Privacy and Personal Data Protection Policy

Privacy and Personal Data Protection Policy

PRIVACY AND PERSONAL DATA PROTECTION POLICY 1. CONTROLLER AND IDENTIFICATION The controller is K.r.b do Carmo da Luz Outras Atividades Profissionais, trade name Acustica Lagos, identified by Brazilian CNPJ 20.172.919/0001-70, established at Rua Quatorze, 736, Reserva do Pero, Cabo Frio, Rio de Janeiro, ZIP 28921-665, Brazil. This Policy applies to websites, authenticated areas, accounts, licensing, support and online features of the CRYSOUND/SONARA ecosystem administered by Acustica Lagos. 2. LOCAL-FIRST ARCHITECTURE AND RESPONSIBILITY FOR TECHNICAL DATA SONARA uses a hybrid, local-first architecture. Measurements, projects, acoustic files, technical evidence and other work data remain by default on the user’s computer, under the user’s responsibility for storage, backup, retention and continuity. Acustica Lagos does not automatically receive or keep a complete copy of those data. Limited data enter the online environment only when required for the account and service or when the user knowingly activates a function that requires transmission, such as an authorized transfer between SONARA Connect PC and SONARA Live SONARA is not a general cloud-storage service. Primary custody of local technical files belongs to the user. This includes choosing where files are saved, maintaining backups, controlling access to the computer and defining retention. Acustica Lagos is responsible only for data it actually receives or generates in the online environment under its administration. 3. WHEN DATA ENTER THE ONLINE ENVIRONMENT Technical content is not transmitted automatically merely because the local software is used. When a hybrid feature requires transmission, the flow is initiated or authorized by the user for the selected purpose. One example is transfer between SONARA Connect PC and SONARA Live. That authorization is specific to the operation and is not a general authorization to copy all projects, measurements or files from the computer to the cloud. 4. PERSONAL DATA PROCESSED Categories: account registration and contact data; authentication credentials and identifiers; commercial and licensing information; support records; access, session, security and audit logs; and, only when the user activates the corresponding online function, the technical data strictly required to execute that function Sources: information provided directly by the user or represented organization; events generated by use of the account and online services; technical security records; and files or data that the user voluntarily decides to transmit through a hybrid SONARA feature Online data may include account registration, authentication, licensing, billing, support, and minimum security and audit records. Measurement and project data are processed online only when required by a feature the user chose to use. 5. PURPOSES AND LEGAL BASES Purposes: manage accounts, authentication, licenses and modules; process commercial relationships and billing; provide support; record events required for security, audit and integrity; and execute online features that the user chooses to activate, including authorized transfers between SONARA Connect PC and SONARA Live Legal bases: performance of a contract and pre-contractual procedures; compliance with legal or regulatory obligations where applicable; exercise of legal rights; legitimate interests strictly necessary for security, fraud prevention and operation of the service, subject to necessity and impact assessment; and consent where the operation requires a specific manifestation by the data subject Acustica Lagos applies purpose limitation, adequacy, necessity, transparency, security, prevention and accountability. The existence of a technical capability does not authorize indiscriminate collection or a silent change of purpose. 6. NO EXTERNAL CUSTODY OF LOCAL FILES Acustica Lagos may use infrastructure, hosting, communications, commercial processing, support, security or technical service providers when required to deliver the service. Those providers process only the data necessary for the contracted purpose and must observe compatible confidentiality, security and data-protection obligations. This does not authorize general custody of the user's local technical files. The local-first architecture does not presume international transfer of the user's local technical files. If a necessary infrastructure or service provider processes data outside Brazil, the transfer must follow the applicable legal grounds, safeguards and mechanisms, and processing remains limited to the purpose of the service. Acustica Lagos does not claim ownership of the user’s measurements, projects or technical documents. Content remains under the control of its owners, except for the strictly necessary processing when the user chooses an online function. 7. SESSIONS, COOKIES AND BROWSER FEATURES The system uses only technical mechanisms required for web operation, such as sessions, authentication, security, preferences and local storage necessary for the interface. This policy does not authorize advertising tracking or transmission of local technical files to analytics services Mechanisms essential to security and authentication may remain active while needed for the session. Their use does not convert local technical files into data hosted by Acustica Lagos. 8. RETENTION AND DELETION Technical files kept on the computer follow criteria defined by the user, who is responsible for custody, backup and deletion. In the online environment, account, licensing, transaction, support, security, audit, acceptance and operational records are retained only for a period compatible with service delivery, legal obligations, security, audit and exercise of legal rights. Data transmitted through a hybrid function are processed for the period necessary to perform the chosen operation and according to the controls available in the service Deletion of a file that exists solely on the computer is the user’s responsibility. For online data controlled by Acustica Lagos, retention remains tied to purpose, service delivery, security, legal or regulatory duties, audit and exercise of legal rights. When no longer needed, deletion, anonymization or another legally appropriate measure is applied as applicable. 9. SECURITY Account- and role-based access control, authentication and session protection, access and security event logging, audit trails, legal-document versioning and hashes, privilege segregation, updates controlled through the Update Manager and integrity controls. Security of technical files that remain on the PC also depends on safeguards adopted by the user on the device, operating system, network and backup routine No control eliminates all risk. Protection is therefore allocated by layer: Acustica Lagos protects the online components it administers; the user protects the computer, credentials, network, local files and backups. 10. DATA-SUBJECT RIGHTS The data subject may use the official Acustica Lagos channels or the privacy-request workflow available in the system. The request is recorded, may require proportionate identity verification, and is assessed according to the right exercised and the data actually processed by Acustica Lagos. Technical data that exist only on the user’s PC are not in Acustica Lagos custody and must be managed by the user The data subject may exercise applicable rights, including confirmation of processing, access, correction and other rights available in context. The response concerns only data actually processed or controlled by Acustica Lagos; a file that remains exclusively on the user’s PC and was never transmitted cannot technically be supplied, corrected or deleted by Acustica Lagos. 11. AUTOMATED DECISIONS Standard SONARA operation does not use solely automated decisions intended to produce legal or similarly significant effects on the data subject. Acoustic calculations, technical classifications and software results are support tools and remain subject to evaluation by the user or responsible professional 12. CHILDREN AND ADOLESCENTS The services are intended for professional, business, technical and specialized educational use and are not specifically directed to children. Acustica Lagos does not intentionally collect children’s data as an ordinary purpose of SONARA 13. INCIDENTS The incident channel is The official Acustica Lagos service channels and the authenticated system environment, when available, for registration and traceability of the occurrence. Incidents involving the online environment administered by Acustica Lagos are assessed according to nature, affected data, risk and containment measures. Incidents confined to the user’s computer, network or local backups are handled by the user, without prejudice to technical support where applicable. 14. CONTACTS Privacy: the official Acustica Lagos service channels made available on the website and in the authenticated area of the system Service and support: the official Acustica Lagos service and support channels made available on the website and in the authenticated area of the system 15. VERSION, EFFECTIVE DATE AND LAW This Policy is controlled by version, content hash, publication date and effective date. Published versions remain immutable; a material change creates a new version. Applicable rules: laws of the Federative Republic of Brazil. Where a choice of forum is legally valid, Cabo Frio, Rio de Janeiro, Brazil is indicated, without excluding mandatory jurisdiction or any forum guaranteed by applicable mandatory law

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