Privacy Policy

Last updated: 09.12.2021

NXT DESENVOLVIMENTO DE SOFTWARE LTDA. (“us”, “we”, or “our”) operates https://denise.ai/ and provides services and applications to its users (the “Services”). This Privacy Policy informs you of our policies and practices regarding the collection, use, storage and disclosure of Personal Information we receive from users of the Services (“you” or “user”).

By using the Services, you agree to the collection and use of your Personal Information in accordance with this Privacy Policy.

1. Important Information

Our Website is not intended for children, and we do not knowingly collect data relating to children.

This Privacy Policy supplements the other policies (including our terms of use “Terms”) and is not intended to override them.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us by e-mail.

2. Information Collection and Use

We may collect, use, store and transfer the types of personal data about you listed in Part 1 of Schedule 1.

We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as your personal data.

We do not collect any special categories of personal data or any information about criminal convictions and offences.

If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into the contract with you and, we may have to cancel a product or service. We will notify you of this at the appropriate time.

Generally, you control the amount and type of information you provide to us when using our Services; they are divided into three categories: (i) information you choose to share with us; (ii) information we get when you use our services; and (iii) information we collect from third parties.
- I) Information you choose to share with us
  - You provide most of this information directly, such as when you create an account, submit enquiries or voice or text commands, contact us or interact with our Services.
- II) Information we get when you use our services
  - While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you to improve the Services in a customized level for you. Personally identifiable information may include, but is not limited to, your name, address, payment details and other information you choose to disclose while using the Services (“Personal Information”, “personal data” or “Data”).
  - We get Data by recording how you interact with our Services by, for example, using technologies like cookies, and receiving error reports or usage data from software running on your device. The Data we collect can include: name and contact data, your credentials, demographic data, payment data, device and usage data.
  - You have choices about the Data we collect. When you are asked to provide Data, you may decline. But if you choose not to provide Data that is necessary to provide the Services, you may not be able to use it or feature of it.
  - We collect data about the features you use, the items you purchase, and the web pages you visit. This data includes your voice and text search queries or commands to our chatbots.
  - We collect data about your device and the network you use to connect to our Services. It includes data about the operating systems and other software installed on your device, including product keys. It also includes IP address, device identifiers (such as the IMEI number for phones), regional and language settings.
  - We collect data about the performance of the Services and any problems you experience with them. This data helps us to diagnose problems in the Services you use, and to improve our Services and provide solutions.
  - We collect data about you and your hardware, software, and other details related to the support incident. Such data includes contact or authentication data, the content of your chats and other communications with our support, data about the condition of the machine and the application when the fault occurred and during diagnostics, and system and registry data about software installations and hardware configurations.
  - We collect content of your files and communications when necessary to provide you with the Services you use such as audio recording and transcript of a voice message or a text message you dictate.
  - We also collect the content of messages you send to us, such as feedback and Service reviews you write, or questions and information you provide for customer support. When you contact us, such as for customer support, chat sessions with our representatives may be monitored and recorded.
- III) Information we collect from third parties
  - We also obtain Data from third parties. We protect data obtained from third parties according to the practices described in this statement, plus any additional restrictions imposed by the source of the data. These third-party sources vary over time, but have included: (i) social networks when you grant permission to access your Data on one or more networks; (ii) service providers that help us determine a location based on your IP address in order to customize Services to your location; (iii) partners with which we engage in joint marketing activities; and (iv) publicly-available sources such as open government databases or other data in the public domain.

3. When do we collect information?

When ordering a Service or registering on our site, as appropriate, you may be asked to enter your name, e-mail address, mailing address, phone number, credit card information and other information submitted by you in order to allow us to provide you with the best experience while using our Services.

We collect Data from you and the device you are using when you register on our site, open a Support Ticket, download an application or enter information while interacting with our Services.

Provide us with feedback on our products or services during use.

4. How do we use the Data we collect?

The Data we collect has the main objective to improve and personalize your experiences on the Services we provide. We also may use the Data to communicate with you, for example, informing you about your account, security updates and Services’ information.

