Privacy Policy | Crossbaum

Privacy Policy of cossbaum.com

This Site collects some Personal Data from Users.

This document contains a section dedicated to California consumers and their privacy rights.

This document contains a section dedicated to Brazilian Users and their privacy rights.

This document can be printed for query purposes, via the print command in your browser settings

Owner and Data Controller

Rua da Alemanha, Lote 51, Elvas 7350-478 Elvas – Portugal

Owner’s contact email: crossbaum@crossbaum.com

Data Types Collected

Among the types of Personal Data that this Site collects, by itself or through third parties, there are: Tracker; Usage data; name; surname; e-mail; phone number; All Data you share while using the service; answers to questions; clicks; key events; motion sensor events; mouse movements; scrollposition; touch events; various types of Data.

Full details about each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific callouts displayed prior to data collection.

Personal Data may be freely provided by you, or, in the case of Usage Data, automatically collected when using this Site.

Unless otherwise specified all Data requested by this Site is mandatory and failure to provide such Data may make it impossible for this Site to provide its Services. In cases where this Site specifically states that some Data is not mandatory, Users are free to stop communicating this Data without any consequence to the availability or operation of the Service.

Users who have questions about which Personal Data are required are invited to contact the Owner.

Any use of cookies – or other tracking tools – by this Site or by the owners of third-party services used by this Site will be for the purpose of providing the Services requested by the User, in addition to the other purposes described in this document and the Cookie Policy, if available.

Users are responsible for any Third-Party Personal Data that is obtained, published, or shared through this Service (this Site) and confirm that they have the authorization of the third parties to provide the Data to the Owner.

Data processing mode and location

Processing method

The Owner shall take appropriate security measures to prevent unauthorized access, disclosure, alteration or unauthorized destruction of the Data.

Data processing is carried out using computers and /or it tools enabled, following organizational procedures and means strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessed by certain types of persons in charge, involved with the operation of this Service (this Site) (administration, sales, marketing, legal administration of the system) or external persons (such as third-party providers of technical services, postmen, hosting providers, IT companies, communication agencies) appointed, when necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis for processing

The Owner may process the Personal Data relating to the User if one of the following applies:

users have given their opinion for one or more specific purposes; Note: In accordance with certain laws, owner may be permitted to process Personal Data until you object to this (“opt-out”) without having to rely on consent or any other legal bases below. This, however, does not apply where the processing of Personal Data is subject to European data protection legislation;

the provision of the Data is necessary for the fulfillment of a contract with you and/or any pre-contractual obligations thereof;

processing is necessary for the fulfilment of a legal obligation to which the Owner is subject;

the processing is related to a task that is performed in the public interest or in the exercise of an official authorization in which the Owner is invested;

processing is necessary for the purpose of legitimate interests pursued by the Owner or a third party;

In any case, the Owner will gladly cooperate to clarify which legal basis applies to the processing, and in particular if the provision of Data is a mandatory requirement by law or contractual, or a requirement necessary to enter into a contract.

Place

The data is processed at the Owners’ operating sites, and anywhere else where the parties involved with the processing are located.

Depending on your location, data transfers may involve transferring Your Data to a country other than yourown. To find out more about the place of processing of such transferred Data Users may check the section containing details on the processing of Personal Data.

Users also have the right to be informed about the legal basis of data transfers to countries outside the European Union or to any international organisations governed by public international law or formed by two or more countries, such as the UN, and about the security measures taken by owner to protect their Data.

If any such transfers occur, Users may find out more about it by checking the relevant sections of this document or asking owner using the information provided in the contacts section.

Conservation period

Personal Data will be processed and stored for as long as necessary for the purposes for which it is collected.

So:

Personal Data collected for the purposes related to the performance of a contract between the Owner and the User will be retained until such contract has been fully fulfilled.

