Privacy Policy

Last Revised on January 20, 2020

CITRUS SYSTEMS DESENVOLVIMENTO DE SOFTWARES E SERVIÇOS LTDA. (“Company”) respects and acknowledges the importance of your privacy and has prepared this policy (“Privacy Policy”) to explain to you how your data will be treated and for which purposes they will be used. In case you do not agree with the terms of this Privacy Policy, we recommend that you do not access or register in our website Fluxonaut (“Website”) and that you do not download, install, access or use our online platform “(Platform”).

Below you will find an explanation on how we use your personal information, addressing specific questions on your privacy and security. If you have any doubts, please contact us by email at contact@fluxonaut.com.

1. GATHERING OF DATA

The Platform offers its users the possibility to choose, select and organize viewing of content published by third-party sites, social networks and third-party applications. The Website offers information on the Company and its activities and an area to download the Platform. When you visit the Website and use the Platform, we collect certain Personal Data obtained as follows:

Information supplied by you. To use the Platform, you will need to register on our Website, at which time we will collect and treat certain personal identification information such as your name, date of birth, gender and electronic address. To better protect your privacy, you should not supply us with any personal data not specifically requested. We are not liable for incorrect or unduly submitted information.

Information on Website browsing and Platform use. During your visit, we use cookies and other technology tools to collect information about your computer. Cookies are small text files sent to your device to temporarily store your visit data on a website. This information is obtained without your direct supply and may contain information such as the type of language of your browser, operating system, IP (Internet Protocol) address, which websites were accessed, Platform usage frequency or the types of information involved, among others

Geolocation information. Whenever you use the Platform, we will collect information on your location, which will help us to offer our services in a more tailored and directed manner. We may determine your location by means of data on your device sensor and IP address.

Third-party applications authentication. When using the Platform, we will provide the possibility of authenticating with third-party applications (such as YouTube, Twitter, or other social networks, sites and services) to allow you to visualize your data and help you discover content in the Platform. We perform this via fully compliant and secure authentication methods required by each application and only store the information permitted by them, namely the authentication tokens and basic information such as name, username and e-mail (when available or relevant). We do not store passwords or other personal data from these sources. The imported data from these applications will only help you improve your experience inside Fluxonaut and is not stored in our database, only presented at the moment you request them

Financial information. Even though the Platform may be used free of charge during the Preliminary Period, the Free Use Period (as defined in the Terms of Use) and under the terms of certain access keys, ordinary Platform use and access to third-party additional content (“add-ons”) is paid. When you opt for a payment plan or subscribe to the use of an add-on, we will request personal (such as date of birth, taxpayer registration number (CPF), full name as stated in the credit card) and banking data (credit card number, safety digits) necessary to bill the plan and add-on chosen. This request is made not only for collection purposes, but also to prevent potential fraud. The collection and treatment of the data may be made directly by us or by a payment means company.

2. USE OF DATA AND INFORMATION

The list below mentions all the uses we make of your data. When visiting the Website or using the Platform, you expressly, consciously and willingly accept that your Personal Data may be treated for the following purposes:

(i) To direct the user to a pre-indication of macro interests upon first access to the Platform;

(ii) To allow adequate functioning and operation of our Platform and facilitate or enable your participation in the interactive resources offered in our Platform;

(iii) To allow you to visualize third-party applications information that you have previously given authorization to with the intent to facilitate your own content discovery;

(iv) To bill you for use of the Platform and any add-ons;

(v) To develop statistical analysis to understand how our services are used, improve and develop our Website and Platform, or to develop new products and services;

(vi) To comply with our legal obligations and exercise our rights, including billing and collection;

(vii) For specific and restricted internal use, such as for audits, data analysis or research;

(viii) In reply to your requests for information, products and services, including managing your account information;

(ix) To forward notices, communications, marketing offers or to offer products and services;

(x) To conduct research and development activities;

(xi) To comply with legal or regulatory orders or requests issued by a competent authority;

(xii) To carry out activities or transactions in your legitimate interests; and

(xiii) For any other purposes, subject to your consent.