We may use the Data we collect from you to personalize your experience and: (i) to allow us to deliver the type of content and product offerings in which you are most interested; (ii) to administer a contest, promotion, survey or other site feature; (iii) to quickly process your transactions; (iv) to ask for ratings and reviews of Services; (v) to contact you, (vi) to perform the contract, we are to enter into or have entered into with you.

We may analyse your personal data to form a view on what products and or services we think may be of interest to you. You will only receive marketing communications from us, if you have requested information from us or purchased services from us, if you consent to marketing at the time we collect your personal data and you have not subsequently opted out or withdrawn your consent or if we have another basis to send you the marketing communications.

You can opt out of e-mail marketing by clicking the unsubscribe button within the marketing e-mail. You can also withdraw your consent to marketing at any time by contacting us.

Even if you opt-out of receiving marketing, we may still use your personal data for other purposes provided we have a lawful basis for doing so.

We will only use your personal data for the purpose that we originally collected it for, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to use your personal data in this manner.

We may process your personal data (without your knowledge or consent) where this is required or permitted by law.

We do not sell, rent, or otherwise provide your Data to third parties for marketing purposes. We may provide your Data to affiliates that provide services to us with regards to our Services; such affiliates will only receive information necessary to provide the respective services.

Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.

5. How do we protect your information?

Your personal information is contained behind secured networks and is only accessible by a limited number of people who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures to maintain the safety of your Personal Information when purchasing Services. All transactions are processed through a gateway provider (payment processors) and are not stored or processed on our servers.

6. Use of Cookies

We use “cookies” on this site. Cookies are small files that a site or its service provider transfers to the device you are using through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

If you turn cookies off, some of the features that make your experience with the Services more efficient may not function properly.

7. Third-party disclosure

There are three categories of third Parties that may have access to your Data: (i) third parties in which assist us on providing the Services; (ii) third parties which are our affiliated companies; and (iii) third parties authorized by law or a legal process to obtain your Data.

We do not sell, trade, or otherwise transfer to outside parties your Data unless we provide users with advance notice. This does not include Website hosting partners and other parties who assist us in operating our Services, Website, conducting our business, or serving our users. We share your Data with your consent or as necessary to complete any transaction or provide any Service you have requested or authorized. We also share data with our affiliates and subsidiaries; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of our Services; and to protect the rights or property.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.

We may have to share your personal data with third parties further details of which are set out in Part 4 of Schedule 1. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. They can only process your personal data for specified purposes and in accordance with our instructions.

8. Third-party links

Occasionally, at our discretion, we may include or offer third-party products or services on our Website. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

9. Your Legal Rights

You have certain rights in certain circumstances under data protection law. These are set out in full in Part 3 of Schedule 1. If you wish to exercise any of your rights, please contact us.

You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.

We may request specific information from you to help us confirm your identity when you contact us. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

10. Control Over Your Information

We strive to let you access and update the personal information that we have about you. You can change your personal information by logging in to your account, by chatting with us or by sending us a support ticket. Because your privacy is important to us, we may ask you to verify your identity or provide additional information before we let you access or update your personal information.

You are free to delete your account whenever you prefer. Please note that when you delete your account, all Data will also be deleted, and we won’t be able to retrieve it. All Data collected to offer you customized Services will be lost.

11. Do Not Track Disclosures

Because there is not yet a common understanding of how to interpret the Do Not Track signal, our Services do not currently respond to browser DNT signals. However, if you wish to navigate without being tracked, we recommend you to navigate on our Website with your browser’s “private mode” activated.

12. Protecting Your Child’s Privacy

Our Service is not designed for use by anyone under the age of 18 (“Child”), though we realize we may have a Child attempt to make purchases through our Website. We do not verify the age of our users, nor do we have any liability for verifying a user’s age. If you are a Child, please seek the permission of a parent or guardian before using our Website. If you are a parent or guardian and believe your Child is using our Website, please contact us to remove your Child’s account; we reserve the right to ask you for verification of your relationship to the Child before we honor such a request. If we discover that a Child has created an account on our Website, we will immediately delete the account as soon as we find it out, we will not use the information for any purpose, and we will not disclose the information to third parties. However, as parent of such a Child, you understand that you are legally liable for any transactions created by the Child.