Personal Data collected for purposes related to the legitimate interests of the Owner will be retained for as long as necessary to fulfill such purposes. Users may obtain specific information about the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain the Personal Data for a longer period whenever the User has given his/her consent to such processing, until such authorization has been withdrawn. In addition, the Owner may be obliged to retain personal data for a longer period of time at all times when he is obliged to do so for the fulfilment of a legal obligation or in compliance with a mandate of an authority.

Once the retention period expires the Personal Data will be erased. In this way the right to access, the right to erase, the right to correct and the right to portability of the data may not have its fulfillment required after the expiration of the retention period.

The purposes of processing

User Data is collected to enable the Owner to provide his Service, fulfill his legal obligations, respond to enforcement requests, protect his rights and interests (or those of his Users or third parties), sense any malicious or fraudulent activity, as well as: Statistics, Platform and hosting services, Registration and authentication, Contact the User, Access to third-party service accounts, Interaction with live chat platforms, Anti-spam protection, Tag management, Optimization and traffic distribution, Payment processing, View content from external platforms and Social Features.

Para obter informações específicas sobre os Dados Pessoais utilizados para cada finalidade, o Utilizador poderá consultar a seção “Informações detalhadas sobre o processamento de Dados Pessoais”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Access to third-party service accounts

This type of service allows this Site to access your account Data with a third-party service and perform actions with them. These services are not activated automatically, they require explicit authorization from the User.

Stripe (Stripe Technology Europe Ltd) account access

This service allows this Site to connect to your Stripe account provided by Stripe, Inc.

Personal Data processed: e-mail; name; surname.

Lugar de processamento: Irlanda – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.

This processing constitutes a sale, based on the definition of the CCPA. In addition to the information in this clause, you may find information about opt-out in the section describing California consumer rights.

Contact the User

Mailing list or newsletter (this Site)

By registering on the mailing list or newsletter, your email address will be added to the contact list of those who may receive email messages that contain commercial or promotional information about this Site. Your email address may also be added to this list as a result of your registration on this service (this Site) or after making a purchase.

Personal Data processed: e-mail; name; surname.

Category of personal information collected according to the CCPA: identifiers.

Contact Phone (this Site)

Users who have provided the telephone number may be contacted for commercial or promotional purposes related to this Site, as well as for the fulfillment of support requests.

Personal Data processed: telephone number.

Category of personal information collected according to the CCPA: identifiers.

Contact Form (this Site)

By completing the contact form with your Data, Users authorize this Site to use these details to respond to requests for information, quotation or any other type of request as indicated by the form title.

Personal Data processed: e-mail; name; surname.

Category of personal information collected according to the CCPA: identifiers.

Tag management

This type of service helps the Owner manage the tags or scripts required by this Site centrally. As a result, User Data flows through these services and there is the possibility of retaining this Data.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a management service provided by Google Ireland Limited.

Personal Data processed: Usage data; Tracker.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: information on the Internet.

Traffic optimization and distribution

These types of services allow this Site to distribute their content using servers located in different countries and to optimize their performance. What Personal Data will be processed depends on the characteristics and how those services are implemented. Its function is to filter the communications between this Site and the User’s browser.Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents, which may contain personal information of the User, have been transferred.

Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.The way Cloudflare is integrated means that it filters all traffic through this service (this Site), i.e. communication between this Site and your browser, while allowing analytical data from this Application to be collected.

Personal Data processed: Tracker; various types of Data as specified in the service’s privacy policy.

Place of processing: USA – Privacy Policy.

Category of personal information collected according to the CCPA: information on the Internet.

Anti-spam protection

These types of services analyze the traffic of this service (this Site), potentially containing Users’ Personal Data, in order to filter them from the parts of traffic, messages and content that are recognized as SPAM.

Google reCAPTCHA (Google Ireland Limited)

Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.Use of reCAPTCHA is subject to Google’s privacy policy and terms of use.

Personal Data processed: clicks; Usage data; key events; touch events; motion sensor events; mouse movements; scroll position; Tracker; answers to the questions.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: information on the Internet; implicit information.

