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PRIVACY POLICY – SMART

smart.dcsbrasil.com.br | Updated on: 11/29/2025

1. Who We Are

This Privacy Policy describes how DCS BRASIL LTDA - EPP, registered under CNPJ no. 19.288.416/0001-85, headquartered at Av. Paulista, 1471 – Edif. Barão de Cristina – Suite [xx] – Bela Vista – ZIP 01311-927 – São Paulo/SP, hereinafter referred to as "DCSBRASIL", collects, uses, stores and shares personal data in the context of using the Smart application available at smart.dcsbrasil.com.br (hereinafter "Smart" or "Application").

Smart is a DCSBRASIL product focused on digital marketing management and automation.

The data controller within the scope of this Policy is DCS BRASIL LTDA - EPP, represented by Danilo Ceccon.

Contact for privacy matters:
Email: comercial@dcsbrasil.com

2. Who This Policy Applies To

This Privacy Policy applies to:

  • Users registered on Smart (individuals who use the platform);
  • Representatives of corporate clients who use Smart;
  • Visitors who access the site/application smart.dcsbrasil.com.br;
  • Users who connect their Meta Platform accounts (e.g., Facebook and Instagram) to Smart.

This Policy does not replace or modify the privacy policies and terms of use of Meta (Facebook, Instagram, etc.) or any other third parties. When you use Facebook, Instagram, or other Meta services, your data is also processed according to their policies.

3. Personal Data We Collect

We may collect the following categories of personal data, always in compliance with the Brazilian General Data Protection Law – LGPD (Law No. 13,709/2018):

3.1. Data provided directly by you

  • Full name;
  • Email;
  • Contact phone number;
  • Access identification data (login/password) to Smart;
  • Data of the company you represent (company name, tax ID, business area, position/role);
  • Communication and marketing preferences (e.g., whether you wish to receive notifications).

3.2. Data from Meta Platforms (Facebook, Instagram, etc.)

When you connect your Facebook, Instagram, or other Meta accounts to Smart, we may receive, according to the permissions you grant to the application, for example:

  • Basic profile data (name, user ID, profile picture, email associated with the account, if authorized);
  • Information about pages and professional accounts you manage (page name, page ID, photo, description);
  • Statistics and metrics (campaign insights, reach, engagement, clicks, ad and post performance);
  • Interaction information (user messages on pages, post comments, if the functionality is enabled and authorized);
  • Other information necessary for the operation of integrations, always respecting the scopes and permissions approved by Meta.

The exact set of data received will depend on the permissions you authorize during the account connection process with Smart.

3.3. Browsing and usage data

During the use of Smart, we automatically collect:

  • IP address;
  • Device and browser data (type, version, operating system);
  • Date and time of access;
  • Pages and features accessed;
  • Session identifiers and cookies;
  • Error logs and usage logs for security, support, and service improvement purposes.

4. Legal Bases for Data Processing (LGPD)

We process your personal data based on the following LGPD provisions:

  • Contract execution (art. 7, V): to provide the contracted Smart service and fulfill the offered functionalities;
  • Legal or regulatory compliance (art. 7, II): to meet tax, accounting, regulatory obligations and orders from authorities;
  • Legitimate interest (art. 7, IX): to prevent fraud, ensure platform security, improve our services and perform internal analysis, always with impact assessment and respect for data subject rights;
  • Consent (art. 7, I): for direct marketing actions, sending promotional communications and other situations where the law requires consent, which may be revoked at any time.

5. How We Use Your Data

We use the collected personal data to:

1. Provide and operate Smart

  • Create and manage your user account;
  • Enable Smart connection to Meta accounts (Facebook, Instagram, etc.);
  • Enable configuration, scheduling, management, and analysis of marketing campaigns and content.

2. Integrate with Meta platforms and other third-party tools

  • Connect and manage pages and professional accounts;
  • Obtain ad and post performance metrics;
  • Assist in message and interaction management, when enabled.

3. Improve our products and services

  • Analyze Smart usage to enhance features;
  • Develop new automation and digital marketing solutions;
  • Perform tests, bug fixes, and stability monitoring.

4. Communicate with you

  • Send notices about your account, security updates, technical and operational notifications;
  • Send commercial communications and marketing materials, when permitted by law or with your consent, with opt-out option.

5. Comply with legal and regulatory obligations

  • Respond to requests from competent authorities;
  • Prevent fraud, ensure application and data security and integrity.

6. Sharing of Personal Data

We may share your personal data in the following situations:

1. Service providers (operators)

  • Hosting companies, server infrastructure, email services, monitoring tools, support and customer service, among others.
  • These providers process data on behalf of DCSBRASIL, according to our instructions and in compliance with LGPD and Meta Platform Terms.

2. Meta Platforms and other authorized integrations

  • When you connect your Facebook, Instagram, or other Meta services account to Smart, data is exchanged with these platforms to enable contracted functionalities (e.g., metrics reading, post scheduling, campaign management).
  • The use of this data by Meta is governed by Meta's own terms and policies, which you must also accept.

3. Legal compliance

When necessary, we may disclose data to public authorities, regulatory agencies, tax or judicial authorities, to comply with law, regulation, legal process, or judicial/administrative order.

