Privacy policy

XMOBOTS AEROESPACIAL E DEFESA LTDA, a legal entity governed by private law registered with the CNPJ/MF under No. 08.996.487/0001-16, headquartered in the city of São Carlos/SP, at Rodovia Washington Luiz, KM 226, Letra 738, Jardim Maracanã, CEP 13.571-291 ("XMobots"), respects the privacy of its Users and guarantees the security of Personal Data that may be shared through its official communication channels.

Always striving for transparency and respecting the privacy of our employees, candidates, users, customers and suppliers, XMobots has developed this Privacy Policy ("Policy"), which seeks to list the situations in which the processing of personal data is carried out from our website, as well as the ways in which it does so.

Here you will also find out what your rights are in relation to this data and how to exercise them properly. We recommend that you read this Policy carefully, and revisit it periodically, since the processing of personal data carried out may undergo changes, which will always be reflected in this Policy.

This Privacy Policy does not apply to unofficial websites and/or websites controlled by third parties not affiliated with XMobots. XMobots assumes no responsibility for the content and Personal Data shared with third-party websites.

1. SCOPE

This Policy applies to all users of our website, whether they are clients, job applicants, business partners or internet users, and must be observed and complied with by all our employees and service providers in any operation involving the processing of personal data.

2. CONCEPTS:

All the terms and concepts mentioned in this Policy comply with the LGPD, but to make it easier for you to understand, we have highlighted the main concepts here:

Anonymization: Use of technical means by which a piece of data irreversibly loses the possibility of being associated, directly or indirectly, with an individual.

National Data Protection Authority (ANPD): Public administration body responsible for ensuring, implementing and overseeing compliance with the General Personal Data Protection Law (Law 13.709/2018) throughout the national territory.

Official Communication Channels: XMobots' official website ("Site") and social networks.

Consent: Free, informed and unequivocal expression by which the Data Subject agrees to the Processing of their Personal Data for a specific purpose.

Cookies: small files or information that may be stored on the device that has been used to access the XMobots Sites or online services. Cookies are used to improve navigation through the Site;

Controller: Natural or legal person, of public or private law, who is responsible for decisions regarding the Processing of Personal Data.

Personal Data: Any information relating to an identified or identifiable natural person, such as name, ID, CPF, gender, date and place of birth, telephone number, address, IP address (Internet Protocol) among others.

Sensitive Personal Data: Personal data concerning racial or ethnic origin, religious conviction, political opinion, membership of a trade union or religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data, when linked to a natural person.

Data Protection Officer ("DPO"): The individual designated as the formal/official data protection officer, as provided for in the data protection laws, the LGPD, for a given territory. The DPO can be a member or a third party
.

Operator: Natural or legal person, under public or private law, who carries out the Processing of Personal Data on behalf of the Controller.

Data Subject: Identified or identifiable natural person to whom a specific Personal Data relates.

Processing of Personal Data or Processing: Any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Users: any person who accesses or interacts with the XMobots Website and/or its official XMobots social networks.

By using this Site, Users accept and consent to this Privacy Policy.

3. COLLECTION, USE AND STORAGE OF PERSONAL DATA

The Personal Data provided by Users on the XMobots Sites, or by contacts made by official Xmobots e-mail or telephone, have a specific purpose, contribute to providing a satisfactory experience to Users, and also help to improve our Site, making it increasingly targeted to the needs and information that Users seek.

Use of the XMobots website does not necessarily require the provision of personal data. However, if the User wishes to contact XMobots with any type of request, their data may be requested in order to fulfill their demand.

The table below describes the information concerning the Personal Data we process:

When do we process your data?	What data is processed?	For what purpose?
Contact	First name, surname, e-mail address, telephone number and any other information you enter in the message.	In order to answer your message, we need to know your name, phone number and e-mail address. This communication is currently done through the Blip platform, which integrates corporate WhatsApp, following all the compliance rules of Meta (the tool's maintainer), to enable communication between the company and the user.
Work with us	Name, e-mail address, date of birth, telephone number, city, state, country and any other information you enter on the CV. The candidate can choose to indicate their LinkedIn.	Provide users with access to differentiated content and exclusive methodology.
Site navigation data	Access time on page; Start of access session; First visit; Consent to cookies; Traffic source; Access URL; Session ID; Session UTM; Access language (whether in Portuguese or English); Unique access ID; User access ID; Cache variable; Cache variable ID; WordPress Log (in the case of a registered WordPress user, for admin only); GID (Google Paid Campaigns Access Id); fbp (Meta Ads Campaigns Access Id); Notify Banner Dismiss (In the case of not accepting or refusing cookies); Access ip; Approximate location; Unique Access ID hash for use in CRM.	To enable the proper functioning of the site, to generate statistics, research and surveys regarding the use of products or services. This data will be stored for up to 90 (ninety) days, or until the data subject revokes it. To comply with legal regulations, present in the Marco Civil da Internet.
Marketing	Full name, telephone number and e-mail address	Enable us to send you relevant information and updates when you contact us and show an interest in receiving this material and/or information.
Parts Sales, Maintenance, Support and Training	Identifying information required for sales, maintenance, support and/or training.	We provide our contact details and you can contact us for information about our services or to receive technical support and training.

