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Legal

Privacy Policy

WGMI TECNOLOGIAS LTDA. ("WGMI", "we", "us", or "our") is committed to excellence in serving its customers and takes the privacy and security of your personal data seriously. For this reason, this Privacy Policy ("Policy") has been created to explain which Personal Data is collected and how it is processed by us.

During your browsing of our website www.8arm.io ("Platform"), and so that we can provide our services and products available on the Platform — primarily directed at payroll processing for companies and human capital management (collectively, "Services") — we need access to certain information about you (collectively, "Personal Data"). It is not possible to provide the Services without access to such Personal Data. In other words, the processing of Personal Data is a condition for using the Platform.

Access and registration of legal entities must necessarily be carried out by a duly authorized legal representative. For the purposes of this Policy, when the User is a legal entity, its legal representative will also be considered a "User", to the extent that their Personal Data is provided to and processed by WGMI. For the purposes of this Policy, "Users" are all individuals who in any way use the Platform and benefit from its Services.

By using the Services, the User declares that they will only provide true, current, and accurate Personal Data and will not misrepresent their identity in any way when accessing and using the Services.

This Policy explains, in a simple, objective, and transparent manner, which Personal Data is collected, used, and processed by us and for which purposes, in addition to identifying with whom such data may be shared and the resources available to Users for managing their Personal Data.

This Policy contains important information about the processing of your Personal Data, organized into the following sections:

  1. General Information
  2. Personal Data of minors under 18
  3. Which Personal Data we collect and process
  4. Why we collect and process this Personal Data
  5. Cookies
  6. When we delete Personal Data
  7. Who else will have access to Personal Data and for what reason(s)
  8. Your rights with respect to this Personal Data
  9. How we store and protect your Personal Data
  10. International Transfer
  11. Do you need to provide your consent for WGMI to use your Personal Data as described in this Policy?
  12. Changes to this Policy
  13. Want to talk to us?

1. General Information

WGMI protects the privacy rights of Users who register or who, in any way, browse, access, or use the Services, in accordance with applicable law and with the provisions of this Policy. Pursuant to Law No. 13.709/2019, the Brazilian General Data Protection Law ("LGPD"), WGMI will act as controller of your Personal Data in most of its processing activities.

Through this Policy, we want to give you transparency about which Personal Data we collect about you and use in the provision of the Services. We remind you that the Platform makes available to companies, our customers ("Customers"), a payroll processing service, as well as creating a directory of employee information so that reports, time tracking, and onboarding of new employees can be managed. In addition, when one of our Customers contracts the Platform, the Customer provides its employees with the ability to create specific logins and passwords for individual access to the Platform, which allows the employee to manage information related to their employment relationship. For this reason, we need to collect and use certain Personal Data to verify that the Personal Data you provide is in fact yours; to provide the Services; and so that we can communicate with you.

Therefore, Personal Data may be used, among other purposes described in this Policy, so that we may:

  • Authenticate your identity;
  • Identify you when you sign in and access the Services, as well as personalize the Services for you and your needs;
  • Communicate with you whenever necessary within the scope of the Services and for satisfaction surveys;
  • Share your Personal Data with our business partners and service providers;
  • Allow you to use the Services from your registration, as described in our Terms of Use; and
  • Offer you other products or services that may be of interest to you.

Personal Data is collected, used, and processed on the basis of different legal grounds, such as: the performance of the Services and of the terms of use to which you are a party (including preliminary procedures for the execution of such documents); compliance with legal obligations; the legitimate interests of WGMI or of third parties (provided your fundamental rights are respected) and, when necessary, on the basis of your consent. Withdrawing your consent will only require us to cease the use of Personal Data granted through consent, and we may continue to use the Personal Data, when necessary, for example, to prevent fraud and falsehood in authentications and identifications, for defense in judicial and administrative proceedings, and to comply with legal obligations, all to the extent permitted by law.

If, after reading this Policy, you still have any questions, or for any reason need to contact us about how we process your Personal Data, you may contact the WGMI Data Protection Officer through the channels below:

E-mail: privacidade@8arm.io

2. Data of minors under 18

On occasion, we may collect and process Personal Data of dependents, young apprentices, or interns who are minors. In such cases, the processing of this Personal Data will be carried out in accordance with the law and observing all specific requirements.

3. Which Personal Data do we collect and process?

The User may use the Services by registering on our Platform. WGMI receives or otherwise collects the following types of information related to Users:

A. Navigation and Device Information. Information collected through technologies such as cookies, pixels, identifiers, and others, when Users interact with the Platform, whether registered or not. This information includes:

  • Information about the mobile device or computer
  • Type of browser
  • Pages visited on the website or app
  • Visit duration
  • Site navigation paths
  • Page views
  • Geolocation
  • IP address
  • Data on browsing behavior

‍B. Account Data. Information requested from the User when opening an account on the Platform. In addition, we may also process your Personal Data when you contact us, modify your registration, or contact our support team, for example.

  • Full name
  • CPF (Brazilian tax ID)
  • E-mail address
  • Access password
  • Proof of residence
  • Personal video or image

C. Data received from Customers. We may have access to certain Personal Data through third parties, in particular our customers, who are responsible for making information related to their employees available on our Platform.

