Privacy Policy

Inner AI's Privacy Policy

Last updated September 12, 2024

WHAT WE DO WITH YOUR INFORMATION

We have done our utmost to explain clearly and simply what personal data we will need from you and what we will do with it. That's why we've listed the most important points below, which you can also read in detail in our Privacy Policy.

To talk specifically about your personal data, we have a specific channel: dataprotection@innerai.com.

1) Who is responsible for data processing?

We are the controllers of the processing of personal data relating to Simple Users, i.e. once you enter our platform, we will collect some information and make decisions in order to provide our service in the best and safest way possible. 

With regard to Business Users, we are data operators, since these companies make the relevant decisions about the data included on the platform, including their representatives.

In addition, some operators are necessary for the platform to be available, such as: server platforms, hosting, chatbot, AI models, among others.  This gives these companies access to your data. However, our contracts always ensure that your information is treated securely. 

2) How will we secure your data?

To ensure that your information is stored in a secure environment, the platform uses AWS and Azure servers, to which access is restricted. This means that these companies only have access to your data in order to store it and keep it secure once you provide it to INNER AI. In addition, the use of these servers may imply an international transfer of your personal data to the country where the servers are based, the United States. 

3) What data do you need to provide us with in order to use our platform?

To register and use our services, you must provide the following information:

  • If you are a Simple User: full name, e-mail address.
  • If you are a Business User: full name of the company representative(s), e-mail, CNPJ, company name and address.

4) For what purposes do we use your personal data?

All your data is processed for specific purposes and in accordance with the General Personal Data Protection Act. We may process this information for:

  • Account creation and identification;
  • Create digital characters (avatars);
  • Providing our service integrated with the APIs on the platform;
  • Send contacts related to sales and marketing;
  • Drawing up contracts and complying with tax obligations;
  • Providing support and customer service;
  • Offer our services or products;

5) Who do we share your personal data with?

We will not share your data with third parties, except in the cases mentioned in the Privacy Policy, in the event of the legal consent of the holder of the personal data and by virtue of a court order or legal determination.

6) Will your access logs be collected?

When you enter our platform, we collect your access logs, i.e. a set of information relating to the date and time of use of a particular Internet application from a particular IP address. This information will be kept by INNER AI, under confidentiality, in a controlled and secure environment, for a minimum period of 06 (six) months, under the terms of Law no. 12.965/2014, and article 7, II, of Law no. 13.709/18. 

7) Will personal data be collected indirectly?

In addition to access logs, we may also collect some information indirectly, in accordance with our Cookie Policy. 

8) Will records of communications be stored?

We will also store the conversations you have with us on our communication channels, as this will improve your service and make it more efficient and bring more security to the parties. 

9) What are your rights?

Even if you have already provided us with your personal data, you have the full right to, at any time, ask the controller to: confirm the existence of the processing of your data; access your data; correct your data; anonymize your data; block or delete data that is unnecessary, excessive or processed in breach of the law; request data portability to another provider; delete data, except for that required by law; obtain information on who the controller has shared data with; obtain information on the possibility of not providing consent and the consequences of refusing; and go back and revoke your consent.

10) What is the content of the Privacy Policy?

The following Privacy Policy is divided as follows to make it easier for you to access the information:

  1. Date Text Available;
  2. Explanation of Technical or Foreign Language Terms;
  3. Handling Agents;
  4. Information Security;
  5. Data Collection;
  6. Processing of Personal Data;
  7. Cancellation of the Platform, Access Accounts and Deletion of Data;
  8. Rights of the Data Subject;
  9. Changes to the Privacy Policy;
  10. Privacy Communication Channel;
  11. Contact on General Matters.

PRIVACY POLICY

Before accessing the INNER AI platform, it is important that you read, understand and freely, unequivocally and informedly accept this Privacy Policy.

This platform, whose name is INNER AI, is owned and maintained by INNER AI TECNOLOGIA LTDA, registered with the Brazilian National Register of Legal Entities under nº 42.888.509/0001-62, with address at Avenida Sagitário, nº 138, suite 2513B, condominium A, Sitio Tambore Alphaville, Postal Code nº 06473-073 Barueri - SP, Brazil.

