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Privacy Policy

This Privacy Policy describes the privacy practices for the Site operated by WT Software (hereinafter referred to as the “Site” if singular, or “Sites”) and how the Site operated by WT Software collects and uses the personal data you provide. on the WT Software Site for the purpose of using the WT Software Service. It also describes the choices available to you regarding our use of your personal information and how you can access, update and delete that information.'

Paulo Roberto ([email protected]) is the designated representative of WT Software in accordance with the law 13.709/209 regarding the protection of individuals with respect to the processing of personal data (the LGPD). The use of the Site is possible without any indication of personal data; however, if a user wants to use the WT Software Service through our Site, the collection and processing of personal data may be necessary. If processing of personal data is necessary, we generally obtain consent from the user as an interested individual.

The processing of personal data such as the name, address, email, telephone number or billing information of an interested individual will always be in accordance with the General Data Protection Law (LGPD) and in accordance with data protection regulations. country-specific data applicable to WT Software. Through this Privacy Policy, we would like to inform the general public about the nature, scope and purpose of the personal data we collect, use and process. In addition, interested individuals (users) are informed, through this Privacy Policy, about the rights that apply to them.

As the controller, WT Software has implemented numerous technical and organizational measures to ensure the most complete protection of the personal data processed through this Site. In this Privacy Policy, “WT Software, “we” and “our” mean WT Software.

Definitions

Personal data means any information relating to an identified or identifiable natural person “interested individual/user”. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to physical, psychological, genetic, mental, economic, cultural or social status of that individual.

Interested individual/user is an identified or identifiable natural person whose personal data is processed by the controller responsible for the processing; a user of the WT Software Software.

Processing is any operation or set of operations that is performed on personal data or sets of personal data, whether by automated means or not, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Pseudonymization is the processing of data in such a way that personal data can no longer be attributed to a specific interested individual/user without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that personal data are not attributed to an identified or identifiable natural person.

Encryption is a security measure for personal data; as a form of encryption, is a process whereby personal data is transformed into an encoded and intelligible version using encryption algorithms and an encryption key, and whereby a decryption key or code allows users to decode the data again.

Consent of the interested individual/user is any specific, informed, unambiguous and freely given indication of the wishes of the interested individual/user whereby he or she, by means of a statement or clear affirmative action, indicates that he or she agrees with the processing of personal data relating to him or her.

Controller for purposes of the General Data Protection Law (LGPD), and other provisions related to data protection is:

WT SOFTWARE LTDA ME, CNPJ : 10176559/0001-20 | R. Manuel Borba, 292 - Santo Amaro, São Paulo - SP, 04743-011 Phone: +55 11 3042-4808 E-mail: [email protected]

Information Collection

Anyone can access our Site without having to provide their personal data. The purpose of processing your personal data by WT Software and collecting information about you is as follows the “Purpose”:

Your intent in using our Service; In order for WT Software to provide you with the requested and purchased Service; For the performance of a contract to which the user is a party, in accordance with Article 11 of the LGPD, and the data collected is necessary for WT Software to identify the user and make the charge if necessary. To verify your identity and provide customer service and assistance; Analyze your use of our Site and Service to better understand how they are being used so that we can improve our Services and user experience, and thus attract and retain users.

As you are willing to use our Service, you must provide your personal data (to register an account and purchase software), thereby becoming a user of WT Software. For this Purpose, we collect and process two types of information: aggregated monitoring (collective data relating to a group or category of customers) and Site usage information that we automatically collect as you access our Site, such as (1) types and browser versions used, (2) the operating system used by the accessing system, (3) the website through which the accessing system arrived at the Site (also called a referrer), (4) the subsites, (5) the data and time of access to the Site, (6) the Internet provider of the access system, (7) data provided by Google Analytics, Facebook, AdWords, Instagram, Tawk.to, and (8) any other similar data and information which can be used in case of attacks on our information technology systems.

When using this data and general information, we do not draw any conclusions as to the individual concerned. Rather, this information is necessary to (1) input the content of our Site correctly, (2) optimize the content of our Site in addition to its advertisements, (3) ensure the viability of our information and technology systems of the Site in the long term, and (4) provide law enforcement authorities with the information necessary for prosecution in the event of a cyberattack. Therefore, we anonymously analyze the data and information collected in order to increase the protection and security of our company's data, and to guarantee a level

great protection for the personal data we process. Anonymous data from server log files is stored separately from all personal data provided by an interested individual (depersonalization), and personal data that you voluntarily provide, subject to your consent, when placing an order for a subscription plan. WT Software Software and accept the usage, privacy and cancellation policies. Please be aware that you are not required to provide us with your personal data. However, if you do not provide us with your name and email address, you will not be able to create an account to log in and make a purchase of the WT Software Software and, accordingly, use our Service.

