Privacy Policy

This Privacy Policy is part of the data governance measures adopted by MOBWAY Ltd., a limited liability company, registered with CNPJ/ME under No. 45.743.737/0001-32, located at Av. Luiz Boiteux Piazza, 1302, ACATE Sapiens Parque, Bairro Canasvieiras, Florianópolis, Santa Catarina, CEP 88.054.700.

We are committed to safeguarding your privacy and protecting your data.

The purpose of this document is to ensure transparency regarding the information and data collected from users of the mobway platform.

This Privacy Policy provides information on the collection, use, storage, processing, and protection of your personal data, with the aim of demonstrating absolute transparency on the subject and clarifying to all interested parties the types of data that are collected, the reasons for their collection, and how users can manage or delete their personal data.

This document has been prepared in accordance with the General Law for the Protection of Personal Data (Law 13.709/18) and the Brazilian Civil Rights Framework for the Internet (Law 12.965/14) and may be modified as a result of any regulatory updates or at the initiative of MOBWAY.

The document is written in a simple and accessible manner, with several examples of data collection and use, precisely so that you can read and understand how we use your data to provide you with a safe and comfortable experience when using the services we offer you.

If You do not fully agree with the terms of this Privacy Policy, do not use MOBWAY's services, even those that do not require registration and are free of charge.

For your convenience, this policy is organized as follows:

Sources of personal data
Collection of personal information
Use of personal information
Disclosure of personal information
Retention of personal information
Security of your personal information
Rights of data subjects
Modifications to the Privacy Policy
How to communicate with MOBWAY about your Personal Data

1. Sources of Personal Data

The amount and type of information collected by MOBWAY will vary depending on the services we provide and the agreement we enter into.

This policy applies to personal information that we collect from or about you through the following sources:

MOBWAY's website: Websites directed to customers and prospective customers that are operated by or for MOBWAY, including websites that we operate under our own domains/URLs and mini-sites that we maintain on third-party social networks such as Facebook, LinkedIn, Instagram, and YouTube.
Public Sources: Data made publicly available by its owners, always respecting the principles of the General Data Protection Act as well as the legal bases for its collection.
Customer Contacts: We may collect personal data through direct contact with customers, in which case MOBWAY will act as the data controller.

It is also worth mentioning that we store information about all contacts already made with our users, regardless of the type of user who made the contact.

1.1 What are the legal bases for data collection?

We only use legally permitted forms of data collection, such as, but not limited to, consent and legitimate interest. When the legal basis for collection is not consent, we will always comply with applicable laws and respect the rights and individual freedoms of data subjects.

2. Collection of Personal Information

2.1 When you simply browse our website, even if you do not complete a registration form, we act as the data controller and collect the following categories and types of personal data:

Information about your computer, including your IP address, geographical location, browser type and version, and operating system;
Information about your visits to and use of this Website, including referral source, length of visit, page views and navigation paths through the Website.

2.2. In order to become a MOBWAY USER and gain access to the restricted area of the MOBWAY Platform to set up the API (Application Programming Interface), the interested party must register on the MOBWAY Platform by providing accurate and complete personal information:

CNPJ;
Mobile or telephone number;
Company address.
1. Street;
2. City;
3. State;
4. Country;
5. Postal Code.

2.4. If the data is processed as a result of services provided to customers, we will act as a mere operator and the following data may be collected:

User name;
Vehicle chassis data;

2.5. Cookies

When you access our sites and services, we collect statistical and marketing cookies. Statistical cookies, such as Google Analytics, help us understand the number of visitors and how they interact with the site by collecting and reporting information anonymously. Marketing cookies are used to track visitors in order to subsequently display relevant advertisements on third-party networks.

3. Use of Personal Information

The personal information we collect may be used to:

Administer our Site and our business;
Customize our Site for you;
Allow you to use the services available on our Site;
Provide services purchased through our site;
Provide services to our customers when acting as a data carrier;
Send you commercial and marketing communications;
Send e-mail notifications that you have specifically requested;
Send you our e-mail newsletter if you have requested it (you can inform us at any time if you no longer wish to receive the newsletter);
Send you support or service messages, such as alerts, notifications and updates.
Send you marketing communications about our business or the business of carefully selected third parties that we think may be of interest to you, where you have expressly agreed to this, by email or similar technology (you can tell us at any time if you no longer wish to receive marketing communications);
To provide third parties with statistical information about our users (but these third parties will not be able to identify individual users from this information);
To respond to inquiries and complaints made by or about you in connection with our site;
Maintain the security of our site and prevent fraud;
Verify compliance with the terms and conditions governing the use of our site (including monitoring private messages sent through our site's private messaging service);
Communicate with you about products, services, promotions, news, updates, events and other matters that may be of interest to you;
Deliver targeted advertising based on your preferences, interests and other information collected.

The email information collected from you will be shared with our marketing team to send you content and news about our services. You may request to change these preferences at any time through our Privacy Channel at info@mobway.cloud.

4. Disclosure of Personal Information

MOBWAY may disclose your personal information only to its employees, officers, insurers, professional advisors, agents, suppliers or subcontractors:

To the extent it is required to do so by law;
In connection with any current or potential legal process;
To establish, exercise or defend legal rights (including providing information to third parties for fraud prevention and credit risk reduction purposes);
In other cases where the law requires us to disclose.

5. Retention of Personal Data

MOBWAY may retain your personal information only for as long as necessary to fulfill the purposes for which we collected it, including to comply with any legal or contractual obligations or requests from competent authorities.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes by other means, and applicable legal requirements.

If you use our products and services, your account information will be retained for as long as you maintain an active account. If you request cancellation, your information will be deleted.

Notwithstanding the other provisions of this section, we will retain documents (including electronic documents) that contain personal information:

To the extent we are required to do so by law or contract;
If we believe that the documents may be relevant to a current or potential legal proceeding;
To establish, exercise or defend our legal rights (including providing information to third parties for fraud prevention and credit risk reduction purposes).

6. Security of your personal information

We work daily to protect your privacy and maintain the security of your Data. We adopt the appropriate security practices for our market, using encryption techniques, access control, records management and other applicable information security measures.

However, unfortunately, we cannot guarantee total security. Unauthorized account access or use, hardware or software failures, and other factors could compromise the security of your personal information at any time. So please help us maintain a safe environment for everyone.

In addition to adopting good security practices in relation to your account and your Data (such as not sharing your password with third parties), if you identify or become aware of anything that compromises the security of your Data, please contact us at info@mobway.cloud.

If you have an account on our Services, it is protected by a password. You must prevent and avoid unauthorized access to your account and personal information by choosing and protecting your password or other connection mechanism, and limiting access to your computer or device and browser by logging out when you are finished accessing your account.

7. Data subjects' rights

You can always choose not to disclose your data to us, but keep in mind that some of this data may be necessary in order to register on our platforms or use some of our features and products that we offer you.

Regardless of this, you always have rights regarding the privacy and protection of your personal information, and we are concerned not only with the security of that information, but also with your access to and knowledge of all of your rights regarding personal information.

You may instruct us to provide you with any personal information we hold about you; the provision of such information will be subject to the provision of appropriate evidence of your identity.

For this purpose; we will generally accept a certified copy of your official identity document. We may retain the personal information requested to the extent permitted by law. Accordingly, below we summarize all the rights you have under the General Data Protection Act (LGPD), which are:

Right of access;
Right of rectification;
Right to erasure;
Right to confirmation of the existence of processing;
Right to request blocking or deletion;
Right to information from public or private entities;
Right to restrict processing;
Right to review an automated decision;
Right to object to processing;
Right to an explanation of the logic behind the collection of your data;
Right to information about the possibility of not giving consent and the consequences of not giving consent;
The right to withdraw consent.

Below is a brief explanation and examples of some of these rights:

Access to your personal data. This right allows you to request and receive a copy of the personal information we hold about you.
Request rectification of your personal data held by MOBWAY. This right allows you, at any time, to request the correction and/or rectification of your personal data if you discover that some of them are incorrect. However, in order to carry out this correction, we need to verify the validity of the data you have provided us with.
Request deletion of your personal data. This right allows you to ask us to delete your personal data from our platform. All data collected will be deleted from our servers when you so request or when it is no longer necessary or relevant for us to offer you our services, unless there is any other reason for retaining it, such as any legal obligation to retain data or the need to preserve it to protect MOBWAY's rights.
Right to object to data processing. When we are relying on a legitimate interest (or that of a third party) and there is something about your specific situation that makes you want to object to processing in this field, as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes, for example. In some cases, we can demonstrate that we have legitimate grounds for processing your data which override your rights, as in these cases they may be essential for the provision of the product and/or service.
Right to request blocking or erasure. This right allows you to ask us to stop processing your personal data in the following cases: (a) if you want us to establish the accuracy of the data; (b) if we need to keep the data even if we no longer need it for the establishment, exercise or defense of legal claims; or (c) if you have objected to the use of your data, but in this case we need to verify whether we have legitimate grounds for using it.
Restrict the processing of your personal data. This right allows you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the accuracy of the data; (b) when you need us to keep the data even if we no longer need it, as necessary to establish, exercise or defend legal claims; or (c) you have objected to the use of your data, but we need to verify whether we have legitimate grounds to use it.
Right to withdraw consent at any time. You have the right to withdraw your consent, however, this will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide you with certain products. And if this is the case, we will notify you at the time this occurs.
Right to review automated decisions. You also have the right to request a review of decisions taken solely on the basis of automated processing of your personal data that affect your interests.

We may need to request specific information from you to help us confirm your identity and guarantee your right to access your personal data (or to exercise your other rights). This is a security measure to ensure that personal data is not disclosed to anyone who has no right to receive it. We may also contact you for further information in relation to your request in order to speed up our response.

8. Changes to the Privacy Policy

As we strive to improve our services and offer new features, this Privacy Policy may be updated.

Any changes to our Privacy Policy will be widely posted and communicated to you.

9. How to communicate with MOBWAY about your Personal Data

If you believe that your Data has been used in a manner inconsistent with this Privacy Policy or if you have any other questions, suggestions or comments regarding this Policy, please contact us at info@mobway.cloud.

we are committed to protecting your privacy