1. Privacy Policy
COMPANY NAME, ADDRESS, ZIP CODE 00000-000, registered with CNPJ/MF under no. , so o CRP 01/28881, is committed to safeguarding the privacy of our customers and users. This privacy notice sets out our personal data collection and sharing practices for our website and is intended to inform you about the ways in which our website collects personal data, the uses of that personal data and the ways in which we will share any personal data we have about you. Our website contains links to third party websites. If you follow a link to any of these third party websites, please note that they have their own privacy policies and that we have no responsibility or liability for these policies or for the processing of your personal data. Please check these policies before submitting any personal information to any third party websites.
2. Information we collect about you
We will collect and process all or some of the following personal data about you:
A) Information you provide to us: personal data you provide to us, such as when filling out the contact form or any subscription form on our website, including your name, email and other contact information;
B) Our communication: if you contact us, we will keep a record of our communication either via email or messaging via App (Whatsapp/Telegram), except via phone call in which we will not record the calls;
C) Survey information: if we ask you to complete surveys that we use for research purposes, we will collect the data provided in the completed survey. In such cases, we strive to pseudonymise or de-identify your data wherever possible.
D) Website and communication: information about your visits to the website and data collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, online traffic data, location data, web logs and other communication data, and the functionalities you access.
3. How we use your personal data
The purposes for which we use the personal data we collect through our website and, in compliance with our obligations under data protection legislation, including the Brazilian General Data Protection Law, we have identified the “legal bases” on which we rely to process your data. The Brazilian Data Protection Law allows companies to process personal data only where the processing is permitted by specific “legal bases” set out in law. Please note that, in addition to what we describe below, in some circumstances we will also disclose personal data to service providers, contractors, agents and/or affiliates who perform on our behalf the activities described in this notice.
(a) To communicate effectively with you and conduct our business: to conduct our business, including to respond to your inquiries, or to carry out our obligations arising from any agreements entered into between us, which in some circumstances may include the transmission of your data to third parties, such as agents or contractors or to our advisors.
(b) To provide you with marketing materials: to provide you with updates and offers if you have opted in to receive them or if we think you would be interested in a particular product or service. We may also use your data to market our own products and services and those of selected business partners to you by post, email, SMS, telephone and fax and, where required by law, we may ask for your consent at the point we collect your data to carry out any of these types of marketing. We will provide you with an option in every electronic marketing communication sent to you to unsubscribe or opt-out of receiving these communications, or you can contact us and opt-out of receiving these communications.
(c) For research and development purposes: to analyse your personal data in order to better understand the marketing objectives for you and our other customers and to better understand our business and develop our products and services. Where possible, we carry out these analyses without identifying you within our data set.
(d) To monitor certain activities: to monitor queries and transactions to ensure service quality, compliance with procedures and to combat fraud.
(e) To inform you about changes: to notify you about changes to our services and products.
(f) To ensure that the content on our websites is relevant: to ensure that the content on our websites is presented in the most effective manner for you and for the device you use, which may include passing your data to business partners, suppliers and/or service providers. (g) To reorganise or make changes to our business: if (I) we are subject to negotiations for the sale of our business or part of it to a third party; (II) we are sold to a third party; or (III) we undergo a reorganisation, we may need to transfer some or all of your personal data to such third parties as part of a due diligence process for the purposes of considering a proposed sale or reorganisation. We may also need to transfer your personal data to such reorganised entity or to such third party following the sale or reorganisation for them to use it for the same purposes as set out in this notice. (h) In connection with legal or regulatory obligations: We process your personal data to comply with our regulatory requirements or as part of interaction with regulators, as applicable, which may include disclosing your personal data to third parties, a court, regulators and/or government agencies in connection with inquiries, proceedings or investigations by them anywhere in the world or where we are required to do so.
4. Transmission, storage and security of your personal data
Internet Security
No data transmission over the Internet or website can be guaranteed to be secure from hackers. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal data in accordance with legal data protection requirements. All information you provide to us is stored on secure servers owned by us or our subcontractors and accessed and used in accordance with our security policies and standards. If you choose a password, which enables you to access certain parts of our websites, you are responsible for keeping this password confidential and for complying with any other security procedures that we inform you of. We will never ask you for your password, and we ask that you do not share it with anyone.
International Transfer
Your personal data may be accessed by employees or suppliers, transferred to and/or stored at a destination outside the country in which you are located, whose data protection laws may be of a lower standard than those in your country. In all circumstances, we will safeguard personal data as set out in this Privacy Notice.
Storage limits
We will retain your personal data for as long as necessary for the processing purpose(s) for which it was collected and any other permitted linked purposes. Our retention periods are based on business necessity, and personal data that is no longer needed is irreversibly anonymized or securely destroyed in accordance with our internal retention policy.
5. Your rights & how to contact us
Marketing
You have the right to ask us not to process your personal data for marketing purposes. You can exercise this right at any time by clicking the “unsubscribe” option on any electronic marketing communication sent to you or by contacting us.
Information update
We will use reasonable efforts to keep your personal data accurate. In order to help us do this, you must notify us of any changes to your personal data.
Your rights
If you have any questions regarding our use of your personal data, you should first contact us. Under certain conditions, you have the right to request the following from us: a) Confirmation of the processing of your data b) Access to your data c) Rectification of your data d) Deletion, blocking or anonymization of unnecessary, excessive data belonging to you, or your data that is processed in violation of the law e) Possibility of data portability f) Deletion of data processed with your consent g) Information about the sharing of data h) Information about the possibility of refusing consent i) Revocation of consent j) Request review of decisions that affect your interests and have been made exclusively based on the automated processing of your personal data Your exercise of these rights is subject to certain exemptions to safeguard the public interest and our interests. If you exercise any of these rights, we will check these exceptions and respond to your request in a timely manner. If you are not satisfied with our use of your personal data or our response to any exercise of these rights, you have the right to complain to the Brazilian Data Protection Authority (ANPD).
