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This Privacy Policy is part of the data governance actions adopted by ASSET DESENVOLVIMENTO DE SOLUÇÕES DIGITAIS LTDA., a limited liability company registered under CNPJ No. 30.766.176/0001-10, headquartered at Avenida das Águias, No. 231, Ed. Inaitec, Room 205, Bairro Pedra Branca, Palhoça/SC, ZIP Code 88.137-280 (“Assetway” or “We”).
Last Updated: 2025/12/02
We are committed to safeguarding your privacy and protecting your data. The purpose of this document is to explain how your data is collected and processed when you use the Assetway Platform and our website, in compliance with the Brazilian General Data Protection Law (Law 13.709/18 – “LGPD”), the Brazilian Civil Rights Framework for the Internet (Law 12.965/14), and, when applicable, the European Union General Data Protection Regulation (GDPR).
If You do not fully agree with this Policy, You must not use Assetway’s services (including those that are free or do not require registration).
The amount and type of information we collect vary depending on the services we provide and the way You interact with our environments (website, platform, social networks, etc.).
This Policy applies to the Personal Data we collect from or about You from the following sources:
Assetway Websites and Webapp:
Webapp and landing pages we maintain on third-party social networks (e.g., Facebook, LinkedIn, Instagram, and YouTube).
Public Sources:
Data made publicly available by the data subjects themselves or in open databases, always respecting the LGPD and other applicable laws.
Contacts with Clients and Users:
Direct requests, registration forms, support chats, events, customer service channels — in which Assetway may act as a data controller or merely as a data processor, depending on the context.
We rely only on legally authorized bases for data collection, such as — but not limited to — consent and legitimate interest. When the legal basis is not consent, we will always observe current legislation and respect data subjects’ individual rights and freedoms.
Even if You simply browse our site without registering, We may collect:
To access the Assetway Platform and become a user/client, we collect Personal Data such as:
Other data may be expressly provided by users to enable the personalization of marketing materials with customer data, such as: Department, business unit information (name, address, website, phone, social media), logo, and user photo.
When accessing our site, small files called cookies are stored in your browser to improve your experience, enable technical features, generate browsing statistics, and allow content and ad personalization.
We use the following types of cookies:
Necessary Cookies: Essential for the proper operation of the site and its basic features, such as navigation and access to secure areas.
Performance Cookies: Collect information on how visitors use the site, such as the most visited pages or error messages. These are used to improve site performance.
Functionality Cookies: Allow the site to remember your previous choices (such as language or region) and provide personalized features.
Marketing Cookies: Used to track visitors across different sites and display relevant ads based on their interests.
Upon first access, users may choose — via a preference panel — which categories of cookies they wish to authorize. The use of non-essential cookies (e.g., performance, functionality, and marketing cookies) occurs only with free, informed, and unequivocal consent, pursuant to Article 7, item I, of the LGPD (Law No. 13.709/2018).
Users may review or revoke their consent at any time by adjusting their browser settings.
We process Personal Data based on legal grounds authorized by the LGPD, such as:
Assetway commits to collecting and processing only the personal data strictly necessary to fulfill the purposes described in this Policy, in accordance with the data minimization principle under Article 5(c) of the GDPR.
Personal data will not be processed in ways incompatible with the specific, explicit, and legitimate purposes informed at the time of collection, pursuant to the purpose limitation principle under Article 5(b) of the GDPR.
Assetway periodically reviews its data processing activities to ensure that only necessary information is retained and used for its original purposes, eliminating or anonymizing data no longer justified.
The Personal Data we collect may be used to:
a) Administer our website, services, and the Assetway Platform;
b) Personalize our site and Platform for You;
c) Enable the use of services available on our site;
d) Provide services contracted through our site;
e) Provide services to our clients when acting as a data processor;
f) Send commercial and marketing communications;
g) Send email notifications specifically requested by You;
h) Send our newsletter if You have requested it (You may unsubscribe at any time);
i) Send You support or service messages, including alerts, notifications, and updates;
j) Send marketing communications related to our business or carefully selected third-party businesses We believe may interest You (You may opt out at any time);
k) Provide third parties with statistical information about our Users and Clients (without identifying any individual user);
l) Handle inquiries and complaints made by or about You regarding our site or Platform;
m) Keep our website secure and prevent fraud;
n) Verify compliance with the terms and conditions governing Platform use (including monitoring private messages exchanged through our site’s private messaging service);
o) Communicate with You about products, services, promotions, news, updates, events, and other subjects You may find relevant; and
p) Conduct targeted advertising based on your preferences, interests, and other collected information.
Your collected email data may be shared with our Marketing team to send content and updates about our services. You may request changes to your preferences at any time through our Privacy Channel at marketing@assetway.com.br.
Assetway may share Personal Information with:
We retain your personal data for the period necessary to fulfill the purposes for which it was collected, including legal, contractual, regulatory compliance, or for regular exercise of rights in judicial, administrative, or arbitration proceedings.
To determine appropriate retention periods, we consider:
If the contractual relationship ends, Assetway will retain the data and files stored on the Platform for up to 30 days to allow extraction and portability upon the Client’s request. After this period, the data will be deleted from active environments and permanently removed, respecting legal retention deadlines and legitimate purposes of documentary preservation for legal or regulatory matters, pursuant to Article 15 of the LGPD.
