Privacy Policy

Last updated: September 24, 2026

Openness Technology Brasil LTDA, registered under CNPJ no. 18.652.975/0001-60, headquartered at R. Cel. José Eusébio, 95, Higienópolis, São Paulo – SP, Brazil ("Openness", "we", "us"), is the controller responsible for the processing of personal data collected on this website, www.opennesstechnology.com (the "Site").

This Policy explains, in plain terms, what data we collect, why we collect it, who we share it with and what your rights are, in accordance with the Brazilian General Data Protection Law (Law No. 13,709/2018 – LGPD) and the Brazilian Internet Civil Framework (Law No. 12,965/2014 – Marco Civil da Internet).

This Policy applies only to the corporate Site. The processing of data within our systems (Miller ERP, Peter ERP, Winmed and Moby Dick) by contracting customers is governed by the respective contracts and terms of use.

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1. Definitions

• Personal data: information relating to an identified or identifiable natural person.
• Usage data: technical data collected automatically while you browse, such as IP address, browser and pages visited.
• Cookies: small files stored on your device (computer or mobile phone) by your browser.
• Data subject: the person to whom the personal data refers — that is, you.
• Controller: the party that makes decisions about the processing of personal data. For the purposes of this Policy, Openness Technology Brasil LTDA is the controller.
• Processor (service provider): a company that processes personal data on behalf of the controller, such as the services listed in Section 6.
• Data Protection Officer (DPO): the person appointed by the controller to act as the point of contact with data subjects and with the Brazilian National Data Protection Authority (ANPD).

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2. What data we collect

2.1 Data you provide

When you fill out the contact form, we collect:

• Name;
• Email address;
• Phone number;
• Message (and any information you choose to include in it).

Please do not include sensitive data (such as health information) or third-party data in your message.

When you contact us via WhatsApp, email or phone, we receive the data you send us through those channels (for example, your name, phone number and the content of the conversation).

2.2 Data collected automatically

While you browse the Site, technical data may be recorded automatically, such as:

• IP address;
• Date and time of access;
• Browser type and version and operating system;
• Pages visited and referring page.

Access logs (IP address, date and time) are kept for 6 months, as required by Article 15 of the Marco Civil da Internet.

2.3 What we do not collect

The Site does not collect location data from your device, does not process payments and does not store card details.

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3. How we use your data

Purpose	Data used	Legal basis (LGPD, Art. 7)
Responding to your inquiry, providing support and presenting our solutions	Name, email, phone, message	Pre-contractual steps at your request (item V)
Sending commercial proposals and following up on a negotiation you started	Name, email, phone	Pre-contractual steps (item V) and legitimate interest (item IX)
Keeping the Site secure, detecting and fixing technical issues and protecting the form against spam and automated use	Technical access data and page interaction data	Legitimate interest (item IX)
Complying with legal obligations (e.g., retention of access logs)	IP address, date and time	Compliance with a legal obligation (item II)
Measuring Site usage in an aggregated and anonymous way to improve it	Technical access data	Legitimate interest (item IX)

We do not sell your personal data and we do not use it for purposes other than those described above without first informing you.

We will only send you marketing materials (such as newsletters, news and offers) if you expressly authorize it. You can unsubscribe at any time through the unsubscribe link in our emails or through the channels in Section 13.

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4. Who we share data with

We share personal data only when necessary, with:

• Service providers that help us operate the Site and customer service (hosting, security, email and messaging), listed in Section 6. They may only use the data to provide the contracted service and are obligated not to disclose it or use it for any other purpose.
• Openness group companies, including Openness Technology LLC (United States), when your inquiry involves products or operations handled by it.
• Public authorities, when required by law, by court order or by a valid request from a competent authority.
• In the event of a corporate transaction: if Openness is involved in a merger, acquisition or asset sale, personal data may be transferred to the successor. You will be notified before your data becomes subject to a different privacy policy.

We may also disclose personal data, in good faith, when necessary to:

• comply with a legal or regulatory obligation;
• protect and defend the rights or property of Openness;
• prevent or investigate possible wrongdoing in connection with the Site;
• protect the personal safety of Site users or the public;
• exercise rights in judicial, administrative or arbitration proceedings.

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5. Cookies

This Site uses only strictly necessary cookies for its operation and security, such as:

• technical cookies from the Site itself (WordPress);
• Cloudflare security cookies, used to identify and block malicious traffic;
• Google reCAPTCHA cookies, used to verify that the contact form is being submitted by a person and not a bot.

These cookies are essential to provide the service you request and therefore do not require consent.

We do not use advertising, remarketing or cross-site tracking cookies. Visitor statistics are measured by Cloudflare Web Analytics, which does not use cookies.

You can set your browser to refuse cookies or to alert you when a cookie is sent. Blocking necessary cookies may prevent the contact form from being submitted.

"Do Not Track" signals: since the Site does not track users for advertising purposes, a "Do Not Track" signal sent by your browser does not change how the Site works.

