We at MEISTRARI DESENVOLVIMENTO DE SOFTWARE LTDA ("MEISTRARI"), a company headquartered at Alameda Ministro Rocha de Azevedo 599, apt 11, respect and care for the privacy of Personal Data Holders, always striving to be transparent and provide clear information about the Processing of Personal Data. The Processing of your Personal Data aims, first and foremost, to provide better and more personalized service, taking into account the specific conditions of each User. The more the User interacts with us, the more they inform us, and the more capable we are of offering personalized services.
As Users contact us, register, access, and use Tela, personal information about the User may be collected and processed. This Privacy Policy describes the types of Personal Data we may receive about the User, how we may use it, with whom we may share it, how we protect and keep it secure, and your rights regarding your Personal Data. Therefore, this Privacy Policy provides an overview of the situations through which we may interact. This Privacy Policy is an integral and inseparable part of the Terms and Conditions of Use of Tela ("Terms of Use"), available at the link https://tela.com/terms-of-use.
1.1 Terms capitalized will have their meaning defined according to the Terms of Use or applicable legislation. Below are some definitions used throughout this Privacy Policy:
2.1 Collected data and data sets. MEISTRARI collects and processes various types of Personal Data when Users access, register, and use Tela according to Tela's functionalities.
Some of this data is (i) automatically collected by Us (such as information collected from the device used to access Tela; geolocation information; access logs, Tela usage information, Cookie information or similar technologies, statistical information, and aggregated data), (ii) provided directly by Users (such as registration and identification data, information entered by Users in Tela, and information shared by Users when contacting us or interacting with other Users), and (iii) others provided to Us by third parties, such as employee names for service provision, always in compliance with Data Protection Legislation.
See here the Personal Data we collect:
Data Group | Data Subject | How it is collected | What data is collected and processed |
---|---|---|---|
Access Records | User | Automatic collection of all Users accessing Tela | IP address, date and time of access, precise or approximate geolocation, GPS data, access log, browser type, device type, hardware model, network data, operating system, and browser used. |
Registration Data | User | Data provided by the Data Subject to create an account on Tela. | Full name, position, phone number, email, and password. |
Data on Tela usage | User | Automatically collected by MEISTRARI from the User's use of Tela. | Access history, accessed content, access duration, session, interaction history with Tela and other Users, preferences and settings activated for your account, Tela functionalities used or pages viewed, Tela failures, and other system activities and third-party sites or services used by the User before using Tela. |
Data collected through Cookies and similar technologies | User | Automatically collected by MEISTRARI from the User's use of Tela. | MEISTRARI may use Cookies and electronic device identifiers (such as SDKs, web beacons, among others) when the User uses Tela. These technologies allow statistical analysis of the use of a particular application, offering or developing functionalities, but can also allow the identification of devices, browsers, and User profiles. |
Data provided by Clients | User | Product: data provided anonymously by Clients when integrating, inputting, or sending their employees' data into Tela. |
4.1 Security. MEISTRARI will do everything possible to keep Personal Data always secure and will adopt security and protection measures, both technical and administrative, compatible with the nature of the Data collected, used, stored, or otherwise Processed by MEISTRARI, in accordance with appropriate market practices.
4.1.1 Exceptions. However, no method of electronic data transmission or retention is fully secure and may be subject to external attacks. Thus, MEISTRARI cannot guarantee that such security measures are error-free or not subject to third-party interference (hackers, among others). By its nature, despite MEISTRARI's best efforts, any security measure may fail, and any Data may become public. BY USING Tela, USERS EXPRESSLY UNDERSTAND AND ASSUME THIS RISK AND AGREE THAT MEISTRARI WILL NOT BE RESPONSIBLE FOR SUCH TYPE OF LEAKAGE OR UNAUTHORIZED ACCESS TO DATA.
4.1.2 The above-described security measures apply to User Data only from the moment MEISTRARI receives them and while they are under its custody. The operation and security of the device Users use to access Tela, as well as third-party networks through which data travels, are not the responsibility of MEISTRARI.
4.2 Servers. For as long as Users keep their account on Tela active, all collected information will be stored with a high-security standard on MEISTRARI's or third-party servers, located in Brazil and/or abroad. The User is hereby aware that MEISTRARI may store their Personal Data on servers outside Brazil and/or use service providers not located in Brazilian territory. In such cases, MEISTRARI will observe the legal requirements for such international transfers, ensuring the same level of security applied to Processing carried out in Brazilian territory.
4.3 Storage period. Personal Data will be retained as long as necessary for the purposes listed in this Privacy Policy. MEISTRARI adopts controls to ensure that Data is retained only as long as it is indeed necessary, being discarded whenever the Processing is terminated or no legal retention hypothesis applies. In addition to the provisions, data may eventually be retained for a longer period when necessary to comply with legal/regulatory obligations.
