Since 2017, MachLeV has stood out for its continuous pursuit of innovation and excellence. The company has driven the development of technological solutions aimed at facilitating and optimizing the education sector.

This Policy, which we present to you at this time, demonstrates our values and affirms our commitment to processing your personal data in a lawful, transparent, and ethical manner. Beyond merely complying with the requirements established in the legislation applicable to the matter, we believe in the need to process personal data through an ethical lens that represents MachLeV’s values and conduct.

This Policy provides all those who receive our services, including but not limited to our users, here individually referred to as “Data Subject,” with important information about how Gradepen handles their personal data.

After reading this Privacy Policy, if you have questions, complaints, wish to exercise your rights related to your personal data, or wish to communicate with us regarding this matter, you may contact our team at the email contact@gradepen.com.

The website/application reserves the right to modify these rules at any time, especially to adapt them to updates and changes in the service or to the legislation in force. Therefore, we recommend that you visit our page/app periodically to stay informed of any changes. Any amendment and/or update to this Privacy Policy shall take effect from the date of its publication.

WHAT DATA IS COLLECTED BY MachLeV

During your experience on our Website and Application, we may collect different types of personal data, either automatically for verification, monitoring, and control purposes, or provided directly by you, for example, when completing your registration. Below are the types of personal data we may collect and in which situations:

During registration: Name; CPF (Individual Taxpayer Registry); Name of the institution where the professional works; Email; Address; Phone number; Banking information; Login and Password.

During navigation on the platform: IP address; Information about the device used for navigation; Preferred language; image from the mobile device’s camera.

You may contact us at any time for requests or clarifications regarding the processing of personal data through our team at the email: contact@gradepen.com.

HOW WE USE YOUR PERSONAL DATA

We use personal data to ensure the provision of a high-quality service and a better experience in the use of our educational software. Below are the purposes for which we may use your personal data:

• To enable the provision of various services available on our digital platform (Creation and correction of exams, publishing answer keys, registering questions, reading QR Codes and exam answer sheets, among others).
• To contact you when necessary. Such contact may concern various matters, such as communication about performance alerts, questions regarding comments made, or the disclosure of a new product on the website.
• To assist in diagnosing and resolving technical issues.
• To develop new functionalities, improving your experience with our available services.
• To assist in analyses that may be used to protect your account and increase the security level of your registration data or to prevent possible fraud.

WITH WHOM WE MAY SHARE PERSONAL DATA

At MachLeV, we do not sell or trade data that identifies our users. We also do not share or transfer your personal data to third parties, except when:

1. Service providers: to ensure we offer our services with quality, we rely on various service providers who process personal data collected on our behalf and in accordance with our instructions.
1. Payment processors, intermediaries responsible for payment management, or insurance providers, for obtaining payment for the contracted services or products, as well as providing protection related to acquired products.
2. Providers of computer systems, cloud services, databases, and technological services.
2. Government authorities: we must provide personal data in compliance with judicial orders, administrative requests issued by authorities with lawful access powers, legal or regulatory obligations, or to act cooperatively with government authorities.
3. Other users of the website/application: we may disclose your personal data to other users to identify that a question was created by you, institutions, or third parties, when there are sufficient reasons to believe that your activity is suspicious (attempting or committing a crime or attempting to harm others).
4. It is important to note that all personal data will be shared with administrative authorities within the limits of the Law and, where allowed and not restrictive to the exercise of their official duty, confidentiality of the shared data will be requested.

STORAGE AND SECURITY OF PERSONAL DATA

We retain your personal data for as long as necessary to fulfill the purposes for which they were collected, regulatory or legal requirements, or until the legal limitation period for certain legal or contractual liabilities expires. After this period, the data will be deleted or anonymized (so that no person can be identified, as permitted by the laws of each country).

In certain cases, and whenever permitted or required by applicable law, we will retain internal use of the personal data you asked us to delete for a limited time. Once this period expires, we will delete your personal data.

In accordance with Article 48 of Law No. 13.709/2018, we will notify you and the National Data Protection Authority (ANPD) of any security incident that may pose a risk to your personal data.

YOUR RIGHTS AS A PERSONAL DATA SUBJECT

Transparency regarding the processing of your personal data is a priority for MachLeV. In addition to the information provided in this Privacy Policy, you may also exercise the rights established in the General Data Protection Law (LGPD – Law 13.709/2018), including:

• Confirmation of whether personal data processing is being carried out.
• Access to personal data.
• Correction of incomplete, inaccurate, or outdated personal data.
• Objection or restriction to the processing of personal data when carried out in disagreement with LGPD requirements.
• Deletion of personal data processed with consent or those unnecessary, excessive, or when some LGPD requirement has not been met, whenever possible.
• Information on the situations, partners, and other institutions with whom we may share or from whom we may receive personal data concerning you.

All requests will be submitted free of charge and will undergo preliminary evaluation of your identity and feasibility at the email: contact@gradepen.com, in order to fulfill any obligations preventing complete compliance with data subject requests.

CHANGES TO THIS PRIVACY POLICY

We are constantly seeking to improve the experience of our platform users. Therefore, our personal data processing practices may be updated with the inclusion of new features and services.

We value transparency in the way we process your personal data. Whenever any relevant condition of this Privacy Policy is changed, such amendments will be valid, effective, and binding once the new version is published on our website.

CONTACT US

Whenever you have any questions about this Privacy Policy, even after reading it, or need to interact with us regarding matters involving your personal data, you may contact us through our email contact@gradepen.com, requesting clarifications regarding the privacy of your personal data.

Version June 30, 2024