SpySkyTech Privacy Policy

SPYSKYTECH DO BRASIL LTDA., a private legal entity registered with CNPJ under nº 53.457.117/0001-65, headquartered at Rua Luiz Gonzaga Bicudo, 931, room 522, Itu/SP, CEP 13.309-036 (“SpySkyTech” or “We”), presents this Privacy Policy (“Privacy Policy”) to inform Users about how their Personal Data is processed. 

SpySkyTech respects and values the privacy of Personal Data Holders, striving to be transparent and provide clear information about its Personal Data Processing practices. We are committed to protecting the confidentiality of your information. Processing your personal information primarily aims to provide better and more personalized service, considering each User’s specific conditions. The more the User interacts with us, the more information we receive, and the more capable we are of offering personalized services.

By using our services and Platform, Users declare that they have read and expressly consent to all provisions of this Privacy Policy. Similarly, Users declare that they have read and agree with the SpySkyTech Platform Terms and Conditions of Use available at the link <[insert link]> (“Terms and Conditions”).

1. DEFINITIONS

The capitalized terms used in this Privacy Policy shall have the meanings defined below:

(i) Contracting Party: Legal entity that has contracted the services offered by SpySkyTech through the Platform
.
(ii) Controller: Natural or legal person who decides on the Processing of Personal Data;

(iii) Independent Controllers: Two or more natural or legal persons with decision-making power over the Processing of Personal Data, each Controller separately and independently defining the purposes and method of Processing, each being responsible for the Processing carried out within their scope of action;

(iv) Cookies: Navigation files that temporarily store what the User is visiting on a particular website or application;

(v) Artificial Intelligence or “AI”: Refers to computer systems or software programs that can analyze data, identify patterns, and make automated decisions based on those patterns, using advanced algorithms and techniques;

(vi) Sensitive Personal Data: Personal Data on racial or ethnic origin, religious belief, political opinion, membership in a union or organization of a religious, philosophical, or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a natural person;

(vii) Personal Data: Data that identifies or makes a natural person identifiable;

(viii) LGPD or General Data Protection Law or Federal Law nº 13.709/2018: Legislation that regulates the Processing of Personal Data in conjunction with any other laws and regulations regarding the treatment, protection, and privacy of personal data, including User Data, that are applicable and, if applicable, all guidelines, standards, rules, ordinances, regulations, and codes of practice and conduct issued by the National Data Protection Authority or other relevant supervisory or data protection authority;

(ix) National Data Protection Authority (ANPD): The ANPD is a special autarchy responsible for protecting personal data and regulating, implementing, and overseeing compliance with the LGPD in Brazil;

(x) Holder: Natural person to whom the Personal Data subject to Processing refers;

(xi) Processing: Any operation or set of operations performed on Personal Data or sets of Personal Data, whether by automated means or not, such as, but not limited to, collection, use, access, organization, consultation, production, alteration, reception, classification, utilization, reproduction, communication, transmission, distribution, processing, archiving, recording, structuring, storage, adaptation, retrieval, transfer, availability, combination, restriction, elimination, evaluation or control, modification, deletion or extraction; 

(xii) Third Party: Clients, partners, suppliers, or any entity external to SpySkyTech that has its Personal Data processed;

(xiii) Operator: Natural or legal person who processes Personal Data on behalf of the Controller; and

(xiv) Platform or SpySkyTech Platform: Online platform exclusively owned by SpySkyTech for offering software as a service for drones, transforming images into valuable data through the advanced use of artificial intelligence.

(xv) User or You: Legal person or natural person accessing the Platform on behalf of a legal person, who registers, accesses, and/or uses the Platform to benefit from the functionalities offered therein, adhering to this Privacy Policy, the Terms and Conditions, and, where applicable, the Commercial Proposal.

(xvi) Terms of Use: The Terms and Conditions of Use of the SpySkyTech Platform.

(xvii) Personal Data Breach: A security incident that results in the accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to Personal Data transmitted, stored, or otherwise processed by SpySkyTech or an authorized subcontractor;

(xviii) Consent: Free, informed, and unequivocal expression by which a natural person agrees to the Processing of their Personal Data for a determined purpose.

All general provisions present in the Terms and Conditions, including defined terms, limitations of liability, applicable law, and dispute resolution methods, are fully applicable to this Privacy Policy.

