Privacy Policy
We at HARMO DESENVOLVIMENTO DE SOFTWARE LTDA (“Harmo” or “we”), CNPJ/ME no. 37.779.053/0001-62 and headquartered at Av. Mauro Ramos, 1970 – Sala 308 – Centro, Florianópolis – SC, 88020-304, in the municipality of Florianópolis, state of Santa Catarina, are a feedback management and control platform between companies and consumers (“Harmo Platform” or “Platform”) for our clients (“Clients”), and we are committed to safeguarding your privacy and protecting your personal data. The purpose of this document is to clarify Harmo's practices in handling data collected from users of our website and our clients' applications.
You can change or withdraw your consent to the Cookie Statement on our website at any time.
This Privacy Policy does not cover third-party websites and applications, and we are not responsible for their privacy policies and practices. It is important that you always access the policies of each third-party application to learn more about how these companies handle your data.
Why does Harmo collect my personal data?
Harmo is a company that works with data processing in order to operate a feedback platform between businesses and consumers. We are very serious about complying with laws that protect your privacy, and this policy describes how your personal information and data are collected, used, shared, and stored through our website, applications, and related services. This document is an integral part of our Terms of Use, which provide an overview of our platform.
Your acceptance of our Policy will occur when you agree to the use of your Personal Data for each of the purposes described herein. This will indicate that you are aware of and in full agreement with how we will use your information and your Data. If you do not agree with this Policy, please do not use our services and inform us of the reasons for your disagreement so that we can improve it.
1. Basic concepts: What do I need to know to understand this policy?
To simplify your reading, we present some useful definitions to aid your interpretation:
- "Legal Bases" are the legal grounds that authorize Harmo to process Personal Data. Any and all processing of Personal Data is only considered legitimate if it is based on a legal basis.
- "Personal Data" is any data relating to an identified or identifiable individual, including identification numbers, location data, electronic identifiers, or any data that, when combined with other information, is capable of identifying someone, making them identifiable, or individualizing them.
- "Processing" refers to the uses that Harmo makes of Personal Data, including, for example, the following activities: collection, recording, storage, organization, consultation, use, disclosure, sharing, transmission, classification, reproduction, processing and evaluation.
- “You” or “Data Subject” refers to the person to whom the Personal Data relates.
2. What types of data does Harmo collect?
The amount and type of information collected by Harmo varies depending on the relationship our clients or we have with you. You may be a visitor to our website, interested in hiring our services; you may already be one of our clients and use our services; or you may be a user of a website or application that uses our technology.
Below, we explain what data we collect in each situation, for what purpose we use it, and the respective Legal Basis.
WEBSITE VISITORS:
If you only access our website, we may collect data from your browsing activity and also registration data, as follows:
Origin
Website navigation.
Types of data collected
Browsing data: data collected through cookies or device IDs, including IP address, date and time of access, geographic location, referral source, browser type, visit duration, and pages visited.
Data about the access device: model, manufacturer, operating system, carrier, browser, connection type and speed.
Purpose
Website functionality: enable essential features such as antivirus software, desktop/mobile responsiveness, and other functions.
Legal basis: legitimate interest and legal obligation.
Analytics: Understanding your browsing behavior and how the site is being used, to improve your user experience. The data collected is aggregated, and we use pseudonymization and anonymization techniques whenever possible to ensure the security of Personal Data in data analysis and usage situations where Data Subjects do not need to be individually identified.
Legal basis: consent.
Marketing: targeted content and advertising, both ours and our partners', according to your profile and preferences.
Legal basis: Consent and legitimate interest.
Business prospecting: contacting you and offering our products and services.
Legal basis: Consent.
CUSTOMERS:
If you use any of our services and/or products, we may collect information from you and the Data Subjects that you submit on the Platform.
Origin
Platform usage.
Types of data collected
Browsing data: data collected through cookies or device IDs, including IP address, date and time of access, geographic location, referral source, browser type, visit duration, and pages visited.
Data about the access device: model, manufacturer, operating system, carrier, browser, connection type and speed.
Purpose
Website functionality: enable essential features such as antivirus software, desktop/mobile responsiveness, and other functions.
Legal basis: Legitimate Interest, Regular Exercise of Rights (provided for in the contract) and Fraud Prevention.
Analytics: Understanding your browsing behavior and how the Platform is being used, to improve your customer experience and prevent fraud. The data collected is aggregated and, whenever possible, anonymized.
Legal basis: Legitimate Interest and Fraud Prevention.
Registration form.
Registration data: name, email, phone number, address, CPF number (Brazilian tax ID), store, salesperson, and other information that the company wishes to import from its CRM or ERP system.
Provision of Services: fulfilling our contractual obligations with our clients, as well as preventing fraud.
Legal basis: Legitimate Interest, Regular Exercise of Rights (provided for in the contract), Credit Protection and Fraud Prevention
Relationship Contact: We may send you updates and content about our products and services whenever they are relevant to you.
