Note

We have reviewed our policies in order to make sure we are in compliance with the European Union's General Data Protection Regulation

Privacy Policy - Rest PKI

Last amended: May 24, 2018
Effective Date: May 25, 2018

This Privacy Policy applies to the website https://pki.rest (the "Site") owned and operated by Lacuna Software Ltda (collectively, "Lacuna", "we", "us", or "our"). This Privacy Policy describes how Lacuna collects, uses, shares and secures the personal information you provide, as well as the information about our customers' end users that we process on behalf of our customers. It also describes your choices regarding use, access, correction and deletion of your personal information.

How we Collect Information

We collect the following personal information from you:

Information that you provide to us about yourself

When you sign up for the Services, we ask you for information such as

Contact Information, such as name, email address, mailing address, or phone number;
Unique Identifiers, such as username, account number or password;
IP address.

If you do not provide this information, we will not be able to provide the Services to you.

Information you provide to us about your end users and contacts

For the provision of our Services to you, you provide us with information which may identify your end users or employees. Such information includes:

Digital certificate;
IP addresses;
Document Hash.

You may also provide us personal information about your employees such as Name and email address where we can send receipts of your purchases. When you provide us with personal information about your employees will only use this information for the specific reason for which it is provided. If you believe that one of your employees has provided us with your personal information and you would like to request that it be removed from our database, please contact us at the contact information below.

Information collected automatically

When you use our Services, we use cookies and similar technologies to collect information about your location, and your activities on our website, information about your device and log information. This is described in more detail below. These cookies and similar technologies collect anonymized Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data.

Lacuna allows Google Analytics and Snowplow Analytics to use these technologies to analyze trends, administer the website, track users' movements around the website, and to gather demographic information about our user base as a whole for the purpose of analytics.

You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. We do not use or allow the use of cookies or similar technologies in connection with your customers' data.

Google Analytics:

We use a tool called "Google Analytics" to collect some information we listed above about your use of the Services. We use the information we get from Google Analytics to improve the Services and to help you improve your Application. In order to collect this information, Google Analytics may set cookies on your browser or mobile device, or read cookies that are already there. Google Analytics may also receive information about you from apps you have downloaded, that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google's ability to use and share information collected by Google Analytics about your visits to the Services to another application which partners with Google, is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Please review those and see https://policies.google.com/technologies/partner-sites for information about how Google uses the information provided to Google Analytics and how you can control the information provided to Google. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here.

Purpose and Legal basis of the Processing

We use the information about you in order to provide the services to you and in order to improve them. We use information about your customers or end users only in order to provide you the services. To the extent EU data protection law applies to these uses of your information, we act as the "data controller". To the extent EU data protection law applies to our processing of your customer or end user data, you serve as the "data controller" and we serve as the "data processor".

To perform the Services: We use your information to identify you, process your payment, provide you with technical support and assistance; and communicate with you about the Services via email. For example, we will contact you to notify you of any issues with the Services or any suspicious activity in your account. The legal basis for these uses in the performance of the contract with you.

To Optimize or improve the Services: We use your information to authenticate you, prevent fraud and abuse of our Services and perform research. The legal basis for these uses is our legitimate interest in the improvement and optimization of our service offerings and in ensuring the security of our services and we apply appropriate safeguards to protect your information (see section Security).

We share information with service providers, as required by law, and in connection with the protection and enforcement of our legal and contractual rights.

With Service Providers: We share your information with third parties who provide services on our behalf to help with our business activities. This includes: payment processing, providing customer service, sending marketing communications (this does not include information about your customers), conducting research and analysis and providing cloud computing infrastructure. The legal basis for sharing this information is our legitimate interest in providing our Services efficiently and we implement measure to safeguard your information.