This document aims to provide information on the collection, use and storage ("processing") of data provided by Visitors and complies with Federal Law nº 12.965/2014 (Civil Framework for the Internet) and Federal Law nº 13.709/18 (Brazilian Data Protection Law).

1. DATE THE TEXT WAS MADE AVAILABLE

1.1 This document was drafted and made available on 09/12/2024.

2. EXPLANATION OF TECHNICAL OR FOREIGN LANGUAGE TERMS

2.1 Below are the meanings of technical nomenclature and terms: 

  • Controller: a natural or legal person, whether governed by public or private law, who is responsible for decisions regarding the processing of personal data.

  • Cookies: small text files that are stored on the internet user's computer and can be retrieved by the website that sent them during browsing. They are mainly used to identify and store information about Users.

  • Cryptography: set of principles and techniques for encrypting writing, making it unintelligible to those who do not have access to the agreed conventions.

  • Personal data: information relating to an identified or identifiable natural person.

  • Sensitive personal data: personal data on racial or ethnic origin, religious conviction, political opinion, membership of a trade union or religious, philosophical or political organization, data relating to health or sex life, genetic or biometric data, when linked to a natural person.

  • DPO: person appointed by the controller and operator to act as a communication channel between the controller, the data subjects and the National Data Protection Authority (ANPD).

  • AI: Artificial intelligence. AI is human-like intelligence displayed by mechanisms or software, and is also a field of academic study.

  • IP (or Internet Protocol): Unique identification for each computer connected to a network.

  • Operator: a natural or legal person, governed by public or private law, who processes personal data on behalf of the controller.

  • Data processing: any operation carried out with personal data, such as those relating to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

    2.2 The types of Users of the Platform are:

    2.2.1 Simple User: People who register directly on the platform for personal or professional use. These people can become Paid Users in the future if they wish to use paid features.

    2.2.2 Business User: People who are part of a company that has contracted INNER AI in order to use its functionalities for professional and commercial use.

3. PROCESSING AGENTS

3.1 We are controllers of the processing of personal data relating to Simple Users, i.e. once Simple Users register on our platform or use our tools, we collect certain information and make decisions in order to provide our service in the best and safest way possible. 

3.2 We are the operators of the processing of personal data of Business Users and people who access the system through this type of account, since our technology is contracted to be used by the contracting company in its activities, without our interference. We therefore process data based on the decisions of our clients, the controllers.

3.3 Some operators are necessary for the platform to be available. They will therefore have access to User data for the following purposes:

3.3.1. Intercom Chat: used to assist Users, store conversations and for training and customer service purposes;

3.3.2 Experience personalization software: data analysis and product performance software, responsible for traffic analysis, preferences and ad distribution. These include Google Analytics, Google, Microsoft, Pendo and PostHog.

3.3.3 AWS and Azure: used as storage servers and for platform security.

3.4 Our contracts always prioritize the secure handling of User information. For this reason, once these companies have access to this data, they become responsible for the security, treatment and proper sharing of this information, and may not disclose it for other purposes, in breach of current legislation or this Privacy Policy, under penalty of being liable for all penalties, in particular those of a civil, criminal nature and those applied by the National Data Protection Authority. 

3.5 International transfer: the servers used by INNER AI, which are equipped with mechanisms capable of ensuring the security of your data, are located outside Brazil, more precisely in the United States and are used so that INNER AI can perform its service properly, as determined by article 33, IX, of Brazilian Federal Law nº 13.709/18.

4. INFORMATION SECURITY

4.1. INNER AI is very concerned about the security of your personal data. Therefore, it undertakes to keep the information provided on the platform in a secure environment, observing the size of the processing, by means of technical measures compatible with international standards and by encouraging the use of good practices, which includes an analysis of information security risks and the implementation of effective and widespread Information Security Policies.

4.1.1 In addition, we have effective measures and controls in place to avoid or reduce Information Security risks, in order to prevent, detect, respond to and recover quickly from a threat to protect the confidentiality, integrity and availability of technological assets and information.

4.1.2 We take strict measures to restrict access to the database, using authentication and authorization mechanisms such as access restricted by specific keys and two-step authentication. 

