Cookie Policy

❗ NOTICES ❗

The privacy policy is the document by which the person responsible for maintaining a website or application explains to all interested parties how the personal data of users and visitors to the platform will be treated.

The adoption of the European Union General Data Protection Regulation (GDPR) raised the debate on the protection of personal data in the “internet age”. In Brazil, the General Law for the Protection of Personal Data (Law no.13709/18) which will come into full force as of August 2020. This standard brings a series of requirements regarding the collection, storage and processing of users’ personal data.

The platform that collects, stores and processes personal data from users must inform all interested parties what personal data is collected, how this data is collected, among other information that must be made available in the privacy policy.

Personal data: is all information related to a natural person that can identify him. Also, personal data can be sensitive personal data, these are all information about racial or ethnic origin, religious conviction, political opinion, affiliation to a union or organization of a religious, philosophical or political nature, related to health or sexual life, given that genetic or biometric, when linked to a natural person.

It is important to point out that:

• Privacy Policy refers to specific information on the collection, storage and protection of personal data of users of a website or application.
• General Terms and Conditions of Use serve to indicate the rules that must be respected when using the platform. That is, they inform the obligations and rights of users as well as the platform, since it serves as a kind of adhesion contract.

So, understanding this difference, if the contract that fits your situation is the General Terms and Conditions of Use, we recommend that you consult our model:Terms and conditions of use.

Finally, we remind you that the Privacy Policy is a customizable document, and the person responsible for its preparation must pay attention to the peculiarities of its platform, as well as possible legislation applicable to the industrial branch of the company.

Model

PRIVACY POLICY

SECTION 1 – GENERAL INFORMATION

This Privacy Policy contains information on the collection, use, storage, treatment and protection of the personal data of users and visitors of the OR application ____ OR/E website ____, with the purpose of demonstrating absolute transparency on the matter and clarifying to all interested parties about the types of data that are collected, the reasons for the collection, and the way in which users can manage or delete their personal information.

This Privacy Policy applies to all users and visitors of the OU application ____ OR site ____ and integrates the General Terms and Conditions of Use of the OU application ___ OR site ____, duly registered with the CNPJ under No. ___, located at _____ ( full address), hereinafter referred to as ____.

This document was prepared in accordance with the General Personal Data Protection Act (Law13,709/18), theCivil Rights Framework for the Internet(Law12,965/14) (and EU Regulation No. 2016/6790). Also, the document may be updated as a result of any regulatory update, which is why the user is invited to periodically consult this section.

SECTION 2 – HOW DO WE COLLECT USER AND VISITOR PERSONAL DATA?

User and visitor personal data are collected by the platform as follows:

(Perform multiple choice question with other option)

• When the user creates an account/profile on the ___ platform: this data is the basic identification data, such as ___ (example: email, full name, city of residence and profession). From them, we can identify the user and the visitor, in addition to ensuring greater security and well-being to their needs. Users and visitors are aware that their profile on the platform will be accessible to all other users and visitors to the platform ___.
• When a user and visitor access EI website pages __ OR the application ___: interaction and access information is collected by the company to ensure a better user and visitor experience. This data can deal with the keywords used in a search, the sharing of a specific document, comments, page views, profiles, the URL where the user and visitor come from, the browser they use and their access IPs, among others. others that can be stored and retained.
• Through a third party: the ____ platform receives data from third parties, such as ___ (indicate from whom the platform receives data, for example Facebook and Google), when a user logs in with their profile from one of these websites. The use of this data is previously authorized by users with the third party in question.
• others

SECTION 3 – WHAT PERSONAL DATA DO WE COLLECT ABOUT USERS AND VISITORS?

The personal data of the user and visitor collected are as follows:

(Perform multiple choice question with other option)

• Data for creating the account/profile on the platform ___: ___ (example: e-mail, full name, city of residence and profession).
• Data for browsing optimization: ____ (example: access to pages, keywords used in the search, recommendations, comments, interaction with other profiles and users, followed profiles, IP address).
• Data to complete transactions: data regarding payment and transactions, such as credit card number and other information about the card, in addition to payments made.
• Newsletter: the e-mail registered by the visitor who chooses to subscribe to the Newsletter will be collected and stored until the user requests to unsubscribe.
• Sensitive data: the platform may collect the following sensitive user data – ___________ (example: ethnic or racial origin, political opinion, religious conviction, genetic data, data relating to health, sexual orientation)
• Data related to contracts: upon formalization of the contract of purchase and sale or provision of services between the platform and the user and visitor, data related to contractual execution, including communications between the company and the user, may be collected and stored.
• others

SECTION 3 – FOR WHAT PURPOSES DO WE USE USER AND VISITOR PERSONAL DATA?

