Data Processing and Privacy Policy
Last Updated: Apr 9th, 2025
This Privacy Policy describes how Seasoned ("we," "us," or "our"), as the Controller, collects, uses, and shares your Data when you use Flashboard, our SaaS platform for generating admin panels and CMS ("Flashboard" or the "Service"). We are committed to protecting your privacy and complying with applicable data protection laws, including the Brazilian Lei Geral de Proteção de Dados (LGPD) and relevant U.S. privacy laws, such as the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA).
1. Definitions
General Data Protection Law - LGPD: Federal Brazilian Law No. 13,709 published on August 14th, 2018 that regulates the activities of personal Data Processing, including in digital media, by natural person or legal entity of public or private law, in order to protect the fundamental rights of freedom and privacy and the free development of the personality of the natural person.
Processing: Any operation carried out with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of information, modification, communication, transfer, dissemination or extraction.
Data: Any information related to an identified or identifiable natural person processed under the Contract.
Service: The https://www.getflashboard.com website operated by Seasoned Desenvolvimento de Software LTDA.
Controller: Natural person or legal entity, under public or private law, who is in charge of the decision-making concerning the Processing of personal data.
Processor: A natural person or legal entity under public or private law who processes personal data on behalf of the Controller.
Data Subject: The natural person to whom the Data that are the object of the Data Processing belong.
User: The individual using our Service. The User corresponds to the Data Subject.
System Logs: Records of events that occur within the Service, including errors, security incidents, and performance data.
Identifiers: Information that can be used to identify an individual, such as IP addresses, cookie IDs, and device identifiers.
Sub-processors: Third-party entities we engage to process Data on our behalf to provide the Service.
Advertising Partners: Third-party entities we engage to display advertisements to you.
2. Information We Collect
We collect the following types of Data:
- Data provided by You: When you register for the Service, we collect your email address and name.
- Configuration Data: We collect settings and customizations you make when configuring your admin panels and CMS.
- Metadata: We collect data related to your use of the Service, such as logs, usage patterns, and performance data.
- System Logs: We collect logs related to the Service's operation, including errors, security events, and performance data.
- Usage Analytics: We collect data on how you use the Service to improve the platform.
- Technical Data from your device: We can collect Data from the devices You use to access our Services, such as your operating system, IP address, geolocation information and device identification.
- Data obtained from third-parties: We can collect your Data that is publicly available, such as in social network profiles that You allow to share your Data, as well as receive them from third-parties or contractors. We ask our contractors and third-parties to comply with the applicable laws and to protect your privacy when necessary.
- Analytical Data obtained automatically: We can use technologies such as cookies, web beacons, pixels and others to automatically collect and store data regarding the Services use.
3. How We Use Your Information
We, as the Controller, use your information for the following purposes:
- Providing the Flashboard Service: Generating and hosting admin panels, enabling you to manage your data and your application configurations, and providing support and maintenance.
- Service Improvement: Analyzing usage data to improve the Service's functionality and performance, and debugging and troubleshooting issues.
- Security: Protecting Flashboard and user data from unauthorized access and security threats, and implementing security measures and monitoring for vulnerabilities.
- Billing and Account Management: Processing payments and managing your account, and sending important notifications related to the Service.
- Legal Compliance: Complying with applicable laws and regulations, including the LGPD.
- Advertising: We may use your personal data, including Identifiers and usage data, to provide targeted advertising and remarketing.
4. Data Sharing
We may share your Data with the following third parties:
- Hosting Providers: We use a third-party hosting provider, DigitalOcean, to host Flashboard and your account data. Their privacy policy can be found at https://www.digitalocean.com/legal/privacy-policy.
- Payment Processors: We use a third-party payment processor, Stripe, to process payments. Their privacy policy can be found at https://stripe.com/privacy.
- Analytics Tools: We use analytics tools, such as Google Analytics, to track Flashboard usage. Their privacy policy can be found here: https://policies.google.com/technologies/partner-sites.
- Advertising Partners: We share data with Advertising Partners, such as Google Ads, for targeted advertising and remarketing purposes. We will provide a list of Advertising Partners upon request.
- Sub-processors: We may use Sub-processors to perform specific functions. We will provide a list of Sub-processors and their functions upon request.
- Legal Obligations: We may disclose your Data if required by law or to comply with legal processes.
- International Data Transfer: We may share your Data with foreign contractors, including cloud-based contractors. Every time this occurs, We will adopt the necessary measures to guarantee the security of your Data, based on the LGPD, prioritizing contractors located in countries with data protection regulations with at least the same level of rules as the LGPD.
5. Data Security
We implement appropriate technical and organizational measures to protect your information, including:
- Encryption of Data at rest and in transit.
- Access controls to limit access to your information.
- Data backups to prevent data loss.
- We limit the use of any personal data collected to the necessary operation of the Service.
6. Payment Processing
We use Stripe to process payments for Flashboard. We do not store or collect your payment card details. That information is provided directly to Stripe, whose use of your personal information is governed by their Privacy Policy, available at https://stripe.com/us/privacy. Stripe adheres to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
7. Your Rights
As a Data Subject, you have the following rights regarding your personal data:
- Access: You can request access to the information we hold about you.
- Rectification: You can request that we correct any inaccurate or incomplete information.
- Deletion: You can request that we delete your information, subject to legal limitations.
- Data Portability: You can request to receive your information in a portable format.
- Objection: You can object to the Processing of your information.
- Withdraw Consent: If we rely on your consent, you can withdraw it at any time.
- LGPD Rights: Under the LGPD, you have additional rights, including the right to confirmation of the existence of Processing, and the right to anonymization, blocking, or deletion of unnecessary or excessive data.
- CCPA/CPRA Rights: If you are a California resident, you have the right to opt-out of the sale or sharing of your personal information, and the right to limit the use of your Personal Data.
- Exercising Your Rights and Opting Out: To exercise any of these rights, including opting out of the sale or sharing of your personal information for targeted advertising, please contact us at [email protected].
8. Cookies and Tracking Technologies
We use cookies and similar tracking technologies, including third-party advertising cookies, to improve your experience, analyze usage, and provide targeted advertising. We use the AdOpt cookie banner, which provides a clear opt-in and opt-out mechanism for cookie preferences.
9. Data Retention
Your Data will be stored and Processed by Seasoned for the necessary period for Us to comply with our legal, contractual and regulatory obligations or until the purpose of the Data processing is achieved.
Despite that, You can withdraw your legal consent for the Data Processing and request the deletion of your Data anytime You want, as per item 7. In this case, We will delete your Data every time applicable, as per item 7, when your legal consent is the sole legal ground for the Data Processing.
10. Data Protection Officer (DPO)
As required by the LGPD, we have designated a Data Protection Officer. You can contact our DPO at [email protected].
11. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on our website or by email.
12. Legal Basis for Processing (LGPD)
We process your personal data based on the following legal bases:
- Performance of a contract (to provide the Service).
- Legitimate interest (to improve our Service and ensure security).
- Consent (for certain types of Processing, such as cookies and advertising, managed by the AdOpt banner).
- Compliance with legal obligations.
13. Minor's Privacy
Flashboard is not intended for use by minors. We do not knowingly collect personal information from children under the age of 18. If we discover that we have collected personal information from a child under 18, we will promptly delete it.
14. Contact Us
If you have any questions about this Privacy Policy, or would like a list of our current Sub-processors and Advertising Partners, please contact us at:
Seasoned.cc
Av Carlos Gomes, 700 - Sl 606 5° andar. Boa vista. Cep: 90.480-000. Porto Alegre/RS - Brazil