Always acting with ethics and honesty, we base our work on meeting the demands of all entities participating in this process, without any restrictions, preserving their unique and exclusive right, even before any existing regulation.
We understand that compliance with data protection regulations (LGPD/GDPR) and other existing standards is a shared responsibility and therefore, we are committed to this compliance in all our iSend services and products.
We at Intelly are constantly working and updating to achieve all existing privacy objectives. We believe that privacy is a fundamental right and we understand that existing and future regulations serve to provide the legal and sustainability basis for this vision of protecting individual privacy.
With this vision and the desire to have a relationship with as much transparency as possible, we present here the Privacy Policy of our company Intelly and the iSend family of products.
To make our services available, through our websites, systems, applications, devices, data and information are collected, in order to provide the best experience with our technology for you and your audience.
We recognize that privacy is a fundamental right of the individual and a duty of the whole society to protect him/her and for this we take all possible measures, create and maintain processes, continue to improve and focus on the search for this protection.
In this way, this privacy policy aims to inform you how your information and personal data are collected, stored, used and shared through our services.
The other policies and terms are part of this document:
This policy applies when you use our Services that involve data collection (online and offline), including personal data that may be collected through various means and channels, including websites, forms, applications, third-party social networks, customer service, sales teams, sales channels, events, and business partners.
Acceptance of this privacy policy will be made when you register on our platforms to enjoy any of our services and/or products available. This acceptance takes place at the moment you agree to the use of your data for each of the purposes described.
This means that you will be aware of and in full agreement with how we will use your information and the data collected. In the event that you choose not to provide us with your personal data necessary to use our services and/or products, or do not agree with our privacy policy, we understand that we will not be able to provide, to provide you with our services and/or products.
Therefore, if you do not agree with our policies, we strongly recommend that you do not proceed with the proper registrations, registrations and filling in information and do not use our services and/or products.
However, as it is very important for us to know your disagreement so that we can find a way to continue providing our services and/or products, we ask you to inform us of your disagreement, your reasons, so that we can find a solution, clarify what is possible and continue to improve our processes.
Depending on the nature of the services and our products, it is necessary for us to process certain personal data on behalf of our customers, who may act as a controlling agent or as a processing agent/processor of personal data. So we have the following definitions:
• LGPD: refers to the General Data Protection Law, Law 13.709 of August 14, 2018. To learn more visit this link;
• Applicable Data Protection Laws: refers to all applicable laws, regulations, legislative and regulatory requirements and codes of conduct applicable to the processing of personal data, including all provisions of the LGPD and any other relevant laws, regulations or instruments to be amended or repealed from time to time, together with any regulations or instruments made under the same, which are applicable to a Controlling Agent or a Processing Agent/Processor;
• Personal data: refers to any information or data, univocally referring to an identified or identifiable natural person. An identifiable person is one who can be identified directly or indirectly, specifically through referencing an identifier such as a name, ID number, location data, an online identifier, or through one or more factors that are specifically physical, physiological, genetic, mental, economic, cultural, or the individual’s social identity;
• Sensitive Personal Data: personal data on racial or ethnic origin, religious conviction, political opinion, membership in a union or organization of a religious, philosophical or political nature, data related to health or sex life, genetic or biometric data, when linked to a natural person;
• Anonymized Data: data relating to a data subject who cannot be identified, considering the use of reasonable technical means available at the time of its processing;
• Database: structured set of personal data, established in one or several locations, in electronic or physical support;
• Holder: natural person to whom the personal data that is the object of processing refers;
• Controlling Agent: natural or legal person, under public or private law, who is responsible for decisions regarding the processing of personal data, in this case you – your company;
• Operator/Processing Agent: natural or legal person, under public or private law, who processes personal data on behalf of the controller – in this case we at Intelly;
• Processing Agents: the controller and the operator;
• Processing: any operation carried out with personal data, such as those referring to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction;
• Anonymization: use of reasonable technical means available at the time of processing, through which data loses the possibility of direct or indirect association with an individual;
• Consent: free, informed and unequivocal manifestation by which the holder agrees to the processing of his or her personal data for a specific purpose;
The information collected by us, as well as the type, quantity, etc., varies depending on the channel, service or product you choose and how you make use of each of these sources. In order to help you understand and facilitate the understanding of each source and how we collect, we have separated below how each one applies to you:
Web-Sites (Intelly, IntellyIT): These are sites where we present our companies and our services (Intelly and IntellyIT). They are aimed at you, consumers, interested parties and customers who want to know or have access to information, procedures, etc. about our companies and our services. All domains and URLs are operated by our company Intelly.
