Privacy Statement

Updated on 02th September 2022


1.Privacy Statement

Tracenet IT Solutions knows how important it is to know and be confident about the use of your personal data as well as that of your customers. Therefore, we have taken care to clarify and explain our Privacy Policy.

We recognize the need for adequate protection and management of the personal information collected on our site, as well as that shared with us by our customers. This Privacy Policy will help you understand what types of information we may collect, how this information may be used, and with whom the information may be shared.


2. What personal information we collect

The personal information we obtain may be collected in the following ways:

Website: Personal information is collected at the time a user interacts on our site through forms, comments, testimonials, and surveys. This personal information includes, but is not limited to, the user’s name, e-mail address, and phone number. When collecting the user chooses whether or not to consent to the processing of this data for the purpose of sending news, articles and promotions. The user of our portal is not obliged under any circumstances to provide any personal data to navigate the pages of the site, so that any information is provided freely and spontaneously. The collection of basic data is only necessary when the user wishes to have his contact returned. All Personal Information is collected in a fair and non-invasive manner, with your voluntary consent. Personal Information is not accessible to any person outside the specific function for which it was collected.

Cookies: Personal data may be collected via cookies, with the consent of the user. For more information, see our Cookies Policy.

Contracts: We collect data from our customers necessary for the preparation of the contract and issuance of the invoice. These data are, among others, the e-mail for contact and eventual sending of the Electronic Invoice, name, CPF, CNPJ, corporate name, full name of the responsible, telephone, complete business address with zip code, neighborhood, city and state and state registration when applicable.

Sharing: We may have access to personal data shared by our customers. In this case Tracenet IT Solutions, as a data operator, will follow all the instructions and policies of privacy and data protection of its customers, protecting these shared data against improper access, and in accordance with the standards of the General Data Protection Act.

E-mail: Are stored on Gmail servers, setting up international data transfer.

Employees: We collect personal data from our employees and job applicants. This data is necessary for execution of the employment contract, to register the employee and to comply with labor legislation.


3. Social Media

TRACENET IT SOLUTIONS also uses Social Media to communicate and interact with its  through third parties websites such as Facebook or Twitter. These third parties, websites are an Internet-based technology that is not operated or controlled by TRACENET IT SOLUTIONS. By interacting, sharing or “Liking” the TRACENET IT SOLUTIONS page on Facebook, twitter, or other social media, you may disclose certain personal information to TRACENET IT SOLUTIONS or other third parties.

We use “social buttons” to allow our users to share or bookmark web pages. These are buttons on third parties social media sites, and may record information about your activities on the internet, including this site. Please review the respective terms of use and privacy policies of those sites to understand exactly how they use your information, how to opt-out of receiving or deleting such information.

The amount of personal information you see will depend on your own privacy settings on Facebook, twitter and other social media.


4. Purposes and legal bases


Listed below are the purposes and legal bases of TRACENET IT SOLUTIONS’ data processing:


Purposes Legal Basis

Comply with terms and

conditions established in contracts with our customers.

Required for performance

of a contract in which you, your company, or a controller of your data represents one of the parties.

Recruitment and assessment

of adherence to the job vacancy.

Justified on the basis of

our legitimate interests to ensure that we recruit the right employees.


To facilitate communication

with you (including in cases of emergency and to provide you with information


It is justified on the basis of

our legitimate interests in ensuring proper communication and emergency management

in the organization.

Comply with


Necessary for

compliance with a legal obligation to which we are subject.

Monitor your use of our systems

our systems (including monitoring your use of our site and any applications and

any applications and tools you use).

It is justified on the basis of

our legitimate interests in avoiding non-compliance and protecting our


Social listening (identifying

and analyzing what is being said about TRACENET IT SOLUTIONS and our

customers on social media [publicly accessible content only] in order to understand sentiment, intent, disposition and market trends and the needs of our

needs of our stakeholders and thereby improve our services).

It is justified on the basis of

our legitimate interests in protecting our assets and brand in social media.

brand in social media.

Improve security and

of our website, operation and information.

It is justified on the basis of

our legitimate interests in ensuring that you have an excellent user experience and that

experience and that our networks and information are secure.

Performing data analytics, i.e., apply analytics to operations and business data to

describe, predict, and improve business performance within TRACENET IT

SOLUTIONS and/or provide a better user experience. (about how we use analytics on our site are found in our cookie


It is justified on the basis of

our legitimate interests in ensuring the proper functioning of our business operations.

