Crawly Privacy and Security Policy

At Crawly, we value relationships built on trust, a concept based on transparency and security, essential principles for our philosophy. Thus, this Privacy Policy aims to provide a clear understanding of the procedures involving the processing of your personal information.

Who We Are

This website is exclusively owned and managed by CRAWLY SOLUCOES E TECNOLOGIA LTDA, referred to in this document as CRAWLY, registered under CNPJ/MF No. 29.178.865/0001-24, located at Avenida do Contorno, No. 2905, room 405, Santa Efigênia neighborhood, in the city of Belo Horizonte/MG, ZIP code 30.110-915, and contact email “contact@crawly.com.br”.

CRAWLY develops intelligent robots for automating large-volume data collection. CRAWLY's robots perform real-time queries to feed data to internal corporate sectors such as compliance (certificates and checks on public portals), pricing (checking prices of own and competitor products online), among others.

This document aims to establish the Privacy and Security Policy for the functionalities of the website “www.crawly.com.br”, hereinafter referred to as the “site”, describing the ways personal data of individuals accessing and using the site are collected, stored, used, shared, and disclosed, as well as the measures taken to ensure the protection of data collected by CRAWLY.

1. Definitions

For a better understanding of this Privacy Policy, here are some specific and relevant definitions:

• “Data” Any information that identifies or can identify a natural or legal person; and anonymized and/or statistical information. This definition includes Personal Data.
• “Personal Data” Any information that identifies or can identify a natural person; data of a natural person, a living individual who can be identified from that data.
• “Anonymized Data” Any data that does not identify the Visitor individually.
• “Cookies” Cookies are small pieces of data stored on the Visitor's device (e.g., data from previously visited websites or links).
• “Robots” or “Crawlers” Software developed by CRAWLY that navigates the world wide web methodically and automatically, capturing public information and data from web pages.
• “Visitor” or “User” Any individual who accesses the CRAWLY site and may or may not fill in the information in the “Contact Us” field.

2. Collection and Processing of Personal Data

2.1. Data Provided by the VISITOR

Data collection on the site is guided by the principles of the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados - Law 13.709/19), namely: purpose, necessity, transparency, security, prevention, non-discrimination, data quality, adequacy, free access, and accountability.

To contact CRAWLY through the “Contact Us” form, the Visitor will need to provide: (i) Name*; (ii) Email*; and (iii) Phone*. *data considered personal data.

This data will be collected and stored for specific purposes, namely:

Name, Phone, and Email: This personal data is necessary for CRAWLY to identify the Visitor and get in touch to address requests submitted in the “Message” field. The Visitor may receive communications from CRAWLY at their registered email address, including announcements, information about new features, updates, and similar emails.

It is important to note that the use of this information is restricted to the objectives indicated in this document, and CRAWLY commits not to use or share it with third parties for purposes other than those stated in this Privacy Policy.

The use of the site implies the Visitor's consent to the collection, storage, and use of the personal information provided. The Visitor hereby authorizes CRAWLY, at its discretion, to preserve and store all content submitted on the site, as well as all their data and other information provided and/or collected for statistical purposes in an anonymized form.

2.2 Data Collected Automatically (Cookies)

Cookies are essential elements of the online browsing experience, being small fragments of information stored on devices such as computers, smartphones, or tablets when users interact with various sites and platforms.

In this context, cookies can record individual browsing preferences, such as chosen language, layout customizations, and purchase history. They also enable the convenience of staying logged into an account, eliminating the need to enter credentials repeatedly.

Cookies facilitate the delivery of relevant content, directing information that matches your interests and needs, resulting in a richer and more personalized experience during your navigation.

During interactions with the Crawly site, information may be collected about how the services, pages, and functionalities of the site are used by the Visitor. This collection may include data such as: characteristics of the access device, browser, IP address (with date and time), IP origin, information about clicks, pages accessed, subsequent pages accessed after leaving the site, or any search term typed on the sites or in reference to them, among others.

For such collection, CRAWLY will use some standard technologies, such as cookies, for navigation memory.