Collection and Use of Personal Data

We strive to be GDPR compliant and implement the principle of data minimization. Personal data, as defined above, which we collect, consists of: full name (first and last name), (ii) email address, providing the interested individual with the ability to register an account and become a user of the our Service for the purpose of using the WT Software Software accordingly, (iii) billing information, which includes full address, zip code, city, country (iv) payment method (not full credit card number and expiration date), (v) IP address – assigned to the Internet Service Provider (ISP) and used by the interested individual/user, and (vi) location data – for statistics regarding user areas.

The storage of this data assumes that this is the only way to prevent the misuse of our Service, and, if necessary, to enable the investigation of crimes. Storing this data is necessary to protect the controller. These data are not transmitted to third parties, unless there is a legal obligation to transmit the data, or if the transfer serves the purpose of criminal proceedings. The personal data entered by the interested individual/user is collected and stored exclusively for internal use by the controller and for its own purposes. Personal data is stored separately in WT Software's database to avoid identifying the interested individual using depersonalization features in accordance with the LGPD's storage limitation principle. We do not authorize the use of your personal data by any third parties (only under exceptional conditions described below under “Legal Matters”). We operate and maintain a variety of online security measures to protect and keep your personal information private and secure.

When purchasing Software from WT Software, you must fill in User Information, which must contain your personal information, such as identification (first name, last name) and e-mail address, which is processed and stored by WT Software. You must also fill in the Billing Information and Payment Method, which must contain your personal data, which is partially stored by WT Software and processed by payment providers. Based on the personal data you provide us during account registration, we may send you a welcome email to verify your login and password. You can log into your account on the Site using the login and password sent to your email. All activity on your account is password protected, and you must maintain and take all necessary steps to protect the confidentiality of your password. We will also communicate with you to answer your questions regarding any information or Service you request.

Our Site contains information that enables quick electronic contact with us, as well as direct communication with us, which also includes an email address, telephone number and WhatsApp. If a user contacts us in any way, the Personal data transmitted by that user is automatically stored. We will communicate with you via email or any other method you choose (including, but not limited to, telephone). We may use your Personal Data to: (a) improve your browsing experience by personalizing the Site and to improve the Service; (b) send information to you by email regarding registration status, password verification, payment confirmation; (c) send you communications related to your use of the Service.

We may use your Personal Information to contact you with newsletters, promotional or marketing materials and other information that is related to the Service. In this regard, you must separately consent within your account for each communication. You can always unsubscribe from any type of communication on your account. As you use our Service, you may import information that you have collected from target devices into your account. All information is stored and encrypted on servers contracted by WT Software. Information downloaded by a user to their device or browser is not encrypted and the user is solely responsible for protecting it. We do not have a direct relationship with anyone other than you, and as such, you are solely responsible for ensuring that you have appropriate consent to collect and process information from an owner of a target device. If you use a computer in a public place or share a computer with others, please remember to log out of your account and close your browser window when you end your access to our Site and Service to prevent others from accessing your personal information. You are solely responsible for the control and use of each password you create.

Encrypted Data

We use security hardware and software, software update and network scanning procedures designed to protect the information (including personal data) under our control, following generally accepted industry standards. We work with service providers and third-party vendors who use encryption and authentication to maintain the confidentiality of your personal data. If stored, we host personal information on systems protected by firewalls that are accessible only to limited personnel and under a data processing agreement (DPA).

User credentials are stored in the database. User password is not stored. We only store the password hash generated from the user's password. We receive open data from devices using encrypted HTTPS protocol

Legal issues

WT Software considers your use of its Services to be private. However, we may disclose your personal data stored on your account and/or on WT Software's servers and databases to:

(1) comply with the law or legal process given to us; (2) enforce and investigate potential violations of this Privacy Policy; including using this Service to participate in or facilitate activities that violate the law; (3) investigate potential fraudulent activities; (4) protect the rights, property, or safety of WT Software, its employees, its customers, or the public.

In the event of a change in control of WT Software (such as a transfer of assets through a merger, assignment or liquidation of the business entity, or any part of its property, assets or shares), or in the case of a direct or indirect sale of any part of your publishing properties and/or your Site(s), personal data of users of the affected Site(s) in our possession will be transferred to the new owner/successor. You will be notified of such transaction and will be able to exercise your legal rights under the GDPR. You can always change or delete your personal data, or cancel your participation by contacting us as provided below, or if the acquirer publishes a new Privacy Policy with new contact information, you can change or delete your personal data, or cancel your participation following any new instructions that are posted.