As described in the table above, XMOBOTS collects Personal Data entered or forwarded actively and voluntarily by Users when contacting XMOBOTS, in addition to site navigation data.

In addition to the information described above, you should also be aware that XMOBOTS does not process Personal Data defined as Sensitive Personal Data, nor does it process the personal data of children and adolescents on our website. Therefore, if you are not 18 (eighteen) years old, you should not interact on our platforms and social media profiles. If it is found that this processing has occurred in error, we will delete the data as soon as it is identified, using secure means of disposal.

Any CVs sent by the User for participation in XMOBOTS selection processes, sent by email, WhatsApp or LinkedIn, will be processed in accordance with this Policy, only for the intended purpose and for the time necessary to carry out the selection processes, considering the interest of the candidates and the alignment with the vacancy offered. Personal data may be shared with partner companies to enable hiring, limited to the purposes described in this Policy.

4. STORAGE TIME

Users' Personal Data will be stored and kept securely for the period strictly necessary for each of the purposes set out in this Privacy Policy.

The storage of Personal Data processed by XMobots is based on the legal guidelines authorizing this activity and will be automatically deleted by XMobots when they are no longer useful for the purposes for which they were collected or when Users request their deletion, unless the maintenance of the Personal Data is expressly authorized by law.

In addition, we may store the Personal Data processed for a longer period of time if this is necessary for compliance with a legal obligation or for the exercise of rights. In these cases, we may leave it stored for the limitation period or for the period determined by the applicable legislation.

The personal data of job applicants collected via e-mail is stored for 12 (twelve) months, during which time the User may be contacted to carry out stages of the selection process. Once this period has elapsed, the data will be completely deleted in a safe and appropriate manner.

Through our website there is also the possibility that you will be taken to other portals, websites and domains, such as Youtube, Facebook, Instagram, LinkedIn and WhatsApp. Responsibility for the processing of personal data on these other portals lies solely with their maintainers. You should always read the respective Privacy Policies when you are redirected, to understand how your data will be handled by such maintainers, before, for example, making registrations or requests.

5. SECURITY OF PERSONAL DATA

XMobots has adequate security measures in place to protect your personal data against any incident, whether accidental or intentional destruction, improper alteration, unauthorized disclosure, misuse or access.

Although XMobots makes every effort to safeguard the privacy and protection of Users' Personal Data, no security system is completely immune to third-party attacks, so XMobots cannot guarantee the absolute security of its databases or the complete impossibility of their interception. In the extreme event of episodes of this nature, XMobots will not be liable for damages that may arise from the leakage of Personal Data due to the violation or breach of security barriers by third parties such as hackers or crackers, provided that it demonstrates that it has done everything in its power to prevent such an incident, and guarantees its absolute commitment to interrupting the repercussions of the event.

XMobots, in order to protect Users' Personal Data, in addition to making technical efforts, has a privacy program applied to its activities that is frequently updated.

XMobots also guarantees restricted access to Personal Data exclusively to employees who need to access it to perform the corresponding services, who are obliged by contract to keep the information confidential and not to use it inappropriately.

In the case of processing of Personal Data by external agents acting in partnership with XMobots, these must ensure the full confidentiality of the data accessed, as well as assume that they will use the best practices for handling this information, under the terms of the contractual obligations established between XMobots and the external agent.

6. SHARING PERSONAL DATA

The Personal Data collected by XMobots may be shared with third parties, with the aim of operationalizing the purposes proposed in this Policy, in the following cases:

With public entities, authorities, or other institutions, in order to protect XMobots' needs in any possible conflicts, including lawsuits and administrative proceedings;
In cases where information needs to be transferred for the continuity of XMobots' services in possible operations and corporate reorganizations;
By court order or at the request of administrative authorities that have the legal power to requisition them.

In addition, your data may be shared with third-party companies that provide technical support for the site, in order to maintain the regular operation of activities.

There may also be sharing with financial institutions to enable payments and other financial issues when applicable, always doing so for legitimate purposes.

We would like to point out that this sharing will only take place when strictly necessary and that only the data necessary to fulfill the purpose of the processing will be provided.

