Privacy Policy

This app collects some personal data from its users.

Important notes

• This document contains a section dedicated to visitors who live in the state of California (CCPA) and their privacy rights.

• This document contains a section dedicated to visitors who live in Brazil (LGPD) and their privacy rights.

• This document can be printed for reference using the Print command in any browser settings.

The type of information we collect about you

We appreciate your interest and your concerns about the privacy of your data on the Internet.

This policy has been prepared to help you understand the nature of the data that we collect from you when you visit our website and how we deal with this personal data.

Among the data that this site collects about you (alone or with the assistance of a third party) are your full name, email address, phone number and country. As all this data is data that you provide to us when it is requested from you, and failure to provide this data may lead to making this site unable to provide the services you request, and this data will not be sold or shared with any other party except for governments and country institutions. You are completely free to request that this data be deleted or modified by contacting us.

In the event that some data is mentioned as not mandatory, users have the right to ignore it without consequences for the availability of services or their work, and we are fully prepared to receive your inquiries about providing data, which is mandatory and which is optional.

There is some other data that is automatically collected through the Google Analytics service, which in turn determines the audience of the site and some other details of the site’s visitors, which in turn help us to know our audience and how our visitors deal with the site in order to ensure that we continue to provide the best services to our customers and visitors to our site. Note that this data is collected automatically upon entering the site.

This site also records your cookies and we have the right to deal with any other party to analyze this data in order to improve the quality of the services we provide to our valued customers. In addition, your visit to any website (in addition to our site) will lead to the recording of your Internet Protocol (IP) address, the type and version of your browser, the time of your visit to the site and the link that you visited, as all of this data will be recorded by the company that provides the hosting services of our website.

Note that your use of the site and its services means your approval of all that is mentioned in this document, and the user bears full responsibility in the event that the third party publishes or shares the data that it collects from the users, as long as there is an authorization from the owner of this site for the third party to provide this data to us.

The way we're processing your collected data

The owner of this website takes appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of data. Where data is processed using computers and / or IT-enabled tools, following regulatory procedures and methods strictly related to the purposes indicated. In addition to that, the owner of the site, in some cases, may provide this data to certain types of persons responsible for or involved in the operation of this application (administration, sales, marketing, legal affairs, system administration) or external parties (such as: technical service providers and mail hosting providers, IT companies, and telecom agencies), if required, as authorized data processors by the owner. An updated list of data for these parties may be requested from the owner at any time.

Legal basis for data processing

The owner of this site or other entities authorized by the owner may process this personal data, if one or more of the following procedures apply:

• Users have given their consent for one or more of the specified purposes;

  Note: According to some legislations, the owner of this website may be allowed to process personal data until the user objects to this processing by "unsubscribing" or informing the work team with a request to delete all his data from the site's records, without having to rely on consent or any of the following legal rules . However, this procedure does not apply, when the processing of personal data is subject to European data protection law.

• Providing data from the user is necessary, in order to be able to implement an agreement with the user and / or any previous contractual obligations;

• Processing is necessary to comply with the legal obligation to which the owner is subject;

• Processing relates to a mission in the public interest or in exercising the official authority vested in the owner;

• Processing is necessary for the purposes of the legitimate interests of the owner or a third party; And

• In any case, the site owner and persons authorized to represent the company will gladly help clarify the specific legal basis that applies to the processing, and in particular whether the provision of personal data is a legal or contractual requirement, or a necessary condition for entering into a contract.

Where the data is processed

The data is processed at the owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the user's location, data transfers may involve the transfer of user data to a country other than their own. To find out more about where this transferred data is processed.

Users also have the right to learn about the legal basis for data transfers to a country outside the European Union or to any international organization governed by public international law or established by two or more countries, such as the United Nations, and about the security measures taken by the owner to protect his data.

Should any such transfer occur, users can find out more by checking the relevant sections of this document or inquiring with the owner using the information provided in the Contact section.

The lifetime of the data

Personal data must be processed and stored for as long as required according to the purpose for which it was collected.

And therefore:

• The personal data collected for the purposes of performing a contract between the owner and the user will be kept until that contract is fully executed.

