Terms and Responsibilities

BDCo takes the privacy and security of your information seriously.

This policy describes how BDCo collects, uses, transfers, and discloses our clients' information. This policy covers the information collected by BDCo in the exercise of its activities, collectively or individually, whether before or during the provision of our services (referred to as "services"). This policy also covers the information collected through:

Website ("site") we operate,
Software applications ("applications") we make available for use on computers or mobile devices,
Our pages on social networks ("social networks") and applications linked to the site, and messages and content received via email, WhatsApp, SMS, and other communication means (collectively, including the site, applications, and our social networks, the "online systems").
This policy also covers other means by which we collect information. For example, it also covers information collected in personal discussions, phone conversations, and/or non-electronic communications (i.e., collection by means other than our online systems).

PERSONAL INFORMATION WE MAY COLLECT

BDCo may collect information from clients as a company, legal entity, or individual, as an identifiable individual (collectively referred to as "personal information"), for the provision of services and products, and to operate our business. The type of personal information we may collect depends on the specific situation and the type of service to be provided in each case.

We may collect name, contact details, and preferred communication method. We may also collect responses to survey and evaluation questions.
When the client uses our online systems, we may collect login user credentials, such as usernames, passwords, and password hints unique to our online systems. We may also use cookies for session control, permissions, storing preferences, and collecting browsing information, access metrics, etc.

We always recommend that our clients do not provide us with any personal information that does not comply with this policy and emphasize that:

Personal data and information are not sold or exchanged with third parties.
BDCo does not archive or store banking data and information, including credit or debit card numbers. In the case of online payments, if used, the information is archived and processed directly by payment systems.

HOW WE COLLECT PERSONAL INFORMATION

When interacting with BDCo, our clients may provide some personal information directly.

We may collect personal information when the client registers to use our online systems, purchases a service, responds to an evaluation, interview, or survey, participates in courses or training, whether through online systems, email, electronic forms, mail, phone, messages, or even in person.
If the client sends personal information about other people to us or our service providers, the client represents that they have the authority to do so and allows us to use the information in accordance with this policy. Personal information about the client may come directly from our clients, from the individuals to whom we provide services, or through third parties. We may use third-party companies to manage evaluations and other products offered on our online systems, as well as event registration. If the client wishes to purchase a physical product or register for an event, they may be directed to a webpage hosted by third parties (or their service providers) and not by BDCo.
Any personal information that the client provides through these pages will be subject to the third party's privacy policy, not this policy. BDCo does not control and is not responsible for the use of information collected by third parties on these pages. Please note that this policy does not address the collection and use of information through third-party pages or the privacy practices or information of third parties.

HOW WE USE THE PERSONAL INFORMATION WE COLLECT

BDCo uses the personal information it collects in various ways. The summary below provides additional details on how we use the personal information we collect.

We use personal information to provide services to our clients. We do this to fulfill our contractual relationship. We have a legitimate and beneficial interest in using personal information to conduct our business.
We use your personal information to respond to your inquiries, verify your information, or share information with the client.
We use personal information to respond to questions raised by clients and meet their requests. If the client contacts us, we keep a record of their contact and correspondence information and use the information provided in their message in the interaction with the client.
Periodically, we use personal information to send important information about the online systems, changes to our terms, conditions, policies, and other administrative information.
We may also contact our clients to verify if their personal information is up to date. We use personal information to manage our relationship with the client or to comply with a legal obligation.
We use personal information for our business purposes, such as preparing service supply proposals, customer guidance, evaluating our promotional activities, monitoring customer satisfaction, strategic planning for the company, and administering our services.
We may use personal information to conduct analyses, training materials, or reports. However, any published product refers only to aggregations, does not personally identify individuals, and does not attribute any content or result to a specific client, except where there is specific authorization for such use.
We may retain and use the personal information of the client collected in the exercise of our contractual obligations for research, publication, development, benchmarking, validation, studies, and trend analysis, with the aim of improving and enhancing our services or developing and marketing new services.
We may use the client's personal information to ensure that our services comply with legal requirements, such as equal opportunity laws.
As long as contractual obligations allow, we may also use the information in an aggregated and non-identified manner to associate and combine the client's information with other information of the same collected through other services.
Frequently, we use pseudonyms or encode personal information, which means that personal information is dissociated from all information that can directly identify you, replacing it with a code to minimize unwanted or unintentional identification. This encoded information can be decoded using the key so that the client can be re-identified.
We may also anonymize, differentiate, or discharacterize personal information so that the final product does not identify the client, whether the company or the individual. In this way, we can use the client's information to generate statistics and graphs that allow us to understand where and how our services are being used, conduct ongoing validation studies, compile reports, and publish articles to enhance the knowledge base of organizational and leadership science. This compiled, anonymous, or discharacterized information is not considered personal information for the purposes of this policy, and we may use it for any purpose.
We may use personal information to relate to the client as an individual, forward content and/or marketing materials. Please note that if the personal information has been obtained through a service contract with your employer, the client will not receive marketing materials as a result of the personal information obtained from these services. BDCo sends informative emails, articles, communication materials, proposals, commitment letters, and information about our services. We also use your personal information to conduct surveys. We do this with your consent or because we have a legitimate beneficial commercial interest. Occasionally, with the client's consent, personal information may be used in press releases and direct marketing materials.