2. HOW IS PERSONAL DATA COLLECTED?

Personal Data is collected from various sources, such as:

a. Directly provided by the User: The Personal Data holder, through sharing via inclusion on the Platform. Among the received data are name, email, address, phone number, and position. You must ensure the truthfulness/update of the provided Personal Data.

b. Automatically collected when using the Platform: Some Personal Data may be automatically collected during the Platform’s use, including IP address, browser, operating system, Platform usage patterns, geolocation data, cookies, statistics, and aggregated data.

c. Sent by third parties: We may receive information about you from other sources, including our business partners and third-party providers. The Platform is not responsible for the information provided by these third parties, and the responsibility for processing and protecting these data lies solely with them, according to their respective privacy policies. We recommend that You review and
be aware of these platforms’ privacy policies before using the registration through them;

3. WHAT PERSONAL DATA IS PROCESSED BY SPYSKYTECH?

We are responsible for Processing Personal Data of various categories from your access, registration,
and use of our Platform, as shown in the table below:

Category of
Personal Data		 Data Holder How Personal Data
is Collected		 Personal Data Processed
Registration Data
You
Data provided by the Holder to
create an account on the Platform.
Name, email, address, phone number
and position.
Payment Data
You
Data provided by the Holder to make
payment for subscribing to a service
package on the Platform.
Bank data and credit card data.
Informative Data
You
Data provided by the Holder when
interacting with the Platform.
Images, posts, forums, questions, and
feedback (depending on the content,
the listed information may become
Personal Data).
Biometric Data
You /
Third-party
holders
Data collected through the services
provided by the Platform.
Capture of images of the User and/or
third-party individuals in areas with
cameras operated by the
SpySkyTech Platform.
Behavioral Data
You /
Third-party
holders
Data collected through the services
provided by the Platform.
Capture of images of the User and/or
third-party individuals in areas with
cameras operated by the SpySkyTech
Platform, analyzing behavior and
generating alerts indicating potential
pattern deviations.
Telemetry Data
You /
Third-party
holders
Data collected through the services
provided by the Platform.
Tracking location and movement of
vehicles (if associated with other
information, it may become
Personal Data).
Access Logs
You
Automatic collection of all Users
accessing the Platform.
IP address, date and time of access,
precise or approximate geolocation,
GPS data, access log, browser type,
device type, hardware model,
network data, operating system,
and browser used.
Data Collected via Cookies
and Similar Technologies
You
Automatically collected by Us from
the use of the Platform by the User.
We may use Cookies and electronic
device identifiers when the User
uses the Platform.

SpySkyTech offers software as a service for drones, transforming images into data through the advanced use of AI. Our service democratizes access to AI by allowing image and video analysis with precision that surpasses traditional methods for this purpose, which involves the possibility of capturing images of third parties.

Thus, if you are a Data Holder, it is important to highlight that the Personal Data collected by Us may be processed so that we can offer our services to the Contracting Parties. However, all Data is Processed in an aggregated or anonymized manner.

In such situations, it is important to clarify that SpySkyTech may act as a Personal Data Operator during the provision of its services, i.e., all Processing that we eventually carry out involving Personal Data happens according to the respective Contracting Parties’ instructions, which, in turn, process their Personal Data according to their respective privacy policies and their own legal bases. Therefore, we recommend the Personal Data Holder to read carefully the privacy policy of the respective SpySkyTech Contracting Party with whom you have a relationship or believe is using your Personal Data. Furthermore, if you have any questions about the Processing of your Personal Data carried out by the SpySkyTech Contracting Party, we recommend that you contact them directly, in their role as the Controller of the Personal Data

4. PURPOSE OF DATA COLLECTION AND PROCESSING

The Users’ Personal Data is processed for the following purposes:

Purpose Explanation
Identification and creation of access account to the Platform
We will use your Personal Data to identify, authenticate, and individualize you on the Platform to generate your access.
Provide, improve, and personalize the User experience on the Platform
We will process your Personal Data to offer a service more aligned with your expectations regarding the services contracted from SpySkyTech.
Provision of the services offered on the Platform
We will process your Personal Data to provide the services offered on the Platform.
Marketing activities and market research
Personal Data may be used by Us for marketing activities to promote our services, conduct engagement surveys, and other market activities.
Protection and security of the Platform
We may use Access Logs to detect potential fraud and security incidents on the Platform. We may also use browsing data from the browser to improve your experience, as well as access logs to detect errors on the Platform.
Problem resolution or request fulfillment
In case of a technical problem during your navigation on our Platform, we may use your data to identify, address, and correct the problem or fulfill other requests, including support through the available channels.
Sharing with AI systems to perform our service
We share Your Personal Data with AI systems as necessary for providing our services, including operational analysis reports. This means that sharing with such systems is necessary to deliver the services You expect.
Compliance with legal or regulatory obligations of SpySkyTech
We will process the User's Personal Data to comply with its legal and/or regulatory obligations as necessary. These obligations may include, for example, tax and accounting obligations, obligations regarding maintaining technical records, service documentation, reporting, among others.
Exercise of rights related to judicial, administrative, and extrajudicial processes
We may process your Personal Data to exercise our own rights and/or defend our rights and interests. This may include extrajudicial negotiations between the parties, judicial or arbitration processes, administrative procedures, among others.