With Public Authorities or Law Enforcement: In certain situations, Lacuna may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, when we believe there is a violation to our Terms of Service (see RestPKI Terms of Service, Beanstalk Terms of Service), protect your safety or the safety of others, investigate fraud, or respond to a government request. If Lacuna is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We do not sell, rent or share personal information with third parties without your prior consent. The legal basis for this is our legitimate interest in protecting our legal rights and those of others, compliance with legal obligations and our legitimate interest in fulfilling legal obligations imposed by legal authorities outside of the EU.

Prevent fraud and abuse of the Services: We will share information to prevent or detect fraud or to address technical issues and if we believe it is necessary to investigate, prevent, or take action regarding situations that involve abuse of the Services infrastructure. The legal basis for this is our legitimate interest in the maintaining the security of our Services.

We also process and share information in an aggregated, de-identified manner, where the information is shared as part of a statistical report and does not contain personal information.

Security

The security of your personal information is important to us. We implement adequate measures to protect the personal information submitted to us, both during transmission and once it is received. Lacuna Software Ltda takes steps to ensure that all source code, files and data remain private and confidential. Due to the sensitive nature of source code we take this very seriously and make it our primary concern for all customers. We restrict access to personal information to Lacuna employees, contractors and agents who need to know that information in order to operate, develop or improve our service. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. If you have any questions about the security of your personal information, you can contact us at the contact information below.

Rights with respect to your information

Upon request Lacuna will provide you with information about whether we hold any of your personal information. You may access, correct, obtain a copy of or request deletion of your personal information by logging into your account or by contacting us at the contact information below. We will respond to your request within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

Lacuna Software Ltda acknowledges that you have the right to access your personal information. Lacuna has no direct relationship with your end users whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct their query to the Lacuna Software Ltda's Client (the data controller). If requested to remove data we will respond within a reasonable timeframe. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

Your Choices with respect to the information

Promotional Email communication: You may sign-up to receive email or newsletter or other communications from us. If you would like to discontinue receiving this information, you may update your email preferences by using the "Unsubscribe" link found in emails we send to you or by contacting us at the contact information below.

Google Analytics: see https://policies.google.com/technologies/partner-sites for information about how Google uses the information provided to Google Analytics and how you can control the information provided to Google. To prevent your data from being used by Google Analytics, you can download the Google Analytics opt-out browser add-on for Google Analytics which can be found here.

Data Retention

We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements. In certain circumstances we may be required by law to retain your personal information, or may need to retain your personal information in order to continue providing a service.

Even if you delete your account, keep in mind that the deletion by our third party providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time.

Policy Regarding Children

The Services are not directed to children under the age of 16. We do not knowingly collect Personal Information from children under 16. If you are under 16, please do not use the Services and do not provide any personal information to us. If you become aware that a child under 16 has provided us with personal information without your consent, please contact us at support@lacunasoftware.com. If you are a California resident under the age of 18 and you wish to remove publicly available content, please contact us at support@lacunasoftware.com with the subject line "California Eraser".

Transfers of information not from the EEA

To the extent that personal information is transferred to the United States from countries other than countries within the European Economic Area and Switzerland, including personal information that is transferred from Canada, we employ similar safeguards such as selecting third party vendors carefully, ensuring personal information will be used and disclosed only as set out in this privacy policy and that it is protected by appropriate security safeguards.

However, in connection with these transfers of personal information, your personal information may be subject to privacy laws that may not provide the same protection as your country of residence. For example, government entities in such other countries may have certain rights to access your personal information. By using this Site or using our Service that this privacy notice relates to you are consenting to this transfer of your personal information.

Browser Do Not Track

The Services honor and enforce Do Not Track preferences. Do Not Track (DNT) is a privacy preference you can set in your web browser to indicate that you do not want certain information about your webpage visits collected across websites when you have not interacted with that service on the page. For all the details, including how to turn on Do Not Track, visit donottrack.us.

Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Privacy Questions / Feedback

If you have questions or concerns about Lacuna's Privacy Policy please contact us at suporte@lacunasoftware.com or CLN 110 - A - Sala 203, Brasília-DF, Brazil. Phone: +55 61 3030-5700.