(Do multiple choice question with others)

The user’s and visitor’s personal data collected and stored by the ____ platform is intended to:

• User and visitor well-being: improve the product and/or service offered, facilitate, expedite and fulfill the commitments established between the user and the company, improve users’ experience and provide specific functionality depending on the user’s basic characteristics.
• Platform Improvements: Understanding how the user uses the services of the platform, to help with business and technical development.
• Advertisements: Present personalized advertisements to the user based on the data provided.
• Commercial: the data is used to personalize the content offered and to generate subsidy to the platform to improve the quality of the operation of the services.
• User profile prediction: automated processing of personal data to assess usage on the platform.
• Registration data: to allow user access to certain contents of the platform, exclusive to registered users
• Contract data: provide the parties with legal certainty and facilitate the conclusion of the deal.
• Others

The processing of personal data for purposes not provided for in this Privacy Policy will only occur upon prior communication to the user, so that the rights and obligations set forth herein remain applicable.

SECTION 4 – HOW LONG IS PERSONAL DATA STORED?

The personal data of the user and visitor are stored by the platform for the period necessary for the provision of the service or the fulfillment of the purposes set out in this document, as provided for in itemIof the article15of law13,709/18.

The data can be removed or anonymized at the user’s request, except in cases where the law offers other treatment.

Furthermore, the personal data of users can only be kept after the end of their treatment in the following cases provided for in article 16 of the aforementioned law:

I – compliance with a legal or regulatory obligation by the controller;

II – study by a research body, guaranteeing, whenever possible, the anonymization of personal data;

III – transfer to a third party, provided that the data processing requirements set forth in this Law are respected;

IV – exclusive use of the controller, its access by a third party being prohibited, and provided that the data is anonymized.

SECTION 5 – SECURITY OF STORED PERSONAL DATA

The platform undertakes to apply the technical and organizational measures capable of protecting personal data from unauthorized access and from situations of destruction, loss, alteration, communication or dissemination of such data.

Data relating to credit cards is encrypted using “secure socket layer” technology (SSL) which guarantees the transmission of data in a secure and confidential manner, so that the transmission of data between the server and the user takes place in an encrypted and encrypted.

The platform is not exempt from liability for the exclusive fault of a third party, as in the case of an attack by hackers or crackers, or the exclusive fault of the user, as in the case where he himself transfers his data to third parties. The website undertakes to notify the user in the event of any breach of security of their personal data.

The personal data stored are treated confidentially, within legal limits. However, we may disclose your personal information if we are required by law to do so or if you violate our Terms of Service.

SECTION 6 – DATA SHARING

The sharing of user data only occurs with data referring to publications made by the user himself, such actions are publicly shared with other users.

The user’s profile data is publicly shared in search systems and within the platform, and the user is allowed to modify this configuration so that his profile does not appear in the search results of such tools.

SECTION 6 – WILL THE PERSONAL DATA STORED BE TRANSFERRED TO THIRD PARTIES?

Personal data (not) may be shared (with third parties) (with the following (individual) (legal) persons: _________, CPF/CNPJ _________.

(Whether data can be shared)

The indicated third parties receive the data to the extent necessary to allow them to perform the contracted services.

With respect to third-party service providers such as payment transaction processors, please note that each has its own privacy policy. Therefore, we recommend that you read their privacy policies to understand what personal information will be used by these providers.

(If transfer to other countries)

Suppliers may be located or have facilities located in different countries. Under these conditions, the personal data transferred may be subject to the laws of the jurisdictions in which the service provider or its facilities are located.

By accessing our services and providing your information, you are consenting to the processing, transfer and storage of this information in other countries.

When you are redirected to a third party application or website, you will no longer be governed by this Privacy Policy or our Platform Terms of Service. We are not responsible for the privacy practices of other websites and we encourage you to read their privacy statements.

SECTION 07 – COOKIES OR NAVIGATION DATA

Cookies refer to text files sent by the platform to the user’s and visitor’s computer and which are stored there, with information related to navigation on the website. Such information is related to access data such as access location and time and is stored by the user’s and visitor’s browser so that the platform’s server can read them later in order to customize the platform services.

The user and the visitor of the ___ platform declare to know and accept that a navigation data collection system can be used through the use of cookies.

The persistent cookie remains on the user’s and visitor’s hard drive after the browser is closed and will be used by the browser on subsequent visits to the website. Persistent cookies can be removed by following your browser’s instructions. The session cookie is temporary and disappears after the browser is closed. You can reset your web browser to refuse all cookies, however some features of the platform may not function properly if the ability to accept cookies is disabled.

SECTION 8 – CONSENT

By using the services and providing personal information on the platform, the user is consenting to this Privacy Policy.

The user, when registering, declares that he knows and can exercise his rights to cancel his registration, access and update his personal data and guarantee the veracity of the information made available by him.

The user has the right to withdraw his consent at any time, for which he must contact us via email _______ or by mail sent to the following address: ________

SECTION 9 – CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, so it is recommended that the user and visitor review it frequently.

The changes and clarifications will take effect immediately after their publication on the platform. When changes are made, users will be notified. By using the service or providing personal information after any modifications, the user and visitor demonstrate their agreement with the new rules.

In the event of the merger or sale of the platform to another company, user data may be transferred to the new owners so that the services offered remain.

SECTION 10 – JURISDICTION FOR CONFLICT RESOLUTION

For the settlement of disputes arising from this instrument, Brazilian law will be fully applied.

Any disputes must be filed in the court of the district where the company’s headquarters are located.