Regarding other activities involving Personal Data Processing, applicable legal bases will be used, such as contract execution or preliminary steps, compliance with legal or regulatory obligations, exercise and defense of our rights and interests, or based on a legitimate interest of ours, always considering and respecting your fundamental rights and guarantees. Additionally, we may request your express consent when necessary through the Platform.

5. DATA SHARING

For the proper development of the contractual relationship and excellence in service provision, as well as for its legitimate interest, SpySkyTech may share certain Users’ Personal Data with:

 • Other Users, in case of information sharing by public users.
 • SpySkyTech’s third-party service providers and business partners;
 • Vendors of payment processing, credit anticipation, and/or digital account management
services and solutions for processing payments made through the Platform;
 • Private security companies and public authorities;
 • Upon legal requirement, SpySkyTech may share information with public agencies and/or third
parties regarding information requests related to criminal investigations and alleged illegal
activities or to comply with legal obligations;
 • Companies providing messaging services to Users, including WhatsApp and email; and
 • Cloud data storage companies.

Personal Data may also be shared with third parties for statistical purposes, provided that it is Anonymized Data.

It is highlighted that Users’ Personal Data will not be transmitted to third parties, except (a) when necessary for the requested services; (b) when the User requests or consents to the sharing; (c) when requested by a competent authority in the exercise of its functions (including to investigate, prevent, or take actions related to illegal acts); (d) if required by law; or (e) for purposes provided in the Terms
and Conditions and the Privacy Policy.

Sharing with Processing Operators. SpySkyTech may hire third parties to assist in providing its services, such as messaging platforms, onboarding tools, CNPJ and CNAE verification companies, SMS code authentication companies, infrastructure providers (servers, hosting, and cloud storage services, IT service providers), among others, always according to SpySkyTech’s instructions. 

Third-Party Services. During the use of the Platform, the User may use other services, channels, products, and platforms provided, maintained, and/or operated by third parties, used as channels or support means for services provided by SpySkyTech but without any relation to SpySkyTech (“ThirdParty Services”). These Third-Party Services may include, for example, onboarding tools, payment processing platforms, credit anticipation and/or digital account management, statistical analysis tools for Platform usage, communication and instant messaging applications, and cloud hosting servers. These providers may be replaced at any time, provided that adequate security and confidentiality standards for Data are maintained. When SpySkyTech’s services use such Third-Party Services, Personal Data Processing will be subject, in addition to this Privacy Policy, to the privacy policies and terms of use of such Third-Party Services, over which SpySkyTech has no control or influence.

We encourage the User to be informed about the policies applicable to such Third-Party Services, as SpySkyTech has no influence over the relationship between the User and such Third Parties and is not responsible for the use of the User’s Personal Data by such Third Parties inserted by the User in the Third-Party Services.

Other. In addition to the situations already mentioned in this Privacy Policy, Personal Data may also
be transferred to third parties, including as Controllers, in the following cases:

New Businesses. Personal Data may be transferred to and between SpySkyTech affiliates and/or in the context of acquisition, sale, merger, corporate reorganization, investment round, or any other change of control of SpySkyTech. In this case, SpySkyTech will ensure that the person, natural or legal, who comes to access or assume control over the Personal Data Processed under this Privacy Policy is also bound to it, ensuring the continuity of Personal Data protection, and notifying Users in advance if such transfer implies any change in the Privacy Policy.

Regular exercise of rights by administrative or judicial or extrajudicial means. SpySkyTech may share Personal Data with third parties such as law firms, consultancies, collection companies, accounting firms, and others, to exercise its own rights or ensure the enforcement and application of this Privacy Policy and the Terms and Conditions. It may also share Personal Data for purposes of administrative, judicial, extrajudicial, or arbitral defense of SpySkyTech’s interests and rights. This may include extrajudicial negotiations between the parties, judicial or arbitration processes, administrative procedures, among others.

6. WHAT ARE THE USERS' RIGHTS?

SpySkyTech provides tools for Users to exercise their legal rights over the Personal Data they hold. In this section, we will describe these rights and how Users can exercise them.

