Privacy Policy | BHub

BHUB SERVIÇOS E TECNOLOGIA LTDA. (“TECNOLOGIA“), with registered office at Rua Cardeal Arcoverde, nº 2365, 3º andar, conj. 31, 32, 33 e 34, Pinheiros, CEP (Zip Code) 05407-003, registered with CNPJ (Corporate Taxpayer Registration) under No. 42.330.545/0001-06, as well as the other companies of the BHub group (“BHUB” or “Group“) are primarily committed to respecting the privacy, protection and security of the personal data they process, according to the provisions of Law No. 13,709/2018 (“LGPD”) and other current legal provisions governing the matter.

For this reason, our team adopts all protection measures possible, within the best practices and existing solutions, in order to guarantee the privacy, protection, and security of the personal data processed by BHUB! In order to provide maximum transparency regarding the processing we carry out, we, at BHUB, present the following Privacy Policy (“Privacy Policy“). Here you will find information about the personal data we collect and the processing we carry out in our environments, including our websites, applications, platforms, and social pages, mainly so that you can enjoy our products (“Products“) and services (“Services“) with maximum safety and comfort!

In order to remove the complexity and ensure a unique and enjoyable experience with BHUB, with the desired security, we have written this Privacy Policy in a simple and accessible way so that everyone can clearly understand how we collect, use, share, and, in short, process personal data. Ready to get started?

Before we begin our partnership, we clarify that this Privacy Policy, together with our Cookies Policy (“Cookies Policy “), is an integral part of the General Terms and Conditions (“General Terms“) and the Terms and Conditions of Use relating to specific BHUB platforms (“Specific Terms“). You will find in them more detailed information on how to use our environments, including the obligations, restrictions, and responsibilities of the parties.

IMPORTANT!

We hereby clarify that, by registering on our websites/applications, entering data on our platforms/social networks, and/or sending us any information in any other way, the user shall be legally and formally bound by this Privacy Policy, the Cookies Policy, the General Terms and Conditions and the regulations governing BHUB’s activities (“Acceptance“).

What does that mean?

Acceptance means that the user declares and attests to full and complete knowledge of how personal data shall be processed by BHUB.

ATTENTION!

Agreement with this Privacy Policy and other BHUB terms, policies, and regulations is required for using the Products and Services. If the User does not agree with any of the aforementioned provisions, he/she must immediately stop using the websites/applications/platforms made available by BHUB, and not register in said environments, including social networks, nor consume any features, functionalities, service, product or other benefit offered and/or otherwise provide any information to BHUB. Please be aware that if you do not agree to our Privacy Policy, Cookies Policy, General Terms and/or Specific Terms, and/or the other regulations governing the activities of this company, such activities, including the supply of our Products and the provision of our Services, may not take place.

Although our joint journey cannot continue if the above documents are rejected, your opinion is extremely important to us! Therefore, we kindly ask you to let us know why you disagree so that we can continuously improve our activities.

We aim to cut through the complexity and that’s why we’ve tried to make this Privacy Policy as simple as possible, but if you still have any questions, please don’t hesitate to contact us at the following e-mail address: privacidade@bhub.ai, indicating “Privacy Policy – [Title]” as the subject line.

BHUB hereby informs you that it does not collect or process personal data unless there is a specific need and purpose, with a compatible legal basis. BHUB also clarifies that it makes every reasonable effort, in accordance with current technology, to guarantee the security of its systems, and thus the privacy and protection of the personal data it processes.

By accessing, using or otherwise interacting with our websites/applications/platforms, the user declares to comply with the conditions set out in BHUB’s policies, terms, and regulations. If you are accessing, using or otherwise interacting with our environments on behalf of any organization, you hereby declare that you have all the legal powers to bind said organization to this Privacy Policy, as well as to the other terms, policies, and regulations of BHUB.

1. WHAT IS PERSONAL DATA?

Any information relating to an identified or identifiable individual (art. 5, I, LGPD – General Data Protection Law), known as the data subject.

2. WHAT DOES IT MEAN TO PROCESS PERSONAL DATA?

Processing personal data means carrying out any activity related to the data/information of an identified or identifiable individual. These activities include collecting, producing, receiving, classifying, using, accessing, reproducing, transmitting, distributing, processing, archiving, storing, deleting, evaluating or controlling information, modification, communication, transfer, dissemination, or extraction (art. 5, X, LGPD).