  • Full name
  • Date of birth
  • Nationality
  • Address
  • Gender
  • Marital status
  • E-mail
  • Phone number
  • Identification documents (such as RG, CPF, CNH, CTPS, PIS/PASEP)
  • Filiation (parents' names)
  • Dependent data
  • Employer company (Customer)
  • Contractual data
  • Job title at the company
  • Area and department within the company
  • Unique employee identifier at the Customer (e.g., employee number, ID, code, etc.)
  • Education information
  • Professional history
  • Pre-employment, periodic, and termination medical exams
  • Health certificates
  • Salary
  • Benefits provided by the Customer
  • Race or ethnic origin
  • Union membership
  • Data related to health and safety in the workplace
  • Health data
  • Physical, visual, hearing, or intellectual disabilities

4. Why do we collect and process this Personal Data?

WGMI uses Users' Data for the following purposes:

  • Provision of our Services in the best possible way;
  • User authentication and identification;
  • Communication with the User;
  • Verification of the authenticity of information and documents;
  • Registration and updates;
  • Sharing of Personal Data, when necessary;
  • Fraud prevention, as a means of ensuring WGMI's security;
  • Improving and enhancing the User experience;
  • Personalization of the Services according to the User's preferences;
  • Payroll processing for Customers;
  • Processing and reporting of data required for eSocial;
  • Issuance of pay stubs;
  • Generation of reports;
  • Creation of net salary payment lists and government remittance forms (DARF, social security obligations, etc.);
  • Creation of an employee directory;
  • Time tracking;
  • User experience analysis;
  • Safeguarding rights and obligations related to the use of the Services, including in judicial and administrative proceedings;
  • Compliance with legal and regulatory obligations;
  • Cooperation with and/or compliance with a court order or a request from a competent administrative authority, to the extent required by law;
  • Compliance with contractual obligations;
  • To pursue our legitimate interests, while respecting your rights provided by law;
  • Recommending WGMI Services, as well as third-party services, to the User;
  • Sending marketing content and messages with information about products or Services that may be of interest to you, including from third parties;
  • Verifying your viewing of WGMI advertising, including on third-party websites;
  • User profile analysis;
  • Statistics and studies;
  • Internal and external audits.

5. Cookies

Cookies are small data files capable of storing and recognizing information related to your browsing. During the use of the Platform, three distinct types of cookies may be employed:

  • User identification and authentication: intended to individually recognize Users, allowing access to and use of restricted content and/or services on the Platform, as well as providing personalized browsing experiences.
  • Security and detection of malicious activity: used to enable security features of the Platform, in order to help monitor and/or detect malicious activity or activity that breaches the Terms.
  • Performance and navigation analytics: intended to help us understand the performance of the Platform, evaluate audience, and analyze Users' navigation patterns on the Platform.

6. When do we delete Personal Data?

We have structured the Services and our operations so that your Personal Data is not retained in identifiable form for longer than necessary. That is, we keep Personal Data only during the period in which it is needed for the purposes described above, if there is a legal obligation requiring us to retain your Personal Data, or if it is in our legitimate interest to retain your Personal Data.

For this reason, we may retain your Personal Data, among other reasons, to comply with legal obligations, for defense in judicial and/or administrative actions, and to combat fraud. To the extent that consent is the applicable legal basis and if you wish to request the withdrawal of consent, we remind you that we may retain your Personal Data to the extent expressly provided for by law.

7. Who else will have access to Personal Data and for what reason(s)?

We may, on occasion, share your Personal Data with the third parties identified below. Any sharing of Personal Data carried out by WGMI will be done in accordance with legal provisions and, in particular, in a manner that protects your privacy.

a. Other companies in WGMI's economic group

We may share your Personal Data with other companies belonging to the same economic group as WGMI for the purposes of:

  • Marketing, prospecting, market and opinion research, and promotion of our products and services;
  • Prevention and resolution of technical or security issues; and
  • Compliance with legal or regulatory obligations.

b. Service Providers

We may share your Personal Data with our service providers for the following purposes:

  • User authentication and identification;
  • Verification of the authenticity of information and documents;
  • Prevention of risks and fraud, and ensuring security in identification and/or authentication processes;
  • Provision of the Services;
  • Sending advertising campaigns and offering Services;
  • Improvement of Services and operationalization of new products or services;
  • Prevention and resolution of technical or security issues; and
  • Support, maintenance, and customer service.

c. Third parties in case of corporate reorganization

We may share your Personal Data with third parties such as auditing firms, law firms, and potential investors in the event of corporate reorganization of WGMI.

d. Authorities and regulators

We may share your Personal Data with judicial, police, or governmental authorities, regulators, or other third parties with whom we are required by law, regulation, or court order to share Personal Data, to the extent permitted by law.

8. Your rights with respect to your Personal Data

The User has rights and guarantees with respect to their Personal Data. We provide the mechanisms detailed below so that Users have clarity and transparency in exercising their rights. Whenever necessary, our team will be ready to address any requests.