(i) Confirmation of the existence of Processing: Users have the right to obtain confirmation of whether or not their Personal Data is being Processed by the Controller;

(ii) Access to Personal Data: Users can request a copy of their Personal Data being Processed by the Controller;

(iii) Correction of incomplete, inaccurate, or outdated Data: Users can request alteration or correction of their incorrect Personal Data;

(iv) Anonymization, blocking, or deletion: Users can request the anonymization, blocking, or deletion of unnecessary, excessive, or improperly processed data in accordance with Data Protection Legislation and the purposes described in this Privacy Policy or the Terms and Conditions;

(v) Portability: Users can request the portability of their Data to another service provider through export tools available on the Platform or by request through the contact channels indicated in this Privacy Policy;

(vi) Deletion of Personal Data: Users can request the deletion of their Personal Data processed by SpySkyTech through the Platform or by request through the contact channels indicated in this Privacy Policy. Deleting Personal Data implies the discontinuation of the service provision by SpySkyTech;

(vii) Information about sharing: Users can request information about which public and private entities SpySkyTech has shared their Personal Data with, under this Privacy Policy;

(viii) Information about the possibility of not consenting: Users are informed through this Privacy Policy and can request information through contact channels about the possibility of not consenting to the Processing of Personal Data and potential consequences, including the inability to provide SpySkyTech’s services;

(ix) Revocation of Consent: Users can, at any time and at their discretion, revoke the previously provided consent for the Processing of Personal Data, with the treatments carried out based on it remaining valid until such revocation.

Exercise of rights. The rights mentioned above and others provided by applicable legislation can be exercised by the Data Subject directly through the Platform, according to the functionalities available on it (such as access and editing Personal Data tools), or through a request sent to the email legal@spyskytech.com. Requests should include, at a minimum, the Data Subject’s full name, the right to be exercised, details and specifications about the request, CPF, email address, and phone number. SpySkyTech reserves the right to request other information or documents to verify the identity and claims of the requester.

Consequences of data deletion. It is important to note that, in some cases, by complying with deletion requests, which, when possible, will be informed to Users, SpySkyTech may not be able to provide its services. Therefore, reque sting the deletion of Personal Data will result in the immediate deactivation of the User’s account on the Platform, with the permanent loss of any such Data entered on the Platform. After deleting such Personal Data, SpySkyTech may continue to use it in a non-individualized and anonymized form, i.e., without any personal identification, for the purposes set out in this Privacy Policy.

To the extent permitted by applicable law or compliance with a court order, SpySkyTech may retain certain Personal Data for a period of no less than 6 (six) months after your deletion request. Such Data will not be anonymized or destroyed by SpySkyTech before the end of this period. SpySkyTech will store your deletion request and, observing the legally required retention period of certain data, will proceed with the destruction or anonymization, at SpySkyTech’s sole discretion, of information capable of identifying the user.

If the User requests the deletion of their information but still has any pending obligations with SpySkyTech, their information will not be deleted and will remain stored to enable the resolution of the pending issue and the adoption of appropriate measures by SpySkyTech until final resolution.

7. DATA SECURITY

Security. SpySkyTech will do everything possible to keep Personal Data secure, including adopting technical and administrative security and protection measures compatible with the nature of the Personal Data collected, used, stored, or otherwise Processed by SpySkyTech, in accordance with appropriate market practices.

Exceptions. However, no method of electronic data transmission or retention is fully secure and may be subject to external attacks. Thus, SpySkyTech cannot guarantee that such security measures will be error-free or immune to third-party interference (hackers, among others). By its nature, despite SpySkyTech’s best efforts, any security measure may fail, and any Personal Data may become public.

By consenting to this Privacy Policy and/or using the Platform, the User expressly understands and assumes this risk and agrees that SpySkyTech will not be responsible for such types of data leaks or unauthorized access. 

If a Security Breach occurs on the Platform, the Data Subject and the National Data Protection Authority (ANPD) will be notified of the existence of such an incident, and SpySkyTech will inform:

(i) The nature of the affected Personal Data;
(ii) Information about the involved Data Subjects;
(iii) The technical and security measures used to protect the Personal Data, considering trade and
industrial secrets;
(iv) The risks related to the incident; and
(v) The measures that have been or will be taken to reverse or mitigate the effects of the damage.

The above-described security measures apply to the User’s Personal Data only from the moment SpySkyTech receives and maintains them under its custody. The functioning and security of the device used by the User to access the Platform, as well as third-party networks through which the data travels, are not SpySkyTech’s responsibility.