iSend Web-Site: This is the main site for our products that make up the iSend family (iSend Express, iSend, iSend PRO…). Specific domains of our iSend products and for the public interested in Multichannel Digital Marketing. I touch our knowledge, tools, processes, from sales to service, pass through these domains. Here you will have access to all the information pertinent to the Digital Marketing universe related to our iSend products. All domains and URLs are operated by our company Intelly.
iSend Applications: These are specific domains for customers who have purchased a license to use our iSend product and their respective registered users. Only accredited customers and users will be able to access these domains, which can be run both by mobile devices and by desktops and other equipment, as long as they have the minimum characteristics required for such. All domains and URLs are operated by our company Intelly.
Ads: These are all those online and even offline interactions that collect information from you and that may eventually be passed on the information from your interactions to our company.
Generated Data: We understand that during the most diverse interactions that we can carry out with you (phone calls, digital messages (e-mail, SMS, VOICE…), personal conversations, purchases at our University, on our website, interactions with our content (posts, e-books…) etc., we can generate information about you, for example: your consumption profile, segmentations that you fit for our company, among others.
Events: Any event (Webinar, Congress, Lecture, Meeting…) that, by its nature, will hold the meeting between people, with a determined planning, date and time, organized by us or by third parties, on behalf of our companies and products, as well as events where we are participating as spectators, sponsors, exhibitors, but not limited to, may generate information and data that will be collected by us about you and used by us in the future.
Administrative: Data collected from our employees and suppliers, in order to meet all regulatory and legal needs, as well as to be able to effectively provide our services. All domains and URLs, as well as physical and administrative processes are operated by our company Intelly.
Other Occasions: It is very important to make it clear that every interaction, contacts, etc. with our users, customers, employees, etc., can generate information that we will eventually store, regardless of who made such interaction. Some examples are: Content that is accessed on our web-sites, downloaded, clicked on. Interactions carried out through e-mail messages, SMS, VOICE, access to digital publications, calls to our customer service, administrative, financial, after-sales teams, in short, to the most diverse channels we have, will generate interactions of openings, clicks, messages viewed, heard, duration, etc. This data is stored by us.
Here it is very important to make it clear that all data collected, its forms and channels, are only carried out during, and only for, the provision of our services. Once we have this clear, we emphasize that all your information is treated as confidential and owned by you and will only be used for the purposes you authorize us.
This confidentiality is extended to all our customers through service contracts that formalize the impossibility on our part of making any improper use, session, commercialization, availability to third parties, of the data that these customers have submitted to our platforms. In short, all data in our possession will be treated by us as private and confidential.
All the solutions we implement, both in our products, as well as web-sites, applications, etc., follow a clear process where we adopt the concept of minimizing the data necessary to carry out our activities. To do this, we follow the minimum steps below, not limited to:
– Identification of Needs: We identify the information necessary for the solution to be developed, which may or may not include personal data and other confidential data.
– Data Need Analysis: We analyze the need for each data identified, questioning whether they are essential for the proposed solution or if there are alternatives that can be adopted.
– Implementation of Data Minimization: We have adopted data minimization as a core concept in the design of our solutions, services, and products, including reducing the scope of the data collected and adopting technical and organizational measures aimed at minimizing data use, access, and retention.
– Process Documentation: All our solutions/services/products follow a standard of documentation of the entire design of the same, including the analysis of data needs and the implementation of data minimization. These documents can be found in appropriate repositories (Systems Development) and the company’s Internal Intranet (Wiki).
– Conducting Reviews and Updates: We conduct periodic reviews of our processes to ensure that they remain effective and compliant with applicable laws and regulations.