Legal basis: Legitimate Interest, Regular Exercise of Rights (provided for in the contract), Credit Protection and Fraud Prevention
USERS OF CLIENTS' WEBSITES AND APPLICATIONS ON THE PLATFORM:
If you are using a website or application belonging to one of our Clients, our Clients may use our Platform for a variety of purposes, depending on how they configure the Platform. Depending on how Clients configure the Platform, we may collect data from your browsing activity through a feedback collection technology that we implement in our Clients' applications. It's important to remember that, in these situations, Harmo is the data processor and always acts on behalf of our Client, who is the data controller, and our Clients also need a valid legal basis to authorize Harmo to process the data.
Origin
Website or app navigation.
Types of data collected
Browsing data: data collected through cookies or device IDs, including IP address, date and time of access, geographic location, referral source, browser type, visit duration, and pages visited.
Data about the access device: model, manufacturer, operating system, carrier, browser, connection type and speed.
Data on participation in advertising campaigns: type of advertisement viewed and information about your interaction with the campaign.
Purpose
Website functionality: enable essential features such as antivirus software, desktop/mobile responsiveness, and other functions.
Legal basis: Legitimate Interest.
Analytics: Understanding your browsing behavior and how the Platform is being used, to improve your customer experience and prevent fraud. The data collected is aggregated and, whenever possible, anonymized.
Legal basis: Legitimate Interest and Fraud Prevention
Marketing: Our Clients can use the Platform to help target content and advertising to their own websites and applications, according to their profile and preferences, in order to finance them.
Legal basis: Legitimate Interest and Consent
Important: It is the Client's sole responsibility, in this case, to ensure the legal basis.
Registration form.
Registration data: name, email, phone number, address, CPF number (Brazilian tax ID), store, salesperson, and other information that the company wishes to import from its CRM or ERP system.
Provision of Services: fulfilling our contractual obligations with our clients, as well as preventing fraud.
Legal basis: Legitimate Interest, Regular Exercise of Rights (provided for in the contract), Credit Protection and Fraud Prevention
Relationship Contact: We may send you updates and content about our products and services whenever they are relevant to you.
Legal basis: Legitimate Interest, Regular Exercise of Rights (provided for in the contract), Credit Protection and Fraud Prevention
3. With whom does Harmo share your data?
Harmo, like any company, operates in partnership with a number of other companies to offer its services. Therefore, we may share your Personal Data with these companies, aiming to preserve your privacy as much as possible and, whenever possible, in an anonymous manner. Here we describe in what situations we will share Personal Data and for what purposes.
Below, we explain what data we collect in each situation, for what purpose we use it, and the respective Legal Basis.
Enterprise
Our suppliers.
Types of shared data
Browsing data, data about the access device, login and password data, data on participation in advertising campaigns, registration data, non-personal data.
Explanation
We have a number of vendors that we need to contract with to operate our services, and some of them may process personal data that we collect. For example, we have data hosting services contracted with Amazon Web Services, and Auth0 for login management systems, Zenvia for SMS sending, and Zendesk for possible integration of the customer's account with our platform.
Our analytics and social media tools.
Browsing data, data about the access device.
On our website and platform, we also use software tools to understand your browsing behavior and how the platform is being used. We also have tools that allow you to connect with our social networks, such as Facebook, YouTube, Twitter, Instagram, and LinkedIn.
Public authorities.
Browsing data, data about the access device, data on participation in advertising campaigns, registration data, non-personal data.
We must comply with the law: if a judge or a legally competent authority requires us to share certain data for, for example, an investigation, we will share it. We are against any abuse of authority and, if Harmo believes that a particular order is abusive, we will always defend the privacy of the Data Subjects.
Co-marketing partners.
Registration data (name, email, company, position, department, phone number, company website, company segment).
We have the following agreement with our partners: they promote the marketing campaign (which could be a webinar, e-book, online event, or any similar digital content) through their channels (email, social media, website, blog, contact list, etc.), and in exchange, we share the data (listed in the left-hand column) of those who have registered and are interested in participating in the event or accessing the digital content. This data is shared only once (at the end of the campaign) via a spreadsheet sent by email to each partner.
4. Can my data be transferred to other countries?
Yes. Although Harmo is headquartered in Brazil and the Data we collect is governed by Brazilian law, Harmo collects and transfers Personal Data collected in Brazil to servers located in the United States. This transfer occurs to store Personal Data and other information necessary for the operation of the Platform. These transfers involve only companies that have demonstrated compliance or are in the process of complying with applicable laws, and which can be identified in this list: Amazon Web Services and Oracle.
5. What are the rights of data subjects?
Your personal data belongs to you, and Brazilian law guarantees that you have a series of rights related to this data. We are committed to upholding these rights, and in this section, we will explain how you can exercise these rights with Harmo.
- How can I find out if Harmo has data about me, and how can I access that data?
Harmo allows you to confirm whether we hold data about you and access this data by emailing seguranca@harmo.me (as a security measure, we may request additional information to verify your identity and prevent fraud).
