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Privacy and Data Protection Policy

Vozis Tecnologia Humanizada LTDAUpdated on July 25, 2025

*This is a convenience translation. In case of any discrepancy, the Portuguese version prevails.*

Vozis Tecnologia Humanizada LTDA, or simply "Vozis", a private legal entity headquartered at Avenida Prefeito Osmar Cunha, 416, Sala 1108, Centro, Florianópolis/SC, CEP 88015-100, duly registered with the CNPJ (Brazilian National Registry of Legal Entities) under No. 55.645.165/0001-02, in its capacity as a company that provides technological infrastructure for the delivery of virtual customer service through artificial intelligence in a "humanized" manner, and in view of the provisions of Federal Law No. 13,709/2018, known as the General Data Protection Law (Lei Geral de Proteção de Dados Pessoais), or simply LGPD, hereby establishes, by means of this document, its privacy and personal data protection policy governing its business relationships with its customers, clarifying that personal data will be processed in a transparent and appropriate manner, in accordance with the obligations and safeguards set forth in the applicable legislation.

Definitions

  • ANPD: National Data Protection Authority (Autoridade Nacional de Proteção de Dados), the public administration body responsible for safeguarding personal data, as well as for regulating the LGPD and its enforcement. For more information, visit: https://www.gov.br/anpd/pt-br.
  • Data Subject: the natural person to whom the personal data refers.
  • Controller(s): the company responsible for making decisions regarding the processing of personal data.
  • Sensitive Personal Data: exclusively data concerning a natural person's racial or ethnic origin, religious belief, political opinion, membership in a trade union or in a religious, philosophical or political organization, data concerning health or sex life, and genetic or biometric data.
  • Personal Data: any information that makes it possible to identify a natural person, such as name, CPF (Brazilian Individual Taxpayer Registry number), marital status, parentage and address, email, telephone number, profession, IP address, age or sex.
  • Data Protection Officer (Encarregado): also known as the DPO, the person responsible for ensuring Vozis's compliance with the LGPD and for serving as a communication channel regarding the LGPD.
  • Applicable Legislation: all Brazilian legislation, including laws, regulations, rules, orders, decrees or other directives having the force of law that govern the processing of personal data, in particular the LGPD (General Data Protection Law).
  • Processor(s): the company that processes personal data in accordance with the Controller's instructions.
  • Security by Design: means incorporating Information Security best practices from the very beginning of the development of projects, systems or technologies.
  • Privacy by Design: means that every stage of the development process of a product or service at Vozis must have privacy and data protection applied from the outset.
  • Processing: any operation carried out with personal data, such as the collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
  • AI (IA): Artificial Intelligence or, in Portuguese, "inteligência artificial";
  • ANATEL: National Telecommunications Agency (Agência Nacional de Telecomunicações). The Brazilian regulatory agency responsible for overseeing and regulating telecommunications services in Brazil.
  • API: Application Programming Interface. A set of definitions and protocols for integration between software systems, enabling communication between different programs.
  • Customer: Refers to the legal entity that uses the services of the Vozis platform.
  • End Customer: A natural person or legal entity that is served by, or benefits from, the services contracted by the legal entity (customer), or that is served through the customer service channels of the Vozis Customer.
  • Inbound: Refers to calls or contacts made by the company to customers (calls placed by the company).
  • 0303 Prefix: A non-geographic prefix code used for telemarketing calls or other automated services.
  • Outbound: Refers to calls or contacts made by the Vozis Customer (legal entity) to end customers (calls placed by the company).
  • LGPD: General Data Protection Law (Lei Geral de Proteção de Dados). The Brazilian law that regulates the processing of personal data and seeks to ensure the privacy and protection of such data.
  • Uptime: Refers to the period of continuous operation of a system or service without interruption or failure.
  • Webhook: An interface that allows one system to send data in real time to another system. Generally used for notifications or communication between applications.

1. Purpose

1.1 The purpose of this Policy is to explain how Vozis processes and protects personal data, as well as what your rights are and how they may be exercised.

1.2 The initial addressee of the Vozis Privacy Policy is the customer that contracts the services it offers, which must maintain its own privacy policy whenever it directly processes the data of its end customers.

1.3 By accessing or using Vozis, even briefly, the Customer fully accepts our Privacy Policy.

2. Compliance Audit

2.1 During the term of the service agreement, Vozis may exercise the right to conduct audits to verify or supervise how its customer is processing the personal data of its own customers that may pass through or be used on the Vozis platform to communicate with the data subjects.

