Privacy Policy
Sentimonitor Privacy and Data Use Policy
Updated on June 11, 2023
This document is intended to inform our customers or potential customers of our Monitoring Platform, internet users who access our Site (“Site”) and users of the social networks monitored by Sentimonitor, collectively referred to as data subjects (“Data Subjects”) about the Terms of Use of Our Monitoring Platform, and about the collection, use and non-sharing of their data, of in accordance with the Brazilian Federal Law No. 13.709/2018 (“Lei Geral de Proteção de Dados Pessoais”, “LGPD”).
Sentimonitor built and operates the Sentimonitor web tool (“Monitoring Platform”), which offers its customers with a signed and valid software licensing agreement, monitoring services on social networks of profiles owned or managed by the customer, or of their interest, as well as “posts” and comments that mention the client, names, brands, events or subjects of their interest.
Applicability. This policy is applicable to all persons who may access our Sites, as well as the Monitoring Platform and may be applicable to other forms of data collection by Sentimonitor, which allow the licensing of the software, as well as any provision of services or provision of products or content.
Acceptance. By using the Monitoring Platform or our Sites, the customer certifies that he has read, understood and accepts this document, in addition to agreeing to be bound by it. If you do not agree (or cannot comply) with this document, you may not use our Sites or our Monitoring Platform, or access any of its contents.
Additional documents. Some services offered by Sentimonitor may be subject to additional terms and conditions specified by Sentimonitor or third parties from time to time, which will be incorporated into this Privacy Notice.
2. WHEN WE COLLECT YOUR PERSONAL DATA
We may collect data directly from the Owner when you use our Sites and our Monitoring Platform, indirectly through public databases or third parties, partners or not, or even posts and comments on social networks, websites or blogs whose subject is of interest to our client.
User Supplied Data. When the Owner registers on the Monitoring Platform, accesses any of our products or services or participates in events, campaigns and promotions, their data will be subject to treatment, including the following uses:
- Use of all the features of the Monitoring Platform with a good browsing experience.
- Customer support request or other form of communication with Sentimonitor.
- Access to support channels.
- Registration in campaigns, blogs, promotion forms.
- Participation in surveys and events.
- Receipt of any information, notice of promotions, content updates or news.
- Storage.
- Contests, promotions, sweepstakes.
Public data. Sentimonitor may also collect data and information about you that is publicly available or made public by you, including data and information about mentions or interactions with our Monitoring Platform.
Public data. Sentimonitor may also collect data and information about Owners that are publicly available or made public, including data and information about mentions or interactions captured by our Monitoring Platform.
Data provided by third parties. We may receive Owner information from third parties, such as affiliated companies, advertising partners, security and quality service providers.
Data Collected Automatically. Eventually, we may also automatically collect data from the electronic devices used by the Owner to access our Site, for example, in order to improve your browsing experience. Some of this data may be collected using cookies or similar technologies, as explained below.
Agreement. When using the Monitoring Platform or the Site, the Owner is aware of the collection and use of data necessary for the use of the tool. The data of data subjects collected by Sentimonitor are only used to allow the operation and access by the Owner of the tool. This data will not be shared by Sentimonitor with any person, organization or entity outside the customer and Sentimonitor itself, unless required by law.
3. WHAT PERSONAL DATA WE COLLECT FROM YOU
Data types. For each operation on Sentimonitor carried out by a Owner, information is collected about the operation carried out including, but not limited to:
- Main identifying information: such as name, date of birth, RG, CPF, CNPJ, corporate name, profession, position, company you work for, among others with particular relevance;
- Information to help us contact you: such as home and/or business address, zip code, landline or cell phone and personal and/or professional e-mails;
- Your Sentimonitor account information: such as username, password, email address, country/region. This data is used by Sentimonitor to identify each Owner and, eventually, to send messages and alerts intrinsic to the operation of Sentimonitor;
- Purchase and registration information: data arising from purchases of products and services that the Owner may have made with us, such as the shipping or invoice address, invoice history containing an overview of the products or services purchased;
- Customer Service Information: including data such as call history and recording, purchase history and content of requests that the Owner has made to us;
- Behavioral information: to ensure an improvement in our services and processes, navigation and system usage history;
- Attributes associated with the Owner’s electronic devices: such as access provider, operating system, browser (type, version, enabled options and installed plug-ins), video settings (size/resolution and number of colors), date and time of access and pages viewed through cookies;
- Navigation data: internet protocol (IP), browser type, Internet service provider, referring/exit page URLs, operating system, date/time, searched information, locale and language preferences, identification numbers associated with devices, service provider cell phone and system configuration information;
- Information from third parties: from public databases or not, including information from the API of social networks and credit bureaus, which present registration, behavioral and financial data; and
- General data: content sent by the Owner to Sentimonitor freely and spontaneously and that may be collected through online chat, email, publications on blogs and websites, applications or any other tool that the Owner uses to send content to our servers.