WHO HAS ACCESS TO PERSONAL INFORMATION

The way personal information is disclosed will depend on each situation. While providing our services, we may disclose personal information to the employer in a personalized manner, as long as it is within the scope of the service contract, agreed upon, or required by contractual obligations. Otherwise, we will refer only to larger aggregations of individuals, not personally identifying them or including any results attributable to clients who hired our services.

We have affiliates in other locations around the world. To the extent permitted by law and required by contract, we may share aggregated and anonymous personal information of individuals from a specific client with our affiliates to provide consistent services across different geographies for our clients. BDCo is responsible for jointly administering the use of this personal information. BDCo discloses selected personal information to third parties that provide support for our services or business operation.

BDCo works with third parties that provide services, which may include, among others, assessment services, training and coaching, website hosting, IT consulting, data research and analysis, marketing services, lawyers, accountants, installation and security services.
As part of the provision of services, these third parties may have access to personal information and may use it to modify, improve, refine, and validate the execution of their services and technology. There may be other occasions when we disclose your personal information.
BDCo may also use or disclose personal information to: (i) comply with applicable laws, (ii) respond to inquiries from regulators or government authorities, including those outside your country of residence, or (iii) protect the rights, privacy, security, or property of BDCo and our affiliates.
We cannot and do not assume any responsibility for the actions or omissions of third parties, such as clients, including how they use the personal information received from BDCo or other independent sources.

ADDITIONAL GUIDELINES FOR CHOICE AND ACCESS

To make a request regarding your personal data, contact us at contato@bdco.com.br if you wish to:

Ask questions about how we handle your personal information.
Withdraw your consent for the use of your personal information.
Object to the use of your personal information for legitimate business interests.
Request an electronic copy of your personal information for the purpose of transmitting it to other companies (to the extent that this right to data portability is provided to the client by applicable law).
Request review, correction, updating, deletion, or restriction of the use of your personal information.
To remove your personal information from BDCo's database, review, correct, update, delete, or restrict the use of your personal information, please include all user IDs and email addresses, as well as the names of any BDCo or related websites, products, or services that the client may have accessed.
To opt-out of receiving our marketing communications or request that your information be removed from our marketing databases. Please write "Remove User" in the subject line of the email and include your full name, user ID, and phone number in the body of the email.

For your protection, we can only implement requests regarding personal information associated with the email address that the client uses to send us your request, and it may be necessary to verify your identity before implementing your request. We will comply with your request as soon as reasonably practical and may need to contact the client to ensure that we understand your request.

The client can request to be removed from marketing communications through the link available in the same communications they wish to deactivate, when available.

BDCo will make every effort to delete personal information, or make the requested changes, within a maximum period of 30 business days.

We strive to maintain accurate personal information. If it is determined that personal information is not accurate, we will work quickly to correct it.