We may share Aggregated Information to third parties, including strategic partners, for promotional or marketing purposes under data processing agreements, which protect the transfer and processing of personal data (DPA) in accordance with the GDPR. We may share Aggregated Information to third parties, including strategic partners, for promotional or marketing purposes under data processing agreements, which protect the transfer and processing of personal data (DPA) in accordance with the GDPR. The controller may also transfer to one or more processors (e.g. payment provider under data processing agreement) the personal data of an interested individual for the purpose of payment processing, which is attributable to the controller and without which a user cannot could acquire the Software and use the WT Software Service.

As we use a third-party technology Service to provide the Service, we may transfer your personal data internationally. Providers of such technological Service may process the personal data collected during the process of providing their Services to us in the form of a subcontractor only under a data processing agreement (DPA) in accordance with the LGPD. of personal data, the controller communicates the personal data breach to the interested individual without undue delay. However, as the controller has implemented appropriate technical and organizational protection measures, such as encryption, having been applied to the personal data affected by the personal data breach, the controller is not obliged to notify the interested individual. However, encryption is useless if the access password or other credentials are poorly protected and stored by the interested individual. In this case, the controller is not responsible for the breach of personal data. In the event of a personal data breach, the controller will notify, without undue delay, whenever practicable, within 72 hours after becoming aware of this fact, the personal data breach to the competent supervisory authority.

Rights of the Interested Individual

a Right of confirmation Each interested individual will have the right granted by the legislator to obtain confirmation from the controller as to whether personal data relating to him or her is being processed. If one of the above reasons applies, and an interested individual wishes to request removal of personal data stored by WT Software, he or she may at any time contact us as instructed at the end of this Privacy Policy. We will promptly ensure that the removal request will be complied with immediately.

b Right of access Each interested individual will have the right granted by the legislator to obtain from the controller free information about their stored personal data at any time and a copy of this information. In addition, European directives and regulations grant the interested individual access to the following information: the purposes of processing; the categories of personal data involved; the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular recipients from third countries or international organisations; where possible, the anticipated period for which the personal data will be stored, or, if not possible, the criteria used to determine such period; the existence of the right to request the controller to rectify or remove personal data, or to restrict processing of personal data involving the interested individual, or the purpose of such processing; the existence of the right to file a complaint with a supervisory authority; where personal data is not collected from the interested individual, any information available as to its source; the existence of automated decision-making, including characterization, as indicated in Article 20(3) of the LGPD and, at least in such cases, significant information as to the logic involved, in addition to the significance and anticipated consequences of such processing for the individual concerned. In addition, the interested individual will have the right to obtain information as to whether personal data are transferred to a third country or an international organization. Where this is the case, the interested individual shall have the right to be informed of appropriate safeguards in connection with the transfer. If one of the above reasons applies, the interested individual may at any time contact us as instructed at the end of this Privacy Policy. We will promptly ensure that the removal request will be complied with immediately.

c Right to rectification Each interested individual shall have the right granted by the legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of processing, the interested individual will have the right to complete their incomplete personal data, including by means of a supplementary declaration. If one of the above reasons applies, the interested individual may at any time contact us as instructed at the end of this Privacy Policy. We will promptly ensure that the removal request will be complied with immediately.

d Right to removal (Right to be forgotten) Each interested individual shall have the right granted by the legislator to obtain from the controller the removal of personal data concerning him or her without undue delay, and the controller shall have an obligation to erase the personal data without delay where one of the following reasons apply, provided that the processing is not necessary: ​​Personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed. The interested individual withdraws the consent on which the processing is based, and where there is no legal reason for the processing. The interested individual contests the processing and where there are no overriding legitimate reasons for the processing, or the interested individual contests the processing. Personal data has been processed illegally. Personal data must be erased to comply with a legal obligation to which the controller is subject. Personal data has been collected in connection with the Information Society Service offering. If one of the above reasons applies, and an interested individual wishes to request removal of personal data stored by WT Software, he or she may at any time contact us as instructed at the end of this Privacy Policy. We will promptly ensure that the removal request will be complied with immediately.

