Documents
Privacy Policy
Protecting personal data is part of the practices adopted by Willer · Systems and guides how information is collected, used, stored, shared, and protected during use of this website and in relationships with clients, prospective clients, partners, suppliers, and other data subjects.
1. Purpose of this Policy
This Privacy Policy establishes guidelines applicable to the processing of personal data by Willer · Systems in connection with its website, contact channels, and relationships arising from the presentation, analysis, engagement, and performance of services.
Personal data will be processed in accordance with applicable Brazilian law, especially the General Data Protection Law (Lei Geral de Proteção de Dados Pessoais — LGPD), Law No. 13,709/2018.
2. Scope
This Policy applies to information processed by Willer · Systems as a result of access to the website, contact through its official channels, and relationships with individuals connected to clients, prospective clients, partners, suppliers, service providers, and other interested parties.
When necessary, supplementary information may be provided to clarify specific privacy practices related to a particular service, system, project, feature, or engagement.
Systems developed for clients may have their own privacy policies, defined according to each party’s responsibilities and the nature of the corresponding operation. This Policy does not replace those specific documents.
3. Information That May Be Collected
Willer · Systems may receive personal data when a data subject makes contact, requests information, presents a need, requests a proposal, begins negotiations, engages a service, or maintains a relationship related to the activities performed.
Depending on the situation, the information may include:
- full name;
- email address;
- telephone number;
- company, organization, role, or professional affiliation;
- information provided in messages, documents, meetings, or requests;
- data required to prepare proposals, contracts, billing, tax documents, and administrative records;
- information related to a project, process, or operation presented by the data subject or by the organization they represent;
- other data required to fulfill a specific request or obligation.
The amount and nature of the data processed will depend on the purpose of the interaction. Willer · Systems seeks to limit collection to what is appropriate and necessary for each context.
4. Sensitive Personal Data and Confidential Information
The website is not primarily intended to collect sensitive personal data.
Data subjects should avoid voluntarily sending sensitive information, credentials, passwords, private keys, authentication codes, trade secrets, or other data whose disclosure could create risk, unless providing such information is necessary, requested, and carried out through a channel appropriate to the context.
When information of this nature is indispensable to the performance of a particular service, its processing must observe measures consistent with the purpose, necessity, confidentiality, and applicable law.
5. Information from Other Sources
Willer · Systems may receive information from third parties when necessary for a commercial relationship, project execution, data validation, compliance with obligations, or provision of services.
Depending on the circumstances, these sources may include organizations represented by the data subject, partners, suppliers, service providers, platforms used in the relationship, and legitimately accessible public sources.
Receiving information from third parties does not authorize its use for a purpose incompatible with the context in which it was obtained.
6. Technical Information and Automatic Logs
During access to the website, certain technical data may be processed automatically by servers, hosting services, security mechanisms, or components required for the page to function.
Depending on the infrastructure used, this information may include:
- Internet Protocol address;
- date and time of access;
- pages or resources requested;
- browser and operating system;
- general device type;
- referrer address;
- technical logs related to availability, performance, and security.
These logs may be used to operate the website, diagnose failures, preserve security, prevent abuse, analyze incidents, and maintain technical records consistent with service provision.
8. How Information May Be Used
Depending on the context, personal data may be used to:
- receive, identify, and respond to requests;
- understand needs, processes, requirements, and issues presented;
- conduct meetings, analyses, and assessments related to projects;
- prepare quotations, proposals, contracts, and other documents;
- perform, monitor, and document contracted services;
- maintain communication before, during, and after service performance;
- manage relationships with clients, partners, suppliers, and service providers;
- process billing, payments, and tax documents when applicable;
- comply with legal, regulatory, contractual, and administrative obligations;
- preserve the security of the website, systems, data, and communications;
- prevent fraud, abuse, unauthorized access, and security incidents;
- exercise rights and respond to administrative, judicial, or extrajudicial claims;
- improve processes, services, and customer service practices.
9. Legal Bases for Processing
Personal data processing will be associated with a legitimate purpose and a legal basis permitted by applicable law.
Depending on the situation, processing may be necessary for preliminary procedures related to an engagement, performance of a contract, compliance with a legal or regulatory obligation, regular exercise of rights, pursuit of legitimate interests compatible with the rights of the data subject, or other grounds provided by law.
When consent is the appropriate basis for a particular activity, it will be requested in a manner consistent with the corresponding purpose and may be withdrawn in accordance with applicable law.
10. Data Retention and Deletion
Personal data will be retained for the period necessary to fulfill the purposes for which it was collected or while there is a legitimate basis for retaining it.
Retention periods may vary according to the nature of the information, the existence of a contractual relationship, support or continuity needs, legal, tax, accounting, and regulatory obligations, limitation periods, exercise of rights, fraud prevention, and preservation of security.
