Privacy Policy

At StartADAM.com (owned and operated by Speedlancer Inc, a Delaware C Corporation), privacy and security are priorities and we are committed to transparent handling of our users´s personal data. Therefore, this Privacy Policy sets out how the collection, use and transfer of information from customers or other people who access or use our website is carried out.

By using our services, you understand that we will collect and use your personal information in the ways described in this Policy which follows rules on various legislations, particularly: -Europe: GDPR (EU Regulation 2016/679) -USA: CCPA (Civil Code, Division 3, Part 4, title 1.81.5, 1798.100-1798.999) -Brazil: LGPD (Federal Law 13.709/2018). In this way, StartAdam.com, hereinafter referred to simply as “StartAdam”, is bound by the provisions of this Privacy Policy.

StartADAM collects and uses your personal data listed below in order to enable the provision of services and improve the user experience. These data may be directly collected (if you’re a StartADAM user) or given by a service you use which contracted with StartADAM. a.Personal data provided by the user or service you contracted:

• Name
• Contact information (Email, Phone, Slack workspace, Discord server, etc)

b.Personal data collected automatically None.

Personal data collected when an account is created or updated by you or by the service who you use which contrated with StartADAM.

Your personal data is processed by StartADAM with your implicit authorization when you contract StartADAM’s services.

This implies on a consent which is the free, informed and unequivocal expression by which you authorize StartADAM to process your data.

By using the services of StartADAM and providing your personal data, you are aware and consenting to the provisions of this Privacy Policy, in addition to knowing your rights and how to exercise them. It is important to note that the revocation of consent for the processing of data implies the impossibility of StartADAM to provide its services. Therefore, consent revocation implies StartADAM’s service termination.

StartADAM assures its users their rights according to the legislation cited above. That way, you can, free of charge and at any time:

• Confirm the existence of data processing, in a simplified way or in a clear and complete format.
• Access your data, being able to request them in a legible copy in printed form or by electronic means.
• Correct your data.
• Limit your data when unnecessary, excessive or treated in breach of legislation through anonymization, blocking or elimination.
• Request the portability of your data.
• Delete your data, except in cases provided for by law.
• Revoke your consent, disallowing the processing of your data.
• Inform yourself about the possibility of not providing your consent and about the consequences of denial.

Confirmation of existence of data processing and access to your personal data provided within 72 hours of identity confirmation of the requester, free of charge via email. All requests are fulfilled free of charge by StartADAM but external fees may apply.

To exercise your rights, you must contact StartADAM through the following available means:

• Email to privacy@startadam.com

In order to ensure your correct identification as the holder of the personal data object of the request, we may request documents or other evidence that can prove your identity. In this case, you will be informed in advance.

Your personal data collected by StartADAM will be used and stored for the time necessary for the provision of the service, considering the rights of data subjects and controllers.

In general, your data will be kept as long as the contractual relationship between you and StartADAM continues. At the end of the storage period, these will be deleted from our databases or anonymized, except for the cases legally such as:

I – compliance with a legal or regulatory obligation by the controller;

II – study by a research body, guaranteeing, whenever possible, the anonymization of personal data;

III – transfer to a third party, provided that the data processing requirements set forth in this Law are complied with; or

IV – exclusive use of the controller, its access by a third party being prohibited, and provided that the data is anonymized. That is, personal information about you that is essential for the fulfillment of legal, judicial and administrative determinations and/or for the exercise of the right of defense in judicial and administrative proceedings will be kept, despite the exclusion of other data. The storage of data collected by StartADAM reflects our commitment to the security and privacy of your data.

We employ technical protection measures and solutions capable of guaranteeing the confidentiality, integrity and inviolability of your data.

In addition, we also have risk-appropriate security measures and access control to stored information.

To keep your personal information secure, we use physical, electronic and managerial tools aimed at protecting your privacy.

We apply these tools taking into account the nature of the personal data collected, the context and purpose of the treatment and the risks that any violations would generate for the rights and freedoms of the data subject collected and processed. Among the measures we have adopted, we highlight the following:

• Only authorized persons have access to your personal data
• Access to your personal data is made only after the confidentiality commitment
• Your personal data is stored in a safe and suitable environment.

StartAdam is committed to adopting the best postures to avoid security incidents. However, it is necessary to point out that no virtual service is entirely safe and risk-free.

It is possible that, despite all our security protocols, problems that are solely the fault of third parties occur, such as cyber attacks by hackers, or also as a result of the negligence or recklessness of the user himself.

In the event of security incidents that may generate relevant risk or damage for you or any of our users, we will communicate to those affected and to Protection Authority about what happened.

In order to preserve your privacy, StartADAM will not share your personal data with any unauthorized third parties. But there are also other hypotheses in which your data may be shared, which are:

I – Legal determination, request, requisition or court order, with competent judicial, administrative or governmental authorities.

II – Case of corporate movements, such as merger, acquisition and incorporation, automatically

III – Protection of the rights of (simplified business name) in any type of conflict, including those of a judicial nature.

Some of the third parties with whom we share your data may be located or have facilities located in foreign countries.

Under these conditions, in any case, your personal data will be subject to data protection legislation.

In this sense, StartADAM is committed to always adopting efficient cybersecurity and data protection standards, in the best efforts to guarantee and comply with legislative requirements.

By agreeing to this Privacy Policy, you agree to this sharing, which will take place according to the purposes described in this instrument.

StartADAM makes use of cookies, which are text files sent by the platform to your computer and stored there, which contain only information related to navigation. In short, cookies are used to improve the user experience. By accessing StartADAM’s website and services and consenting to the use of cookies, you declare that you know and accept the use of a navigation data collection system with the use of cookies on your device.

No personal information is store on cookies.

You can, at any time and at no cost, change the permissions, block or refuse Cookies. However, revocation of consent for certain cookies may make it impossible for some features of the platform to function correctly.

The current version of the Privacy Policy was formulated and last updated on April 9, 2022. We reserve the right to modify this Privacy Policy at any time, mainly depending on the adequacy of any changes made to our website or in the legislative scope.

We recommend that you review it frequently. Any changes will take effect as of their publication on our website and we will always notify you of the changes.

By using our services and providing your personal data after such modifications, you consent to them.

StartADAM provides for the liability of agents who act in the data processing processes, in accordance with cited regulations.

We undertake to keep this Privacy Policy updated, observing its provisions and ensuring compliance. In addition, we are also committed to seeking technical and organizational conditions that are safely able to protect the entire data processing process.

StartADAM provides the following means for you to contact us to exercise your rights:

• Email privacy@startadam.com

If you have questions about this Privacy Policy or the personal data we process, you can contact our Personal Data Protection Officer, through the following channels:

• Emaildpo@startadam.com