Under no circumstances will we sell or exchange your personal data, and sharing will take place by secure means, always preserving your privacy and in compliance with the provisions of the LGPD.

7. INTERNATIONAL TRANSFER OF PERSONAL DATA

International data transfers may occasionally occur when personal data is stored on cloud computing servers located outside Brazil. To this end, XMobots observes the rights of the Data Subject, adopts the applicable safeguards and the data protection regime provided for by the applicable Data Protection legislation, as well as applying the best security and privacy practices to guarantee the integrity and confidentiality of your Personal Data.

8. USERS' RIGHTS AS DATA SUBJECTS

XMobots guarantees Users the following rights in relation to their Personal Data, in accordance with article 18 of the LGPD:

Confirmation of the existence of processing and access to Personal Data:You can request that XMOBOTS confirm that it processes your Personal Data and inform you what data it holds about you, including data categories and storage period.
Information on data sharing:You may request information about entities with which XMOBOTS has shared or shares your Personal Data.
Correction of incomplete, inaccurate or outdated data:If you identify that your Personal Data is incomplete, inaccurate or out of date, you can request that XMOBOTS correct or complete this data.
Information on not providing consent:If XMOBOTS requests your consent for a specific processing of Personal Data, you can ask for clarification on the possibility of carrying out such activity without your consent, as well as the consequences of not providing it.
Anonymization, blocking or deletion of unnecessary, excessive or unlawfully processed data:If you believe that any Personal Data is processed unnecessarily, excessively or in breach of applicable law, you may request that XMOBOTS anonymize, block or delete such data.
Revocation of consent:At any time, you may request the revocation of the consent provided for the processing of your Data, when this is the applicable legal basis. Upon review, XMOBOTS may contact other organizations involved in the processing of your data to stop processing, as per your request. Revocation of consent may result in the termination of the services provided, but does not affect the use of anonymized data or data processed on another legal basis.
Deletion of Personal Data:If you have given consent to the processing of your personal data for specific purposes, you may request the deletion of this data. However, please note that data retained due to legal or regulatory obligations may be kept regardless of the data subject's consent.
Objection to Irregular Processing:You have the right to object to irregular processing of your Personal Data by XMOBOTS. We will take appropriate measures without undue delay to deal with the objection to the processing, in whole or in part.
Review of automated decisions:You have the right to challenge decisions made solely on the basis of Personal Data processed in an automated manner, which affect your interests. This includes decisions that define your personal, professional, consumer or credit profile or aspects of your personality. You also have the right to know the criteria and procedures used for such decisions, while respecting commercial and industrial secrets.

To exercise any of these rights, please contact our Data Controller at dpo@xmobots.com.br. In order to analyze your requests, we will ask you to prove your identity by sending photos of you holding an identification document, front and back, as a security and fraud prevention measure.

We will respond to your request within 15 (fifteen) working days.

Please note that your rights are not absolute and may not apply to all situations. In the event of a refusal, we will provide justification for the impossibility of fulfilling the request.

9. COOKIES

Cookies are small text files transferred via a server to the hard disk and stored on the User's computer that can collect information such as the date and time of access, browsing history, preferences and the User's name.

We use Cookies for authentication purposes, security and product integrity, advertising, recommendations, measurements, insights, performance, analysis and research, which allow us to understand site usage behavior in order to improve our services and offer the best possible experience.

Users have the option of accepting or refusing the use of cookies on their computer, regardless of registration on the Site, by configuring their browser as they wish. Refusing the use of cookies may, however, result in the User having limited access to certain tools available on the Site, such as login difficulties and the comments tool.

Occasionally, third-party service providers may use cookies on the site, which XMobots does not control or access. Such cookies are not governed by these Terms and Conditions.

As XMobots may enter into partnerships with third parties, they may collect information from users such as IP address, browser specification and operating system. These terms and conditions do not apply to personal information provided to third parties and stored and used by them.

10. DOUBTS, CLARIFICATIONS AND SUGGESTIONS

If you have any questions or suggestions about the XMOBOTS Privacy Policy, please contact the Data Protection Officer at dpo@xmobots.com.br.

11. APPLICABLE LEGISLATION

This Privacy Policy has been drawn up in compliance with the following federal laws: Law No. 13,709/2018 - General Personal Data Protection Law, Law No. 12,965/2014 - Marco Civil da Internet and Law No. 8,078/1990 - Consumer Protection Code, without prejudice to compliance with other laws applicable to XMOBOTS.

12. CHANGES

XMobots may make rectifications and changes to this Privacy Policy whenever necessary. Therefore, we suggest that you periodically access this Policy to be aware of the processing that takes place with your Personal Data.

VERSION HISTORY

Date	Version
01/07/2024	Issue v.01