4.4 Data deletion. When we no longer need to use Personal Data, it will be removed from our systems and records or anonymized so that MEISTRARI can no longer be identified from this data, at MEISTRARI's sole discretion. MEISTRARI may retain some Personal Data to comply with legal or regulatory obligations, as well as to allow and ensure the regular exercise of our rights (for example, in judicial, administrative, or arbitral proceedings). For audit, security, fraud control, and rights preservation purposes, MEISTRARI may retain the historical record of Personal Data for a longer period in cases where the law or regulatory norm so establishes or for rights preservation.
4.5 LIMITATION OF LIABILITY. NOTHING IN THIS PRIVACY POLICY IS INTENDED TO EXCLUDE OR LIMIT ANY CONDITION, WARRANTY, RIGHT, OR LIABILITY THAT CANNOT BE LEGALLY EXCLUDED OR LIMITED. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF CERTAIN WARRANTIES OR CONDITIONS OR THE LIMITATION OR EXCLUSION OF LIABILITY FOR LOSS AND DAMAGE. CONSEQUENTLY, ONLY THE LIMITATIONS THAT ARE PERMITTED BY LAW IN YOUR JURISDICTION WILL APPLY TO YOU. IN CASES WHERE EXCLUSION OF LIABILITY IS NOT POSSIBLE, BUT LIMITATION OF LIABILITY IS LEGALLY APPLICABLE, MEISTRARI'S TOTAL LIABILITY WILL BE LIMITED TO R$ 1,000.00.
5.1 MEISTRARI provides tools for Data Subjects to exercise their legal rights over their Personal Data. In this item, we will describe these rights and how Data Subjects can exercise them.
5.2 Exercise of rights. The rights mentioned above and others provided by applicable legislation can be exercised by the Data Subject directly through Tela, according to the functionalities made available on it (such as tools for accessing and editing Personal Data) or by requesting it via email privacy@tela.com. MEISTRARI reserves the right to request information or documents to verify the applicant's claims.
5.3 Consequences of data deletion. It is important to note that, in some cases, by complying with deletion requests, MEISTRARI may be unable to provide its services. Thus, the request for deletion of Personal Data will result in the immediate deactivation of the User's account on Tela, with the permanent loss of any such Data entered into Tela. After the deletion of this Personal Data, MEISTRARI may continue to use it in a non-individualized and anonymized manner, i.e., without any personal identification, for the purposes provided in this Privacy Policy.
5.4 Data retention. MEISTRARI may retain the Personal Data of certain Users for a period longer than the legal retention period, in compliance with possible orders from public authorities, to defend itself in judicial and/or administrative proceedings, and in cases where Personal Data has been duly anonymized.
IN COMPLIANCE WITH APPLICABLE LEGISLATION OR COURT ORDER, MEISTRARI MAY RETAIN CERTAIN PERSONAL DATA FOR A PERIOD NOT LESS THAN 6 (SIX) MONTHS AFTER YOUR DELETION REQUEST. SUCH DATA WILL NOT BE ANONYMIZED OR DESTROYED BY MEISTRARI BEFORE THE END OF THIS PERIOD. MEISTRARI WILL STORE YOUR DELETION REQUEST AND, OBSERVING THE LEGAL MANDATORY RETENTION PERIOD OF CERTAIN DATA, WILL PROVIDE FOR THE DESTRUCTION OR ANONYMIZATION, AT MEISTRARI'S SOLE DISCRETION, OF INFORMATION CAPABLE OF IDENTIFYING THE USER.
IF THE USER REQUESTS THE DELETION OF THEIR INFORMATION BUT STILL HAS ANY PENDING OBLIGATION WITH MEISTRARI, THEIR INFORMATION WILL NOT BE DELETED AND WILL REMAIN STORED TO ENABLE THE RESOLUTION OF THE PENDING ISSUE AND THE ADOPTION OF APPROPRIATE MEASURES.
5.5 Failure to provide consent in cases where it is necessary may prevent MEISTRARI from providing its services or certain functionalities of Tela from being used by the User.
6.1 In case of doubt, suggestions, complaints, or clarifications about this Privacy Policy or the Processing of Personal Data by MEISTRARI, or to request the exercise of any of the rights described in this Privacy Policy or Data Protection Legislation, the User can contact MEISTRARI via email: privacy@tela.com. MEISTRARI will be pleased to clarify any doubts and/or fulfill your request.