2.2 The monitoring of privacy and data protection risks is part of Vozis's Corporate Risk Management, in accordance with the guidelines established for that purpose.

2.3 The Vozis customer is required to submit to any necessary independent external audits or governmental audits whenever a complaint is filed regarding the improper processing of its customers' personal data.

3. Data Processing

3.1 Personal data collected by Vozis's customer companies that use its services to communicate with other natural persons will be processed by those who collected such data and who can demonstrate the legitimacy of the processing.

3.2 Vozis shall not be responsible for data that does not pass through Vozis's systems during the service/communication process with the personal data subject.

3.3 The Vozis customer must ensure, through its own Privacy Policy, the confidentiality and protection of the data subjects' personal data throughout the entire process of using the platform, even if the data is not stored in its own systems.

3.4 The company that contracts Vozis to use its technological infrastructure must ensure that, in its use of the platform, any data stored in a database managed by Vozis will be processed in accordance with the provisions of the LGPD.

3.5 No personal data shall be collected, stored or processed within the Vozis platform unless the data subject has given express consent to the customer of the services, as provided in item I of Article 7 of Law No. 13,709/2018 (LGPD).

3.6 If Vozis determines that its customer is not complying with minimum security rules in the processing of personal data, it may terminate the service agreement for cause, upon notice to the company, by email, of the measures that must be adopted.

4. Data Protection

4.1 Vozis adopts security best practices in the processing of personal data and is guided by four fundamental pillars that are also binding on the customer companies that use our communication platform.

  • confidentiality: we allow access to data and to our systems only to authorized persons, in accordance with the "principle of least privilege", which consists of granting only the minimum permissions necessary to perform a specific activity;
  • integrity: we preserve the reliability of data and information against any type of alteration, whether accidental or fraudulent, with respect to the data of our customers (companies that use Vozis's technology services).
  • availability: we establish the controls necessary to ensure that information is available to be accessed when needed and within appropriate security levels.
  • auditability: which consists of the systematic and documented process of obtaining objective evidence regarding the adequacy and effectiveness of the internal controls of the Vozis customer company in relation to the audited criteria.

4.2 When importing personal data from its own database into a database managed by Vozis, the Vozis customer company must ensure that the information originates from entirely lawful sources and that it has legitimate grounds to collect and process its customers' personal data.

4.3 To keep our environment protected, it is essential that we act proactively, identifying threats, vulnerabilities, potential risks and fraud and, when necessary, respond in a reactive and effective manner.

4.4 In the event of a compromise of the platform or of personal data entered into Vozis's databases, Vozis may adopt preventive measures to protect the data under its custody, including:

  • Blocking access for all persons/users linked to the Vozis customer's account until the integrity of the system has been verified;
  • Suspending the services of the customer associated with the threat of risk to data integrity until the integrity of the system has been verified;
  • Terminating the service agreement for cause if a violation of data processing by the Vozis customer company is proven.

4.5 If we identify the occurrence of any of the events described in item 4.4 resulting from the voluntary act of persons/users linked to any customer that uses the platform's services, Vozis will take the appropriate legal action against the offender(s), including filing a complaint with the ANPD and other competent authorities.

4.6 The Vozis customer company declares that it is aware that its legal entity data, when submitted for registration with Vozis, is not protected by the LGPD pursuant to Article 5, item I, of Federal Law No. 13,709/2018.

4.7 During the processing of personal data lawfully collected by Vozis's customers with the data subject's consent, the controller that obtained the consent referred to in item I of Article 7 of the LGPD and that needs to communicate or share personal data with other controllers must obtain the data subject's specific consent for that purpose, except in the cases in which consent is waived under the Law.

4.8 No personal data passing through the scope of processing within Vozis's systems may be used beyond the purposes for which it was collected directly from the data subject.

4.9 A violation of item 4.7 by any person/user linked to the Vozis customer will result in the adoption of the measures set forth in item 4.4.

4.10 Vozis will not use personal data collected by its customers in the course of their economic activities for its own benefit, but may access such data in order to share it with the ANPD or another competent authority or, further, to comply with a court order.

4.11 Vozis may share personal data to comply with the procedures and regulations of ANATEL (National Telecommunications Agency), for oversight purposes and other legal purposes.