3. WHAT IS BHUB’S ROLE IN PROCESSING PERSONAL DATA?

According to the LGPD, a controller (“Controller“) is the one responsible for decisions regarding the processing of personal data, whether an individual or legal entity, whether governed by public or private law (art. 5, VI, of the LGPD). The operator (“Operator“) is the one who processes personal data on behalf of the Controller.

Based on the definition of the LGPD and the activities carried out by BHUB:

When BHUB provides its Services and/or supplies its Products, from the back-office service packages (“Back-office”) offered on its websites/applications/platforms/pages, it processes personal data on behalf of its clients (companies/entrepreneurs), thus acting as an Operator, and following the guidelines and purposes determined by them for processing said data;

When BHUB carries out internal operations, it has decision-making power over the processing of the personal data it carries out, acting in this sense as a Controller. Examples of such operations are the processing of personal data relating to the management of registration information of clients/potential clients, suppliers, and partners, as well as personal data of BHUB employees and candidates in the recruitment and selection process promoted by BHUB.

By exercising the role of Controller, BHUB shall respond directly to any claims made by the holders of personal data, in compliance with the applicable legislation in force, in particular the LGPD, as well as the provisions of this Privacy Policy and other policies and regulations of BHUB and/or of the competent authorities.

The user hereby declares and guarantees that the personal data, including that of third parties, shared with BHUB, in its capacity as Operator, to provide the Services and/or supplying the Products, has been obtained from the data subjects, clearly and transparently and with the appropriate authorizations, being up to each of BHUB’s clients, as Controller, to respond directly to any demands made by these data subjects, pursuant to LGPD. In this circumstance, BHUB, in its capacity as Operator, shall only be responsible for providing due assistance to the respective Controllers, under the terms and limits of the applicable legislation in force, in particular the LGPD, as well as in accordance with this Privacy Policy and the contractual provisions signed between the parties.

In any event, users acknowledge and agree that they are fully liable for the accuracy and veracity of the data they provide to BHUB, including through their legal representatives, employees, and/or interlocutors, and that they must always keep them up to date. Under no circumstances shall BHUB(i) process personal data if there is reason to believe that such processing is in breach of any applicable law, or if the user is using our environments for any illegal or illicit purpose; (ii) be liable for any result and/or damage arising from errors, the falsity of information provided by the user, including by their legal representatives, employees, and/or interlocutors, and/or the failure to update said data.

Within the scope of the Entrepreneur Hub, BHUB shall not be liable for any direct, indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of profits, business interruption, loss of information or data, or for any breach of the confidentiality, integrity, or availability of personal data resulting from access management by the Primary User, whether caused by error, coercion, or any other circumstance. When managing access rights, each Primary User acts as the Controller of personal data accessible by new users and is solely responsible for ensuring that data processing strictly complies with the LGPD.

Additionally, the Primary User is responsible for the accuracy of information provided when adding new users to the Entrepreneur Hub system and for ensuring that personal data entry and access grants are conducted with the proper consent of the data subjects. For more information, please refer to the Terms and Conditions of Use Entrepreneur Hub.

4. WHICH PERSONAL DATA DO WE PROCESS?

Registration data: data collected through forms/fields available on our websites/applications/platforms/pages so that BHUB can provide its Services and Products available and contact users. These include: name/surname, e-mail address, telephone number, and any access data.

Data collected for the effective performance of activities: data collected so that BHUB may effectively perform its activities, including providing its Services and supplying its Products, recruiting, hiring/managing employees, signing partnership agreements and/or other agreements, and other related activities. This data includes the following, according to the specific activity/purpose to be carried out, which is always informed to the user: name/surname, e-mail, telephone, ID/RG/Passport, CPF (Individual Taxpayer Registration), copy of identification document, address, nationality, place of birth, date of birth, parents, marital status, education, curriculum vitae, professional/work information, dependent/spouse information, financial data.