Platform and hosting services

These services aim to host and run key components for this Site, thus allowing the offer of this application within a unified platform. Such platforms offer a wide range of tools to the Owner – such as analysis, user registration, comments, database management, e-commerce, payment processing – which results in the collection and handling of Personal Data.Some of these services work through geographically distributed servers, which makes it difficult to know where exactly personal data is stored.

WordPress.com (Aut O’Mattic A8C Ireland Ltd.)

WordPress.com is a platform offered by Aut O’Mattic A8C Ireland Ltd. that allows the Owner to build, execute and host this Site.

Personal Data processed: e-mail; name; surname.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.

Social characteristics

Invite and suggest friends (this Site)

This Site may use the Personal Data provided to allow Users to invite their friends – for example, through the address book, if access has been provided – and to suggest friends or connections within it.

Personal Data processed: various types of Data.

Category of personal information collected according to the CCPA: information on the Internet.

Statistics

The services contained in this section enable owner to monitor and analyze web traffic and can be used to track User behavior.

WordPress Stat (Aut O’Mattic A8C Ireland Ltd.)

WordPress is an analysis service provided by Aut O’Mattic A8C Ireland Ltd.

Personal Data processed: Usage data; Tracker.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: information on the Internet.

Google Analytics with anonymous IP (Google Ireland Limited)

Google Analytics is an Internet analytics service provided by Google Ireland Limited (“Google”). Google uses the data collected to track and examine the use of this service (this Site) to prepare reports on activities and share it with other Google services.Google may use the data collected to contextualize and personalize ads from its own advertising network. This Google Analytics integration makes your IP address anonymous. It works by shortening users’ IP addresses within the Member States of the European Union or other Signatory States to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server and shortened within the US.

Personal Data processed: Usage data; Tracker.

Place of processing: Ireland – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: information on the Internet.

Google Analytics (Google Ireland Limited)

Personal Data processed: Usage data; Tracker.

Place of processing: Ireland – Privacy Policy – Opt Out.

Category of personal information collected according to the CCPA: information on the Internet.

Interaction with live chat platforms

These types of services allow Users to interact with third-party live chat platforms, directly from the pages of this service (this Site), to contact and receive contact through the support of this service (this Site). If one of these services is installed, it may collect Usage and Browsing Data on the pages where they are installed, even if Users do not actively use the service. In addition, live chat conversations can be recorded.

Facebook Messenger Customer Chat (Facebook Ireland Ltd)

Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook Ireland Ltd

Personal Data processed: Usage data; Tracker; All data you share while using the service.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: information on the Internet.

Payment processing

Unless otherwise specified, this Site will process any payments via credit card, bank transfer or other means through third-party payment service providers. Generally speaking and unless otherwise specified, Users will be asked to provide their payment data and personal information to these third-party payment service providers. This Site has no involvement in the collection and processing of such information: instead, you will receive only a notification from the respective payment service provider stating whether the payment has been successfully completed.

Paypal (PayPal Inc.)

PayPal is a payment service provided by PayPal Inc., which allows Users to make payments online.

Personal Data processed: e-mail.

Processing Place: Please refer to the privacy policy of PayPal – Privacy Policy.

Category of personal information collected according to the CCPA: identifiers.

Registration and authentication

By registering or authenticating, Users allow this service (this Site) to identify them and give them access to dedicated services. Depending on what is described below, registration and authentication services may be provided by third parties. In this case, this Site may access some Data stored by these third-party services for registration or identification purposes. Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to learn more, see the description of each service.

WordPress.com Single Sign On (Aut O’Mattic A8C Ireland Ltd.)

Single Sign On WordPress.com is a registration and authentication service provided by Aut O’Mattic A8C Ireland Ltd. and is connected to the WordPress.com.

Personal Data processed: Tracker; various types of Data as specified in the service’s privacy policy.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: information on the Internet.

