Data Subject Rights

Fagner Azevedo Neri has been appointed as XCOM’s Data Protection Officer to ensure that your request is answered within 15 (fifteen) days.

For any information regarding personal data processing, contact us through the email encarregadolgpd@xcom.net.br

When making contact, for your own security, confidentiality, and data inviolability, we may request that you provide us with additional information or perform procedures capable of confirming your identity.

8. Privacy Policy Review

XCOM reserves the right to modify this Privacy Notice at any time, always informing the latest updated version of the Privacy Notice on our website. These changes will become effective on the day of their publication. XCOM encourages you to frequently review the privacy policy.

This Privacy Notice was updated on August 2, 2021.