4.1.3 We use the most advanced AI models on the market to generate content in text, audio, video and images and no data included in INNER AI will be used to feed or teach artificial intelligence models. The information entered by the User will be used exclusively to fulfill their request and then stored in a separate database.

4.1.4 We are constantly aware of the AI models used in order to avoid any kind of discrimination or generation of content that is not lawful. However, we clarify that these technologies are independent and are not developed or taught by INNER AI. Therefore, in the event of any type of damage caused exclusively by the AI model, INNER AI will not be held liable.

4.2 All access logs, a set of information relating to the date and time of use of a given internet application from a given IP address, will be kept by INNER AI, under secrecy, in a controlled and secure environment, for a minimum period of 06 (six) months, under the terms of Brazilian Federal Law nº 12.965/2014, and article 7, II, of Brazilian Federal Law nº 13709/18.

4.3 INNER AI is committed to preserving the stability, security and functionality of the platform, through technical measures compatible with international standards and by encouraging the use of good practices. However, no service available on the Internet is fully guaranteed against illegal intrusions. In cases where unauthorized third parties hack into the system illegally, INNER AI will make every effort to find the person responsible for the illegal action, but will not be liable for any damage caused by them.

5. DATA COLLECTION

5.1 In order to register and use INNER AI services, the following information will be required:

5.1.1 For Simple Users: full name and e-mail address.

5.1.2 For Business Users: full name and e-mail address of the representative, CNPJ, company name and address.

5.2. Digital Character (Avatar): Business Users may optionally create digital characters (avatars) of Simple Users of the company on the platform, in which case they will need to share photos and voice (audiovisual content) with INNER AI. 5.2.1. In this case, Business Users will be fully responsible for collecting specific and informed consent from Simple Users, and INNER AI will not be responsible, under any circumstances, for the creation of digital characters using photos and voice of Simple Users without their proper consent. 5.2.2. INNER AI will not pay any amount to Users for the use of their photos and voice.

5.3. Contact History: INNER AI stores information about all interactions already carried out between Users, such as the support chat and email, as this will improve your service, make it more efficient and secure for the parties. In addition, we use chat conversations for training and improving customer service.

5.4. Information we collect indirectly: in addition to access logs, we may also collect some information indirectly, as per our Cookie Policy.

6. PROCESSING OF PERSONAL DATA

6.1 By accepting this privacy policy, the User understands that the collection and processing of the following personal data is necessary for the performance of the contract with INNER AI, as set out below.

6.1.1 Full name, company name and Brazilian National Register of Legal Entities. Used to create, identify and verify the User. This is essential personal data so that we can contact the User to respond to their requests and provide targeted responses. It is also used to create the Contract with INNER AI and to issue invoices.

Legal Basis: Necessary for the performance of a contract or preliminary procedures related to a contract to which the data subject is a party, at the request of the data subject (Art. 7, V, Federal Law nº 13.709/2018). And compliance with a legal or regulatory obligation by the controller (Art. 7, II, Federal Law nº 13.709/2018).

6.1.2. Photos and voice (audiovisual content): Used for creating digital characters (avatars) on the platform. This is an optional feature provided by INNER AI, meaning that providing audiovisual content is not mandatory for using other services and will only be used with the User's consent. Legal Basis: Upon provision of consent by the data subject (Art. 7, I, Law No. 13,709/2018).

6.1.3 Business User Address. Used for identification, creating the Contract with INNER AI and issuing invoices.

Legal Basis: Necessary for the performance of a contract or preliminary procedures related to a contract to which the data subject is a party, at the request of the data subject (Art. 7, V, Brazilian Federal Law nº 13.709/2018). And compliance with a legal or regulatory obligation by the controller (Art. 7, II, Brazilian Federal Law nº 13.709/2018).

6.1.4 E-mail. Used for validation and login of registration on the platform, means of communication with the User, and for contracts. It is also used to send marketing, news, classified and newsletter emails.

Legal Basis: Necessary for the performance of a contract or preliminary procedures related to a contract to which the data subject is a party, at the request of the data subject (Art. 7, V, Brazilian Federal Law nº 13.709/2018). It is necessary to meet the legitimate interests of the controller or a third party (Art. 7, IX, Brazilian Federal Law nº 13.709/2018).