Visualizar content from external platforms

These types of services allow you to view and interact with content hosted on external platforms directly from the pages of this service (this Site) and interact with them. This type of service may also collect web traffic data for pages where the service is installed, even when Users are not using it.

Google Fonts (Google Ireland Limited)

Google Fonts is a type face viewing service provided by Google Ireland Limited that allows this Site to incorporate such content into its pages.

Personal Data processed: Usage data; various types of Data as specified in the service’s privacy policy.

Place of processing: Ireland – Privacy Policy.

Category of personal information collected according to the CCPA: information on the Internet.

YouTube IFrame Player (Google Ireland Limited)

YouTube IFrame Player is a video content viewing service provided by Google Ireland Limited that allows this Site to embed such content on its pages.

Through this Service, this Site may collect Data directly or indirectly from Users’ devices, including using Trackers to do so. Users may restrict such access to their Data through the security settings page provided by Google. Users may ask owner for more information about these privacy settings at any time through the contact details provided in this document.

Data collected through the service may also be used to help third parties generate advertising based on interest. Users may choose not to accept interest-based third-party advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.

Personal Data processed: Usage data.

Place of processing: Ireland – Privacy Policy – Opt out.

Category of personal information collected according to the CCPA: information on the Internet.

Additional information about Personal Data

Sale of products and services online

The personal data collected is used to provide you with services or to sell products, including payment and possible delivery. Personal Data collected to complete the payment may be related to the credit card, the bank account used for the transfer, or any other means of payment provided for. The type of Data collected depends on the payment system used.

Users’ rights

Users may exercise certain rights with respect to their Data processed by the Owner.

In particular, Users have the rights to do the following:

Withdraw your opinion at any time. Users have the right to withdraw their opinion in cases where they have previously given their opinion for the processing of their Personal Data.
Object to the processing of your 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 the application. Additional details are provided in the specific section below.
Access your Data. Users have the right to know if their Data is being processed by the Owner, to obtain revelations about certain aspects of processing and get a copy of the Data being processed.
Check and request rectification. Users have the right to verify the accuracy of their Data and to request that they be updated or corrected.
Restrict the processing of your Data. Users have the right, under certain circumstances, to restrict the processing of their Data for any purpose other than storage thereof.
Have your Personal Data deleted or otherwise withdrawn. Users have the right, under certain circumstances, to obtain the deletion of their Owner Data.
Receive your Data and have it transferred to another controller. Users have the right to receive their Data in a structured format, commonly used and able to be read by machines and, if technically feasible, to have it transmitted to another controller without any hindrance. This determination applies to the processing of the Data being processed by automated means and that the processing is based on the User’s consent, on a contract of which the User is one of the parties or by pre-contractual obligations thereof.
File a complaint. Users have the right to lodge a complaint with their competent data protection authority.

Details on the right to object to processing

In cases where Personal Data is processed in the public interest, in the exercise of an official authorization in which the Owner is invested or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a reason related to their particular situation to justify the objection.

Users should know, however, that if their Personal Data is processed for direct marketing purposes they may object to such processing at any time without providing any justification. Users can refer to the respective sections of this document.

How to exercise these rights

Any requests to exercise the rights of users may be directed to the Owner through the contact details provided in this document. These requests may be exercised at no cost and will be met by the Owner as soon as possible and in all cases within less than one month.

Additional information on data collection and processing

Legal action

Users’ Personal Data may be used for legal purposes by the Owner in court or in the steps leading to possible legal action arising from misuse of this Service (this Site) or related Services. The User declares to be aware that the Owner may be obliged to disclose the Personal Data upon request of the government authorities.

Additional information about Your Personal Data

In addition to the information contained in this privacy policy, this Site may provide you with additional and contextual information about the specific services or the collection and processing of Personal Data upon request.

System logs and maintenance

For the purpose of operation and maintenance, this Site and any third-party services may collect files that record interaction with this Site (system logs) or use other Personal Data (such as IP address) for this purpose.