We may combine data collected from multiple contexts, always in a legitimate manner, according to the purposes listed above and only when authorized by law.

In case of merger, sale or corporate reorganization, your Personal Data may be transferred to the companies directly involved in these transactions, provided the same confidentiality conditions currently established are maintained.

Your Personal Data will be used solely for the purposes of the Website and the Platform. We do not sell, share or disclose personal information to third parties, except subject to the following.

Exceptionally, some sharing may become necessary either to comply with legal or administrative determinations, to meet requests by a competent public or governmental authority (regardless of the country of origin), during a court or administrative suit, or for any other public interest purposes when disclosure of the information is considered necessary or appropriate.

In the event of any such atypical sharing of personal information, you, the User, will be duly informed. If necessary, based on legislation applicable to the matter, we will request your prior consent before an atypical sharing of your Personal Data with third parties. We will also inform, whenever required by applicable legislation, the purposes, manner of duration of treatment, who is the third party with whom the data will be shared and the liability of those involved, and other requirements that may be made by law or competent authority.

3. KNOWLEDGE, AMENDMENT AND EXCLUSION OF PERSONAL DATA

As holder of your personal data, you have the right to obtain facilitated access to information on the treatment of your Personal Data and may, at any time, request from us information on:

The specific purposes for which we are treating your data;

The manner and duration of a data treatment operation, observing legal restrictions; and

How we make shared use of your Personal Data and for which purposes.

You may also:

at any time, request rectification or correction of your Personal Data in our Database;

at any time, revoke – should you have supplied it – your consent to the treatment of your Personal Data;

upon closing your account, request deletion of your Personal Data from our Database.

Whenever permitted by law and respecting legal requirements, we will comply with your request to obtain further information or to rectify, correct or delete your Personal Data from our Database.

To exercise any of your rights or to request further information, please send an email to contact@fluxonaut.com.

4. STORAGE OF DATA AND INFORMATION; INFORMATION SECURITY

All data and information you supply will be incorporated into a database (“Database”) in a secure, encrypted environment, with due regard for the available state of the art and best market practices. Our administrative, technical and physical controls were conceived to protect your Personal Data against illegal uses and unauthorized disclosure and your Personal Data will be accessed only by persons trained and authorized by us.

In order to mitigate potential attacks and/or leaks, we highlight the following measures:

The Platform uses intermediate code obfuscation methods in order to hinder reverse engineering.

All access to our servers is made through proprietary APIs* and requires use of authenticated tokens, there being no external direct access to our databases.

All data are encrypted (SSL* certificates used)

All chat messages are encrypted. Encryption key access is restricted to persons trained and authorized by us. However, our chat does not use end-to-end encryption, i.e., the content of the messages may be accessed either at the request of authorities or automatically to detect inappropriate content.

In case of corporate accounts, the contracting company will have access to the encryption key to its users’ chat history, enabling the contracting company to access chat contents in accordance with its internal policies.

Should there be a leak or hacking incident, we will notify our users of the fact and of the information potentially affected. This notice will only be made after full analysis of the incident.

Given no security system is entirely foolproof, we refuse any liability for damage and/or losses arising from failure, virus or hacking of the database or of the Application

5. COMMUNICATIONS

We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt our of receiving any, or all, of the these communications from us by following the unsubscribe link or instructions in any email we send.

6. CHANGES TO THE PRIVACY POLICY

From time to time, this Privacy Policy may be updated by us to reflect new or different privacy practices. In the case of any substantial change to this Policy, we will notify our users by email and publish the information in our blog. Depending on the amendments made to this Policy, we will request your consent in case any change demands it necessary or advisable.

If any item of this Privacy Policy is considered in breach of applicable legislation, its nullity will not affect the remaining terms of the Policy, which will remain in effect