Please note that, to maintain consistency in our services and operations, we maintain backup systems. When the client requests that their information be removed from BDCo's databases, we may not be able to delete residual copies from our systems or our backup systems, but they will continue to be protected as required by this policy.

We may also need to retain certain personal information of the client, such as your email address, to respond to reactivation, deletion, or similar requests. Please note that this residual personal information will remain in BDCo's databases, access logs, and other records, which may or may not contain identifiable personal information about the client. Residual personal information will not be used for commercial purposes. However, BDCo reserves the right to occasionally contact former users of its services, as appropriate.

LOCATION OF COLLECTED AND MAINTAINED PERSONAL INFORMATION

Depending on the product or service we are providing to the client, especially the delivery location or client origin, your personal information may be collected, used, processed, transferred, and disclosed in other countries, according to the rules set forth in this policy. However, the client understands that their personal information, when collected, used, processed, transferred, and disclosed in countries outside their country of residence, is subject to data protection rules that may be different from those of their country.

SECURITY

BDCo has organizational, technical, and administrative measures in place to protect against the loss, misuse, and alteration of personal information about users of the online systems that are under our control. Unfortunately, however, no security system or information transmission system over the Internet can be 100% secure.

If the client has reason to believe that their interaction with us is no longer secure (for example, if the client thinks that the security of any account they may have with us has been compromised or that their user credentials are no longer secure), please notify us immediately to resolve the issue by sending an email to contato@bdco.com.br.

RETENTION PERIOD

We keep your personal information for as long as necessary or permitted, considering the purpose(s) for which it was obtained.

The criteria used to determine our retention periods include:
- The length of time we maintain a continuous relationship with the client (for example, as long as the client has an account with us or continues to use the services),
- A period beyond the ongoing relationship, if there is a legitimate internal need for operations, such as the need to retain this information for analysis, record-keeping, and compliance with data retention schedules,
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them).
- Or if retention is advisable considering our legal position (such as in relation to applicable statutes of limitations, litigation, or regulatory investigations).
In the event that a data subject chooses to withdraw their consent for all their information, the data must be deleted at the request of our databases within 5 business days.
In the event of any significant changes to the privacy policy that affect the rights of clients, they must be notified at their primary email address at least 30 days in advance.

LINKS TO OTHER WEBSITES

This policy does not address, and we are not responsible for, the privacy, information, or other practices of third parties.

In the online systems, the client may have the opportunity to follow a link to or from other sites maintained by BDCo affiliates or third parties. The inclusion of a link in our online systems does not imply our endorsement of the linked site. As these other sites may not be hosted or controlled by BDCo, this policy does not address the privacy practices of these sites. We recommend that the client review the privacy policies of each of these sites.
Please note that we are not responsible for the collection, use, and disclosure (including data security practices) policies and practices of other organizations, such as LinkedIn, Facebook, Apple, Google, Microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including any personal information that the client discloses to other organizations through or in connection with the apps or our social media pages.

POLICY UPDATES

BDCo regularly reviews its privacy practices and these practices are subject to change. The client can identify when this policy was last reviewed by checking the "Updated on" caption at the bottom of the policy. Any changes to the policy will take effect immediately upon publication on the Internet, accessible through the BDCo website.

USE OF ONLINE SYSTEMS BY CHILDREN

The online systems are not directed to individuals under sixteen (16) years old, and we ask that these individuals do not provide their personal information through BDCo's online systems.

COMMERCIAL TRANSFERS

Personal information may be transferred to third parties as part of our business assets in a sale of part or all of BDCo.

POLICY SUMMARY

This policy is the only authorized statement of BDCo's practices regarding the collection and use of personal information. Any summaries of this policy generated by third-party software or otherwise have no legal effect, are not binding on BDCo in any way, may not be invoked in place of this policy, and do not replace or modify this policy.

QUESTIONS

BDCo is responsible for the collection, use, and disclosure of your personal information under this policy. Questions related to this policy should be directed to BDCo at the email address: contato@bdco.com.br.

ADDITIONAL INFORMATION

The client may also file a complaint or report an alleged violation of the applicable data protection law to a data protection authority in their country or region or where an alleged violation of the applicable data protection law by emailing: contato@bdco.com.br.