Once the purpose has ended and there is no basis for retention, the data may be deleted, anonymized, or retained only in cases authorized by law.
11. Sharing of Information
Willer · Systems does not sell or rent personal data.
Information may be shared when necessary to carry out the purposes described in this Policy, including with service providers related to hosting, infrastructure, email, storage, security, communications, accounting, billing, payment, or other resources actually used.
Information may also be shared:
- to comply with a legal or regulatory obligation;
- in response to a court order, request, or determination by a competent authority;
- for the regular exercise of rights;
- to protect the security, integrity, rights, or property of Willer · Systems, its clients, or third parties;
- to investigate or prevent fraud, abuse, incidents, or unlawful activity;
- in corporate reorganizations or equivalent transactions, when legally applicable.
Whenever possible and appropriate, sharing should be limited to the information necessary for the corresponding purpose.
12. Service Providers and Third-Party Processing
Operation of the website and performance of Willer · Systems activities may depend on services provided by third parties.
These third parties may process personal data only to the extent necessary for the contracted service and in accordance with the responsibilities applicable to each relationship.
Each external platform or service may also have its own terms and privacy policies, particularly where the data subject interacts directly with the third-party environment.
13. Storage and International Transfers
The infrastructure used by Willer · Systems or its service providers may involve servers, systems, distribution networks, backups, or services located outside Brazil.
In these situations, personal data may be stored or transferred internationally, subject to applicable data protection requirements and measures appropriate to the nature of the processing.
The technical location of a server or provider does not, by itself, change the purposes described in this Policy.
14. Information Security
Willer · Systems adopts technical and organizational measures intended to protect personal data under its responsibility against unauthorized access and accidental or unlawful situations involving destruction, loss, alteration, disclosure, or improper processing.
Measures adopted may include access controls, authentication, environment segmentation, updates, technical logs, backups, privilege restrictions, and other practices appropriate to the nature of the systems and information involved.
No method of electronic transmission, processing, or storage eliminates all risks. For this reason, absolute security cannot be guaranteed.
15. Data Subject Rights
Under applicable law, data subjects may exercise rights relating to their personal data, subject to the legal limits and requirements applicable to each situation.
These rights may include, where applicable:
- confirmation of the existence of processing;
- access to personal data;
- correction of incomplete, inaccurate, or outdated data;
- anonymization, blocking, or deletion of unnecessary, excessive, or improperly processed data;
- data portability, where applicable and regulated;
- information about data sharing;
- information about the possibility of withholding consent and the consequences of doing so, where applicable;
- withdrawal of consent, when consent is the legal basis used;
- objection to processing in cases permitted by law;
- deletion of data processed on the basis of consent, subject to legally permitted retention.
Before fulfilling a request, reasonable procedures may be adopted to verify the requester’s identity and protect the data against access or alteration by an unauthorized person.
16. Privacy Requests
Requests related to personal data may be submitted through the official channel below:
Email: [email protected].
To help identify the request, it is recommended that the subject line indicate that the message concerns privacy or data protection.
Willer · Systems may request additional information strictly necessary to confirm the requester’s identity, locate the relevant data, or understand the request submitted.
17. Data of Children and Adolescents
The website and services presented by Willer · Systems are primarily directed toward professional, business, and institutional relationships and are not intended to intentionally collect personal data from children.
If data concerning children or adolescents becomes necessary in a specific context, its processing must comply with applicable legal requirements and the best interests of the data subject.
18. Links and Third-Party Environments
The website may contain links to third-party websites, systems, platforms, or services.
Willer · Systems does not control the privacy practices of external environments. Access to these resources will be subject to the terms and policies established by their respective operators.
It is recommended that applicable policies be reviewed before personal data is provided on third-party websites or platforms.
19. Communications and Marketing
Contact information may be used for communications related to requests, proposals, projects, services, and existing relationships.
If promotional communications or direct marketing activities are adopted, processing must comply with applicable law, the corresponding purpose, and appropriate mechanisms allowing the data subject to express their preferences.
This Policy does not state that behavioral advertising, advertising profiling, or sharing of data with advertising networks is used when such practices are not actually implemented.
20. Updates to this Policy
This Privacy Policy may be updated whenever necessary due to the evolution of the website, changes to services, adoption of new technologies, operational changes, or the need for legal or regulatory compliance.
The current version will be the one published at this address.
When changes are considered significant, a prominent notice may be provided on the website or through another means appropriate to the context.
21. Related Documents
This Policy should be read together with:
- the Terms of Use;
- the Cookie Policy;
- the Legal Notice;
- contracts, proposals, terms, and other specific documents that may apply to the relationship with Willer · Systems.
22. Contact
Questions related to this Privacy Policy or the processing of personal data may be submitted to: