Privacy Policy

mLabs is committed to your privacy and recognizes the importance of your personal data.

In order to demonstrate our commitment and transparency when we process your personal data due to your relationship with us and your navigation on our Platform, we have developed this Privacy Policy to inform you how we use your personal data.

Please read this Privacy Policy when accessing, browsing, registering or otherwise interacting with our Platform.

If you do not agree with any or all of the terms described in this Privacy Policy, we ask that you do not access, browse or use any of the Services made available by mLabs.

1. What do I need to know before reading this Privacy Policy?

The definitions, that is, the terms indicated here, in alphabetical order, which will have a meaning as detailed below and can be used in the singular, plural, feminine and masculine and also together:

Affiliate: is the person, natural or legal, who registers in the mLabs Affiliate Program to recommend the Mlabs Platform and Services and receives a commission in return. More details at: https://www.mlabs.com.br/parceiros/programa-de-afiliados

Anonymization: is the technical procedure that prevents information from being related to a natural person, that is, the anonymized information is not Personal Data.

Legal Basis: is the authorization based on law that a Controller and/or Processor has to carry out the Processing of Personal Data of a natural person, provided that a specific purpose is observed.

Cookies: are small files transferred to the electronic device that the User uses to access the Platform, which allow identifying details of the access performed, but do not identify a person directly.

Consent: is the free, informed and unequivocal expression by which a natural person agrees to the Processing of Personal Data for a specific purpose.

Account: is the registration that a User performs with mLabs that allows access and use of the Services offered on the Platform.

Controller: is the person, natural or legal, who is responsible for the decisions regarding the Personal Data Processing operations.

Guest: is the person, natural or legal, who accesses the Platform and performs their own registration through an invitation from a User.

Personal Data: information relating to a natural person, provided by the User or collected by mLabs that is capable, directly or indirectly, of identifying the natural person, such as name, identification numbers such as RG, CPF, address, email, location data, bank details, electronic identifiers, etc.

Sensitive Personal Data: Personal Data that deal with racial or ethnic origin, religious conviction, political opinion, affiliation to a union or organization of a religious, philosophical or political nature, data relating to health or sex life, genetic or biometric data, linked to a natural person.

Non-Personal Data: information that does not allow the identification of a natural person, such as technical, statistical, anonymized information and even information related to a legal entity, therefore not included in this Privacy Policy.

mLabs: name used in this document to identify the owner of this Platform and responsible for this Privacy Policy, MLABS SOFTWARE SA, registered under no. 23.465.964/0001-00, headquartered at Avenida Cassiano Ricardo, 401, sala 1309 – Edifício Hyde Park, in the city of São José dos Campos, State of São Paulo, CEP 12246-870.

Processor: is the person, whether natural or legal, who carries out operations relating to the Processing of Personal Data on behalf of a Controller.

Platform: is the set of tools and services available over the internet, accessed and hosted on the main domain www.mlabs.io, other subdomains associated with the main domain, at www.socialmediaexponencial.com.br, clube.socialmediaexponencial.com.br, www.dashgoo.com and mobile apps available for IOS and Android.

Privacy Policy: this document explains how mLabs processes Personal Data in the provision of the Services made available on the Platform.

Services: are the services provided by mLabs to the User through the Platform that include tools, software, functionalities, facilities, content and resources intended for managing content on social networks and creating landing pages, which can be paid or free.

Third parties: these are third-party companies that provide links on the Platform over which mLabs has no control or power to interfere in decisions, with its own terms of use and privacy policy.

Treatment: is any operation performed with Personal Data such as collection, registration, storage, sharing, transmission, transfer, among others performed through the Platform.

Personal Data Subject (Holder): is the natural person to whom the Personal Data belongs and the General Law for the Protection of Personal Data provides protection.

Terms of Service: is the document that regulates the general terms and conditions for access and use of the Platform by Users. mLabs may still establish specific Terms that apply exclusively to certain Services. In these cases, the User must pay attention to all applicable Terms.

User: is the person, whether natural or legal, including Affiliate and Guest, who accesses the Platform or uses mLabs Services in a paid or free way, notwithstanding, the General Law for the Protection of Personal Data offers protection only to natural persons.

Now that you’ve learned the definitions, let’s get to the Q&A you’re curious to know more about!

2. What data does mLabs collect?

mLabs collects the following data through the Platform:

• Identification data: such as name, RG, CPF.
• Contact data: such as address, email, phone.
• Billing data: bank information, such as credit card number, bank account, billing address.
• Public data: made available in a public database or made public by the User himself through social media.
• Browsing data: through Cookies and similar technologies.
• Non-Personal Data: such as those of companies, notwithstanding, the General Law for the Protection of Personal Data offers protection only to natural persons.

3. Whose data is collected by mLabs from?

The data collected through the Platform by mLabs is User data.

4. How does mLabs collect data?

Data may be collected in the following cases:

• When the User makes the data available through navigation and for access and use of the Platform and Services.
• When the User contacts mLabs through the available communication channels, including for service purposes.
• When the User authorizes other companies used by the User to make the data available to mLabs.

5. What is the legal basis for treating the data collected by mLabs?

mLabs only processes Personal Data in compliance with applicable legislation and in the situations described below:

• For the provision of Services (contract execution).
• To improve the Services provided (legitimate interest).
• Service (contract execution).
• Communication regarding the Platform and Services (contract execution).
• For the dissemination of advertising and marketing actions (consent).
• To comply with requests from competent authorities (legal or regulatory obligation).
• To file or defend itself in proceedings (regular exercise of rights in administrative, judicial and arbitration proceedings).

6. Is mLabs a data controller or processor?

Depending on the Personal Data Treatment carried out, mLabs may be:

• Controller: when carrying out the Treatment of Personal Data by and for itself.
• Processor: when treating Personal Data on behalf of a User, in this case the User is the Controller.

When mLabs is the Processor, it performs the Treatment of Personal Data in strict legal compliance. The Controller in turn is:

1. Obligated to comply with all applicable legislation, including the General Law for the Protection of Personal Data;
2. Responsible for any and all Data Treatment carried out on the Platform;
3. Obligated to indemnify mLabs or a Personal Data Subject for any and all damages, direct or indirect, eventually caused.

Although mLabs has no control over which Personal Data the Controller will enter or otherwise carry out the Treatment on the Platform, with requests from Personal Data Subjects or competent authority regarding the Treatment of Personal Data carried out by the Controller, mLabs, may respond directly to such requests in the event of inactivity of the Controller.

Furthermore, the Controller must keep mLabs informed of any request made by a Personal Data Subject or competent authority.

7. With whom does mLabs share the data?

mLabs shares User information, including Personal Data, only when strictly necessary, with:

• Suppliers: mLabs has several suppliers necessary for the operation of the Services provided to the User and some of them may process part of the Personal Data collected by mLabs to, in the role of Controller: support customer service and communication services, payment processing, hosting of data; and as Processor: data hosting services.
• Third parties: when the User authorizes mLabs to share Personal Data.
• Public authorities: when mLabs is obliged to comply with a legal or regulatory obligation, by legal provision or by a request from a competent public authority, either in the role of Controller or Processor.

8. Does mLabs transfer data to other countries?

mLabs is constantly looking for the best suppliers to provide the User with an incredible and exclusive experience in the use of the contracted Services, and there may, eventually, be the transfer of Personal Data to other countries. In these cases, mLabs processes Personal Data in accordance with Brazilian legislation and chooses suppliers that comply with applicable laws.

9. How long will the data be stored?

mLabs will keep Personal Data for the time permitted and/or required by law, always supported by a Legal Basis. After this period, mLabs will promote the removal and elimination of the data.

10. Hmmmm, what about cookies?

mLabs only uses cookies authorized by the User, through Consent, which can be changed, activating or deactivating their preferences, at any time through their browser on the links indicated below; however, some functionality of the Platform and Services may be affected and may not function properly.

Firefox:https://support.mozilla.org/pt-BR/kb/desative-cookies-terceiros-impedir-rastreamentocomo

Google:https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=pt-BR

Safari:https://support.apple.com/pt-br/guide/safari/sfri11471/mac

Edge:https://support.microsoft.com/pt-br/microsoft-edge/excluir-cookies-no-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09

11. What are my rights as a data subject?

Personal Data belong to the Holder, a natural person. The General Law for the Protection of Personal Data guarantees you the following rights that will be guaranteed by mLabs*:

• Confirmation of the existence of Treatment;
• Access to Personal Data;
• Correction of incomplete, inaccurate or outdated Personal Data;
• Anonymization, blocking or elimination of Personal Data that is unnecessary, excessive or treated in violation of the provisions of the legislation;
• Portability of Personal Data to another service or product provider, upon express request, in accordance with the regulation of the national authority, observing commercial and industrial secrets;
• Deletion of Personal Data treated with the User’s Consent;
• Information on public and private entities with which mLabs shared Personal Data;
• Information about the possibility of not providing Consent and about the consequences of denial;
• Revocation of Consent at any time upon express request of the User, in a simple and free way.

*To ensure the User’s legal rights and for the protection of Personal Data, mLabs will use security mechanisms to verify and confirm the User’s identity.

12. How does mLabs protect data?

mLabs uses the best and most advanced technological resources available on the market related to information security and maintains a robust internal governance policy for the protection of Personal Data treated on the Platform. However, external factors existing on the internet that are not under the control of mLabs may compromise the security of Personal Data.

User, you must keep your Personal Data safe.

Do not share your account login information, use mLabs Services only through computers, mobile devices and trusted networks, and do not provide your Personal Data to unauthorized persons.

Considering the Services of the Platform, which includes the management of content on social networks through a single tool, it is exclusively up to the User to consult the terms of use and applicable privacy policies of each social network they use and of Third Parties, as mLabs does not have any partnership or any interference or responsibility towards the social networks and Third Parties used by the User.

The User is solely responsible for any Personal Data of their own or of others that they make available, whether intentionally or not, publicly on social networks or for Third Parties when using the Platform Services.

13. Can this Privacy Policy change? How do I stay informed?

The world is constantly changing, just like mLabs!

mLabs undertakes to notify the User whenever there is a significant change in this Privacy Policy and also whenever a new Consent for Treatment of Personal Data is required.

Additionally, the User may visit this page at any time and check the Privacy Policy.

Do not worry! We only use Personal Data as authorized by the User and permitted by law.

14. How can I find out more about the data treatment performed by mlabs?

mLabs will be pleased to assist the User in exercising the rights guaranteed by law.

Remember: User, you are a priority for mLabs! And to answer your questions and requests, we put a person in charge, also known as a Data Protection Officer (DPO), at your disposal.

Please feel free to contact mLabs at the addresses below and your request will be dealt with as required by law.
DPO: Marcos Santos
Email: dpo@mlabs.com.br

Physical address for written correspondence, please address for the attention of the DPO: Marcos Santos – Avenida Cassiano Ricardo, 601, sala 161 – São José dos Campos, State of São Paulo, Brazil, CEP 12246-870.

This Privacy Policy is directed to Users residing and using mLabs Services in Brazil, therefore, Brazilian law applies.

Updated: May, 15, 2023