4. WHAT WE USE YOUR PERSONAL DATA FOR
The personal data we collect is used for the following purposes:
4.1. Fulfill the Purpose for which the Data Was Provided
The purpose and legal basis for Sentimonitor to collect and use personal data depend on the personal data in question and the specific context in which Sentimonitor collects it. We process personal data to meet the purpose for which it was provided to Sentimonitor or for other purposes compatible with these and informed at the time of data collection. Normally, Sentimonitor will collect the Owner's personal data when it is needed to perform a contract (for example, to provide the services).
We may also process personal data for the establishment of a contractual bond or for the management, administration, provision, expansion and improvement of products, services, as well as the Monitoring Platform, adapting them to the Owner's preferences. For example, we may process data when contacting our service channels, including to obtain information about our products or for feedback.
4.2. Comply with Our Legal or Regulatory Obligations
We may use personal data to comply with our obligations imposed by law, regulations by government authorities, tax authorities, the Judiciary and/or other competent authority. This treatment may include complete qualification data, personal documents, bank information and sensitive personal data. If we ask the Owner to provide personal data to comply with a legal requirement or make contact, we will make every effort to make it clear at the appropriate time and inform you whether the provision of the Owner's personal data is mandatory or not (as well as the possible consequences in the event of the Owner does not provide his personal data).
4.3. Enable Activities of Our Legitimate Interest
Based on our legitimate interest, we may also process personal data to enable our communication and marketing activities, improvements to our products and services and relationships with our customers and partners, always observing the limits of your expectations and never to the detriment of the rights of the Owner or fundamental freedoms. To customize our services, we will be able to associate the Owner with information provided by him or by third parties, through inferences about topics in which he may be interested and to customize the content that we show on our Monitoring Platform, including in advertisements. Personal data and other information collected may also be used for advertising purposes, such as sending information about brands, products, promotions and discounts, for publicizing events or for carrying out surveys.
Sentimonitor occasionally connects personal data to information collected in its log files as necessary to improve the Site and Services. In that case, Sentimonitor will treat the information combined in accordance with this Privacy Notice as changed, as with most websites and services provided over the Internet.
4.4. Avoid Fraud and Ensure Your Security
Taking care of your safety (and that of third parties), we may also process personal data to control access to our facilities and prevent identification fraud in this access. To operate our services, we use certain personal data, in particular log and navigation data, to enable safe, reliable and robust performance, as well as the security of accounts and proper authentication methods.
4.5. Executing a Contract You Have Entered into With Us, or Performing Pre-Contractual Due Diligence
For example, if someone, institution or company chooses to contract one of our services or purchase one of our products, we may process personal data to price the value of this service, provide you with the necessary assistance with our products, among others.
4.6. Allow Regular Exercise of Our Rights
Finally, even after the end of your relationship with us, we may process some of your personal data to comply with our legal or regulatory obligations, or even to exercise our rights guaranteed by law, including as evidence in judicial, administrative or arbitration proceedings.
5. DATA SHARING
Third Party Services. Personal data and information may be shared with service providers, always subject to the obligations consistent with this Privacy Notice, such as companies providing technological and operational infrastructure, customer service companies, service communication companies, payment intermediary companies and companies and information storage service providers and other partners necessary for the complete activity of Sentimonitor. This sharing is essential so that the Owner can better use our services.
Third-party APIs. Sentimonitor collects information from major social networks and optionally interacts with them using the provided APIs. When necessary, customers are asked for authorization to access profiles, pages or channels managed by each customer. Access to these APIs, and the use of data provided by them is subject to the Terms of Use and Privacy Policies of each network, and social media users agree that, when accessing data from social networks (such as Facebook, Instagram, Twitter, YouTube, Tiktok, etc.) through Sentimonitor are additionally subject to the Terms of Service and Use of each of the networks used:
- the Facebook Terms of Service, available at https://www.facebook.com/terms;
- the Instagram Terms of Service, available at https://help.instagram.com/478745558852511;
- the Twitter Terms of Service, available at https://twitter.com/tos;
- the YouTube Terms of Service, available at https://www.youtube.com/t/terms;
- Google's Privacy Policy, available at https://policies.google.com/privacy;
- any terms of service and privacy policies of websites and social networks that you manage, monitor or access through SENTIMONITOR.