5. Data Access, Settings and User Control

5.1 No unauthorized user may access Vozis's systems.

5.2 Access to registration data or personal data may only be granted to persons/users authorized by Vozis customers, through registration performed directly in the platform's Control Panel or, exceptionally, through registration performed by Vozis's technical team.

5.3 Data processing within the legal parameters of the LGPD must be observed by both Vozis and the customer during the "Integration" process between the Vozis platform and its customer's systems.

5.4 Access to personal data and user control is a shared commitment between the platform customer, that is, the company that contracts Vozis's services, and Vozis, which will maintain strict rules to ensure the proper processing of personal data whenever such data is entered into its databases, observing the following pillars:

  • Anticipate: foresee threats before they occur, managing new risks and learning the malicious techniques, tactics and procedures that attackers use;
  • Prevent: through Digital Security, support our business by ensuring regulatory compliance and privacy, aligning digitalization with security requirements from end to end;
  • Detect: identify any security incident as early as possible, through integrated monitoring;
  • Respond: be able to control and respond to potential security incidents involving personal data, as well as minimize the risks and harm to Data Subjects.

6. Sharing and Cookies

6.1 The Vozis customer company will be fully responsible for any unauthorized sharing of personal data in its custody.

6.2 Sharing ordered by the ANPD or by a competent authority, or by court order, does not require notice to Vozis, unless access to interdependent systems administered solely by us is required.

6.3 Cookies are small text files transferred to the electronic device (mobile phone, tablet or computer) when the user visits the Vozis website. They serve to temporarily store certain information about what is being searched for and make it possible to retain the user's browsing history, preferences and language, saving everything for easier and more direct access the next time the user visits the Vozis website.

6.4 Vozis will collect cookies from its prospective customers to improve the user experience while accessing and browsing the website https://vozis.ai, always subject to the user's express consent.

7. Anonymization of Personal Data

7.1 We clarify that in the anonymization process, where applicable, personal data is replaced by irreversible unique identifiers, and it is not possible to reverse the process to obtain the value of the personal data from that identifier.

7.2 At the user's request or based on its own rules, the Vozis customer must anonymize the customer's sensitive data or, if unable to do so, report it to Vozis so that the rule can be implemented.

7.3 Vozis does not anonymize personal data without an express request from the data subject or from the customer company using its systems.

8. "Do Not Disturb" Rules

8.1 A Vozis customer company that regularly uses our systems to place telephone calls must implement a procedure to ensure compliance with the rules relating to the customer's "Do Not Disturb" (Não Me Perturbe) request, and Vozis shall be fully exempt from any liability for violations of that registry.

8.2 The "Do Not Disturb" list shall apply only to outbound telemarketing activities directed at individual consumers, conducted through telephone calls for the offering and sale of Products and Services of Telecommunications Providers.

8.3 The Vozis customer company may place telemarketing calls for other, non-commercial purposes to anyone excluded from the "Do Not Disturb" list, and such calls will continue to take place normally, as is the case with collection calls, technical installation calls, among others.

9. Deletion of Data Subject Data

9.1 The data subject may request the deletion of their personal data at any time by sending an email to contato@vozis.ai, stating what they wish to delete and properly identifying themselves.

9.2 The request will be reviewed and fulfilled within the applicable legal deadlines, in accordance with the LGPD. Because Vozis acts as a processor, processing data on behalf of its customers (controllers), deletion may take place upon request made by the data subject directly to Vozis or upon request made by the controller customer that has legitimate authority over the data.

10. Final Provisions

10.1 This privacy policy is governed by the laws of Brazil, and the courts of the judicial district (Comarca) in which Vozis is headquartered shall have exclusive jurisdiction, to the express exclusion of any other.

10.2 We will update our privacy policy without prior notice whenever necessary to adapt our services to the legislation and rules governing the telephone call service sector, as well as to any regulation of artificial intelligence tools.

10.3 Vozis does not and will not collect personal data from the end customers of the companies that use its systems for virtual customer service or outbound telemarketing.

10.4 The Vozis customer company is prohibited from collecting and storing personal data of children and adolescents.

10.5 Other responsibilities of the companies that use Vozis's systems will be set forth in the service agreement.

10.6 This Privacy Policy must be fully observed by Vozis customers together with our Terms of Use and the service agreement available in the customer's Control Panel.