Privacy Policies
We at MAESTRO (“we”) are a platform focused on ABM (Account-Based Marketing) solutions, a strategy aimed at reaching specific accounts through highly personalized campaigns. We have a policy of total transparency and respect for you, and we are committed to defining the expectations, rights, and responsibilities among the individuals interacting with our platform.
We are committed to safeguarding the privacy and protection of the personal data of individuals who interact with our platform and our services. Thus, “you,” the data subject, have the right and duty to read this document in full at any time to understand how we operate. In this Privacy Policy, you will find information about how your personal data is collected, used, shared, and stored through our platform and our services.
If you do not agree with this Policy, do not continue providing your data and stop using our websites and platforms.
Access the glossary we have prepared to better understand the concepts and terminology we use in this document.
WHAT PERSONAL DATA DO WE PROCESS?
Processed personal data. The personal data processed by MAESTRO may vary according to the type of interaction with our platform and may be obtained directly from the data subject, from third parties, or collected automatically. They may involve:
access information, such as browsing history, interaction with the platform, and page views;
registration information, such as full name, email address, phone number, mobile phone, CPF, RG, age, and profession;
browsing and device information, such as IP address, access dates and times, time browsing the platform pages, device information, cookie data;
banking information, such as the name of the financial institution where the data subject has a bank account, account number, account type, branch, PIX, credit score, credit card number;
preference information, such as how many texts have been entered, the full text of each text entered in the Text Box and your acceptance or refusal of MAESTRO's spelling and writing suggestions.
Information about campaign indicators, as well as the data contained in them.
Data Subjects. We process the personal data of certain categories of people. This means that our subject (“you”) corresponds to the category of (a) MAESTRO User and Users' Leads.
The MAESTRO Users are those data subjects who access our platform through registration, that is, providing an email, being users of the MAESTRO application who independently registered by providing their name, email, CPF, and mobile phone via landing page with the legitimate interest in utilizing our services.
We do not necessarily collect all the data identified here; they will depend on the interaction with our websites, platform, and services. This means that, for example, we will process the personal data related to credit “score” if you request a payment installment for our services.
The Leads are the potential customers of the users, who are identified and qualified through the ABM (Account-Based Marketing) method. In turn, MAESTRO has access to databases provided by partners, such as email, phone, and name of the subject.
WHAT DO WE USE PERSONAL DATA FOR?
When accessing and navigating the MAESTRO websites and platforms, we may collect and process some personal data for the following purposes:
Enable your access to the platform through the registration completed;
Allow navigation through the platform;
Facilitate the opening of support requests;
Develop better marketing strategies and promotion of our services;
Present offers more suitable to your profile, such as, for example, a bank loan.
For the execution of the ABM (Account-Based Marketing) solution.
a) MAESTRO User
Processing and purpose. When accessing and navigating the MAESTRO platform, we may collect and process some personal data for the purposes indicated above, as well as use the information provided by you, MAESTRO user, to, in joint intelligence with other operators, optimize the functionality and usability of the platform.
MAESTRO also collects and processes personal data when the subject contacts us through our platform or provides their data via email, web form, instant messaging, phone, or through interactions with post content, as well as through other means provided by us. This processing includes the purposes of enabling a response to your request and sending email communications that we believe may be useful to you.
In an objective manner and to clarify the purpose on which we base the processing of your data, you can refer to the following illustrative table:

Treatment and purpose. When accessing and navigating the MAESTRO platform, we may collect and process some personal data for the purposes indicated above, as well as use the information provided by you, the MAESTRO user, to jointly optimize the functionality and usability of the platform in conjunction with other operators.
The MAESTRO also collects and processes personal data when the data subject contacts us through our platform or provides their information by email, web form, instant message, phone, or through interactions with post content, as well as through other means provided by us. This processing includes the purposes of enabling a response to your request and sending communications by email that we consider may be helpful to you.
In an objective manner and to ensure that the purpose underlying the processing of your data is understandable, you can consult the illustrative table below:
Unsubscribing. If you want to stop receiving communications sent by the MAESTRO Platform, including via email or other communication channels, you can configure the deactivation of such receipt in your user profile. Just access the "Settings" tab and "Deactivate notifications".
b) Leads
Personal Data obtained from third parties. The MAESTRO has access to registration information through third parties, which may share contact information of the data subjects so that MAESTRO can register the person interested in accessing the platform, and thus inform about the availability of the service. Additionally, MAESTRO has access to the contact database of some partners, with the aim of identifying ideal profiles for prospecting and launching personalized campaigns.