For the effective provision of our Services and supply of our Products:

From the back-office service packages, users may, due to the very nature of such activities, provide BHUB with data from third parties, such as its employees, hereby declaring and acknowledging that it is their sole and exclusive responsibility to obtain said data from third parties/owners lawfully, with due transparency, and with the appropriate authorizations;

Through the services provided within the Entrepreneur Hub, the user may, due to the nature of such activities, provide the company’s banking/financial information (“Banking/Financial Information”): bank, branch, account, overdraft, balances, transactions, investments, loans, credit. This information may be retained and stored: (i) as long as the registration, account, and/or the user’s use of the resources, features, services, products, and/or other benefits of the Entrepreneur Hub remain active; and (ii) in the situations outlined in item 7 of this Privacy Policy.

Sensitive data, as defined by law, in particular art. 5, II, of the LGPD, when essential to any activity to be carried out by BHUB, such as administration of absence/leave policies and occupational health policies or biometric authentication of electronic system registrations to prevent fraud and ensure security, shall be processed to the extent strictly necessary for the purposes for which it is intended, informed to the user, according to the appropriate legal basis, subject to the applicable legislation, in particular the LGPD and the other provisions of this Privacy Policy, being certain that, under no circumstances, shall this processing be given for any discriminatory purposes.

Browsing/device data on websites/applications/platforms/pages: This is the data collected when browsing our websites/applications/platforms/pages, such as IP address, geographical location, referral source, browser type, duration/frequency of visits, and pages visited. This information is usually obtained through cookies installed in the browser itself. For more information, please visit our Cookies Policy.

Contact history – BHUB may store information about contacts already made, such as personal interactions, via e-mail, platform, and/or telephone/WhatsApp, particularly to manage the relationship with the user.

Data made manifestly public or publicly accessible: due to its activities, BHUB may process this type of data, which includes, for example, information from social networks and the like, as well as information publicly accessible and/or from credit protection companies. But don’t worry! Even in this case, BHUB shall respect the purpose, good faith, and/or public interest that justified the provision/disclosing of said data.

Occasionally, we may request the user for other information through direct contact with our team or through the website/application/platform itself. BHUB may also, at any time, at its sole discretion, request the updating and/or provision of data to complete the registration.

Still worried? Relax! BHUB allows you to ask questions at any time through the channel indicated above. If BHUB acts as Controller of the processing of personal data, it shall also be available for the holder of said data to exercise directly, through its channel, the rights provided for in the LGPD, in particular in its art. 18. If this is not the case, and BHUB is acting as an Operator, please contact the Controller of the processing related to your personal data directly to exercise these rights.

5. WHY DO WE COLLECT AND USE PERSONAL DATA FOR?

All the data collected is used by BHUB so that it may fully carry out its activities, including providing its Services, supplying its Products, recruiting, hiring/managing employees, signing partnership agreements and/or agreements with third parties, among other activities, with the purpose, on the one hand, whenever possible, of improving the experience of the parties that relate to it, and on the other hand, of maintaining the privacy of each one of them. For this reason, the data/information processed by BHUB is kept confidential and used only for the purposes described here.

With this in mind, we will be able to safeguard the personal data involved in the processing carried out by BHUB, protecting them and, at the same time, customizing our activities, including our Products and Services, to improve them and adapt them to the interests of users, subject to the applicable legislation in force, in particular the LGPD, and the other provisions of this Privacy Policy, other policies and regulations of BHUB, and/or competent authorities, as well as the contractual relationships entered into by BHUB.

What kind of services do we offer? Our products and services are provided simply, directly, and quickly, but with the quality our clients deserve, according to their needs and budgets! This is precisely why each package has its own peculiarities and is delivered according to the information, guidelines, and purposes that each client provides, which vary according to the Products and Services desired/contracted!

BHUB may process personal data for purposes that are not provided for herein, but which are within the scope of legitimate expectations. The possible use of personal data for purposes that do not comply with this prerogative shall be done with knowledge, authorization, or consent, as applicable, as in the case of sending/making available newsletters, e-books, and webinars.

In addition to the provisions mentioned in this Privacy Policy, subject to the applicable legislation in force, in particular the LGPD, and the other provisions contained in this instrument and other BHUB policies, terms, and regulations, personal data may also be processed for the following purposes, subject to the applicable legal bases in force:

Registered emails and/or telephone/WhatsApp numbers may be used to send information requested on our websites/applications/platforms. They may also be used to send news, product and service offers, campaign announcements, and other information, always related to topics of interest to the registered user. E-mails and/or telephones/WhatsApp may also be used to communicate the launch of new services and/or products, and, where applicable, to inform about any BHUB selection processes and the like.