Information not contained in this policy

More details about the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Don’t Track Me” requests are handled

This Site does not support “Do Not Track Me” requests. To determine whether any of the third-party services you use honor “Do Not Track Me” requests, please read the privacy policies.

Changes to this privacy policy

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 Service (this Site) and/or – to the extent technically and legally feasible – by sending a notice to Users through any contact information available to the Owner. We strongly recommend checking this page regularly by referring to the date of the last modification reported at the bottom. If the changes affect the processing activities carried out based on the User’s consent, the Owner will collect new consent from the User, where required.

Information for California consumers

This portion of the document integrates and complements the information contained in the rest of this privacy policy and is provided by the company that operates this Site and, as applicable, its parent companies, subsidiaries and affiliates (for the purposes of this section, hereinafter referred to together through the pronouns “we”, “us”, “our” and “with us”).

The provisions contained in this section shall apply to all Users who are consumers residing in the State of California, United States of America, in accordance with the “California Consumer Privacy Act 2018” (CCPA) (Users will hereinafter be referred to through the pronouns “you” and “yours”) and, for such consumers, these provisions supersede all other possibly divergent or conflicting provisions contained in this privacy policy.

This portion 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 will summarize the categories of personal information we collect, disclose or sell and their purposes. You can read about these activities in more detail in the section titled “Detailed Information on the Processing of Personal Data” in this document.

Information we collect: The categories of personal information we collect

We collect the following categories of personal information about you: identifiers, information on the Internet and implied 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-mentioned categories of personal information, whether directly or indirectly, from the time you use this Site.

For example, you provide your personal information directly when you submit requests through any forms on this service (this Site). You also provide personal information indirectly when browsing this service (this Site), as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties working with us with the Service or the operation of this Service (this Site) and its resources.

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

We may disclose the information we collect about you to third parties for business purposes. In this case, we enter into a written agreement with such third parties, requiring the receiving party to keep the personal information confidential and not to use it for any purpose other than those necessary for the performance of the contract.

We may also disclose your personal information to third parties when you expressly ask us or authorize us to do so in order to provide the Service to you.

To learn more about the purposes of processing, see the respective section of this document.

Selling your personal information

For our purposes, the word “sale” shall mean any “sale, rental, lease, disclosure, dissemination, availability, transfer or other form of oral communication, in writing or electronic means, of a consumer’s personal information by the company to another company or to third parties, monetarily or costly.”

This means that, for example, a sale can occur whenever an app runs ads or performs statistical analysis of its traffic or views, or simply because it uses tools such as social and similar plugins.

Your right to opt-out of personal information

You have the right to opt-out of selling personal information. This means that whenever you ask us to stop selling your data, we will fulfill your request. Such requests may be made freely at any time without submitting any verifiable request, simply by following the instructions below.

Instructions for opting out of selling personal information

If you would like to learn more, or exercise your right of choice with respect to all sales made by this Site, both online and offline, you may contact us for more information, using the contact details provided in this document.

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

We may use your personal information to enable the operational operation of this service (this Site) and its features (“business purposes”). In such cases, your personal information will be processed in a manner necessary and proportionate to the business purposes for which it was collected and strictly within the limits of the compatible operational purposes.

We may also use your personal information for other purposes, such as commercial purposes (as indicated in the “Detailed Information on the Processing of Personal Data” section in this document), and also to comply with the law and defend our rights before the competent authorities when our rights and interests are threatened or suffer actual harm.

We will not use your personal information for different, unrelated or incompatible purposes without notifying you.

Your privacy rights in California and how to exercise them

The right to knowledge and portability

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

the categories and sources of personal information we collect about you, the purposes for which we use your personal information and with whom such information is shared;
in the case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
for sales, the categories of personal information acquired by each category of receiving party; and
for disclosures for a business purpose, the categories of personal information obtained by each category of receiving party.

