The main responsible for the treatment of the User’s data for the purposes of our services is the company Handover Tecnologia LTDA (“Handover”), headquartered in Brazil and operating in obedience to Brazilian laws.

The User may always contact Handover to deal with issues relating to the platform and services provided by Handover by sending an email to: diga@oihandover.com.

The use of the platform by the User shall occur whenever and only if the User is in agreement with the conditions set forth in this document and in other conditions eventually present in other documents previously accepted by the User.

1. Data collected

1.1 Data provided through direct interaction

When each User registers on the Handover platform, the minimum data necessary to enable not only the registration but also future access is requested.

Data such as full name, telephone number, address and e-mail are essential for a relationship between Handover and the User.

1.2 Data that is automatically collected when the Handover solutions are used

When the User interacts with the Platform or makes use of the solutions made available there, it is important that the User keeps in mind how Handover makes use of relevant data, such as those listed below:

1.2.1. Device Information: Handover collects specific information about the device employed by the User, such as the operating system version and unique identifiers. The name of the mobile network that the User’s device is accessing may also be collected.

1.2.2 User data present in other platforms, social networks and email accounts: for the proper operation of the solutions presented by Handover, its Platform may access and interact with data held by the User in other platforms, such as partner websites and applications and social networks. The access to such information via API and the approval for the tracking of such data are necessary exclusively for Handover to manage the sending of emails and messages related to the Platform. IN NO CASE SHALL ANY CONTENT FROM THIRD PARTY PLATFORMS ON WHICH THE USER HAS AN ACCOUNT BE STORED, CAPTUALLED OR PROCESSED FOR ANY PURPOSES WHATSOEVER, AND THE IRRESTRICT CONFIDENTIALITY AND PRIVACY OF SUCH CONTENT IS WARRANTED, in compliance with the privacy policies of such platforms.

1.2.3 Location Information: Handover may collect geographic location data related to the User.

1.2.4 User and registration data: Handover collects access registration data and User data to comply with the privacy laws and to comply with the rules established by the Marco Civil da Internet and the General Law of Data Protection. Technical details, including the Internet Protocol (IP) of the User’s device are stored. Handover will also store the User’s login information (date of registration, date of last password change, date of last successful login), the browser type and version, among other data deemed relevant for protection of the system and the User’s own account.

1.2.5 Cookies and Similar Technologies: Handover does not use cookies to manage User sessions and store User preferences.

2. Minors

Minors are not allowed to register as Users and therefore cannot interact with the tool. A minor under the age of 18 who has registered and provided his or her details may have those details deleted immediately, along with the account created by the minor.

3. Use of the User’s and Third Parties’ Personal Data

Handover collects User data and its interactions only to comply with legal or regulatory obligations and to keep the platform running, which only occurs through the Users’ data and by accessing data on publicly accessible networks.

User data directly passed to Handover is not, under any circumstances, anonymized, exploited and/or in any way commercialized for any purposes.

3.1 Providing access to the Platform

> If the User logs into the Platform using his/her email ID or any other information that individualizes him/her, then Handover will have this data to identify him/her as a user and allow him/her to access the Platform.

> The above login information is also used by Handover to provide Users with services in accordance with the Terms and Conditions of Authorized Use.

> Handover processes the above information for the proper execution of the Platform.

3.2 Enabling a Secure Platform

> Handover uses access data and identifiers for the protection of the User and for the protection of the platform itself (including troubleshooting, data analysis, testing, fraud prevention, system maintenance, support, communication and data storage).

4. Changes to this Privacy Policy

Handover may change this Privacy Policy from time to time. Handover will post the changes on this page and will provide notice of such changes by email or through the platform. If the User does not agree with these changes, the User may terminate his account by accessing the account settings and may delete his account and the information contained therein, provided that the maintenance of these is not required by law.

5. Your Rights

Under certain circumstances, and in accordance with data protection laws, the User has rights relating to his/her personal data.

The User has, among others, the rights set out below:

5.1. right to request access to their personal data (known as “data subject access request”), receiving a copy of the personal data that Handover has about the User and being able to then check whether Handover is processing such data within the limits established herein and within the criteria established by law.