13. Fair Information Practices

Despite our best efforts to keep your Data protected, should a data breach occur we will notify you via e-mail or via in-site notification within 15 business days.

14. Revisions to the Privacy Policy

We may change this Privacy Policy from time to time. But when we do, we’ll let you know one way or another. Sometimes, we’ll let you know by revising the date at the top of the Privacy Policy that’s available on our Website and mobile application. Other times, we may provide you with additional notice (such as adding a statement to our websites’ homepages or send you an e-mail notification).

15. Contacting Us

If there are any questions regarding this Privacy Policy, you may contact us using the information below. https://denise.ai | suport@nextos.ai

Schedule 1: Personal Data

Part 1: Types of personal data

contact data	billing address, delivery address, e-mail address and telephone number
financial data	bank account and payment card details
identity data	first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender
marketing and communication data	your preferences in receiving marketing from us and our third parties and your communication preferences
profile data	your username and password, purchase or orders made by you, preferences, feedback and survey responses
technical data	internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Website
transaction data	details about payments to and from you and other details of products and services you have purchased from us

Part 2: Lawful basis for processing and processing activities

The lawful basis upon which we may rely on to process your personal data are:

Consent	you have given your express consent for us to process your personal data for a specific purpose
Contract	the processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you
legal obligation	the processing is necessary for us to comply with legal or regulatory obligation.
legitimate interests	the processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best Service to you via our Website. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest

Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.

Purpose/Activity	Type of data	Lawful basis for processing
to register you as a new customer	identity & contact	to perform our contract with you
to process and deliver your order, manage payments, fees and charges and debt recovery	identity, contact, financial, transaction and marketing & communications	(i) to perform our contract with you; (ii) as necessary for our legitimate interest in recovering debts due to us.
to manage our relationship with you, notifying you about changes to our Terms or Privacy Policy and ask you to leave a review or take a survey	identity, contact, profile & marketing & communications	(i) to perform our contract with you (ii) as necessary to comply with a legal obligation (iii) as necessary for our legitimate interests in keeping our records updated and analysing how customers use our products/services.
to administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	identity, contact & technical	(i) as necessary for our legitimate interests in running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise (ii) as necessary to comply with any legal obligations
to deliver relevant website content/advertisements to you and measure or understand the effectiveness of our advertising	identity, contact, profile, usage, marketing & communications & technical	as necessary for our legitimate interests in studying how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
to use data analytics to improve our Website, products/services, marketing, customer relationships and experiences	technical & usage	as necessary for our legitimate interests to define types of customers for our products and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy
to make suggestions and recommendations to you about goods or services that may be of interest to you, including promotional offers	identity, contact, technical, usage & profile	as necessary for our legitimate interests to develop our products/services and grow our business

Part 3: Your legal rights

You have the following legal rights in relation to your personal data:

access your data	you can ask for access to and a copy of your personal data and can check we are lawfully processing it
correction	you can ask us to correct any incomplete or inaccurate personal data we hold about you
erasure	you can ask us to delete or remove your personal data where: (a) there is no good reason for us continuing to process it; (b) you have successfully exercised your right to object (see below); (c) we may have processed your information unlawfully; or (d) we are required to erase your personal data to comply with local law. (e) We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request
object	you can object to the processing of your personal data where: (a) we are relying on our legitimate interest (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms; (b) we are processing your personal data for direct marketing purposes. (c) in some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms, and, in such circumstances, we can continue to process your personal data for such purposes
restrict processing	you can ask us to us to suspend or restrict the processing of your personal data, if: (a) you want us to establish the accuracy of your personal data; (b) our use of your personal data is unlawful, but you do not want us to erase it; (c) you need us to hold your personal data (where we no longer require it) as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it
withdraw your consent	you can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent

Part 4: Third Parties

service providers	acting as processors or controllers based around the world who provide IT services and system administration services.
professional advisors	Consultants, lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
third parties	third parties whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy