SMART DEVICE USAGE, PRIVACY, COOKIES, AND PERSONAL DATA PROTECTION POLICY
This Privacy and Personal Data Protection Policy was created to reaffirm SMART DEVICE’s commitment to the personal data protection of its users and partners, considering the rules related to the General Personal Data Protection Law (Brazil) (Pt: Lei Geral de Proteção de Dados Pessoais, or LGPD) and the General Data Protection Regulation (GDPR).
PLEASE READ CAREFULLY THE POLICY BELOW. IT DESCRIBES HOW YOUR PERSONAL DATA ARE PROCESSED WHEN YOU: (I) USE SMART DEVICE’S SERVICES; (II) USE OUR PLATFORMS; AND (III) CONTACT US THROUGH OUR SERVICE CHANNELS.
ATTENTION: For the purpose of this Policy, “User” or “You” refer to any individual that logs in SMART DEVICE’s platform, contacts, or uses our Services.
This Policy clearly describes how SMART DEVICE, under the role of the Controller, collects, stores, and uses your personal data, as well as your rights, in accordance with the governing laws, particularly Law no. 13.709/2018 (“General Personal Data Protection Law”) and the Regulation (EU) 2016/679 of the European Parliament - General Data Protection Regulation.
By accepting it, you fully agree with personal data being handled under the conditions explained herein.
We always strive to offer services with higher efficiency, and we are constantly updating ourselves. As such, this policy may be updated at any time, and it is your responsibility to check it when appropriate on our website.
But do not worry! Whenever any relevant changes are made in the way we handle your personal data, we will let you know about the new conditions through the contact details you provided when registering.
We should point out that personal data collection is necessary for SMART DEVICE to provide users with suitable features, as well as to customize services, ensuring that your experience is as easy and satisfactory as possible.
Finally, we have written this policy in clear and accessible language, as required by the LGPD, the Directive 93/12/EEC of the Council of the European Community, and Art. 12 of GDPR, in order to make it understandable how we handle your data. But, in case you have further questions or concerns regarding the handling of your personal data, please contact us on the email: [email protected]
WHAT PERSONAL DATA WILL BE COLLECTED BY SMART DEVICE?
We collect the information necessary to fulfill our purpose and to allow you to enjoy the services we offer on our website.
Many times, you will come across the term “personal data” in this Policy. This
term refers to all the information related to you which make it possible to identify you, such as your full name, CPF [Brazilian Individual Taxpayer Registry Identification], RG [Identity Document], address, phone number and other information concerning you that are relevant to the service.
The main personal data we collect are: full name, email address, access status, city, and occupation (physician, manager, or supplier), but we can also collect data related to your web connection, the device you use to access the website and usage details.
These data will be collected when you directly inform us when you fill website registration and log in forms or even indirectly, when the system automatically collects usage details and your IP address.
WHY WILL SMART DEVICE COLLECT MY PERSONAL DATA?
SMART DEVICE is the entity responsible for its users’ personal data processing or for forwarding them to third-party designated or partner entities.
The personal data collected from users will be processed for the purpose of identifying the user for access to the website restricted area, including systems management and other services, auditing, continuous improvement of the tools offered, satisfaction surveys, notifications of new services and/or tools.
We undertake to collect only the personal data necessary for the provision of service and access to the platform, that is, WE ALWAYS STRIVE TO ENSURE MINIMAL PERSONAL DATA COLLECTION. Regardless of what data you provide us, we will use only those that are actually relevant and necessary for the provision of services and access to the platform (website).
We may also collect personal data automatically when you use the SMART DEVICE website or other platform, such as: IP address; Screens you accessed; Dates and times of each action performed on the SMART DEVICE website; Access account; Device information; (operating system version, geolocation, and other installed applications) and Cookies for a better experience on our digital platform.
Please note that, through the email [email protected], you are able to change your consent grants for data processing, grant new permissions or withdraw your consent for current permissions, however, some services and features may become unavailable, making it impossible to effectively and integrally navigating our website.
We may also use your personal data for the following purposes:
- To conduct satisfaction surveys;
- To send messages with information about products or services;
- To comply with legal obligations;
- To help us understand your usage patterns of the Platform and implement improvements;
- To meet your requests and inquiries;
- To communicate with other platform users to share information, and technical and scientific knowledge.
DOES SMART DEVICE COLLECT DATA FROM CHILDREN AND TEENAGERS?
The SMART DEVICE portal is not intended for minors.
We do not knowingly collect personal data from children and teenagers. If you are a minor, do not use or provide any information or register yourself on the website, do not use any of the website's interactive or public comment features or provide any information about yourself to us, including your name, address, e-mail address or any screen name or username you might use.
If we learn that we collected or received personal data from a child or teenager without checking parental consent, we will delete that information.
If you believe that we may have any information belonging to or about a child or teenager, please contact us via email: [email protected]
WILL SMART DEVICE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?
There will be transmission and communication of personal data between SMART DEVICE departments, with access from designated employees, whenever necessary, to enable the best experience and meet user needs.
SMART DEVICE may also transmit your data to contracted entities that, in some way, work in collaboration with us for your best experience and to provide the best service, such as service providers for systems and equipment maintenance, for cloud services; to provide data to competent judicial, administrative or governmental authorities, whenever there is a legal determination, request, requisition or court order; with potential buyers or investors, in the event of corporate reorganizations, with auditing companies solely to carry out audits of the company's operations and to comply with legal or regulatory obligations.
The data collected through our platform may also be shared with:
- IT service providers to provide services such as website hosting;
- Customer relations management services;
- Email service providers;
- Geolocation services;
- Market research services;
- Application provider services;
- Corporate transactions or events;
- Third parties, to market their products or services to you, if you have consciously opted for such disclosures;
-Other users of the website.
BUT BEWARE, any user contributions that you post and transmit to others will be made at your own risk. While we limit access to certain contributions for registered website users, please be aware that no security measures are perfect or unbreakable. We cannot control the actions of other website users with whom you may choose to share your User Contributions.
We do not share personal data with non-affiliated or non-agent third parties, except as provided in this Policy. Some content may require you to provide personal data to third parties to gain access; however, you will be notified of this requirement, the point where you can accept or deny these terms.
We emphasize that we do not control collection or use of your information by third parties to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
Finally, since SMART DEVICE is a platform dedicated to healthcare professionals and to the exchange of information and clinical and/or scientific studies, your data may be shared with doctors, researchers, and partner authors to better serve the purposes of our website. which is the sharing of information and technical knowledge for the continuous improvement of medical science.
To ensure privacy and security in the transmission of personal data, we use SSL (Secure Sockets Layer) encryption of all information exchanged through the web.
This website uses Google and/or Bing cookies to provide services and analyze traffic. Your IP address and web browser are shared with Google and/or Bing, along with performance and security metrics to ensure quality of service, generate usage statistics and detect and resolve abuse.
WILL SMART DEVICE PERFORM INTERNATIONAL DATA TRANSFER?
SMART DEVICE may perform international data transfer to other countries, such as the United States of America, and to countries in the European Union, in order to carry out some of the activities involved in the services provided to users, to share technical and scientific information brought by users, as well as to be able to obtain information that can contribute to the improvement and security of our services.
This data sharing aims to enable the studies and cases published by users of the SMART DEVICE platform a wider reach, taking the knowledge obtained on this website to the greatest number of professionals, improving science and medical studies.
HOW LONG WILL SMART DEVICE STORE PERSONAL DATA?
SMART DEVICE will keep your personal data for as long as necessary or until when, for legal reasons, we are obliged. Otherwise, we will have to exclude them from our bases or make them anonymous so that they are no longer able to identify You.
The storage period will vary according to the purpose for which the information is used, to meet any request made by You or to serve our legitimate interest.
You can request the deletion of personal data at any time but remember that such exclusion may impair the effectiveness of the services offered on our platform.
In addition, SMART DEVICE reaffirms that it will keep running all technical means at its disposal to prevent the loss, misuse, alteration, unauthorized access, and misappropriation of the personal data of its users and partners. In any case, it should be noted that, by circulating the data on an open internet network, it is not possible to completely eliminate the risk of unauthorized access and use, so the user must program appropriate security measures to navigate the website.
HOW DO WE STORE AND PROTECT YOUR PERSONAL DATA?
SMART DEVICE securely stores your Personal Data in the RD Station software, in addition to using the best technical and administrative practices to protect Personal Data from unauthorized access, destruction, loss, alteration, communication or any form of improper or unlawful treatment .