• Personal data collected for the purposes of the legitimate interests of the owner must be kept as long as it is necessary to achieve these purposes. Users may find specific information related to the legitimate interests of the owner in the relevant sections of this document or by contacting the owner.

• The owner may be allowed to retain personal data for a longer period when the user has agreed to this processing (as long as the user does not request the removal of this data from the site records from the owner or the persons authorized to do so from the owner), and as long as this consent has not been withdrawn. Moreover, the owner may be obligated to retain personal data for a longer period whenever required to do so in order to perform a legal obligation or upon an order from an authority.

• Once the retention period expires, the personal data will be deleted. Therefore, the right to access, right to erase, right to rectification and right to data portability cannot be enforced after the retention period has expired.

The purposes of data processing

User data is collected to allow the owner to provide his service, to comply with his legal obligations, to respond to enforcement requests, to protect his rights and interests (or to the rights of users or third parties), to detect any malicious or fraudulent activity, in addition to the following: contact the user and comment on analyzes and content.

For specific information about the personal data used for each purpose, the user can refer to the "Detailed information on personal data processing" section.

User Rights

Users may exercise certain rights in relation to their data that the owner processes.

In particular, users are entitled to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent as long as they previously agreed to the processing or collection of their personal data.

• Object to the processing of their data. Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent.

• Access to their data. Users have the right to know whether or not the owner processes the data, to obtain disclosure about certain aspects of the processing and to obtain a copy of the data that is subject to processing.

• Check and ask for correction. Users have the right to verify the accuracy of their data and request that it be updated or corrected.

• Restricting the processing of their data. Users have the right, under certain circumstances, to restrict the processing of their data. In this case, the owner will not process his data for any purpose other than storing it.

• Delete their personal data or otherwise remove it. Users have the right, under certain circumstances, to have their data erased from the owner.

• Make a complaint. Users have the right to file a lawsuit before the competent data protection authority.

Details about the right to object to processing

When personal data is processed in the public interest, in the exercise of the official authority vested in the owner or for the purposes of the legitimate interests pursued by the owner, users may object to this processing by providing a basis related to their own situation as a justification for this objection.

Users should know that if their personal data is being processed for direct marketing purposes, they can object to such processing at any time without providing any justification. To find out if the owner is processing personal data for direct marketing purposes, users can refer to the relevant sections in this document.

How to exercise these rights

Any requests to exercise user rights can be directed to the owner of this site or persons authorized to do so by contacting and informing us of that. These requests can be exercised free of charge and will be processed by the owner as soon as possible within one month.

Additional information about the collection and processing of user data

Legal action

User personal data may be used for legal purposes by the owner in court or in the stages that lead to potential legal action arising from the improper use of this application or related services.

The user declares that he is aware that the owner may be required to disclose personal data at the request of public authorities.

Additional information about the user's personal data

In addition to the information contained in this privacy policy, this application may provide the user with additional and contextual information related to specific services or the collection and processing of personal data upon request.

System logs and maintenance

For operation and maintenance purposes, this application and any third-party services may collect files that record interaction with this application (system logs) that use other personal data (such as an IP address) for this purpose.

Information not contained in this policy

Further details regarding the collection or processing of personal data may be requested from the owner at any time.

How are 'Do Not Track' requests handled

This app does not support "Do Not Track" requests.

To determine whether any of the third-party services you use accept "Do Not Track" requests, please read their privacy policies.

Changes to this Privacy Policy

The owner reserves the right to make changes to this privacy policy at any time by notifying its users on this page and possibly within this application and / or - as far as technically and legally possible - sending a notice to users via any contact information available to the owner. It is highly recommended that you check this page often, noting the date of last modification listed below.

In the event that the changes affect the processing activities that are made on the basis of the user's consent, the user must read them well and not request to object to processing or delete the data, which will mean his approval of the new privacy policy, which is a complete authorization to the site owner to continue despite the changes in the privacy policy.