From the moment you use some of our services and/or products, available on our websites, applications and even services made available to you in a non-digital way (consultancies, training, lectures, mentors, etc.), we will collect the following categories of data:
– Contact Data: Name, Email, Phone, Cell Phone, Gender and Photo
– Location Data: Address, State, City, and Country
– Professional Profile Data: Company, Department, Position
– Company Data: Corporate Name, Fantasy, CNPJ, Address, Branch of Activity, Segment of Activity, Approximate Number of Employees, Estimated Revenue
– Billing Data: Name, CPF and/or CNPJ, Address, Billing Data for issuing charges (Bank Slips, Bank Deposits, Credit Card)
– Marketing Data: Your preferences and interactions with our content and CRM information)
It is worth mentioning here that the above-mentioned data is collected on a need-to-know basis. For example: when registering on our website to receive our electronic newsletters, contact data will be collected, in the case of an intention to purchase our iSend product, we will collect location, professional profile, company, etc.
Another important point, we do not keep any records of Credit Cards and similar data in our systems. When charging by this means occurs, it will always be through an accredited supplier who will treat and process this information.
Only in the event that you register on our websites using external accounts such as Facebook, Google, LinkedIn, will the personal data provided by these networks be collected. We will collect data that is made publicly available and accessible by these companies, such as: information about interactions and materials, public profile, clicks on advertisements, etc. In short, all public information made available by these services and companies.
Both for free trials (Prospects) and for the purchase of our iSend products (Customers), we will collect contact, location, company, billing and marketing data, always with the objective and exclusively to be able to provide the best experience in the performance of our services and availability of our products.
The collection of this data can occur both in the digital environment through our web-sites and applications, as well as through human interactions by our pre-sales, sales, service, support, after-sales, administrative, events, etc. teams.
We use specific functionalities to request the collection of data subject consents to assist our customers in the face of the LGPD, existing in our iSend product. Once consent is given through our product, we store the IP address of the machine that made the consent for later use on request. We do not use other means of collecting IP addresses in our services and products.
When using the iSend products by our customers, we act as information processing agents, so the consent of this data is the sole responsibility of our customers, who in this case are the agents responsible for collecting the data and their respective consents.
Our customers, through our products, may collect the following information from data subjects:
– Contact Data: Name, Email, Phone, Cell Phone, Gender and Photo
– Location Data: State, City, Geographic Region
– Professional Profile Data: Company, Department, Position
– Marketing Data: Your preferences and interactions with customer content such as: clicks, opens, views, message listens, listening time, segmentation, etc
– Traffic Data: Your traffic source for the use of iSend channels: Desktop, Mobile, Landline, Mobile, Email Browser, Mobile Phone Company
– IP Address Data: Our iSend products have specific functionalities for requesting the collection of consents from data subjects to assist our customers in the face of the LGPD. Once consent is given through our products, the IP address of the machine that made the consent will be stored for later use in each request. We do not use other means of collecting IP addresses in our services and products.
iSend products do not have specific fields in their records for the collection of sensitive data and similar information. Any and all collection of information of this nature will take place through the controlling agent and his entire responsibility. We even recommend that such data not be collected by our customers, since we understand that, for the purposes normally proposed for our products, such data is not necessary:
– Company Data: Corporate Name, Fantasy, CNPJ, Address, Branch of Activity, Segment of Activity, Approximate Number of Employees, Estimated Revenue
– Billing Data: Name, CPF and/or CNPJ, Address, Billing Data for issuing charges (Bank Slips, Bank Deposits, Credit Card)
If you verify the collection of this type of data by customers of our platform, we kindly ask you to check with him, who is the data controller agent, and if possible also inform us through the email: dpo@intelly.com.br so that we can verify with the customer the compliance with this situation.
Once you become a user of our iSend University platform, we will collect your contact and browsing data on the platform, as well as your preference for courses, events, etc. Only in the event of a purchase of a certain product or services, we will process your data for payments, where billing data will be collected, remembering that we do not store any credit card data on our servers, always using renowned companies in the market for these purposes.
When you participate in events with us, such as: The Art of Digital Marketing, iSend Days, among others, we can use marketplace platforms for ticket sales and registration control or our own platform such as iSend Univer. In this case, contact data, company, etc. necessary for your registration/registration will be collected and in case of paid events, billing data.
The data collected by market platforms will be shared with our company in order to be able to send marketing content, important notices, news, agendas, in short, relevant content about the theme and the respective event to which you have registered.
We collect personal data from all our employees, with the sole and exclusive purpose of complying with legal and regulatory aspects. The data is only shared with a partner company duly contracted, authorized and regulated by us. Case of a company that provides accounting services.