6.1.5 IP (Internet Protocol). Compliance with article 15 of Brazilian Federal Law nº 12.965/2014, which imposes the duty to keep the respective records of access to internet applications confidential, in a controlled and secure environment, for a period of 6 (six) months.

Legal Basis: Compliance with a legal or regulatory obligation by the controller (Art. 7, II, Brazilian Federal Law nº 13.709/2018).

7. CANCELLATION OF THE PLATFORM, ACCESS ACCOUNTS AND DELETION OF DATA

7.1 Cancellation of access accounts by INNER AI: INNER AI may, at its sole discretion, block, restrict, disable or prevent any User from accessing the platform whenever it detects inappropriate conduct, breach of the Agreement with INNER AI, lack of payments or violations of laws, the terms of service, this privacy policy or any INNER AI policy.

7.2 Cancellation of access accounts by the User: in order to cancel the services and request the deletion of the access account, Users must:

7.2.1. Simple User: must make the request by e-mail to support@innerai.com. 

7.2.1 Business User: In the case of cancellations by people using the platforms through a Business User, the request to cancel the account or delete any type of data must be made directly to the Business User, since this company is the data controller and INNER AI acts in accordance with its contract, following the company's instructions.

7.3 When the purpose of data processing ends, at the request of the e-mail dataprotection@innerai.com in the case of Simple Users or at the request of the Business User controller in the case of persons linked to him/her, the User will have all his/her data deleted immediately and permanently, except for data whose maintenance is mandatory by law or regulation, data necessary for the regular exercise of rights in judicial, administrative or arbitration proceedings, such as access records, which will be kept, under secrecy, in a controlled and secure environment, under the terms of Federal Law nº 12.965/2014 and on the legal basis of art. 7, II, of the Brazilian Data Protection Law.

8. RIGHTS OF THE HOLDER OF PERSONAL DATA

8.1. The holder of personal data has the right to obtain from the controller, in relation to the data processed by him, at any time and upon request:

8.1.1. confirmation of the existence of data processing.

8.1.2. access to the data

8.1.3 Correction of incomplete, inaccurate or outdated data.

8.1.4 Anonymization, blocking or deletion of data that is unnecessary, excessive or processed in breach of the provisions of Law no. 13.709/2018.

8.1.5 Portability of data to another service or product provider, upon express request, in accordance with the regulations of the national authority, observing commercial and industrial secrets. 

8.1.6. Deletion of data processed with the consent of the data subject, except in the cases provided for in Federal Law 13.709/2018.

8.1.7 Information on the public and private entities with which the controller has shared data.

8.1.8. Information on the possibility of not providing consent and the consequences of refusing to do so.

8.1.9 Revocation of consent.

9. CHANGES TO THE PRIVACY POLICY

9.1 INNER AI may unilaterally add and/or modify any clause contained in this Privacy Policy. The updated version will apply to use of the platform from the date of its publication. Continued access to or use of the platform after publication will confirm that the new Privacy Policy is in force for Users. 

9.2 If the change made requires the User's consent, they will be given the option of freely, unequivocally and informedly accepting the new text or refusing it. 

9.3 If the User does not agree with the change, they may not provide consent for specific acts or they may completely terminate their relationship with INNER AI. Such termination shall not, however, release the User from complying with all obligations assumed under previous versions of the Privacy Policy.

10. PRIVACY COMMUNICATION CHANNEL

10.1 INNER AI appoints Mr. Diogo Andrade Silva Bernardelli as the person in charge, with the e-mail address dataprotection@innerai.com, under the terms of art. 41 of the Brazilian Data Protection Law, to accept complaints and communications from data subjects and the Brazilian National Data Protection Authority, provide clarifications and adopt measures.

10.2 INNER AI has a specific text to regulate the license of use, rights, duties, guarantees and general provisions: the Terms of Service. All these documents form an inseparable part of this Privacy Policy.

11. CONTACT ON GENERAL MATTERS

11.1 INNER AI provides the following channel to receive all communications that Simple Users wish to make: via e-mail to support@innerai.com and via our chat service via the platform. For Business Users, we have exclusive and dedicated support that responds via WhatsApp when necessary.