Information for California consumers

This part of the document is integrated and complements the information contained in the rest of the Privacy Policy and is provided by the company that runs this website, and if so, the parent company and its subsidiaries (for the purposes of this section referred to collectively as "we", "ours" , "our").

The provisions in this section apply to all users who are consumers who are residents of California, USA, in accordance with the “California Consumer Privacy Act of 2018” (users are referred to below, simply as “you,” “your,” “yours.” For these consumers, these provisions supersede any other potentially conflicting or conflicting provisions contained in the Privacy Policy.

This part of the document uses the term "personal information" as defined in the California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed, or sold

In this section we summarize the categories of personal information that we have collected, disclosed or sold, and their purposes. You can read about these activities in detail in the section titled "The type of information we collect about you" of this document.

Information We Collect: The categories of personal information that we collect

We have collected the following categories of personal information about you: identifiers and internet information.

We will not collect additional categories of personal information without notifying you.

How do we collect information: What are the sources of personal information we collect?

We collect the above categories of personal information, either directly or indirectly, from you when using this application.

For example, you provide your personal information directly when submitting requests via any forms on this site. You also indirectly provide personal information when navigating this website, as your personal information is automatically observed and collected. Finally, we may collect your personal information from third parties who work with us in connection with the service or the operation and features of this website.

How we use the information we collect: Sharing and disclosing your personal information with third parties for a commercial purpose

We may disclose the personal information we collect about you to a third party for commercial purposes. In this case, we enter into a written agreement with this third party that requires the recipient to maintain the confidentiality of personal information and not to use it for any purpose (s) other than those necessary to implement the agreement.

We may also disclose your personal information to third parties when you explicitly request or authorize us to do so, in order to provide you with our services.

To learn more about the purposes of the processing, please refer to the relevant section of this document.

Sell your personal information

For our purposes, the word “selling” means selling, renting, releasing, disclosing, publishing, making available, transferring, or transferring in any other way orally or in writing or by electronic means, the personal information of the consumer by the company to another company. Or a third party, for cash or any other valuable consideration."

This means, for example, that selling can happen when an app is running ads, performs statistical analyzes of traffic or views, or simply because it uses tools like social media plugins and the like.

Your right to opt out of the sale of personal information

You have the right to opt out of the sale of your personal information. This means that whenever you ask us to stop selling your data, we will comply with your request.

These requests can be submitted freely, at any time, without submitting any verifiable request, simply by following the instructions below.

Instructions to unsubscribe from selling personal information

If you would like to know more, or exercise your right to unsubscribe, in relation to all sales made by this application, whether online or offline, you may contact us for more information.

What are the purposes for which we use your personal information?

We may use your personal information to allow the operation and features of this application ("commercial purposes"). In such cases, your personal information will be processed in a manner necessary and proportionate to the business purpose for which it was collected, and within the limits of strictly compatible operational purposes.

We may also use your personal information for other reasons such as commercial purposes (as described in the "The type of information we collect about you" section in this document), as well as to comply with the law and defend our rights before the relevant authorities where our rights and interests are threatened or we suffer actual harm.

We will not use your personal information for various, irrelevant or incompatible purposes without notice to you.

Your California Privacy Rights and How to Exercise them

Right to know and portability

You have the right to request that we disclose to you:

• The categories and sources of the personal information we collect about you, the purposes for which we use your information and with whom this information is shared;

• In the event that personal information is sold or disclosed for a commercial purpose, there are two separate lists in which we disclose:

  • Sales, and classes of personal information purchased by each category of recipients; And

  • For commercial purpose disclosures, the categories of personal information that each category of recipient has obtained.

The disclosure described above will be limited to personal information collected or used during the past 12 months.

If we send our response electronically, the attached information will be "portable", that is, delivered in an easy-to-use format to enable you to transfer the information to another entity without hindrance - provided this is technically feasible.

The right to request that we delete your personal information

You have the right to ask us to delete any of your personal information, subject to the exceptions stipulated in the law (for example, but not limited to, where the information is used to identify and fix errors in this application, to discover security problems and protect against fraudulent or illegal activities, to exercise some rights. Etc.).

If, as a result of exercising your right, no legal exception applies, we will delete your personal information and direct any of our service providers to do so.

