1. DATA CONTROLLER
For student data processed inside an academy, the academy or responsible instructor is the data controller, and ZedScript Automações LTDA/FaceDojo acts as processor. For administrative account, contract, billing, support, and internal operation data, ZedScript Automações LTDA may act as controller. Privacy requests are handled by the DPO/Data Protection Officer through the WhatsApp channels listed on the site.
2. PERSONAL DATA COLLECTED
2.1 Data provided by the user
- Contact data: Name, email, and phone number.
- Professional profile: Registration information and gym data.
- Linked data: Information about the unit and team.
2.2 Biometric data (Sensitive)
- We collect facial biometrics for attendance automation.
- Usage is restricted to student attendance control.
- We do not perform data mining of biometric data for advertising.
- The controlling academy is responsible for defining and maintaining the legal basis and applicable authorizations for facial biometric use.
- Biometric data remains stored while the academy/responsible instructor remains a FaceDojo customer, unless the student or guardian requests deletion earlier.
- The student or guardian may request deletion of biometrics at any time through the student portal, the academy, or the DPO/Data Protection Officer.
2.3 Browsing data
- IP address and access logs.
- Device type and browser used.
- Cookies for platform personalization.
3. PURPOSES OF PROCESSING
- Technical and managerial operation of the platform.
- Facial recognition for security and attendance.
- Technical support and customer service.
- Guaranteeing platform integrity.
- Compliance with industry regulations.
4. LEGAL BASIS (Compliance)
LGPD Compliance (BR)
- Service contract execution.
- Consent for sensitive data.
- Regular exercise of rights.
GDPR Compliance (EU)
- Art. 6(1)(b): Execution of a contract.
- Art. 9(2)(a): Explicit consent for sensitive data.
- Art. 6(1)(c): Compliance with legal obligations.
5. SHARING
- Cloud Providers: Scalable storage and processing (AWS/MongoDB).
- Security and Analytics: Diagnostic tools and continuous improvement.
- Legal Obligation: Compliance with judicial or administrative orders.
6. INTERNATIONAL TRANSFER
Your data may be processed on global servers. We use Standard Contractual Clauses (SCCs) to ensure that the GDPR/LGPD level of protection is maintained regardless of the physical location of the data.
7. OPERATIONAL SECURITY
- End-to-end encryption in transit and at rest.
- Strict policies of least privilege (Least Privilege).
- Vulnerability scans and 24/7 monitoring.
- Data redundancy and encrypted backups.
8. RETENTION AND DELETION
- Operational data is kept while there is an active contractual relationship between the academy/responsible instructor and FaceDojo, observing the purposes of the service.
- Biometric data remains stored while the academy/responsible instructor remains a FaceDojo customer, unless the student or guardian requests deletion earlier.
- Deletion of biometric data may be requested at any time by the student or guardian, including through the student portal, the academy, or the DPO/Data Protection Officer.
- Residual retention of non-biometric data may occur only for tax, legal, contractual obligations, or regular exercise of rights.
9. USER RIGHTS
- Confirmation and Access to existing personal data.
- Correction of incomplete or erroneous information.
- Portability and revocation of consent.
- Opposition to automated processing (GDPR).
10. CONTACT CHANNEL
To exercise any right provided by law, send your request to the DPO/Data Protection Officer through the WhatsApp channels listed on the site. Students and guardians may also request biometric data deletion through the student portal or directly with the controlling academy.