We employ security measures recognized in our industry, including:
However, we cannot guarantee absolute security. Unauthorized account access, hardware or software failures, and other factors may compromise Personal Data security at any time. Help us maintain a safe environment.
In addition to following good security practices regarding your account and Data (e.g., not sharing your password), if You identify or become aware of anything that compromises your Data security, please contact us at dpo@assetway.com.br.
If You have an account in our Services, it is password-protected. You must prevent unauthorized third-party access to your account and Personal Data by selecting and protecting your password or other login mechanisms appropriately and limiting access to your device and browser, logging out after accessing your account.
In the event of a security incident that may pose significant risk or harm to data subjects, Assetway will notify affected individuals and the National Data Protection Authority (ANPD) within 72 hours, as required under Article 48 of the LGPD.
The communication will include, whenever possible, a description of the nature of the affected data, security measures adopted, risks involved, mitigation steps, and actions taken to reverse or minimize the incident’s effects.
Any person — even without registration or an account — may exercise the rights provided in this Policy, including knowing whether their data is being processed, requesting access, correction, deletion, or revocation of consent, pursuant to Articles 9 and 18 of the LGPD and the GDPR.
You may choose not to share your data with us, but note that some data may be necessary to register or use certain features and services. Regardless, You always retain rights regarding privacy and protection of your Personal Data, and We are committed to ensuring that You have access to such rights.
You may instruct us to provide any personal information we hold about You, subject to appropriate identity verification — usually an authenticated copy of an official ID document. We may retain requested personal information to the extent permitted by law.
Below is a summary of your rights according to the LGPD:
a) Right of access
b) Right to rectification
c) Right to erasure
d) Right to confirmation of processing
e) Right to request blocking or deletion
f) Right to information on public or private entities with which data is shared
g) Right to restrict processing
h) Right to automated decision review
i) Right to object to processing
j) Right to clear and adequate information on automated processing criteria
k) Right to be informed about the possibility of withholding consent and the consequences
l) Right to withdraw consent
In this regard, below is a brief explanation and examples of some of these rights:
a) Request for access to your personal data. This right allows You to request and receive a copy of the personal data We hold about You.
b) Request for rectification of your personal data at Assetway. This right allows You to request the correction and/or rectification of your Personal Data at any time if You identify that some of it is incorrect. However, to effect this correction, we will have to check the validity of the data You provide to us.
c) Request for deletion of your personal data. This right allows You to request the deletion of your personal data from our platform. All collected data will be deleted from our servers when You so request or when it is no longer necessary or relevant to offer our services to You, unless there is any other reason for its maintenance, such as a potential legal obligation to retain data or the need to preserve it to safeguard Assetway's rights.
d) Right to object to data processing. When we are relying on a legitimate interest (or that of a third party) and there is something about your specific situation that makes You want to object to processing on this ground, as You feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes, for example. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights, as in such cases they may be essential for the provision of the product and/or service.
e) Right to request blocking or deletion. This right allows You to ask us to suspend the processing of your personal data or even require that it be permanently deleted from our servers. In this hypothesis, we need to verify if we have legitimate grounds to use or keep it archived.
f) Right to restrict the processing of your personal data. This right allows You to ask us to process data only for the purposes defined by You. In this case, we may analyze the applicability of a legal basis for the processing to go beyond what is defined by You in your restriction to processing.
g) Right to withdraw consent at any time. You have the right to withdraw your consent. This fact, however, will not affect the lawfulness of any processing carried out up to that date. Likewise, this request will not prevent processing in cases where another legal basis applies to its performance.
h) Right to review automated decisions. You also have the right to request a review of decisions made solely based on automated processing of your Personal Data that affect your interests.
We may request specific information from You to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact You to ask you for further information in relation to your request to speed up our response.
To exercise any of these rights, You may contact us using the channels listed in Section 11. We may need additional information to confirm your identity and ensure personal data is not disclosed to unauthorized parties.
The data subject may, at any time, review or revoke consent through the Privacy Channel indicated in this Policy or via the cookie preferences panel available on our website.
Assetway may store and process personal data on servers located outside Brazil through cloud service providers or technology partners that adopt adequate security and privacy standards.
International transfers will comply with Articles 33 to 36 of the LGPD, ensuring an adequate level of data protection or using contractual clauses, global corporate standards, seals, or certificates approved by the ANPD.
If no international transfer occurs, data will be processed solely within Brazil.
For personal data of data subjects located in the European Union, transfers to providers in the United States will comply with Articles 44 to 49 of the GDPR.
Assetway uses cloud service providers certified under the EU–US Data Privacy Framework, recognized by the European Commission as an adequate transfer mechanism.
We continually improve our services. Therefore, this Privacy Policy may be updated due to new features or legal changes.
We will always disclose updates clearly, via email notification. The update date appears at the beginning of this document.
DPO (Data Protection Officer): dpo@assetway.com.br
By continuing to use our services, You acknowledge and agree with the provisions of this Privacy Policy.
This version replaces and prevails over any previous versions.