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6. Third-party services

This Site uses the following services, which may process data on our behalf:

Service	Company (country)	What we use it for	Data involved
Cloudflare (network, security and Web Analytics)	Cloudflare, Inc. (USA)	Delivering the Site, protection against attacks and aggregated visitor statistics, without cookies	IP address, browser, pages accessed
cdnjs	Cloudflare, Inc. (USA)	Delivering libraries and icons used on the pages	IP address, browser
Fontshare	Indian Type Foundry (India)	Loading the Site's fonts	IP address, browser
Google reCAPTCHA	Google LLC (USA)	Protecting the contact form against spam and bots	IP address, browser, page interaction data, cookies
Gravatar	Automattic Inc. (USA)	Displaying profile images, a default WordPress feature	IP address, browser and, where applicable, a code generated from the email address
HostGator (WordPress hosting)	HostGator Brasil (Brazil)	Hosting the Site, content management and receiving contact form messages	Form data and technical access data
WhatsApp	Meta Platforms, Inc. (USA)	Customer service, when you choose to contact us through this channel	Phone number, name and content of the conversation

The use of Google reCAPTCHA is subject to Google's Privacy Policy and Terms of Service. The use of WhatsApp is also subject to Meta's privacy policy.

We do not use advertising or remarketing tools (such as Google Ads, Google AdSense, Meta Pixel, X/Twitter or LinkedIn Insight Tag) on this Site.

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7. Links to other sites

The Site may contain links to sites that are not operated by us. If you click a third-party link, you will be directed to that third party's site. We have no control over, and assume no responsibility for, the content, privacy policies or practices of any third-party sites or services. We recommend that you review the privacy policy of every site you visit.

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8. International data transfers

Some of the services above are located outside Brazil, mainly in the United States and India. In these cases, the transfer takes place in accordance with Article 33 of the LGPD, with providers that adopt contractual clauses and security measures compatible with Brazilian law. We do not transfer personal data to organizations or countries without adequate data protection controls.

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9. How long we keep data

• Contact form data and commercial conversations: for as long as necessary to respond and conduct the negotiation and, afterwards, for up to 2 years from the last contact, unless you become a customer (in which case the contract terms apply) or request deletion earlier.
• Access logs (IP, date and time): 6 months, as required by the Marco Civil da Internet. This period may be longer when the data is used to investigate security incidents or when required by law.
• Data needed to comply with legal obligations, resolve disputes or exercise rights in proceedings: for the period required by applicable law.

At the end of these periods, the data is deleted or anonymized.

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10. Security

We adopt technical and administrative measures to protect personal data against unauthorized access, loss or alteration, including encrypted connections (HTTPS), network-level attack protection and access restricted to the people who need the data to do their work.

No method of transmission over the internet or of electronic storage is 100% secure. If a security incident occurs that may pose a relevant risk or harm to you, we will notify you and the Brazilian National Data Protection Authority (ANPD), as required by Article 48 of the LGPD.

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11. Your rights

Under Article 18 of the LGPD, you may, at any time and free of charge:

1. Confirm whether we process your data;
2. Access your data;
3. Correct incomplete, inaccurate or outdated data;
4. Request the anonymization, blocking or deletion of unnecessary or excessive data, or data processed in breach of the LGPD;
5. Request the portability of your data to another provider, in a structured format;
6. Request the deletion of data processed based on your consent;
7. Know which entities we share your data with;
8. Be informed about the possibility of not giving consent and the consequences of doing so;
9. Withdraw your consent;
10. Object to processing carried out based on legitimate interest, if you believe it does not comply with the LGPD.

To exercise these rights, contact us through the channels in Section 13. We will respond within 15 days. We may ask for information to verify your identity before fulfilling your request.

You may also file a complaint with the Brazilian National Data Protection Authority (ANPD): www.gov.br/anpd.

Visitors from other countries: if you are in the United States or the European Economic Area (GDPR), we also respect the rights provided under the laws of your country, such as access, correction, deletion, restriction, objection, portability and withdrawal of consent. You may exercise them through the same channels and file a complaint with your local data protection authority.

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12. Children and adolescents

This Site is intended for businesses and professionals. We do not knowingly collect data from anyone under the age of 18. If you are a parent or guardian and you are aware that a child or adolescent has provided us with personal data, please contact us. If we become aware of such collection, the data will be deleted.

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13. Contact and Data Protection Officer (DPO)

Data Protection Officer: Leandro Miller
Email: contact@opennesstechnology.com

Openness Technology LLC (United States)
Phone: +1 786-460-3280
Email: contact@opennesstechnology.com

Openness Technology Brasil LTDA
CNPJ: 18.652.975/0001-60
R. Cel. José Eusébio, 95, Higienópolis, São Paulo – SP, Brazil
Phone: +55 (11) 4210-6220
WhatsApp: +55 (11) 5192-9899
Email: contact@opennesstechnology.com

You can also reach us through our contact page: https://www.opennesstechnology.com/site/contact/

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14. Changes to this Policy

We may update this Policy to reflect changes to the Site, the services we use or the law. The date of the last update is always shown at the top of this page. Material changes will be prominently announced on the Site before they take effect. We recommend that you review this Policy periodically.

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15. Governing law and jurisdiction

This Policy is governed by the laws of the Federative Republic of Brazil. The courts of the District of São Paulo – SP shall have jurisdiction to resolve any matters related to it, without prejudice to the data subject's right to bring proceedings in the courts of their place of residence, where applicable.

This English version is a translation of the Portuguese original. In the event of any conflict, the Portuguese version prevails.