and Right to restriction of processing Each interested individual shall have the right granted by the legislator to obtain from the controller restriction of processing where one of the following matters applies: The accuracy of the personal data is disputed by the interested individual, for a period allowing the controller to verify the accuracy of personal data. Processing is illegal and the interested individual opposes the removal of personal data and instead requests the restriction of its use. The controller no longer needs the personal data for the purposes of processing, but they are required by the interested individual for the establishment, exercise or defense of legal claims. The interested individual has contested the processing, pending verification that the controller's legitimate reasons override those of the interested individual. If one of the above reasons applies, the interested individual may at any time contact us as instructed at the end of this Privacy Policy. We will promptly ensure that the removal request will be complied with immediately.

f Right to data portability Each interested individual shall have the right granted by the legislator to receive personal data relating to him or her, which is provided to a controller, in a structured, commonly used and machine-readable format. He or she will have the right to transmit this data to any other controller without impediment by the controller to whom the personal data was provided, provided that the processing is based on consent as provided for in the GDPR. Processing is done by automatic means, provided that the processing is not necessary for the fulfillment of a task that is in the public interest or in the exercise of official authority conferred on the controller. Furthermore, by exercising their data portability right, the interested individual will have the right to have their personal data transmitted directly from one controller to another, where it is technically possible and when doing so does not adversely affect the rights and freedoms of third parties. If one of the above reasons applies, the interested individual may at any time contact us as instructed at the end of this Privacy Policy. We will promptly ensure that the removal request will be complied with immediately.

g Right to object Each interested individual will have the right granted by the legislator to object, for reasons linked to his or her particular situation, at any time, the processing of personal data involving him or her, based on the LGPD. This also applies to characterization based on these provisions. If one of the above reasons applies, the interested individual may at any time contact us as instructed at the end of this Privacy Policy. We will promptly ensure that the removal request will be complied with immediately.

h Automated individual decision-making, including characterization Each interested individual shall have the right granted by the legislator not to be subject to a decision based solely on automated processing, including characterization, that produces legal effects involving him or her, or that significantly affects him or her similar, provided that the decision (1) is not necessary to enter into or comply with a contract between the interested individual and the data controller, or (2) is not authorized by the law to which the controller is subject and which also establishes measures reasonable to protect the rights and freedoms and legitimate interests of the individual concerned, or (3) is not based on the explicit consent of the individual concerned. If one of the above reasons applies, and an interested individual wishes to request removal of personal data stored by WT Software, he or she may at any time contact us as instructed at the end of this Privacy Policy. We will promptly ensure that the removal request will be complied with immediately.

i Right to withdraw consent to data protection Each interested individual will have the right granted by the legislator to withdraw their consent to process their personal data at any time. If one of the above reasons applies, the interested individual may at any time contact us as instructed at the end of this Privacy Policy. We will promptly ensure that the removal request will be complied with immediately.

Children's Privacy

The provision of our Service is generally not directed at children. This Site is not intended for use by children under the age of 18. We do not knowingly collect information from children and minors. We encourage parents and legal guardians to monitor their children's Internet usage and help enforce our Privacy Policy by instructing their children never to provide information on our Site without their permission. Our Site and Service are not directed to, nor do we knowingly, collect personal data from children under the age of 13. If we have factual knowledge that we have collected personal data from a child, we will comply with industry guidelines and applicable laws and will promptly delete it, unless we are legally required to retain such data. We do not collect information collected by you from a child's target device. All information is encrypted.

DATA PROCESSING ON YOUR BEHALF: WT SOFTWARE AS A DATA PROCESSOR

Target Device Data. Upon registering an Account with WT Software, the Service begins collecting data from a target device linked to the Account, which may include personal data relating to you, the user(s) of a target device or third parties Data User Information, including information about a target device, websites and apps that are used, contacts, connections, payments, messages and other communications, content posted and received, etc.). In accordance with applicable privacy law, to the extent it applies to the Service, you are the Data Controller of that Target Device, and you appoint us as the Data Processor of such data for the purpose of providing the WT Software Service. .

Your use of the Target Device Data. As the Data Controller, you warrant that you have the appropriate authority to collect and process the Target Device Data and you agree to process and use the Target Device Data in accordance with this Privacy Policy, the Terms of Use and applicable law, and only for the explicit purposes of the Service. You will not submit to the Service any personal data relating to an individual who has not consented to such processing. Through the Service, you may also access a copy of the Target Device Data collected by us on your behalf. You will protect the confidentiality of any accessible Target Device Data and prevent access by or disclosure to unauthorized third parties. You will inform us within 24 hours of any issues arising from the management of your Account and/or Target Device Data. You will be responsible for any unlawful use of another person's data (personal or otherwise) through the Service on a target device, including any use that is contrary to applicable data protection laws and/or that violates this Privacy Policy.