Subject to your express consent, this data may be used for advertising, marketing, promotions, discounts, and events to occur moderately and according to your preferences and habits. This type of information use, when performed, will prioritize well-being both on and off the site and will always respect fundamental rights and your privacy.

It is important to mention that the user can delete all existing cookies on their internet connection devices. However, much of the automatic data produced and collected is essential for the functioning of some services available on the sites. Thus, non-authorization or blocking by the browser may cause errors or make some functionalities unavailable.

Data collected automatically is primarily used to improve the browsing experience on the pages, the Visitor's habits and preferences, as well as the speed of future activities and experiences within the site pages.

2.3 Other Data

Exceptionally, CRAWLY may collect information provided by or about the Visitor voluntarily, other than that expressly identified in this document, during the site navigation process, or when the Visitor contacts CRAWLY.

In addition to the ways outlined here, CRAWLY may use the Visitor's data in the following ways:

• updating registration;
• ensuring Visitor security;
• responding to the Visitor's own requests;
• informing about changes to the Privacy and Security Policy;
• compiling statistics regarding site usage, ensuring Visitor anonymity, including for purposes of improvement and understanding the profile of Visitors to enhance the site;
• improving interactivity tools between the site and the Visitor, ensuring their anonymity;
• complying with court orders;
• defending CRAWLY's rights against the Visitor and third parties in judicial or administrative proceedings;
• customizing offers and experiences;
• monitoring Visitor activities and traffic on the CRAWLY site;
• assisting in compliance with this Privacy and Security Policy.

3. How Data May Be Shared

CRAWLY adheres to the principle of confidentiality and security of Visitor Information. Thus, CRAWLY commits not to disclose, grant access, facilitate access, rent, sell, exchange, or otherwise make such information available to other Visitors and third parties, under any pretext, except in cases expressly authorized by the Visitor, which are indicated here.

CRAWLY may need to disclose Visitor data if required by law, subpoena, or other legal process. Whenever this occurs, CRAWLY will notify the VISITOR about the legal demands concerning their Personal Data, unless prohibited by law or court order, or if the request is urgent.

CRAWLY will only share data with third-party service providers (server, database, backup, analytics) to assist and offer site functionalities. In this case, all service providers must adhere to the terms of this Policy and the terms of data protection legislation.

CRAWLY may also share Visitor data if it believes in good faith that disclosure is necessary to: (i) investigate, prevent, or take action regarding suspected or actual illegal activities or to cooperate with public authorities; (ii) enforce CRAWLY's contracts; (iii) investigate and defend against any third-party claims or allegations against CRAWLY; (iv) protect the security or integrity of CRAWLY's services; or (v) exercise or protect the rights and safety of CRAWLY, VISITORS, employees, or third parties.

CRAWLY reserves the right to share certain non-personal information, such as statistical and/or anonymized data, with third-party service providers or partner companies, in order to better understand which advertisements and services may interest the Visitor and/or to improve the Visitor experience.

4. International Data Transfer

Crawly stores its databases on servers located in Brazil. However, some operations may be conducted on servers located in the United States of America (USA) – Amazon and Google. In this context, all operators have data protection and information security standards compatible with this Privacy Policy, ensuring that data is always protected under these terms, and are subject to the provisions of the legislation, ensuring the application of the protection mechanisms of Art. 33 of the Brazilian General Data Protection Law (LGPD).

5. Visitor Rights

At Crawly, we take the Rights of Personal Data Subjects seriously. Therefore, at any time and upon request, you can exercise your rights provided for in Art. 18 of the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados - Law 13.709/18) - LGPD.

5.1. Right to Access and Control Data

The Visitor may request, at any time, the deletion of all their data through the Contact channel provided in this Privacy Policy.

The Visitor may also request the interruption of the use of all or some of their Personal Data, or limit its use by CRAWLY, being aware that this type of interruption may cause the interruption of services provided or received or the impossibility of maintaining them.

At any time, the Visitor may request a copy of all their Personal Data held by CRAWLY. The format of the file containing the data will be defined according to CRAWLY's internal criteria, and this request cannot be subject to excessive burden for CRAWLY.