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

If we provide our response electronically, the included information will be “portable”, that is, provided in an easily used format, in order to allow you to transmit the information to another entity without obstacles – as long as it is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete your personal information and be subject to exceptions by law (including but not including, but not if not, when the information is used to identify and repair errors on this service (this Site), to identify security incidents and protect against fraudulent or illegal activities, for the exercise of certain rights, etc.).

If there is no legal exception as a result of exercising your right, we will delete your personal information and instruct all of our service providers to do so.

How to exercise your rights

To exercise the rights described above, you need to send us your verifiable request by contacting us through the data provided in this document.

For us to respond to your request, we must know who you are. Therefore, you will only be able to exercise the above rights by making a verifiable request, which shall:

provide sufficient information that allows us, within reasonable limits, to verify that you are the person about whom we collect information or an authorized representative;
describe your request in sufficient detail, which allows us to understand, evaluate and respond to it appropriately.

We will not respond to any request if we are unable to verify your identity and thus confirm that the personal information in our possession actually relates to you.

If you are unable to personally submit a 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 make a verifiable request on behalf of a minor under your custody.

You can submit a maximum of 2 requests in a 12-month period.

How and when we expect to fulfill your request

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

We will respond to your request within 45 days of receipt. If we need more time, we’ll explain to you the reasons and how much longer we’ll need it. For this purpose, please note that it may take up to 90 days to fulfill your request.

Our disclosures will cover the preceding 12-month period.

If we deny your request, we will explain the reasons for our denial.

We will not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee or refuse to comply with the request. In any case, we will communicate our choices and explain the reasons.

Information for Users residing in Brazil

This portion of the document integrates and complements the information contained in the rest of this privacy policy and is provided by the entity operating this Site and, as applicable, its parent companies, subsidiaries and affiliates (for purposes of this section, hereinafter referred to together through the pronouns “we”, “us”, “our” and “with us”). The provisions contained in this section shall apply to all Users who are resident in Brazil in accordance with the “General Data Protection Law” (Users will herein be named through the pronouns “you” and “your”). For such Users, these provisions supersede all other possibly divergent or conflicting provisions contained in this privacy policy. This part of the document uses the term “personal information” as defined in the General Data Protection Act (LGPD).

On which we base ourselves to process your personal information

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

your opinion with their processing activities;
compliance with a legal or regulatory obligation imposed on us;
compliance with public policies provided for in laws or regulations or based on contracts, agreements and similar legal instruments;
studies conducted by research entities, preferably conducted on anonymous personal information;
the performance of a contract and its preliminary procedures, in cases where you are part of the contract;
the exercise of our rights in judicial, administrative or arbitration proceedings;
protection or physical safety of you or a third party;
health protection – in procedures performed by health entities or professionals;
our legitimate interests, provided that their fundamental rights and freedoms do not prevail over such interests; and
credit protection.

To learn more about the legal bases, you can contact us at any time through the contact details provided in this document.

Categories of personal information processed

To find out which categories of your personal information are processed, you can read the section titled “Detailed Information on the Processing of Personal Data” in this document.

Why we process your personal information

To find out why we process your personal information, you can read about the sections titled “Detailed Information on the Processing of Personal Data” and “The Purposes of Processing” in this document.

Your privacy rights as a Brazilian, how to send a request and our responses to your requests

Your privacy rights as a Brazilian

You have the right to:

obtain confirmation of the existence of processing activities for your personal information;
access to your personal information;
make your personal information incomplete, inaccurate or outdated corrected;
obtain anonymity, blocking or deletion of your unnecessary or excess personal information, or information that is not being processed in accordance with the LGPD;
obtain information on the possibility of providing or refusing your opinion and its consequences;
obtain information about the third parties with whom we share your personal information;
obtain, upon your express request, the portability of your personal information (except anonymous information) to another supplier of products or services, provided that our trade and industrial secrets remain protected;
obtain the deletion of your personal information processed, if the processing was based on your opinion, unless one or more exceptions apply to those provided for in Art. 16 of the LGPD;
withdraw your opinion at any time;
register a complaint regarding your personal information to the National Data Protection Authority (ANPD) or consumer protection agencies;
to owe a processing activity in cases where processing is not carried out in accordance with the provisions of the law;
request clear and appropriate information on the criteria and procedures used for an automated decision; and
request a review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. This includes decisions to define your personal, professional, consumer and credit profile or aspects of your personality.

