Privacy policy - GDPR

Responsible party pursuant to data protection laws, in particular the EU General Data Protection Regulation (GDPR), is C SANTOS DE OLIVEIRA DESENVOLVIMENTO DE SOFTWARE (CALSOFT), a private law legal entity, registered with the CNPJ/MF under number 36.359.868/0001-20, headquartered at R MAJOR LARA RIBAS 72 - BELA VISTA, PALHOCA/SC 88.132-789, Brazil.

Your rights as the data subject

You have the following rights regarding your personal data:

  • Information about the data stored by us and its processing (Art. 15 GDPR),
  • Rectification of inaccurate personal data (Art. 16 GDPR),
  • Deletion of your data stored by us (Art. 17 GDPR),
  • Restriction of data processing, provided that we cannot delete your data due to legal obligations (Art. 18 GDPR),
  • Objection to the processing of your data (Art. 21 GDPR),
  • Data portability, provided you have consented to the processing of your data or entered into a contract with us (Art. 20 GDPR).

If you have given us consent, you may withdraw it at any time, with effect for the future.

You can contact a supervisory authority with a complaint at any time, such as the supervisory authority of your state of residence or the authority overseeing us as the responsible party.

For a list of supervisory authorities, please visit: https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html.

Collecting General Information During a Visit to Our Website

When you visit our website without registering or submitting any information, general data will be automatically collected (server log files), including the type of web browser, operating system, domain name of your internet service provider, IP address, and similar data.

Purpose of Processing

  • Ensuring seamless website connection and functionality,
  • Analyzing system security and stability,
  • Administrative purposes.

Legal Basis

This data processing is based on our legitimate interest in improving the stability and functionality of our website (Art. 6 Para. 1 (f) GDPR).

Recipients

Technical service providers working on the operation and maintenance of our website may be recipients.

Retention Period

Data will be deleted once no longer necessary for the stated purposes, typically after the session ends.

Location Data

We collect precise or approximate location data when the user is logged into the mobile app for Android and iOS. APREPARA/ISHPIA collects this data when the app is running in the foreground (open and on the screen) or in the background (open but off the screen) on the user's mobile device.

The use of approximate or precise location data is utilized for:

  • Tracking the start and end locations of activities,
  • Displaying the last known location on a map for the manager,
  • Monitoring presence status and connection to the cloud,
  • Calculating distances between two points.

Background location tracking can be disabled by the account holder or scheduled for specific times. It is the account holder's responsibility to maintain and configure the background data collection.

Mobile app users can use the apps without enabling location data collection on their devices. However, this may impact certain features of the APREPARA/ISHPIA apps. For example, when location data collection is disabled, the manager will not be able to track the last location of the activity. Additionally, location data collected during usage is linked to the user's account, even if they have not enabled location data collection on their device, including for purposes such as generating receipts, customer support, fraud detection, insurance, and legal disputes.

Before disclosing personal information about another person, you must obtain their consent for the disclosure and processing of their personal information in accordance with this policy.

Retention and Use of Location Data

The location data is linked to the user account and may be used for purposes such as generating receipts, customer support, fraud detection, insurance, and legal disputes.

Users may choose to use our mobile apps without enabling location data collection, but this may limit certain app features, such as real-time tracking of the user's location by the manager.

Legal Basis

The collection and use of location data is based on user consent (Art. 6 Para. 1 (a) GDPR). Users can withdraw their consent to location data collection at any time.

Cookies

We use cookies to collect precise or approximate location data when the user is logged into the app. This location data is collected both in the foreground (when the app is open) and in the background (when the app is open but not on the screen).

Cookies are used to enhance user experience on our website.

We collect data such as IP address, browser type, and operating system.

In your browser settings, you can delete individual cookies or the entire set of cookies. You will also find information and instructions on how to delete these cookies or prevent them from being saved in advance. The following links provide the information you’ll need for the respective browser providers:

  1. Mozilla Firefox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
  2. Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
  3. Google Chrome: https://support.google.com/accounts/answer/61416?hl=en
  4. Opera: https://www.opera.com/o/ie-simple
  5. Safari: https://support.apple.com/kb/PH17191?locale=de_DE&viewlocale=en_US

Registration on our system

With the registration to use our personalised services, some personal data such as name, address, contact and communication information (e.g. phone number and e-mail address) are collected. If you are registered with us, you can access content and services that we only offer to registered users. Registered users also have the ability to change or delete the data entered during registration at any time. At any time, we will also provide you with information on the personal data about you that we have saved.

Newsletter

We will only use your data to send newsletters that you have subscribed to via email. We collect your name to address you personally in the newsletter.

Legal Basis

Your express consent (Art. 6 (1) (a) GDPR) allows us to send you newsletters.

You can unsubscribe at any time by following the instructions in the newsletter or by contacting us directly.

Contact form

We collect data you provide in the contact form to communicate with you effectively. A valid email address and your name are required for this communication. Additional information is optional.

Legal Basis

The processing is based on a legitimate interest (Art. 6 Para. 1 (f) GDPR) or to fulfill pre-contractual measures (Art. 6 Para. 1 (b) GDPR).