Storage location. Personal Data will be stored on cloud servers, owned or third-party, located in Brazil
or abroad, according to item 8 – “International Data Transfer,” below.

Storage period. Personal Data will be kept as long as they are necessary for the purposes listed in this Privacy Policy. This may mean, for example, that Access Records will be stored for at least 6 (six) months, as required by law, or for a longer period if requested by the Data Subject or determined by court order. Other Personal Data will be kept for the prescription period of potential civil liability to allow SpySkyTech to defend itself in court, for example. SpySkyTech adopts controls to ensure that Personal Data is kept only as long as it is necessary, being discarded whenever Processing is concluded or no legal retention hypothesis applies.

Data deletion. When we no longer need to use Personal Data, they will be removed from our systems and records or anonymized so that the User can no longer be identified from this data. SpySkyTech may retain some Personal Data to comply with legal or regulatory obligations, as well as to allow and ensure the regular exercise of our rights (for example, in judicial, administrative, or arbitral proceedings). For audit, security, fraud control, and rights preservation purposes, SpySkyTech may retain the historical record of Personal Data for a more extended period in cases required by law or regulatory standard or for rights preservation.

8. INTERNATIONAL DATA TRANSFER

To optimize the efficiency, performance, and security of the Platform, SpySkyTech uses a global-scale technical infrastructure and has service providers not only in Brazil but also abroad. Therefore, your Personal Data may be transferred to other countries for Data Processing and storage under the terms and purposes defined in this Privacy Policy, as well as to provide the services requested by the User. SpySkyTech may transfer your Personal Data to service providers who will Process Personal Data on behalf of SpySkyTech and following our instructions.

Privacy and Personal Data protection laws vary from country to country, and data protection standards in other countries may differ from those in Brazil. Nevertheless, SpySkyTech will apply all efforts to try to ensure the level of data protection outlined in the Privacy Policy, following applicable laws.

The international transfer of Personal Data is a condition for using the Platform and services. If You do not agree with the international transfer of Personal Data, do not install, access, register, or use the Platform, offer, market, seek or purchase products, nor contract SpySkyTech services. If You cease to agree with the international transfer of Personal Data at any time, contact us through the email legal@spyskytech.com to request the deletion of your information and uninstall all related applications, platforms, and services.

Consent for international transfer of Personal Data. SpySkyTech may process your Personal Data, including storage, in Brazil or abroad. In any case, SpySkyTech will take the necessary steps to ensure compliance with this Privacy Policy and Data Protection Legislation to guarantee your rights related to Personal Data protection when the Processing of Personal Data occurs outside Brazil. The User authorizes SpySkyTech, under this Privacy Policy, to transfer, process, store, and use their Personal Data, including Sensitive Personal Data, in other countries. 

9. COOKIES

SpySkyTech uses Cookies and similar technologies, such as pixels and tags, to ensure that the services provided meet our quality standards. Cookies collect only statistics and will not be used for purposes other than those expressly provided in this Privacy Policy. SpySkyTech may use Cookies:

Necessary: Cookies that enable the use of the Platform and without which the Platform may not function correctly. Since these Cookies are necessary, they are used based on the contract’s execution between SpySkyTech and the User.

Functional: Cookies that enable additional functions or provide access to specific sections of the Platform. The use of such Cookies is not absolutely necessary for the service, but if you choose to disable them, the User may have reduced functionalities. The use of these Cookies is based on your consent by enabling such functions.

Performance: Cookies used to measure and improve the performance of a specific web page and its contents.

Can the use of Cookies be limited? Most browsers allow the collection of Cookies to be disabled. If the User does not change their browser’s cookie collection policies, we will consider that the User does not oppose the use of Cookies by the Platform.

If you wish to obtain more information about Cookies and Personal Data protection, consult the Guideline published by ANPD

10. CONTACTING SPYSKYTECH

In case of questions, suggestions, complaints, or clarifications about this Privacy Policy or the Processing of Personal Data by SpySkyTech, or to request the exercise of any of the rights described in this Privacy Policy or Data Protection Legislation, the User may contact SpySkyTech via email at legal@spyskytech.com. SpySkyTech will be pleased to clarify any questions and/or fulfill your request.

11. UPDATES TO THE PRIVACY POLICY

Due to the continuous evolution of SpySkyTech’s activities, this Privacy Policy and the Terms and Conditions may be modified.

If the User does not agree with the changes to the Privacy Policy, they must refrain from using the Platform and may request the cancellation of their account, in compliance with the Terms and Conditions.

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This Privacy Policy is effective as of JUNE, 19th of 2024.