BHUB employees may contact you via e-mail and/or telephone/WhatsApp to answer questions, conduct survey, and/or provide information on Products, Services, campaigns, news, updates, events, selection processes, and other matters that may be of interest to the registered user.

BHUB may send messages regarding support, customer service, and/or related services, such as alerts, notifications, and updates;

BHUB may also use personal data for purposes compatible with the legitimate expectation or authorized at the time of collection;

BHUB may also use personal data to comply with legal/regulatory obligations or for the regular exercise of its rights.

Users may cancel their registration to receive messages of an advertising nature at any time, choosing to no longer receive them, as indicated in the content sent and in this Privacy Policy, in particular the provisions of item 8.

6. WITH WHOM AND WHY DO WE SHARE PERSONAL DATA?

BHUB may share personal data with partners/third parties and/or companies of the same group (“Group“), to the extent that such sharing is reasonably necessary for the purposes set forth in this Privacy Policy and the effective performance of its activities, including the provision of its Services and the supply of its Products, subject to the applicable legislation in force, in particular the LGPD, and the other provisions contained in this Privacy Policy and other BHUB policies, regulations and contractual relations.

BHUB always seeks to carefully evaluate its partners and service providers, signing contractual obligations with them regarding confidentiality and data processing, to always ensure the best practices for the privacy and protection of the information we collect and use.

Personal data/information may be shared with third parties due to negotiations to which BHUB is a party, such as, but not limited to, consolidations, acquisitions, or incorporations, subject to the applicable legislation in force, in particular the LGPD, and other provisions contained in this Privacy Policy and other BHUB policies, terms, regulations, and contractual relationships.

Personal data/information may also be shared with third parties in the following cases: (i) upon judicial, administrative, or governmental determination/request; (ii) if the act is necessary for BHUB’s compliance with current legislation; and/or (iii) if express authorization is given. In this regard, the user acknowledges and agrees that information provided by the user to BHUB may be shared with the competent authorities if BHUB is requested to do so or is charged with this duty under the applicable legislation in force.

BHUB may also share personal data with companies located in other countries, such as Google, Microsoft, and/or Amazon, mainly for cloud data storage.

We clarify that the mentioned third parties/partners are subject to the rules, obligations, and duties of confidentiality, secrecy, and protection of the privacy of the information and data processed, consistent with this Privacy Policy, as well as with other terms, policies, and regulations of BHUB and applicable current legislation, particularly the LGPD, without prejudice to any other applicable laws depending on their location.

BHUB hereby informs that, in the event of an international data transfer, this shall take place according to the security measures necessary to ensure confidentiality, integrity, and availability of the personal data transferred, in compliance with the applicable legislation in force, in particular the LGPD.

7. ACCESS TO PERSONAL DATA, SECURITY AND DISPOSAL

Without prejudice to item 6 above, the personal data processed by BHUB shall only be restricted to BHUB employees, and among these, only to people with internal and specific authorizations to do so, respecting the principles of proportionality, necessity, and relevance to the business purposes. Eventually, if this information is entered through actions created in partnerships, the explicitly identified partners shall also have access to the information, according to the quantum strictly necessary, subject to the applicable legislation in force, in particular the LGPD, and other provisions contained in this Privacy Policy and other BHUB policies, terms, regulations and contractual relationships. Except as required by law, no personal data processed by BHUB may be disclosed publicly without prior express authorization.

Internally, BHUB has rules of good practice, policies, and procedures, which establish organizational conditions, training, educational actions, and mechanisms for supervising and mitigating risks related to the processing of personal data.

Personal data processed by BHUB is considered confidential and the use of such information shall be under the law, in particular the LGPD, with this Privacy Policy, as well as with BHUB‘s other policies, terms, regulations, and contractual relationships. We at BHUB shall make every reasonable effort, according to current technology, to ensure the security of our systems and, consequently, of the processing of personal data that we carry out.

Personal data processed by BHUB may be made anonymous or encrypted, if this practice does not make it impossible for BHUB itself to use them in the supply of its Products and/or in the provision of its Services.

Users are liable for the secrecy and confidentiality of the data they provide to BHUB, as well as for the actions and/or omissions carried out in our environments.