How to exercise your rights

To exercise the rights described above, you need to send your verifiable request to us by calling us.

In order for us to respond to your request, it is essential that we know who you are. Therefore, you can only exercise the above rights by submitting a verifiable application and you must:

• Provide information sufficient to allow us to reasonably verify that you are the person with whom we have collected personal information or an authorized representative;

  Describe your request in sufficient detail to allow us to properly understand, evaluate and respond to your request.

• We will not respond to any request if we are unable to verify your identity and thus confirm the personal information we have in your possession.

If you are unable to make a personal verifiable request, you may authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can submit an application that can be verified on behalf of a minor who is under your parental authority.

You can submit a maximum of two applications within a period of 12 months.

How and when we are expected to handle your request

We will confirm receipt of your verifiable order within 10 days and provide information on how to process your request.

We will respond to your request within 45 days of receiving it. If we need more time, we'll explain the reasons for this and how much time we need. In this regard, please note that it may take up to 90 days to fulfill your request.

Our disclosure will cover the previous 12 months.

If we reject your request, we will explain the reasons for our refusal.

We do not charge a fee to process or respond to your verifiable request unless such request is clear or excessive. In such cases, we may charge a reasonable fee, or decline to act upon request. Either way, we will communicate our options and explain the reasons behind this.

Information for users residing in Brazil

This part of the document is integrated and supplemented with the information contained in the rest of the Privacy Policy and is provided by the entity that manages this website, and if so, the parent company and its subsidiaries and affiliates (for the purposes of this section referred to collectively as "we", ours, “our”, ”ourselves”).

The provisions in this section apply to all users residing in Brazil, according to “Lei Geral de Proteção de Dados” (users are referred to below, simply as “you”, “yours”, “your”, ”yourself”). For these users, these provisions supersede any other provisions that may be conflicting or inconsistent in the privacy policy.

This part of the document uses the term “personal information” as defined in Lei Geral de Proteção de Dados (LGPD).

The bases on which we process your personal information

We can only process your personal information if we have a legal basis for that processing. The legal bases are as follows:

• Your consent to relevant data processing activities;

• Comply with a legal or regulatory obligation that we bear;

• Implement public policies stipulated in laws or regulations or on the basis of contracts, agreements and similar legal instruments;

• Studies conducted by research entities, preferably on anonymous personal information;

• Execution of the contract and its preliminary procedures, in cases where you are a party to the said contract;

• Exercising our rights in judicial, administrative or arbitration proceedings;

• Protection or the physical safety of you or a third party;

• Health protection - in actions carried out by health entities or professionals;

• Our legitimate interests, provided that your fundamental rights and freedoms do not override these interests; And

• Credit protection.

To learn more about the legal grounds, you can contact us at any time.

Categories of personal information processed

To find out what categories of your personal information is being processed, you can read the section titled "The type of information we collect about you" within this document.

Why do we process your personal information

To find out why we are processing your personal information, you can read the sections titled "The type of information we collect about you" and "Purposes of Data Processing" in this document.

Your Brazilian privacy rights, how to place a request and our response to your requests

Your Brazilian Privacy Rights

You have the right to:

• Obtaining confirmation of the existence of processing activities on your personal information;

• Correct incomplete, inaccurate or outdated personal information;

• Obtaining anonymity, blocking, or deletion from your unnecessary or excessive personal information, or information that is not processed according to the LGPD;

• Obtaining information about the possibility of providing or denying your consent and the consequences thereof;

• Obtaining information about third parties with whom we share your personal information;

• Obtain, upon your express request, the ability to transfer your personal information (excluding anonymous information) to another service provider or product, provided that our trade and industrial secrets are protected;

• Get your personal information that is being processed to be deleted if the processing is based on your consent, unless one or more exceptions are provided in the article. 16 LGPDs apply;

• Revoke your consent at any time;

• File a complaint regarding your personal information with ANPD (National Data Protection Authority) or with consumer protection agencies;

• Opposing data processing activity in cases where the processing is not carried out in accordance with the provisions of the law;

• Requesting clear and sufficient information about the criteria and procedures used to make an automated decision; And

• Request a review of decisions made solely on the basis of the automated processing of your personal information, which affects your interests. These include decisions to define your personal, professional, consumer, credit, or personality aspect.