- Can I correct the data that Harmo has about me?
Yes! You can request the correction by emailing seguranca@harmo.me.
- Can I delete my data, either partially or completely?
Yes! Just request deletion by emailing seguranca@harmo.me. Two important notes: (i) we may occasionally perform checks to verify your identity and ensure there is no fraud, and (ii) some data cannot be deleted due to legal obligations.
- Can I restrict the data processing done by Harmo?
Sure! There are a few ways to do that.
- On any website, via a browser. If you are using a browser (Chrome, Explorer, Safari, Firefox), these programs have tools to refuse and disable the collection of some browsing data, including the possibility of browsing anonymously. We will always respect this right of yours. Important: by doing this, some areas of our website may not function correctly.
- On other websites or apps. Unfortunately, we cannot guarantee that other websites and apps not managed by Harmo will respect your privacy. It is always important to access the policies of each third-party application to learn more about how these companies handle your data.
- If Harmo is using my data for a purpose I don't agree with, can I object?
Yes! In our day-to-day activities, it's normal that we may use legal bases that don't depend on your consent, such as legitimate interest. We always exercise this right responsibly and in your best interest, but if you believe that a particular purpose impacts your rights, please send an email to seguranca@harmo.me and we will stop using your data for that purpose. Remember that, in some cases, we may be able to demonstrate that we have legitimate reasons to continue processing your data anyway (for example, to prevent fraud), but we will always justify this to you in the best possible way.
- I gave my consent for Harmo to process my data, but can I change my mind?
Yes! There are several ways to revoke your consent:
- In Harmo's communications, all our marketing emails include an option in the email footer for you to unsubscribe from our communications.
- On our clients' websites and applications. Unfortunately, we cannot guarantee that other websites and applications not managed by Harmo will respect your privacy. This Privacy Policy does not cover third-party websites and applications, and we are not responsible for their privacy policies and practices. It is important that you always access the policy of each third-party application to learn more about how these companies handle your data.
- If I want a copy of all my data, can I request it from Harmo?
Yes! Simply send an email to seguranca@harmo.me and we will provide this information in a format that can be opened on any computer. As a security measure, we may request additional information to verify your identity and prevent fraud.
6. For how long will Harmo retain the data?
Harmo has a data retention policy aligned with applicable law. All data related to IP address and access time is kept for a minimum of 6 (six) months. Regarding other data and maximum retention periods, personal data is stored only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of complying with any legal, contractual, accountability obligations or requests from competent authorities. Of course, you always have the right to request the deletion of your data, as per item 5 above.
We understand that this statement may seem vague, but we will explain it further. Because this data can be used for profiling, Harmo and our clients may have legitimate reasons to continue using the data over time. Even so, we conduct a technical analysis to determine the appropriate retention period for each piece of personal data, considering the quantity, nature, potential risk of harm from unauthorized use, and whether we can achieve those purposes through other means. This period usually lasts from 6 months to a maximum of 24 months after the expiration of your contract, except for data that may be used to exercise Harmo's rights.
Important: Unfortunately, we cannot guarantee that other websites and applications not managed by Harmo will respect your privacy. This Privacy Policy does not cover third-party websites and applications, and we are not responsible for their data retention policies and practices. It is important that you always access the policies of each third-party application to learn more about how these companies handle your data.
7. What are our responsibilities and how does Harmo protect my data?
Our responsibility is to protect your personal data and use it only for the purposes described in this Policy. To guarantee your privacy and the protection of your Personal Data, we adopt security practices appropriate for our market, using encryption techniques and other information security systems.
We strive to protect the privacy of your account, but unfortunately we cannot guarantee complete security. Unauthorized account access or use, hardware or software failure, and other factors may compromise the security of your Personal Data at any time, so please help us maintain a safe environment for everyone. In addition to adopting good security practices regarding your account and your Data (such as not sharing your password with third parties), if you identify or become aware of anything that compromises the security of your Data, please contact us.
It is important to emphasize that HARMO does not control the personal data processed by third parties using its technologies. This data belongs to HARMO's clients, who use, disclose, and protect it in accordance with their respective privacy policies. They are also responsible for directly obtaining user consent or another appropriate legal basis to collect, manage, and process personal data.
8. How do I contact Harmo?
If you believe that your Personal Information has been used in a manner inconsistent with this Privacy Policy or with your choices as a Data Subject, or if you have any other questions, comments or suggestions related to this Policy, please contact us. We have aData Protection Officerwho is available at the following contact addresses:
DPO (Data Protection Officer): Leonardo Rifeli
Mailing address: Av. Mauro Ramos, 1970 – Room 308 – Centro, Florianópolis – SC, 88020-304
Contact email: seguranca@harmo.me
9. Changes to the privacy policy
As we are always looking to improve our services, this Privacy Policy may be updated. Therefore, we recommend that you periodically visit this page to stay informed about any changes. If significant changes are made that require new consent, we will publish the update and request your new consent.