3-HOW DO WE USE COOKIES?
3.1 - What are cookies?
Definition. Cookies are small text files located in the visitor's browser. They are used to help the visitor navigate the sites more efficiently and perform certain functions.
Cookies are files created when the browser loads a site. When the visitor returns to the same site, they can be identified, as the browser will inform whether or not cookies exist. It is worth noting that cookies are not created only by the site being visited, but also by other sites that display ads, widgets, and other elements on the loaded page.
The term cookies also encompasses other technologies such as pixel tags, mobile device identifiers, and web storage. Additionally, they have purposes according to their collection, such as:
strictly necessary cookies for the use of the service such as user session;
performance cookies that collect information from visitors for better platform/app performance;
functionality cookies that allow the site to remember the choices the visitor makes and the pages visited or accessed;
targeting or advertising cookies that are used to deliver more relevant and interesting ads.
3.2 - How does MAESTRO use cookies?

3.3 - How to manage your preferences
Management of cookie usage. The data subject can manage their preferences regarding the use of cookies at any time through their browser's functionalities. If you no longer wish to accept the use, it is possible to use the browser settings to accept, refuse, or delete cookies.
Learn more if you use Internet Explorer.
Learn more if you use Firefox.
Learn more if you use Safari.
Learn more if you use Google Chrome.
Learn more if you use Microsoft Edge.
Learn more if you use Opera.
*The cookie refusal setting may prevent access to all resources of MAESTRO's websites and platforms.
4-LEGAL BASES FOR PROCESSING
Legal bases used. As you already know, MAESTRO is an ABM (Account-Based Marketing) solution, thus, we develop marketing and sales actions with our partners, and these actions include processing your Personal Data for the purposes outlined in this Privacy Policy. This means that MAESTRO processes your personal data, qualifying as an operator, when carrying out processing activities to fulfill the partnership established between us and our partners.
Any and all processing of personal data carried out by MAESTRO is based on a legal basis provided in the applicable legislation. The legal bases used by MAESTRO may vary according to the context of processing. We use the following legal bases:
Contract Execution: When MAESTRO processes personal data due to the contract, such as when registering on the platform to gain access to scheduling services for outings on the vessel.
Regular exercise of rights: When there is a need to process personal data due to judicial action, administrative proceeding, or arbitration;
Compliance with legal or regulatory obligation: When MAESTRO is required to process personal data by legal or regulatory determination;
Legitimate interest: When MAESTRO decides to process data to meet its legitimate interests. This legal basis is used, for example, when MAESTRO sends a communication or email related to the interests of the data subject, considering the interaction with our websites, platforms, campaigns, and content. In these cases, MAESTRO always provides the option to unsubscribe from communications.
5-WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
Sharing of Personal Data. To enable the execution of processing activities, MAESTRO may share some of the collected personal data with third parties. For an understanding of such relationships, you can view the table below for the recipients of the shares and the reasons for this happening.

On the MAESTRO Platform, there may also be content hosted by third parties or references to third-party sites. The MAESTRO is not responsible for any damages or losses incurred as a result of accessing third-party sites or platforms, and recommends that all users, when accessing such sites or platforms, read the Privacy Policy and Terms of Use of that third party.
Know your rights
Rights of Personal Data Subjects. Understand, as per the table below, what your rights are, based on the foundations of the personal data protection legislation that applies to you.

6.2 - Requests
Definition. If the data subject has any questions about the processing of data that we carry out or wants to exercise any of their rights, according to applicable law, it is possible to make a request. The data subject may, for example, request access, rectification, or deletion of their personal data.
How to make a request. The request regarding any of these rights must be made through this email address: contato@maestroabm.com.
6.3 - Opt-out
How to opt-out. Furthermore, as we care about your experience with MAESTRO, we provide the data subject the option to indicate that they no longer wish to receive them.
7 - HOW LONG WILL THE DATA BE STORED?
7.1 - Processing period
Processing period. The personal data indicated in this Policy will be processed by us, according to the law, until one of these situations occurs:
The purpose of the processing is achieved;
The data is no longer necessary or relevant to achieve the proposed purpose;
After the retention period has elapsed, counted from the deletion of the account on the platform;
The right to delete the Personal Data of the data subject is exercised, in the case of processing based on consent and no other purposes being present;
An eventual penalty applied by the responsible authority for overseeing applicable law occurs;
Retention. Additionally, in specific situations, MAESTRO and its Service Providers may retain personal data even after the termination of processing, due to the fulfillment of a legal or regulatory obligation. In these cases, personal data will be stored for the time necessary to comply with the legal or regulatory obligation, always in a secure location with segmented access.
8 - CHANGES AND UPDATES TO THIS POLICY
Updates to this Privacy Policy. We are constantly developing, so some changes or adaptations may be made to this Policy. For this reason, it is important that you check it regularly when using our platform.
9 - HOW TO CONTACT MAESTRO
Contact us. If you have any questions or requests regarding any item of this policy, feel free to contact us at the following email: contato@maestroabm.com


