privacy policy

This Privacy Policy covers the adc mobile application (“Application”) as well as the (“Site”) website, hereafter referred to as simply “adc”, intended to provide Users with and Visitors with a transparent view of practices related to the collection, storage and use of data by adc.


By clicking on the "I have read and accepted" box or by continuing to use adc, in the event of any Privacy Policy updates, you are effectively indicating your agreement to our Privacy Policy and Terms of Use. We therefore suggest that you read Please carefully review this document, as well as any updates, before making the decision to use or proceed with adc.


For ease of reading, we use certain words / terms with the first letter capitalized. Whenever this occurs, you should understand that this word / term has a definite meaning for the purposes of this Privacy Policy / Terms of Use (such as “Application”, “Personal Data” or “Adc Account”). Defined terms have their meaning as described in this Privacy Policy or the Terms of Use, but if you have any questions, we have also made a Defined Terms List for your reference.





The name 'adc' is short for 'Condo Assemblies', the platform's first name. The priority of the adc is to democratize and expand participation in assemblies. To achieve its goals, we value the ethics, transparency, information security and the convenience of our customers. It also has an Advisory Board structure for constant improvement. The adc was developed to be a simplified tool for elections, voting, and aiding in assemblies. We constantly analyze and think about the behavior of our users in order to adjust tools and bring improvements to their daily lives.


In order to use adc satisfactorily, you must provide us with your Personal Data in order for it to interact with the Software. We respect the trust placed by Users in adc, therefore we adopt strict protection standards for our systems and we will not use your data in any way not provided for in this Privacy Policy.


Our Privacy Policy divides User data into the following categories: Personal Data, General Data and Access Data. Each category is defined and explained in more detail and examples below, if you prefer the index below indicates which items of this Privacy Policy describe how each category uses data:


What data is collected?


The data that we collect has the following sources: (a) Data provided by condominium administrators, condominium managers, condominium representatives, unions, publicly traded companies, class bodies and / or institutions that have the necessary information to perform the assemblies; (b) Data provided by the User through email or other electronic means; (c) Data collected by adc through the Site or the Application provided by the User:


Data provided by condominium administrators, condominium managers, representatives of condominiums, unions, publicly traded companies, class bodies and / or institutions that have the necessary information to hold the meetings.


This data includes all information provided voluntarily to adc, including:


User Data: Means any data provided by the User that in any way identifies you, such as, but not limited to, name, social security number, address, telephone number or email address.


User provided data


This data includes all information that Users have voluntarily entered in the adc, including:


Personal Data: Means any data provided by the User that in any way identifies you, such as, but not limited to, name, social security number, address, telephone number or email address.


Data collected by adc


This data includes all information that adc collects from the User or Visitor when using or accessing adc:


Access data:


· Information collected from Users and Visitors using the Site includes, but is not limited to, such data as the User's access browser, information about their screen and computer resolution, Internet Protocol (IP) address, average time spent. , date and city of Adc access.


· Information collected from Users using the Application includes, but is not limited to, data such as mobile device model, operating system, connection or telephone provider, User location (city, state, and country).


· Cookies as provided in the "COOKIES" of this Privacy Policy.


· Communication between User and adc. If you use the communication tools provided by adc, we may keep a record of all communication exchanged to help you eventually resolve future issues you may have.


From time to time, adc may request additional data from the User, being certain that you always have the option to provide it or not.





The adc will use the data collected for the following purposes:


Operation of adc. We will use all data collected so that when accessing adc the User can achieve the expected performance, as well as to develop and improve the services and functionality offered by adc, perform generic statistics to monitor adc usage, troubleshoot the Software, Check the protection of adc against errors, fraud or any other electronic crime, among others.


Emailing and alerts by adc. Adc may send Users emails or notifications with adc related alerts and announcements to assist them in exploring all adc functionality such as election alerts, feature additions, Site / App usage reminders, among others of the kind.