We will keep our employees’ data for the duration of the employment contract and for as long as the legislation requires so that we can comply with the legal and contractual aspects of the relationship. Outside this period, the data will be duly deleted.
If our employees wish to have access or even update their data, they must use the dp@intelly.com.br channel for this purpose.
We do not collect any sensitive data related to issues such as, but not limited to: Sexual Option, Religion or Creed, Race, Associations, Political, Philosophical or Religious Options, Related to Physical or Mental Health, Genetics, Biometrics, etc.
All our suppliers go through various processes and internal criteria for choice and validation regarding their ability to perform, quality of services and products, etc.
We carry out data collection similar to the data we collect from our customers indicated above. This data is only collected for the sole and exclusive purpose of complying with contractual aspects and for the correct provision of the proposed services.
– COOKIES: We use information collection through Cookies on our websites. For a better understanding of how we use, types of cookies and your data, please visit our Cookie Policy that we have prepared specifically for this purpose.
– WEB BEACONS (PIXEL): We use web beacons (pixel) on our websites and products. They are code artifacts, most of the time, an image pixel, which allows obtaining information, such as:
– Traffic from websites and similar services
– Use of third-party pixels (Facebook) and your data to display more relevant ads that are of real interest to you,
Behavior-based
– To obtain the data of opens and interactions in the email channel
– Being able to personalize ads based on your behavior
– Enable unique visit counting, generate more accurate reports of email channels and web-sites
– TARGETED ADVERTISING: We occasionally partner through a network of service providers and advertisers to display advertisements and advertisements on behalf of our company and our products on the websites and platforms of these partners. Such advertisements can be customized to your interests.
We do not handle, as controlling agents, sensitive data. It is not our company’s policy to collect and store sensitive data from data subjects. Therefore, it is not in our interest, within the work normally performed, to obtain sensitive data from any individual, except in the cases provided for by law and for the strict compliance with legal obligations and the execution of our activities.
If you verify the collection of this type of data by our company, we kindly ask you to inform us via email: dpo@intelly.com.br so that we can act as quickly as possible to comply with this situation.
Since the business model we adopt is SaaS (Software as a Service), both our iSend products and our services are oriented towards this model, so for the effectiveness of our operations we use several business partners, in a wide spectrum, from providers of functionalities such as location, messaging, advertisers, commercial partners, specific technologies, and so on.
With this, we reserve the right to share information with these partners and suppliers, always exclusively for the execution of our activities.
All our services and products, have in the commercialization with our customers, contractual legal basis that obliges us to make every effort to ensure that the data processed by us, will not be sold, rented or transferred to anyone, except for companies and supplier partners and always within the execution of our operation.
• All personal data that the LICENSOR receives from the LICENSEE, in the course of providing its Services, in accordance with this agreement, are confidential and the LICENSOR shall not, in any way, alter, provide or make available the personal data to any Third Party without the prior written consent of the LICENSEE.
• The LICENSOR must ensure that only its employees and other persons acting on behalf of the LICENSOR, who have a need to know, provide the services, provide support and service or solve technical or service problems, and are under confidentiality obligations in relation to the Personal Data, have access to this Data.
• The LICENSOR guarantees that it maintains and will continue to maintain appropriate and sufficient technical and organizational measures to protect personal data against accidental loss, destruction, damage, alteration, disclosure or unauthorized access, especially when the process involves the transmission of data through a computer network and against all other forms of illegal processing.
Data will only be shared with third parties in cases:
– To carry out our provision activities in the context of the performance of our services and products
– To fulfil all contractual aspects of business relationships
– When to comply with a certain law or other aspect of a legal obligation
– In response to legal process
– To comply with the competent legal authority duly official and always within the legal framework
In short, your data will be shared with third parties only in cases of Legal Obligations and Legitimate Interest.
It is important to note that our service providers and employees are rigorously selected and are authorized to access personal data on our behalf, only for tasks determined and authorized by us and requested through direct actions and always based on legal and contractual aspects.
All service providers are contractually obliged to maintain the same data confidentiality and security relationships that our company has.
We have as a legal basis for data collection, the forms authorized by law, the fulfillment of legal obligations and the legitimate interest, always focused on the execution, on our part of the signed contract. Only in the case when the legal basis for data collection is not consent, will the current legislation always be observed, together with the individual rights and freedoms of the data subjects. We use as a legal basis:
•Consents
• Compliance with a legal or regulatory obligation;
• Execution of contracts
• Legitimate interests.