Under the LGPD, Users have the right to:

  • Obtain confirmation that we process your Personal Data. In response to such a request, we will inform you whether or not we process your Personal Data.
  • Access your Personal Data. If you wish, you may receive a report listing the Personal Data of which you are the data subject that we process.
  • Correct Personal Data that is incomplete, inaccurate, or out of date. If you believe your Personal Data is incorrect, you may request correction, indicating what needs to be changed and why. We may request supporting documentation in order to make the change.
  • Request anonymization, blocking, or deletion of Personal Data that is unnecessary, excessive, or processed in violation of the LGPD. If you believe we are processing your Personal Data in an unnecessary, excessive, or non-compliant manner, you may request that the Personal Data be anonymized, blocked, or deleted.
  • Request the portability of your Personal Data to another service or product provider, subject to our commercial and industrial secrets, after regulation by the Brazilian Data Protection Authority ("ANPD"). You are the owner of your own Personal Data. Therefore, you may request that such Personal Data be transferred to another service or product provider, in accordance with ANPD regulation, provided that commercial and industrial secrets are respected.
  • Request the deletion of Personal Data processed based on your consent, except in the cases of retention of Personal Data provided for by law. If your Data is processed based on consent, you may request the deletion of such data. However, the LGPD allows the retention of data for the purposes of complying with legal or regulatory obligations; studies by a research body, guaranteeing, where possible, anonymization; transfer to a third party; and exclusive use by the controller, provided the data is anonymized.
  • Obtain information about with whom we share your Personal Data. You may request that we inform you which entities we share your Personal Data with.
  • Obtain information about the possibility of not providing your consent and the consequences thereof. When consent is used as the legal basis for the processing of Personal Data, you have the right to be informed of the possibility of not providing consent and the consequences of refusal.
  • Withdraw your consent for the processing of your Personal Data. If your Personal Data is processed based on consent, you may withdraw such consent. Once withdrawn, any processing of your Personal Data carried out on the basis of consent will be discontinued.
  • Object to processing that violates the LGPD. If you believe we are processing your Personal Data contrary to the LGPD, you may object to such processing. The request will be carefully reviewed and, if we agree, processing of your Personal Data that is not in compliance with the LGPD will be discontinued.
  • Request the review of decisions made solely on the basis of automated processing of your Personal Data. If decisions are made based on the automated processing of your Personal Data, you may request the review of such decisions.
  • File a petition relating to your Personal Data with the ANPD. If you deem it necessary, you may file a petition relating to your Personal Data with the ANPD.

You may exercise any of the above rights by sending an e-mail to privacidade@8arm.io.

9. How do we store and protect your Personal Data

We store your Personal Data securely in restricted-access locations, for the period provided for in applicable law. We store your Personal Data in third-party data centers located in Virginia, in the United States. We currently use data center services provided by cloud computing operators such as AWS.

Before sending your Personal Data for storage in other countries, we adopt all appropriate measures, as well as those required by law, to ensure that your Personal Data remains protected at all times. We also adopt market best practices to prevent the loss or destruction of your Personal Data. In any event, no platform is fully secure. If you have any concerns or suspicions that your Personal Data is at risk, please contact us by e-mail at privacidade@8arm.io.

10. International Transfer

Your Personal Data may be transferred to other countries, for example to overseas storage service providers.

In cases where your Personal Data is transferred outside of Brazil, we will adopt all appropriate measures and those required by law to ensure that your Personal Data remains duly protected, and that such transfer is carried out in accordance with one of the mechanisms set out in the LGPD and in any other applicable regulations.

11. Do you need to provide your consent for WGMI to use your Personal Data as described in this Policy?

The LGPD sets out several situations in which the processing of Personal Data is permitted regardless of the consent of the data subject. These are the so-called "legal bases for processing."

This means that, if you choose to use the Services, in some cases we may collect and process your Personal Data regardless of your consent (if there is a "legal basis" set out in the LGPD that allows us to do so), such as for the performance of preliminary measures prior to contracting or for the performance of a contract with you, for compliance with legal and regulatory obligations, for the regular exercise of rights under a contract or in judicial, administrative, and arbitration proceedings, for credit protection, to ensure the prevention of fraud and the safety of the data subject in identification and authentication processes for registration in electronic systems, for the legitimate interests of WGMI or of third parties, among others.

Where applicable, we will request your consent to process your Personal Data. It is important to note that the withdrawal of your consent will only require us to cease the processing of Personal Data carried out exclusively on the basis of consent.

12. Changes to this Policy

We may amend the provisions of this Policy at our discretion and at any time. Whenever we substantially amend this Policy, such amendments will be effective after being: (i) published on the Platform; or (ii) sent by e-mail to the User.

The User should check the updated version of this Policy each time they visit the Platform.

13. Want to talk to us?

You may file a complaint or clarify any questions through the Service Channels listed below. You may also send a message to the ANPD, but we ask that you first try to resolve any issues directly with us, as our primary concern is to keep our Users satisfied with our Services. We will do our best to fulfill that mission through easy and attentive communication with Users.

Service Channels:

By e-mail at privacidade@8arm.io