Development of new forms of promotion or services. The adc may use the General Data (including, with verification of the users that make up each category / statistic) preserving the honor, intimacy, privacy, image and confidentiality, to identify specific and beneficial needs to the users, in order to provide and / or develop products and services aimed at subsidizing the credit cycle, risk analysis, fraud prevention, among others, such as achieving static results in order to favor Users.


Transmission of Personal Data / Personal Financial Data and Account Data to Third Parties


We will not provide Data to third parties except as described in this Policy. We may provide collected data, without any specific and identity information, for the purpose set forth in the adc Policy, related to the benefits that such assignment may provide to the User, whether with respect to Site / Application services and features, or as regards to new products that can be offered, protected all sensitive data.


Non-commercialization of data. Under no circumstances will User information be marketed to third parties by adc.


How adc uses User data when making commercials


As we have already explained, adc may, in an automated and coded manner, group Users according to categories and criteria in order to create a User profile group (“Group”). Personal Data and Personal Financial Data belonging to each Group will not be disclosed to or transmitted to anyone (this data will only be stored in encrypted form on our servers). Our advertisers will only know, for example, that there is an anonymous group of 3,000 adc users who spend 20% of their budget on clothing.


We imagine some questions you may have:


What kind of commercial will the adc do?


We may make advertisements through your email or on the Site / App itself.


Our advertisers may eventually use cookies (among other such technologies) to serve, measure ads and make their ads more effective. To better understand how this may occur, read the item “COOKIES”.

Will adc transmit any data to advertisers?


DO NOT. Any advertising, whether it is directed to your email or inserted into the Site / App, will be served by the adc and not the advertiser. Advertisers will provide us with advertisements and we will direct them to Users so they will not have access to your data.


We may eventually provide advertisers with information if you consent, or after you remove your Personal Data or even aggregate various data that will not let the advertiser know who you are. The purpose is only to give advertisers an overview of how their ads are performing (for example, how many and what is the profile of the Users who accessed or clicked on each ad).


Can advertisers have access to my data under any circumstances?


Adc will never transmit your data to advertisers without your permission, BUT remember that if you click on an advertising banner or otherwise accept to be directed to the advertiser's website, you will no longer be subject to adc's Privacy Policy .





We consider the security of all data provided by our Users our priority. Although any protection system is subject to data breaches and possible breaches, we always strive to prevent this by adopting a high level of protection with the same encryption technology as major banks, which has received certificates from specialized companies. in safety.


All User Data is encrypted. Information is protected with Secure Socket Layer (SSL) technology, ensuring that all User Account Data and Personal Financial Data are never disclosed. In addition, this technology aims to prevent information from being transmitted or accessed by third parties.


For more information about the security used, please read the terms provided in this link.


For as long as the User keeps their account active, all information collected will be stored with high security standard on their own servers or on servers operated and controlled exclusively by adc, located in Brazil or abroad.





Upon deletion of the ADC Account by the User through the Site or Application, we will delete all Personal Data and Account Data, so that all other data will be anonymized, ie there will be no information on the ADC that may indicate the identity. of user.


It is important to know that when complying with any exclusion requests, the adc will cease to function for its intended purposes. Thus, the request for deletion of Personal Data, will imply the immediate deactivation of your adc Account, with permanent loss of any such data entered in it. In order to reuse adc, the User must initiate the necessary procedures to create a new adc Account.


In compliance with any orders from public authorities, the adc will store data from certain Users and, by court order, may have to make data collected from Users available to an applicant.


To request deletion of your adc Account, please contact



In addition to the assumptions mentioned above, your data may also be transferred to third parties at:


New business. Processes of acquisition, sale, merger, corporate reorganization or any other change of control of adc. In this case, Adc will ensure the continued protection of your Personal Data and will notify you in advance if such transfer entails any change to your Privacy Policy;


Court request. The adc may share personal data in the event of a court order;


With the authorization of the User. In other cases, if there is a need to share information, we will send the User a notification requesting its approval or disapproval.





We will communicate using messaging, email or other means at our disposal. We may send you messages regarding service availability, security, or other service related issues.