The Owner may revoke access to these personal accounts directly in the connected services, although this may impair or make monitoring of the corresponding network unfeasible. Instructions for revocation in each network can be obtained from:
- Facebook: https://www.facebook.com/help/211829542181913;
- Instagram: https://www.facebook.com/help/instagram/536741816349927;
- Twitter: https://help.twitter.com/managing-your-account/connect-or-revoke-access-to-third-party-apps;
- YouTube: https://security.google.com/settings/security/permissions.
Adverts. When using our Sites and our Monitoring Platform, you must agree that Sentimonitor and its partners may use part of the personal data to make ads available that we consider relevant to the Owner and his interests on the Monitoring Platform or in connection with the display of content. In order to provide more customized and effective advertisements, our partners may share some of your personal information with us, in particular navigation, location and interest data, allowing us to combine them with personal data already collected. Revenue from advertising allows Sentimonitor to continuously improve its services.
Other shares. We may use and share personal data or other security data if we believe it is reasonably necessary to:
- Comply with a legal or regulatory obligation, including a court order or a request from administrative authorities that have legal competence for such a request.
- Execute the regular exercise of Sentimonitor's rights, including protection of interests from Sentimonitor in any type of conflict, including lawsuits.
- Execute cases of transactions and corporate changes involving Sentimonitor, in which case the transfer of information will be necessary for the continuity of services and use of the Monitoring Platform.
6. INTERNATIONAL TRANSFER OF YOUR PERSONAL DATA
Your data may be shared with third parties outside Brazil, in particular, data processing and storage infrastructure providers.
In the event of data transfer outside Brazil,we will give preference for this international transfer to occur to countries that have a level of security similar to that provided for by Brazilian law, or when the National Data Protection Authority so authorizes. If this is not possible, we will use appropriate contractual clauses and prior audits, with the purpose of ensuring that third parties who receive your personal data observe the standards of protection required by Brazilian law.
7. USE OF COOKIES
7.1 DEFINITION OF COOKIES
Cookies are files or information that can be stored on the devices of data subjects when they browse the Sentimonitor Site or its Monitoring Platform.
7.2 USE OF COOKIES
We use three types of cookies:
- Functional cookies, to enable and customize features on our websites;
- Statistical cookies, to measure the audience on our website;
- Marketing cookies, to provide targeted marketing support, from third parties.
7.3 REFUSAL OF COOKIES
Your browser can be configured to inform the user about the presence of cookies, and even to refuse them. It is therefore up to the Owner to configure their browsers to refuse cookies, although this may compromise the quality of the experience or even make access to all or part of Sentimonitor's websites unfeasible.
8. SECURITY
Sentimonitor will store information and personal data collected on its Monitoring Platform on its own servers or those contracted by it, using reasonable market means and legally required to preserve the privacy and security of information, such as:
- Standard and industry methods for encrypting and anonymizing data.
- Protection against unauthorized access to your systems.
- Restricted access to previously authorized persons to the location where the collected data and information are stored.
- Commitment and absolute secrecy by the people who have access to data and information.
Caveats. It is important to know that no website is completely secure. Sentimonitor cannot fully guarantee that all information that travels on the Monitoring Platform is not the target of unauthorized access through methods developed to improperly obtain information. For this reason, we encourage all data subjects to take appropriate measures to protect themselves, as far as they are concerned, such as, for example, keeping all usernames and passwords confidential, as well as not transferring access data to any third party. Sentimonitor will take all appropriate measures to preserve and maintain the secrecy of personal data provided by data subjects, but will not be liable for damages arising from any violation of such measures by third parties who use public networks or the internet illegally, corrupting security systems to access user information from the Site and, consequently, of their data subjects, who, through this document, declare themselves aware of such risks.
Links to other sites. Sentimonitor may include links to other websites, including social media posts. By clicking on these links, the browser will be redirected outside the Site of the Sentimonitor system. These external websites are not operated by Sentimonitor. It is recommended that you consult the Privacy Policies of these websites.