4. Corporate situations

In case of reorganization, merger, acquisition, or sale of assets, data may be transferred to the successor, always respecting applicable legislation and ensuring continuity of protection.

We do not sell personal user data to third parties.

7. Data from Meta Platforms

In compliance with Meta Platform Terms and Developer Policies, we commit to:

  • Use data received from Meta Platforms exclusively to provide Smart functionalities requested by you (marketing management, campaign automation, related reports and analyses);
  • Not use data obtained via Meta for targeting purposes outside the authorized scope, creating sensitive profiles, selling data, or any purpose other than those described in this Policy and Platform Terms;
  • Not combine data obtained improperly with third-party information or external databases in a manner that violates Platform Terms or applicable legislation;
  • Delete or anonymize data obtained via Meta Platforms when:
    • You disconnect the Facebook/Instagram account from Smart;
    • You request data deletion, respecting legal deadlines and regulatory obligations;
    • Data is no longer necessary for the purposes described in this Policy.

8. Cookies and Similar Technologies

Smart may use cookies and similar technologies to:

  • Keep your session authenticated;
  • Remember browsing preferences;
  • Generate usage statistics and measure site/application performance;
  • Improve user experience.

You can adjust cookie settings directly in your browser. Disabling certain cookies may affect the functioning of parts of Smart.

9. Storage, Location and Retention Period

Personal data is stored on servers owned or contracted by DCSBRASIL, which may be located in Brazil or abroad.

When there is international data transfer, we will adopt the necessary measures to ensure LGPD compliance, including appropriate contractual clauses and observance of equivalent levels of protection.

Data will be maintained:

  • For the time necessary to fulfill the purposes described in this Policy;
  • For the period required by law or regulations (e.g., tax and accounting deadlines);
  • While there is an active relationship between you (or the company you represent) and DCSBRASIL.

Data related to Meta integrations will be maintained while the integration is active and, after revocation, will be deleted or anonymized within a reasonable period, observing the minimum necessary for security, fraud prevention, and compliance with legal obligations.

10. Information Security

We adopt reasonable technical and administrative measures to protect personal data against unauthorized access, loss, misuse, alteration, or destruction, such as:

  • Access control based on credentials and profiles;
  • Encryption in transit whenever possible (e.g., HTTPS/TLS);
  • Incident monitoring;
  • Backup routines and contingency plans;
  • Training and confidentiality obligations for employees and partners.

No system, however, is completely invulnerable. If we identify any relevant security incident that may pose risk or significant harm to you, we will notify those involved and competent authorities, as per LGPD.

11. Data Subject Rights

Under LGPD, you have, among others, the following rights regarding your personal data:

  • Confirmation of data processing existence;
  • Access to data;
  • Correction of incomplete, inaccurate, or outdated data;
  • Anonymization, blocking, or deletion of unnecessary, excessive, or non-compliant data;
  • Data portability to another service or product provider, when applicable and regulated by competent authority;
  • Deletion of personal data processed based on consent, when applicable;
  • Information about data sharing with public and private entities;
  • Information about the possibility of not providing consent and the consequences of such refusal;
  • Revocation of consent, when processing is based on it.

To exercise your rights, send a request to:
comercial@dcsbrasil.com

In the subject line, indicate: "Data Subject Rights – Smart".

We may request additional information to confirm your identity and securely fulfill the request.

12. Data Deletion Request (including Meta data)

If you wish to request the deletion of your personal data processed by Smart, including data obtained from Meta Platforms (Facebook, Instagram, etc.), you may:

1. Send an email to:

comercial@dcsbrasil.com

Informing, at minimum:

  • Your name;
  • Email used in registration;
  • Account/company identification;
  • Whether the request involves connected Facebook/Instagram data.

2. Disconnect accounts

Disconnect Facebook/Instagram accounts directly through Smart settings (when available) or in Meta's own settings, revoking permissions granted to the application.

After receiving the request and/or access revocation, we will take the necessary measures to delete or anonymize data that does not need to be maintained due to legal obligation or to protect our rights in any judicial or administrative action.

13. Children and Adolescents

Smart is not intended for children or adolescents. We do not intentionally process personal data of children (persons under 12 years old) without specific and prominent consent from at least one parent or legal guardian.

If we become aware that children's data has been collected improperly, we will take the necessary measures to delete it, unless storage is necessary to comply with legal obligation.

14. Updates to This Policy

This Privacy Policy may be updated at any time to reflect legislative, regulatory, technological, business changes, or requirements from partner platforms such as Meta.

When there are relevant changes, we may inform you through a notice in Smart itself or by email, and the updated version will always be available at smart.dcsbrasil.com.br.

We recommend that you periodically review this Policy to stay informed about how we process your personal data.

15. How to Contact Us

If you have questions, comments, or requests related to this Privacy Policy or the processing of your personal data, please contact:

DCS BRASIL LTDA - EPP

Responsible: Danilo Ceccon

Email: comercial@dcsbrasil.com

Address: Av. Paulista, 1471 – Edif. Barão de Cristina – Suite [xx] – Bela Vista – ZIP 01311-927 – São Paulo/SP – Brazil