Using Google Analytics

We use Google Analytics to analyze website usage. Google Analytics uses cookies to collect data, which is typically sent to and stored on Google servers in the U.S. We use this data to evaluate website usage, generate activity reports, and provide other related services.

Legal Basis

Data processing is based on user consent (Art. 6 Para. 1 (a) GDPR).

Third Country Transfers

Google processes data in the U.S. under the EU-U.S. Data Privacy Framework (approved by the European Commission on 10 July 2023, pursuant to Art. 45 GDPR), which provides an adequate level of protection for personal data transferred from the EU to participating U.S. organizations.

Using Google Maps

We use Google Maps to provide interactive maps on our website. Your location data is shared with Google for this feature.

Legal Basis

Your consent is the legal basis for integrating Google Maps and transferring data to Google (Art. 6 Para. 1 (a) GDPR).

Third Country Transfers

Google processes data in the U.S. under the EU-U.S. Data Privacy Framework (approved by the European Commission on 10 July 2023, pursuant to Art. 45 GDPR).

Using Firebase (FCM, Authentication, Crashlytics)

We use several Firebase services provided by Google LLC for the operation of our mobile application:

  • Firebase Cloud Messaging (FCM) — push notifications sent to mobile devices;
  • Firebase Authentication — social login (Google, Microsoft) — not yet enabled; activation planned;
  • Firebase Crashlytics — crash reporting and diagnostics for app stability;
  • Firebase Realtime Database — real-time data synchronization for certain app features.

Legal Basis

Processing is based on our legitimate interest in providing a stable, functional mobile application (Art. 6 Para. 1 (f) GDPR), and on user consent for social authentication (Art. 6 Para. 1 (a) GDPR).

Third Country Transfers

Firebase is operated by Google LLC and processes data in the U.S. under the EU-U.S. Data Privacy Framework (approved by the European Commission on 10 July 2023, pursuant to Art. 45 GDPR).

Using Google reCAPTCHA and Play Integrity API

We use Google reCAPTCHA on the web panel to protect against automated abuse and bots. On Android devices, we use the Play Integrity API to verify the integrity of the mobile application and device.

Legal Basis

Processing is based on our legitimate interest in security and fraud prevention (Art. 6 Para. 1 (f) GDPR).

Third Country Transfers

These services are provided by Google LLC and data is processed in the U.S. under the EU-U.S. Data Privacy Framework (Art. 45 GDPR).

Using Mailgun / Sinch for Transactional Email

We use Mailgun (operated by Sinch) to deliver transactional emails, including notifications, billing reminders, and service communications.

Legal Basis

Processing is based on the execution of the contract (Art. 6 Para. 1 (b) GDPR) and our legitimate interest in communicating with users about service-related matters (Art. 6 Para. 1 (f) GDPR).

Third Country Transfers

Mailgun / Sinch processes data in the U.S. under Standard Contractual Clauses (SCCs) and in compliance with GDPR.

Using Atlassian (Jira Service Management)

We use Atlassian Jira Service Management as our customer support platform. When you open a support ticket, you create a separate account on Atlassian's platform and interact with us through it. Your name, email address, and any information you include in support tickets are processed by Atlassian.

Legal Basis

Processing is based on the execution of the contract (Art. 6 Para. 1 (b) GDPR) for support-related communications.

Third Country Transfers

Atlassian Pty Ltd is headquartered in Australia and processes data in the U.S. and EU under Standard Contractual Clauses (SCCs) and in compliance with GDPR. Atlassian's privacy policy is available at atlassian.com/legal/privacy-policy.

National Sub-processors (Brazil)

The following service providers based in Brazil also access personal data in the course of services provided:

  • Banco Inter S.A. (CNPJ 00.416.968/0001-01) — processing of bank slip payments (boletos bancários) and billing;
  • IPM Sistemas Ltda. / Municipality of Palhoça/SC — issuance of electronic service invoices (NFS-e) for Brazilian clients duly registered with a CNPJ or CPF.

As these providers are located in Brazil, no international data transfer occurs for these services.

SSL encryption

We use SSL encryption (HTTPS) to secure your data during transmission.

Data Retention After Account Cancellation

After account cancellation, personal data is retained as follows:

  • Account and user data (name, email, contact details): deleted within 90 days after cancellation;
  • Location data (GPS records from the mobile app): deleted within 90 days after cancellation;
  • Billing and fiscal records (invoices, electronic tax receipts): retained for 5 years to comply with Brazilian tax law obligations;
  • Access logs: retained for up to 6 months, as required by Brazilian Internet Act (Law 12.965/2014).

During the 60-day period after cancellation, account holders may export their operational data using the tools available in the platform. After this period, data subject to deletion will be permanently removed.

Legal Basis

Data retention is based on compliance with legal obligations (Art. 6 Para. 1 (c) GDPR) and legitimate interests (Art. 6 Para. 1 (f) GDPR) for fiscal, legal defense, and fraud prevention purposes.

Revision of our privacy policy

We reserve the right to amend this privacy policy to comply with legal requirements or to update services. Any future visits will be subject to the new policy.

Questions for the data protection officer

If you have any questions about this privacy policy, please contact us at: contato@aprepara.com

(Version: #2026-03-02).