We do not transfer any data collected by our company, our products, and our technologies internationally. All data collected by us and even data from third parties processed by us, are carried out only in the national territory. For a better breakdown of the data centers and technologies involved, please visit Our Security Policy [INFRASTRUCTURE SECURITY Section] for more detail.
The Applications and Data of iSend products are stored on Microsoft Azure Brasil Southeast servers and Message Send servers distributed between Microsoft Azure Brasil Southeast and Amazon Web Services (AWS) – located in the sa-east-1 region (São Paulo – Brazil).
A Lei Geral Brasileira de Proteção aos Dados, ou LGPD, assim com a GPDR e demais marcos legais mundial semelhantes, fundamentalmente protege e viabiliza os direitos individuais de privacidade e proteção aos dados pessoais. Tais regulamentações estabelecem requisitos de privacidade governando como você gerencia e protege dados pessoais respeitando as escolhas individuais — sem importar para onde os dados são enviados, onde são processados ou armazenados.
We at Intelly are constantly working to achieve all the privacy objectives of these regulatory frameworks.
We believe that privacy is a fundamental right and we understand that any law or any other mechanism has come to give the legal and sustainability basis to this vision of protecting individual privacy.
Our iSend product has been on the market for more than 15 years and we are very proud that over all these years, with the numerous customers we have, never in our history has there been a single relevant security incident. This shows that, regardless of the existence of the LGPD, our security and privacy policy, as well as transparency, has proven to be efficient.
Reliability and care for information security have always been important parts of our mission, where we have always adopted an approach based on the pillars of Trust, Security, Compliance and Transparency.
We understand that compliance with the LGPD or any other similar legislation is a shared responsibility and therefore, we are committed to this compliance in all our services and our iSend products.
We are also committed to sharing our expertise around compliance with complex regulations to help you design the best path for your company to succeed in satisfying LGPD privacy requirements along with our services and products.
As part of our commitment to partner with you during your journey around the LGPD, we have developed a specific area on our web-site to help you with the preparations. It offers an overview of the LGPD, describes what we are doing to prepare for the LGPD and outlines a guide to move forward on this journey.
With each new advance, with each new milestone reached, this documentation and the entire set of processes will be updated and will be available to you on our web-sites
We look forward to sharing additional updates on how we can help you comply with this new law and, in the process, enhance personal data protections between our companies.
Always in order to preserve your rights within the legal framework, we provide a direct channel with our DPO (Data Protection Officer) or the person responsible for supervising all issues related to data protection and our policies, within our company. Thus, at any time you can exercise your right by contacting:
Email: dpo@intelly.com.br
Other forms, physical addresses and service: Service
It is possible that our team will contact you to confirm additional data to ensure the complete identification of your identity for the sole and exclusive purpose of security so that data is not disclosed to people who do not have the right to it.
We intend to respond to your request within 5 business days of registering in our systems. Any and all requests that have a greater complexity will be notified to you and a progress monitoring system will be made available within our company.
Your data will be stored with us within the time necessary for the fulfillment of our contractual obligations and the purpose for which we collect your data, as well as for the fulfillment of any legal, regulatory or required by the competent Brazilian authorities.
In short, we keep your data within the following period:
– iSend Customers and Users: As long as you maintain an active account with us
– Business Contacts: Are maintained for 15 years
– Interactions of our customers’ contacts: Are kept for 3 years
In the case of a request to remove the data:
– iSend Customers and Users: Will be deleted within 90 days
– Business Contacts: Are deleted within 5 days
– Contacts of our customers: Are deleted within 5 days
We adopt the best market practices, combined with the most modern technologies, internal access processes and secure development to ensure the maximum security of information in our technological systems.
To make public and accessible all fronts where we operate, our Security Policy is part of this privacy policy. There you will find extensive documentation dealing with, but not limited to:
– APPLICATION SECURITY
– INFRASTRUCTURE SECURITY
– SECURE DEVELOPMENT
Be sure to visit our policy to learn more about our efforts to keep your data as secure as possible.
Our goal is to always be constantly evolving, keeping up with all the existing movements in terms of technology, regulation and milestones with regard to Privacy and Security, so we strongly recommend that you revisit our policies from time to time to always be informed of changes.
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