The tool used by SMART DEVICE is SSL (Secure Sockets Layer), that is an encryption tool for webpages that authenticates the parties involved before being transmitted over the web.
Unfortunately, no system is considered completely secure, so we suggest that You also take the necessary precautions, such as choosing a strong password exclusive to SMART DEVICE environments.
Never share it with anyone and limit third party access to your browser.
WHAT ARE COOKIES?
Cookies are small data files recorded by your browser on your device, to save information during your access to the web. These files are stored on your computer and can be retrieved by the website that sent them during browsing.
- Analytics: statistical analysis of navigation, with the aim of improving users' browsing experience.
- Advertising: analysis of users' browsing habits and preferences, with the aim of showing them advertising exclusively related to their browsing profile.
If you want, you can disable cookies or delete them in your browser settings, however, some services and features may become unavailable.
COOKIES AND OTHER THIRD-PARTY TRACKING TECHNOLOGY USAGE:
Some content or applications, including advertisements, on the website are served by third parties, including advertisers, ad networks and servers, content providers and application providers.
We do not control third-party tracking technologies or how they can be used. If you have any questions about an ad or other targeted content, you should contact the responsible vendor directly.
As a resource for our Users, when browsing our platform, we can provide links to other websites on the web, such as of clinics, hospitals, discussion forums, scientific journals and other information sharing platforms aimed at technical, medical, and scientific knowledge.
SMART DEVICE is not responsible for these websites and content, and does not share, subscribe, monitor, validate or accept the way these websites or content storage tools treat your personal and private information. We recommend that you consult the respective privacy policies of such websites to properly get informed about the use of your personal information by other websites or other tools.
WHAT ARE YOUR RIGHTS WITH REGARDS TO PERSONAL DATA:
The General Personal Data Protection Act, as well as the General Data Protection Regulation (GDPR), grants You certain rights with respect to the processing of your personal data, such as: the data owner (You) may at any time request access to data concerning him/her, as well as its rectification, elimination, or limitation in the use of personal data, the portability of his data, or even oppose his treatment, except in cases provided for by law.
You can exercise these rights by writing an email to [email protected].
IS THERE ANY EXPRESSION YOU DID NOT UNDERSTAND? PERHAPS THIS SMALL GLOSSARY MIGHT HELP YOU:
SMART DEVICE knows that some terms used in this Policy might be unknown to you in your everyday life. For this reason, we have prepared a small glossary containing some definitions.
If an expression not contained in this glossary has raised doubts, do not hesitate to ask us through the service channels informed in this Policy.
Anonymization: a process in which you remove the personality from the data and remove the link between you and the information provided.
National Data Protection Authority: Government body responsible for ensuring and supervising compliance with the LGPD.
Data base: structured set of data, including personal data,
installed in one or several locations, in electronic or physical means.
Controller: who is responsible and makes decisions regarding treatment
of personal data.
Cookies: files sent by the SMART DEVICE server to the computer, mobile phone, tablet, or any other device used by You, and responsible for collecting access data to the SMART DEVICE website and platforms, personalizing your navigation.
Personal data: all information related to You, able to identify you.
Sensitive personal data: information related to ethnic or racial origin,
religious belief, political opinion, union membership or organization of a religious, philosophical, or political nature, health, or sexual life data, genetic or biometric data related to You.
Data Supervisor: the person nominated to act as a communication channel between You, the Controller, and the National Authority
for Data Protection.
IP: short for “Internet Protocol”. It is a set of numbers and letters that identifies the device used by you to access SMART DEVICE website and platforms.
Operator: someone who carries out personal data processing under the name of the Controller.
Data Holder: individual to whom the personal data that are being processed refer, such as, for example, the student, the legal guardian and/or third parties (family members and visitors).
Processing: any operation performed with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, disposal, evaluation, control, modification, communication, transfer, dissemination, or extraction.
This Policy must be interpreted according to the Brazilian legislation (LGPD) and the General Data Protection Regulation of the European Parliament (GDPR). If any provision is found to be illegal or illegitimate, the remaining valid conditions will remain applicable.
We have implemented procedures to deal with any suspected personal data breach and will notify you of any data loss and leakage.
The Court of the District of Vitória, State of Espírito Santo/Brazil was elected to resolve any dispute or controversy involving this document.