You will never be discriminated against or suffer any kind of injury if you exercise your rights.

How to register your request

You may register your express request to exercise your rights free of charge at any time by using the contact details provided herein or through your legal representative.

How and when we will respond to your request

We will do our best to respond immediately to your requests. In any case, if it is impossible, we will make a point of communicating to you the reasons of fact or law that prevent us from immediately fulfilling, or otherwise, fulfilling your requests. In cases where we are not processing your personal information, we will indicate the natural or legal person to whom you should forward your requests if we are in a position to do so.

If you register an access or confirmation request for processing personal information, be sure to specify whether you want your personal information to be delivered in electronic or printed format. You will also need to inform us if you want us to respond to your request immediately, in which case we will respond in a simplified manner or if you need a complete response. In the latter case, we will respond within 15 days of the time of your request, providing all information about the origin of your personal information, confirmation of whether or not records exist, any criteria used for processing and processing purposes, keeping our trade and industrial secrets protected.

If you request rectification, deletion, anonymity or blocking of personal information, we will immediately communicate your request to other parties with whom we share your personal information in order to allow these third parties to also comply with your request – except in cases where such communication proves impossible or involves a disproportionate effort on our side.

Transfer of personal information outside Brazil permitted by law

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

where the transfer is necessary for the purpose of international legal cooperation between public intelligence, investigative and public prosecutors, in accordance with the legal means laid down in international law;
when the transfer is necessary to protect your life or physical or third-party safety;
when the transfer is authorized by the ANPD;
when the transfer arises from a commitment made in an international cooperation agreement;
where the transfer is necessary for the execution of a public policy or legal assignment of public service;
where the transfer is necessary for the fulfilment of a legal or regulatory obligation, the performance of a contract or preliminary procedures relating to a contract or the regular exercise of rights in judicial, administrative or arbitration proceedings.

Legal definitions and references

Personal Data (or Data)

Any information that directly, indirectly or in connection with other information – including a personal identification number – allows the identification or identification of an individual.

Usage Data

Information automatically collected through this Site (or third party services contracted on this Service (this Site)), which may include: the IP addresses or domain names of the computers used by Users using this Site, uri (Uniform Resource Identifier) addresses, the date and time of the request, the method used to submit the request to the server, the size of the file received in response, the numeric code that indicates the status of the response server (positive result, error, etc.), the country of origin, the characteristics of the browser and the operating system used by the User, the various details of time per visit (for example, the time spent on each page within the application) and the details about the path followed within the application, with special reference to the sequence of pages visited and other parameters about the operating system of the user’s device and/or IT environment.

User

The person using this Site who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

A natural or legal person, public administration, agency or other body that processes Personal Data on behalf of the Controller as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public administration, agency or other body that, alone or in conjunction with others determines the purposes and means of processing personal data, including security measures relating to the operation and use of this Service (this Site). The Data Controller, unless otherwise specified, is the Owner of this Service (this Site).

This Site (or this Application)

The means by which Your Personal Data is collected and processed.

Service

The service provided by this Site as described in the relative terms (if available) and on this site/application.

European Union (or EU)

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

Cookie

Cookies are trackers composed of small sets of data stored in the User’s browser.

Tracker

The term Tracker indicates any technology – such as Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that allows the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information

This privacy statement was prepared based on determinations of multiple laws, including the Arts. 13/14 Regulation (EU) 2016/679 (GDPR – General Data Protection Regulation).

This privacy policy refers only to this Site, if not stated differently in this document.