Data Processor Obligations. As the Data Processor on your behalf, we will (a) implement appropriate technical and organizational measures to protect any Target Device Data from unauthorized or unlawful access, loss, destruction, theft, use or disclosure; (b) we will limit access to the Target Device Data only to those employees who need to know it to enable the Processor to run the Service; (c) we will only process the Target Device Data as specified by this Policy and in accordance with your instructions, and (b) we will not use the Target Device Data for any purpose that is unrelated to the performance of the Service or as provided in your instructions. in writing. Upon expiration or termination of this Agreement upon deregistration or upon your request, we will terminate any and all use of Third Party Data and will destroy or return it to you, except as provided above with respect to backup and termination data. We will not disclose the Target Device Data to third parties without your prior written consent or pursuant to a court or administrative decision.

Warranties. You are solely responsible for the use of the Account and the processing of personal data linked to your Account, which includes, but is not limited to, collecting, storing and analyzing personal data from a target device. WT Software automatically uses the setup and instructions given by you and you are solely responsible for setting up your Account. You warrant, as solely responsible for the Target Device Data that we process on your behalf as Data Processor, that (a) you have informed any users who are 18 years of age or older that the devices used by them include WT Software's software and you have obtained consent from such users to such activity as provided in our Terms of Use and Cancellation, and (b) you comply with all applicable laws regarding monitoring and control software. You agree to fully comply with this Privacy Policy.

Indemnity. You agree to indemnify and hold us harmless from any claims, damages and losses that we may suffer in connection with or arising from the processing of the Target Device Data and other third party personal data submitted to our systems in the course of using and providing the Service.

PERIOD FOR WHICH PERSONAL DATA WILL BE STORED

The criterion used to determine the period of storage of personal data is the respective legal retention period. After this period has expired and when we no longer need the personal data, we will routinely and securely erase or destroy it, provided it is no longer needed for the Purpose.

ROUTINE REMOVAL AND BLOCKING OF PERSONAL DATA

The data controller will process and store the personal data of the interested individual for the period necessary to achieve the purpose of providing the Service, or as long as this is granted by the legislator in laws or regulations to which the controller is subject. WT Software does not store and process personal data of an interested individual for longer than is necessary to achieve the purpose of providing the Service. However, if a plan is not purchased after the free trial or after the expiration of a package, the data will only be stored for 30 days, if not deleted by the individual user within the platform. For the data to no longer be recorded on the online platform, it is necessary for the Software to be completely removed from the device(s), to request the Software deletion procedure, simply contact our team on the website or e-mail. mail: [email protected]

DATA REMOVAL

We generally retain all records and information downloaded from a target device in an identifiable form for a period of 1 month after expiration, so that the individual user can retrieve this data if they wish. Please be advised that all records and information downloaded from a target device using the WT Software Software stored in the WT Software database for more than 1 month will be automatically deleted for security reasons. Records can be downloaded before the package expires or redeemed on a new purchase (if not made within 30 days after the starter package expires) In case of expired free accounts, all information downloaded from a target device is also erased within a period of one (1) month. Also, through the Account, you can erase all saved historical data at any time. This data will no longer be accessible and will be completely removed from our systems at the next backup, except as noted below. If you wish to remove all records, your account and information downloaded from a target device in your Account, please uninstall the WT Software Software from your device(s), and send an email to [email protected] Your Account will be permanently removed within 2 days or less from our live systems, servers and backups. By deleting your Account, all your personal data, with the exception of billing information in accordance with a legal obligation, which requires processing by law of the Member State to which we are subject, and information collected from a target device will also be removed.

HOW DO I CANCEL MY SUBSCRIPTION OR CHANGE MY PERSONAL INFORMATION?

To opt out of receiving future email communications from us, simply click the unsubscribe button in the email, or contact us as instructed at the end of this Privacy Policy. We require up to ten (10) business days to ensure compliance with your request. To change the personal data you have provided to us, please contact us as instructed at the end of this Privacy Policy.

CHANGES OR UPDATES TO THIS PRIVACY POLICY

We may modify this Privacy Policy at any time and post any changes to this Privacy Policy on the Site, so please review it frequently. We have indicated the date of the current version of this Privacy Policy below so that you will know when it was last updated. Changes to this Privacy Policy may not affect your personal data that we previously collected from you or after such changes. If you object to these changes, please contact us as indicated below.

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