5.2. Revocation of Consent

The Visitor may revoke the consent given to CRAWLY to process their Personal Data at any time, through the channels provided in this Privacy Policy.

Revoking consent does not mean that CRAWLY will be prevented from processing the Visitor's Data; processing may occur for other Data that is not personal or when there are other legal bases for processing, as provided in the legislation applicable to this relationship.

5.3. Receiving Contacts

In addition to the above, along with our emails, we always provide a link so you can unsubscribe from receiving advertising emails, newsletters, and information.

6. Legal Bases for Data Processing

CRAWLY collects and processes Personal Data according to legal bases. The legal bases for data processing carried out by CRAWLY through the site include the consent expressly provided in the “Contact Us” field. The consent given by the Visitor is specific to the purposes described in this document.

Whenever this document or any site functionality undergoes updates or modifications that result in changes to personal data processing, the Visitor will be informed so they can provide their consent again.

Other legal bases may authorize CRAWLY to process Visitor data through the site, even without express consent, such as legal obligation, among others.

7. Storage and Security Measures

CRAWLY adopts advanced technological resources compatible with its operations to ensure the security of all Visitor Data collected and stored. Not even CRAWLY employees have free access to the Visitor Database; access is limited only to those individuals whose roles require contact with Visitor Data.

Among the security measures implemented to protect the Data provided on the site are the use of Amazon's AWS Cloud server, highly reputable in the sector with high-level security standards and technologies, as well as the use of SSL encryption, installation of barriers against unauthorized access to the database (firewalls), and password encryption.

Despite CRAWLY's best efforts and dedication to its Visitors, the current state of technology does not allow for the creation of a database that is absolutely inviolable and secure against attacks. CRAWLY uses all protection compatible with its operations and size.

CRAWLY only sends emails to the Visitor with advertising messages, promoting products and services, or updating information. CRAWLY does not send emails requesting personal data, passwords, or financial data. If the Visitor receives an email with such characteristics, disregard it and contact CRAWLY through the communication channels.

8. Contact

8.1. From the VISITOR to CRAWLY

If the Visitor wishes to contact CRAWLY regarding any right related to their personal data and/or matters related to processing carried out by CRAWLY, they should contact us via email at contact@crawly.com.br, stating the reason for contact in the subject line.

8.2. From CRAWLY to the VISITOR

CRAWLY respects your privacy and will not make unwanted, unexpected, or unauthorized contacts with the Visitor.

CRAWLY may send emails regarding site functionalities, products and services, news, guidance, and other important information relevant to the relationship between the Visitor and CRAWLY.

In addition to essential information, CRAWLY may send advertising and promotional messages about CRAWLY's services to the email address provided by the Visitor, which may also include products, services, promotions, content, and news from potential partners.

The sending of these advertising messages will only occur with the prior consent of the Visitor, expressly provided in the “Contact Us” field. The Visitor may, at any time, request the cancellation of advertising or marketing emails via the unsubscribe link provided in the received email itself.

9. Crawly's Data Protection Officer (DPO)

Crawly's Data Protection Officer (DPO), Pedro Fontenelle Reis Cordeiro, is responsible for providing guidance, clarifying doubts, and assisting in all aspects related to data protection and the processing of your personal data. Therefore, you can rely on him to clarify any questions or concerns regarding the protection and processing of your personal data by our company. The contact email is "dpo@crawly.com.br".

10. Updates and Governing Law

This Privacy Policy was updated on 08/23/2023 and may undergo updates. If this occurs, the Visitor will be informed about general changes through a notice on the site or via email.

If there are relevant changes that impact the privacy of Visitors or third parties, a new Privacy Policy must be accepted by Visitors.

This document is governed by and must be interpreted in accordance with the laws of the Federative Republic of Brazil. The venue for resolving any dispute arising from this Privacy and Security Policy shall be the District Court of Belo Horizonte/MG.

We value a culture of personal data protection and are therefore always open to suggestions, criticisms, and compliments.

Thank you for your trust.

THE CRAWLY TEAM