7.1 Processing Operators. MEISTRARI may hire third parties to assist in providing its services, such as cloud storage servers and payment processing platforms. Currently, MEISTRARI shares its Data with infrastructure providers (servers, hosting, and cloud services) for the proper functioning of Tela, IT service providers, and partners related to payment processing, which may be replaced at any time, provided that adequate data security and confidentiality standards are maintained. MEISTRARI, as the Data Controller, will require such partner Operators to maintain adequate security and confidentiality levels.
7.2 Third-Party Services. During the use of Tela, Users may use other services, channels, products, and platforms provided, maintained, and/or operated by third parties, used as channels or support means for services provided by MEISTRARI, but without any relation to MEISTRARI ("Third-Party Services"). These Third-Party Services may include, for example, payment platforms, file-sharing tools, among others. When MEISTRARI services use such Third-Party Services, the Processing of Personal Data will also be subject, in addition to this Privacy Policy, to the privacy policies and terms of use of such Third-Party Services, over which MEISTRARI has no control or influence. In this case, MEISTRARI and this third party will be Independent Controllers of Personal Data, each being responsible for the Processing of Personal Data carried out within their scope of action. Concerning MEISTRARI, even when Personal Data is received by such Third-Party Services, such Personal Data will always be processed in accordance with this Privacy Policy. However, we encourage the User to inform themselves about the policies applicable to such Third-Party Services, as MEISTRARI has no influence over the relationship between the User and such Third Parties and is not responsible for the use made by such Third Parties of the User's Personal Data entered by the Users into the Third-Party Services.
7.3 Other Third Parties. In addition to the cases already mentioned in this Privacy Policy, Personal Data may also be transferred to third parties, including as Controllers, in the following cases:
7.4 Legal basis for sharing. The sharing of Data with such third parties will always be carried out with the User's Consent or (i) for the regular exercise of MEISTRARI's rights, (ii) to comply with legal obligations, (iii) for the execution of a contract, or (iv) for MEISTRARI's legitimate interest (in this last case, not including the User's Sensitive Data), or any other applicable legal basis.
8.1 To optimize the efficiency, performance, and security of Tela, MEISTRARI may use a global technical infrastructure and have service providers not only in Brazil but also abroad. Therefore, your Personal Data, including Sensitive Personal Data, may be transferred to other countries for data Processing and storage, in accordance with the terms and purposes defined in this Privacy Policy, as well as to provide the services requested by You. MEISTRARI may transfer your Personal Data to service providers who will process Personal Data on behalf of MEISTRARI and according to our instructions.
8.2 Privacy and data protection laws vary from country to country, and data protection standards in other countries may differ from those in Brazil. Nonetheless, MEISTRARI will make every effort to ensure the level of data protection informed in the Privacy Policy, in accordance with applicable laws.
9.1 MEISTRARI may use Cookies and similar technologies, such as pixels and tags, to ensure that the services provided meet quality standards. Cookies collect only statistics and will not be used for purposes other than those expressly provided in this Privacy Policy.
9.2 What are Cookies and what are they for? A Cookie is a small file added to your device or computer to provide a personalized access experience to Tela. MEISTRARI may use Cookies:
9.3 Is it possible to limit the use of Cookies? Browsers generally allow the collection of Cookies to be disabled, so if You do not change the Cookie collection policies of your browser, the User can object to such Processing by adjusting their browser settings to reject Cookies.
10.1 Notwithstanding our efforts to keep Personal Data confidential, according to the terms of this Privacy Policy, it is the responsibility of each User to keep their login and password for accessing their account on Tela secure and confidential.
10.2 If the User believes that their login and password for accessing their account on Tela have been improperly accessed by third parties or are known to other unauthorized persons, for any reason, the User should immediately notify MEISTRARI via email privacy@tela.com, without prejudice to the immediate password change through Tela by the User.
11.1 MEISTRARI may, at any time, change this Privacy Policy at its sole discretion. Any changes will be informed, 30 (thirty) days in advance, through Tela itself and/or the email provided by the User and/or we will highlight these changes at the top of these Terms of Use and provide, for a reasonable period, a highlighted link to such changes. The User should check this page and review this Privacy Policy periodically to ensure they agree with the modifications.
11.2 Except when express Consent is mandatory, if the User continues to use Tela and/or does not object to the changes and new terms informed by MEISTRARI after 30 (thirty) days from the disclosure of the new version of the Privacy Policy, it will be understood that they are fully aware and agree with the new terms applicable to the Processing of Personal Data. If the User does not agree with the changes to the Privacy Policy, they should refrain from using Tela, and may request the cancellation of their account, in accordance with the Terms of Use.
MEISTRARI
Date of Last Update: 01/15/2025
Contact:
- Email: privacy@tela.com
- Address: Alameda Ministro Rocha de Azevedo 599, apt 11