5.2 Right to request corrections to any data that Handover has about the User. Such right enables the User to correct any incomplete or incorrect data that Handover has about him, although Handover has the right to verify the accuracy of the new data that the User provides.

5.3 Right to request the deletion of his personal data and/or surveys. Such right ensures the User that we delete or remove his/her personal data whenever requested. The User should bear in mind, however, that for certain purposes, we may be legally obliged to retain your data.

5.4 Right to request the portability of your personal data. In such cases Handover will provide the User or a third party of their choice with their personal data in a structured, commonly used, and electronically readable format. Note that this right only applies to automated information for which the User has initially given us their consent for use or in situations where Handover has used the information for the purposes of complying with what is set out in the Terms and Conditions of Use.

5.5 Free of charge: The User will not have to pay any fee to access his/her personal data (or exercise any of the other rights). However, HandOver may charge a reasonable fee if the User’s request is manifestly unfounded, repetitive or excessive.

5.5 Response Time: Handover attempts to respond to all legitimate requests within one month. Occasionally, we may take longer than one month if your request is particularly complex or if you have made multiple requests. In this case we will notify you and keep you informed.

In addition, the User is entitled to make a complaint at any time to the responsible data protection authority, if any. However, before you file a complaint with the data protection authority, we would like the opportunity to address your concerns in the first instance, so please use the contact by e-mail: diga@oihandover.com.

6. Communication and advertising

Handover will communicate primarily by email, chat or notifications displayed and associated with the platform.

The User will not receive marketing communications from third parties originated and/or managed by Handover.

7. Non-Sharing of Data

In general, Handover does not share Users’ data. They may, however, be directed to:

7.1. affiliated companies: Handover may share data with other companies that have a corporate relationship with Handover and that help provide better services, such as product enhancement, customer support and fraud detection mechanisms.

7.2 Third Party Service Providers: Handover contracts with third party service providers to assist with some aspects of the services, particularly technology infrastructure, such as cloud storage services offered by Amazon Web Services. The service providers may be located inside or outside Brazil, but such providers declare to be in compliance with the applicable rules in the country and abroad.

7.3 Law enforcement authorities, regulators and others: Handover may disclose your personal data to law enforcement authorities, regulators, governmental or public entities and other third parties that require us to comply with any legal or regulatory requirements.

7.4 Potential merger and acquisition transactions: Handover may sell, transfer or merge parts of its business or assets. Alternatively, we may seek to acquire other businesses or merge with them. In the event of any change relating to our business, the new owners may use your personal data as described in this Privacy Policy.

8. International Transfers

Handover guarantees a similar degree of protection of User data even in cases of international transfers of this data.

9. Data storage location and storage period

The data collected from the User will be stored and processed both within and outside Brazil on secure servers in order to provide the best possible user experience.

The User’s personal data will only be kept for as long as it is necessary to serve the purposes for which it was collected, including for the purposes of complying with any legal, statistical and reporting requirements.

In determining the appropriate retention period for personal data, we take into account the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized disclosure or use of your personal data, the reasons why we process your personal data and whether we can fulfill those reasons by other means, and applicable legal requirements.

10. Technical and organizational measures and security processing

All information that Handover receives about the User is stored on secure servers, and technical and organizational measures are implemented that are appropriate and necessary to protect your personal data. Handover continually assesses the security of its network and the adequacy of its internal security information program that is designed to (a) help protect User data from accidental or unlawful loss, access or disclosure, (b) identify reasonable foreseeable risks to the security of the network, and (c) minimize security risks, including through regular risk assessments and testing.

Despite the measures we have implemented to protect User data, the transfer of data over the internet or other open networks is never completely secure, and there is a risk that your personal data may be accessed by unauthorized third parties, especially when the machine employed by the User is contaminated with malicious programs capable of capturing such data.

11. Links and data capture from third party websites

Handover’s platform may contain links and even access websites or applications of third parties. When the User receives information arising from such accesses, it must take into account that each platform will have its own privacy policy. Handover does not control these websites/applications and is not responsible for these policies. Handover recommends that User read the privacy statement of all websites operated by Handover.

12. Contact

For any additional information, please contact us through the channels informed in this Policy and / or those disclosed on the platform.