Our communication will be through Push Notification, email, notices posted on Adc websites or applications, and other means made available by the Services, including mobile text messaging and Push Notifications. These communications include: (1) confirmation of receipt of the call for a condominium meeting; (2) alerts about the deadline to vote at the condominium meeting; (3) welcome announcements and initial access; and (4) service announcements covering service availability, security and other issues regarding the operation of our Services. Please note that you may not opt ​​out of receiving service messages from us.


Push notifications: These are messages sent by applications to your mobile device. You can receive call notifications and alerts about the deadline to vote at the meeting. In the future, other message types may be considered for push notifications. You can also control which notifications you currently receive. We send push notifications to your mobile device through services like Apple Push Notification Service for iOS devices, as well as Google CD2M and Cloud Messaging for Android devices. Both services are standard features of mobile operating systems.





We use cookies and similar technologies, such as pixels and tags, to make sure that the services provided by adc are to the best standard expected by the User. Cookies collected by Adc provide us with statistics only and will not be used for purposes other than those expressly provided in this Privacy Policy and Terms of Use.


What is a cookie?


A cookie is a small file added to your device or computer to provide a personalized Adc access experience.


How does adc collect cookies?


Adc uses companies that specialize in advertising, inside or outside Adc, such as Google Adwords and Facebook.


In addition, cookies may be collected by specialized companies selected by Adc, including Google and Facebook. Adc understands that by accepting this Privacy Policy you have read and agree to the privacy policies for the use of cookies by analytics companies.


What types of cookies does adc use?


Adc allows the collection of two types of cookies: saved and temporary.


(a) A saved cookie is a cookie that is entered on your access terminal (eg computer, tablet, etc.) when you sign in to your Adc Account. This cookie is for storing information, such as name and password, so that the User does not have to log in each time they sign in to Adc.


(b) A temporary cookie is one that is used to identify a specific visit to the Adc website. These cookies are removed from the user's access terminal (eg computer, tablet, etc.) as soon as the browser is finished and are used to store temporary information.

What are cookies used for?


Adc uses cookies for a variety of purposes, including:


- Remarketing Marketing Actions: This feature allows us to reach Users or Site Visitors to remind them to sign up for Adc or to easily re-access the platform.


- Understand site and app usage behavior for better product development


Is it possible to limit the collection of cookies?


Browsers generally allow you to disable cookie collection, so if you do not change your browser's cookie collection policies we will consider that you agree to the collection of cookies by the site. Unfortunately, adc may not work as intended if cookie collection is disabled.


Cookies and Account Information


No Account Data, Personal Data or Personal Financial Data may be collected through cookies and similar technologies, such as pixels and tags.





All data you submit to us via our website forms will be transferred to us via SSL - an encrypted protocol - and stored in databases that cannot be accessed outside our firewall.


In other words, any data you submit to us will be properly encrypted so that it cannot be deciphered and read by any malicious agents. Our firewall is a mechanism that prevents access to our servers by people who do not make up adc staff, and is active around the clock.


Adc does not sell or rent your contacts to anyone, that is, only our employees may eventually have access to the data you provide. We may occasionally use your name and email address to send you information regarding Adc content that may interest you. If at any time you wish to be removed from our free content distribution list, please click here to contact our customer service department.





Although we keep your data confidential in accordance with the terms of this Privacy Policy, it will be the responsibility of each User to keep the adc Account login and password secure and should not provide it to anyone.


If you believe your adc login and password have been stolen or are known to others for any reason, you should immediately notify adc through, without prejudice to your immediate password change through the Site. and / or Application.






The terms of this Privacy Policy are governed by and shall be construed in accordance with the laws of the Federative Republic of Brazil.





In order to ensure User privacy as well as the security of their data, adc undertakes to regularly re-evaluate its Privacy Policy and adapt it as necessary. If changes are made to this Privacy Policy, the User will be notified and will be responsible for reviewing such changes. If User continues to use adc after we announce an update of the Privacy Policy, we will interpret that User agrees to changes made to this document.



April 3, 2019.