You will never be discriminated against, or otherwise harmed, if you exercise your rights.

How to submit your application

You may submit your express request to exercise your rights free of charge, at any time, or via your legal representative.

How and when will we respond to your request

We will strive to respond promptly to your requests.

In any case, if it is impossible for us to do so, we will make sure to inform you of the factual or legal reasons that prevent us immediately, or in any other way, from complying with your requests. In cases where we do not process your personal information, we will inform you of the natural or legal person to whom your requests should be directed, if we are in a position to do so.

In the event that you submit a request for confirmation of access or a request to confirm the processing of personal information, please ensure that you specify whether you wish to have your personal information delivered in electronic or printed form.

You will also need to tell us if you would like us to respond to your request immediately, in which case we will respond in a simplified manner, or if you require a full disclosure instead.

In the latter case, we will respond within 15 days from the time of your request, providing you with all information regarding the origin of your personal information, confirmation of whether or not the records exist, and any criteria used for processing and purposes of processing, while preserving our trade and industrial secrets.

In the event that you submit a request to correct, delete, anonymize or block personal information, we will ensure that your request is promptly transmitted to the other parties with whom we have shared your personal information in order to enable these third parties to also comply with the request - except in cases where it is proven that this is Communication is impossible or involves disproportionate effort on our part.

The law permits the transfer of personal information outside of Brazil

We are permitted to transfer your personal information outside of Brazilian territory in the following cases:

• When the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution agencies, in accordance with the legal means stipulated in international law;

• When the transportation is necessary to protect your life, physical security, or third-party security;

• When the transfer is authorized by the ANPD;

• When the transfer results from a commitment undertaken in an international cooperation agreement;

• When a transfer is necessary to carry out a public policy or legal attribution of public service; And

• When the transfer is necessary to comply with a legal or regulatory obligation, the execution of a contract or preliminary procedures related to the contract, or the regular exercise of rights in judicial, administrative or arbitral proceedings.

Definitions and legal references

Personal information (or data)

Any information that allows, directly or indirectly, or in relation to other information - including a personal identification number - to identify or identify a natural person.

Usage data

Information automatically collected by this site (or third-party services used on this site), which may include: IP addresses or domain names of computers used by users who use this site, URI addresses (Uniform Resource Identifier), and time The request, the method used to submit the request to the server, the size of the file received in response, the numeric code indicating the server's response status (successful result, error, etc.), country of origin, browser features and the operating system used by the user, and the different time details for each visit (for example For example, the time spent on each page within the site) and details about the path followed within the site with special reference to the sequence of pages visited and other parameters about the device's operating system and / or the user's IT environment.

The user

The person using this website who matches the data subject, unless otherwise stated.

Data subject

The natural person to whom the personal data refers.

Data processor (or data supervisor)

A natural or legal person, public authority, agency, or any other body that processes personal data on behalf of the financial controller, as described in this privacy policy.

Data controller (or owner or site owner)

A natural or legal person, public authority, agency or any other body that determines, alone or jointly with others, the purposes and means of processing personal data, including security measures related to the operation and use of this website. The data controller, unless otherwise stated, is the owner of this website.

This website (or app)

The means by which the user's personal data is collected and processed.

The service

The service provided by this website / application.

European Union (or EU)

Unless otherwise specified, all references in this document to the European Union include all current member states of the European Union and the European Economic Area.

Cookies

Cookies are tracking tools made up of small sets of data stored in the user's browser.

Tracker

A tracker refers to any technology - for example cookies, unique identifiers, web beacons, embedded scripts, electronic tags, and fingerprints - that enables users to be tracked, for example by accessing or storing information on the user's device.

Contact information

Please visit the "Contact Us" page to view all contact details available to us.

Legal information

This privacy statement has been prepared based on the provisions of various legislation, including Article. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

Last update: 23 November 2020