9. RETENTION AND DELETION OF YOUR PERSONAL DATA
We will delete personal data when they are no longer necessary for the purpose stipulated for them, when the retention policy so determines or when the Owner or an authority requires it.
Data retention. Even in the event of a request for data deletion or after the end of the relationship, the minimum period for storing information on Sentimonitor users will be respected (for as long as they are customers), safeguarding the treatment requirements established when anonymizing the data. Sentimonitor may store data for an additional period of time for auditing purposes, to comply with legal or regulatory obligations, to preserve Sentimonitor's rights in any legal disputes and to observe the legal bases that justify the retention of data, such as, for example, to comply with any request from the National Data Protection Authority (ANPD).
Deletion of data. If on paper, the data will be shredded, and if stored in electronic format, the data will be destroyed using methods that make the records unrecoverable.
Account exclusion. The Owner is aware that the exclusion of essential information for the management of his access account to the Monitoring Platform will imply the termination of his access account, with consequent cancellation of his access and potential permanent loss of the data collected until then, in case the Owner has not analyzed and/or extracted them in a timely manner.
Request for deletion of personal data
- In the case of data from our customers and their employees, it is sufficient for the customer or attendant, who is no longer using our tools, to request the total deletion of their data by sending an email with a title entitled "To the DPO: Deletion of Data" to sup@sentimonitor.com. This operation will only be performed if there is no legal impediment to its performance.
- In the case of data from internet users, the interested party must confirm their identity and ownership of the profile or public data by sending an email to sup@sentimonitor.com, titled "To the DPO: Deletion of Data" and proceed with the request. This operation will only be carried out if there is no legal impediment to its performance nor if there is a legal possibility for Sentimonitor to keep such data.
11. PERSONAL DATA Owner RIGHTS
Owner's Rights:
- Know if we process any of your personal data;
- Know which personal data of yours are processed by us;
- Update incomplete, inaccurate or outdated data, by the means required by specific regulations, when necessary;
- Request the anonymization, blocking or deletion of data that is unnecessary, excessive or that may have been treated in violation of the law;
- Request data portability from another service or product provider, if this is expressly done;
- Request the deletion of the data processed with the consent of the Owner;
- If the Owner's consent is required for the use of their personal data, in accordance with the provisions of the applicable law, it will be collected electronically, at which time the procedures and purposes will be informed. The Owner has the option not to offer it, as well as to revoke it. This revocation may result in the impossibility of using or accessing functionalities of Sentimonitor's systems and services. It is important that the Owner is aware that the revocation of his consent does not mean that the personal data will be eliminated, in view of the possibility of authorized conservation of the data for the purposes set out in the applicable law.
Non-compliance with request. In specific cases, it is possible that the request is not met. In these cases, we will explain the reasons that justified the non-attendance. For example, requests involving personal data and/or documents of other data subjects will not be met, except by means of a power of attorney, parental authority or another hypothesis that authorizes the exercise of the right of another subject by another person.
Identity confirmation. For security reasons, we request specific information from the Owner to confirm your identity and guarantee your right to access, modify or delete your personal data.
12. DATA PROCESSED ON BEHALF OF OUR CUSTOMERS
Data processed on behalf of a customer is only available to that customer and is not shared, sold or otherwise made available to other customers or third parties.
13. UPDATES TO THE PRIVACY AND DATA USE POLICY
This Privacy Notice may be amended at any time and we will use our best efforts to inform you of updates to guarantee our commitment to transparency, giving preference to communication via the Owner's functional email.
The most current version of this Privacy Notice will always appear on the Privacy Notice page on the Sentimonitor Website and will be effective immediately upon posting, even if updates are not yet reflected in a signed agreement.
14. Contact with the Data Protection Officer - DPO
The Sentimonitor Owner can exercise several of their rights through the personal information section of their account on the Monitoring Platform.
If you do not have an account on the Monitoring Platform or if you prefer to do so, you can make a direct request to our representative appointed in accordance with applicable law for the purpose of dealing with personal data protection questions or requests in Brazil by sending an email with title "Contact with DPO Sentimonitor" to sup@sentimonitor.com.
¹This document applies to ARTIFICIAL INTELLIGENCE ENGINEERS DESENVOLVIMENTO DE SOFTWARE LTDA, registered with the CNPJ under number 10.477.642/0001-30, headquartered in the city of Porto Alegre - RS, at Rua Brito Peixoto, 184, Passo da Areia, CEP 91.030-400.