Upon request, BHUB may provide information about the personal data it processes and stores in its systems to interested parties, subject to the limits of the law, as well as this Privacy Policy, other BHUB policies and regulations, as well as the rights and obligations provided for in agreements, being certain that, in the event(s) in which BHUB acts as Controller, the holders of personal data shall be able to exercise, directly, the rights provided for by law, in particular those contained in art. 18, of the LGPD, which are: (i) confirmation of the existence of processing, (ii) access to data, (iii) correction of incomplete, inaccurate or outdated data, (iv) making anonymous, blocking or eliminating unnecessary, excessive or processed in non-compliance under the LGPD, (v) portability, among others. On the other hand, in the events in which BHUB acts as an Operator, such exercise of rights shall take place directly with the respective Controller of the personal data.

We at BHUB shall only keep personal data in our database: (i) for as long as they are necessary or relevant to the purposes described in this Privacy Policy; (ii) to meet terms provided for by law; (iii) for compliance with legal or regulatory obligations; (iv) for the regular exercise of rights; (v) for as long as necessary to maintain the legitimate interests of BHUB, pursuant to the law.

If the holder of the personal data revokes any authorizations or consents (where applicable) for purposes that are essential to the regular operation of our environments and Services or exercises certain rights that compromise the execution of the agreement, our environments, Services, and/or Products may become unavailable, and such revocation shall not affect the lawfulness of any processing previously carried out.

When using our environments, users may have access to links from partners or third parties which, when activated, redirect them to other websites, portals, or platforms which may collect personal data. The indication of these links does not constitute an endorsement or sponsorship of the services and/or products provided by these third parties. Information on the collection of personal data, access mechanisms, security, and disposal adopted by these partners or third parties can be found in their respective policies, being the sole responsibility of each party to adopt measures according to current legislation, in particular the LGPD, to protect privacy and any data relating to identified or identifiable individuals.

Under no circumstances is BHUB liable for the privacy policy of third parties and/or the content of any websites or services linked to environments that are not its own, nor for the data processing carried out by them and/or any errors, failures, irregularities, or defects in the provision of their services and/or supply of their products.

We recommend, therefore, that the user carefully read the privacy policies, terms and conditions of use, and other regulations of these third parties.

Any complaints or questions regarding third-party services and/or products used and/or acquired by the user via links provided on our sites/apps should be directed to the respective third parties’ customer service channels.

8. HOW TO CANCEL REGISTRATION OR CHANGE/DELETE PERSONAL DATA?

Data processed by BHUB may be deleted from our servers upon request, expressly and in writing, or when they are no longer necessary or relevant to the performance of our activities, unless there is any other reason for their maintenance by BHUB, such as: (i) compliance with a legal or regulatory obligation; (ii) regular exercise of rights; (iii) legitimate interest, without limitation. To change personal information or delete it from our database, subject to the provisions of this Privacy Policy and the applicable legislation in force, the user must send an e-mail to privacidade@bhub.ai, indicating “Privacy Policy – Cancellation of Registration/Change/Deletion of Personal Data” as the subject.

At any time, those who receive e-mails sent by BHUB may opt out of receiving them, except for those: (i) essential to the continued performance of activities by BHUB, including its Services provision and/or supply of its Products; and (ii) which, by legal or regulatory obligation, need to be sent by BHUB to its clients/users. To exercise this option effectively, simply request the e-mail deletion from our contact list, via the following e-mail address privacidade@bhub.ai, indicating “Privacy Policy – E-mail deletion from contact list” as the subject.

It is important to clarify that when you fill in any form again or register in any way, you shall automatically be added to the BHUB contact list. Therefore, if you no longer wish to receive emails from us, you will need to request the deletion of your email address from our mailing list.

9. AMENDMENTS TO THE PRIVACY POLICY

The user acknowledges BHUB‘s right to change the content of this Privacy Policy at any time, at its sole and exclusive discretion, according to the purpose or need, and it is up to the user to consult it periodically, especially when accessing our environments. If there are any relevant amendments, the user shall be informed.

Should any point of this Privacy Policy be deemed inapplicable by any judicial authority or by the National Data Protection Authority, the other conditions shall remain in full force and effect.

10. APPLICABLE LAW AND JURISDICTION

This document is governed by the laws of the Federative Republic of Brazil.

The Judicial District of the capital of the State of São Paulo is hereby elected as competent to settle any questions arising from this document, with express waiver of any other, however privileged.

This Privacy Policy was last modified on October 23, 2024.