Privacy Policy and Data Processing

ProleadSync (hereinafter, "Platform," "We," or "Our") is deeply committed to protecting and respecting the privacy of all individuals whose data crosses our infrastructure. This Privacy Policy describes, with full transparency and without ambiguity, our practices for collecting, using, retaining, and protecting personal data, in strict compliance with the European Union's General Data Protection Regulation (GDPR - Regulation (EU) 2016/679).

1. Identification of the Data Controller

The entity acting as the Data Controller for the information processed as part of the services provided by the ProleadSync platform (proleadsync.com) is Rodrigo dos Santos Silvano, owner of the eponymous registered trademark (INPI Process 761137), with fiscal domicile and legal jurisdiction in Portugal.

To exercise any right related to data protection or for further clarification, formal contact must be established through the support number (+351 935 655 950) or through the dedicated privacy email address (e.g., privacy@proleadsync.com).

2. Dual Architecture of Data Processing

Eliminating the noise in this policy requires absolute separation between two categories of data subjects: "Users" (clients who actively subscribe to the platform) and "Leads" (individuals whose public Instagram profiles are analyzed at the Users' request).

A. Processing of User Data (ProleadSync Clients)

The data provided at the time of registration or subscription to a plan (Free or Pro) are vital for the execution of the service. The table below systematizes this processing:

B. Processing of Third-Party Data (Instagram Leads)

ProleadSync functions as an analysis tool oriented towards data already made manifestly public. Our technology automates the structuring of profiles to support B2B sales processes.

• Typology of Processed Data: Usernames, profile pictures, biographies, publication metrics, interaction volume, and public comments on the Instagram social network. The platform does not have the capability, nor does it attempt, to intercept direct messages (DMs) or extract data from private profiles.
• Legal Foundation: The processing of this category of data is based exclusively on Legitimate Interest (Article 6(1)(f) of the GDPR). It is considered that the compilation of professional and commercial data made public by the users themselves for their digital promotion does not override the fundamental rights and freedoms of the data subjects, thus ensuring the lawfulness of the processing for market prospecting purposes by our clients.
• Responsibility of Use: In this scope, ProleadSync acts primarily as a Data Processor providing the technology. The User, acting as the Data Controller, assumes the obligation to use the generated intelligence ethically, refraining from spam practices, and respecting the regulations on unsolicited commercial communications of the lead's country of residence.

2.2 Integration with Google Services

ProleadSync integrates with Google services to provide calendar functionalities. Below, we detail the specific use of each service:

Google Calendar

We access professionals' Google calendars to read existing events (and thus avoid scheduling conflicts) and to write, edit, and delete appointments scheduled through ProleadSync. Calendar data is used exclusively for the scheduling functionality.

Limited Use Policy

The use and transfer of information received from Google APIs by ProleadSync to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

Specifically:

• Data obtained from Google APIs is used exclusively to provide the scheduling functionality
• We do not use Google data to serve advertising
• We do not sell or share Google data with third parties for marketing purposes
• We do not use Google data to create user profiles for advertising purposes

3. Information Sharing and Recipients

To fulfill our promise of a noise-free and frictionless technological experience ("turn scattered signals into clear decisions"), we rely on infrastructures from trusted partners. Data may be shared strictly with the following categories of providers:

• Cloud Hosting Providers: Entities responsible for the secure and encrypted storage of databases.
• Independent Payment Processors: To ensure the full security of financial transactions.
• Judicial and Regulatory Authorities: Whenever required by judicial warrant or imperative legal determination in Portugal.

ProleadSync guarantees that it does not, under any circumstances, sell or rent personal databases to third parties for cross-marketing or targeted advertising purposes.

4. Rights of the Data Subjects

Under European data protection legislation, regardless of your status as a registered User or the holder of a public Instagram profile indexed by our tool, you are entitled to the following fundamental rights:

• Right of Access and Rectification: You can request confirmation of the processing of your data, as well as demand its immediate correction if it is inaccurate.
• Right to Erasure ("Right to be Forgotten"): You can request the deletion of your data from our registration databases. Holders of Instagram profiles can exercise an opt-out request, ensuring that their public account will not be indexed in ProleadSync's internal search engines.
• Right to Object: You can object to the processing of your information based on legitimate interest, and the platform must cease processing unless it presents compelling legitimate grounds.
• Right to Data Portability: You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format.

The exercise of these rights is free of charge and should be initiated through the contacts listed in Section 1. ProleadSync commits to responding to all requests within a maximum period of 30 days. In case of dissatisfaction with our resolution, you have the right to file a direct complaint with the National Data Protection Commission (CNPD) in Portugal.