Offer our products and services

and services to you (unless you have objected to such treatment).

It is justified on the basis of

our legitimate interests in ensuring that we can conduct and improve our business

Administer benefits

to employees

It is justified based on the

TRACENET IT SOLUTIONS‘ legitimate interests in ensuring that our

employees receive the appropriate benefits.

Delivery of information

to government agencies.

To comply with a

legal obligation.



We only rely on our legitimate interest for specific purposes. Such processing of personal data in no way overrides the interests, rights and freedoms of the data subjects.


5. About the sharing and cession of information

TRACENET IT SOLUTIONS does not have the practice of disclosing information that can identify the user and never shares

information or sells and rents this personal data to third parties. This data is for the exclusive internal use of the company to achieve the purposes expressed in the previous item.

The data may be shared with third parties only in the following situations:

  • Upon court order or request by government oversight bodies.
  • Data transferred to public bodies to comply with the legislation in force, for example, personal data contained in electronic invoices and their XMLs, or data on our employees to be necessary for the payment of INSS or FGTS.
  • Data transferred to accounting or human resources service providers, to meet tax and labor obligations;
  • Data transferred to financial institutions to enable payment options to our customers, or for the payment of salaries to our employees and contractors;
  • Data transferred for business purposes to third-parties service providers who provide services for us, such as billing, payment processing, customer service, emailing, advertising and marketing, security and performance monitoring, repair and maintenance services, order and transaction processing and fulfillment, verification of customer registration information, research, data storage, auditing and data processing;


6. Information Security

To make sure that your personal information is secure information is secure we communicate our privacy and security guidelines to TRACENET IT SOLUTIONS employees and we strictly follow the precautionary measures regarding privacy within the company.

We strive to protect your Information personal, entrusted to us by our customers, through measures physical, technical and organizational to reduce the risks of loss, misuse, unauthorized access, disclosure and improper alteration of this data.


7. Rights of Data Subjects

Holders of personal data have certain rights with regard to their personal data and may exercise these rights by contacting by contacting us at: privacydpo@tracenetsolutions.com

  • Confirmation of the existence of personal data processing;
  • Access to personal data in accordance with applicable law;
  • Correction of incomplete, inaccurate or outdated data;
  • Data portability;
  • Deletion of data, when the data is processed on the basis of the data subject’s consent or when the data is unnecessary, excessive or processed in violation of the applicable law;
  • Request for information on shared use of data;
  • Revocation of consent, where applicable.

For security reasons, we can only fulfill your request if we are sure of your identity. Therefore, we may request additional data or information to confirm the identity and authenticity of the Data Subject. Please note that, as mentioned above, for most of the products and services that we offer, TRACENET IT SOLUTIONS acts as the operator of the personal data, as instructed by our Customers (controllers).

If you are a Consumer and wish to exercise your rights with respect to the personal data that TRACENET IT SOLUTIONS handles as the operator, you should contact the Customer who is using our services, and who is the controller of this data.


8. Termination of Processing

This Privacy Policy applies in the circumstances mentioned above for the entire period of time that TRACENET IT SOLUTIONS stores personal data. We store and maintain your information: (a) for as long as required by law; (b) until the termination of the processing of personal data as mentioned below; or (c) for as long as necessary to preserve the legitimate interest of TRACENET IT SOLUTIONS. Thus, we will process your data, for example, during the applicable statute of limitations or for as long as necessary to comply with a legal or regulatory obligation.

Termination of personal data processing will occur in the following cases: (a) when the purpose for which the personal data was collected is achieved, and/or the personal data collected is no longer necessary or pertinent to the achievement of such purpose; (b) when the Data Subject request the deletion of his/her data; and (c) when there is a legal determination in this sense.

In the cases of termination of personal data treatment, except in the cases established by the applicable legislation or by this Privacy Policy, the personal data will be eliminated


9. Personal Data Officer (PDO)

TRACENET IT SOLUTIONS provides below the contact details of the Personal Data Officer (PDO), who is responsible for answering any and all requests from users, or the National Authority, which are related to personal data.

For any questions, requests or complaints regarding the processing of personal data, please contact our Personal Data Officer:



10. Changes to Privacy Policy

TRACENET IT SOLUTIONS reserves the right to update or modify this Policy, at any time and without prior notice. However, we will always post the new, revised version on our Web site. If there are changes in the way we treat personal data, you will be informed in order to verify if you want to continue using our services.