Privacy Policy
1. Purpose
At Alegry Tecnologia Ltda., we value you and your personal data, and, more than that, we recognize the importance of your privacy. Accordingly, we have taken certain measures in line with the Brazilian General Data Protection Law (LGPD), and in this document we explain how we handle and protect your data.
This Privacy Policy (“Policy”) has been prepared to explain our practices regarding the processing of your Personal Data and applies to individuals who interact with Alegry's services (“You”). Here we explain how your Personal Data is collected, used, and shared by Alegry (“We” or “Us”), as well as how you can access, update, or delete your Personal Data.
Our data collection activities are carried out online, covering the Personal Data that We collect through our various channels, including websites, apps, third-party social media, our Customer Service, and any events we may hold. If You do not provide us with the necessary Personal Data (We will indicate when this is the case, for example, by clarifying this in our registration forms), We may not be able to provide You with our products and/or services.
This Policy may be amended from time to time, as indicated at the end of the document.
2. Who We Are
We are established at Av. Brig. Faria Lima, 1811 - cj1119 - Jardim Paulistano, São Paulo/SP, Brazil, ZIP Code: 01452-001, and we are a company registered under Brazilian company registration (CNPJ) No. 36.098.662/0001-93, acting as the data controller when processing your personal data.
3. Why Does Alegry Process My Personal Data?
Alegry always aims to offer You the best possible service. When You engage our services, we collect certain personal data to complete your registration and to finalize the engagement, such as credit card data. We also collect certain personal data to better understand your profile and offer you personalized advertisements that are more closely aligned with your preferences.
These are some examples of how we use your data to make your experience with our services possible, through the personal data used, within reasonable expectations and in a legitimate manner.
We are committed to complying with all legal provisions that protect your privacy and, if after reading this Policy you still have questions, feel free to contact us through our service channels.
4. Basic Concepts: What Do I Need to Know to Understand This Policy?
To help you understand what we will cover here, these are some important and useful definitions:
a. “Legal Bases” are the legal grounds that authorize Alegry to Process Personal Data. Any and all Processing of Personal Data is considered valid only if based on a legal basis.
b. “Personal Data” is any data relating to an identified or identifiable individual, including identification numbers, location data, electronic identifiers, or any data that, when combined with other information, is capable of identifying someone, rendering them identifiable, or otherwise singling them out. For example, name, national tax ID (CPF), phone number, among others.
c. “Data Protection Officer”, also known as DPO, is the professional responsible for acting as a communication channel between Alegry, Data Subjects, and the Brazilian National Data Protection Authority (ANPD). One of their objectives is to ensure that Alegry complies with the applicable laws and rules relating to privacy and the protection of Personal Data.
d. “Digital Platforms” or “Platforms” are the websites and apps owned by Alegry.
e. “Processing” refers to the uses Alegry makes of Personal Data, including, for example, the following activities: collection, recording, storage, organization, consultation, use, disclosure, sharing, transmission, classification, reproduction, processing, and evaluation.
f. “You” or “Data Subject” is the person to whom the Personal Data relates.
g. International data transfer: the transfer of personal data to a foreign country or to an international organization of which the country is a member.
h. Shared use of data: communication, dissemination, international transfer, interconnection of personal data, or shared processing of personal databases by public bodies and entities in the performance of their legal duties, or between such bodies and private entities, reciprocally, with specific authorization, for one or more forms of processing permitted by such public entities, or between private entities.
i. Consent: a free, informed, and unambiguous manifestation by which the data subject agrees to the processing of their personal data for a specified purpose.
j. National authority (ANPD): the public administration body responsible for overseeing, implementing, and enforcing compliance with this Law throughout the national territory.
5. What Types of Personal Data Does Alegry Collect? How Does Alegry Collect This Data?
The type of Personal Data and the manner in which Alegry collects it depend on how You interact with Alegry. For example, the Personal Data collected will differ depending on whether You are a lead or an existing customer. For this reason, we describe below some of the situations that occur most frequently in the relationship between Alegry and Data Subjects, with a brief explanation of each:
Source
Type of Data Collected
Purpose
Browsing on the Digital Platforms
Browsing data: data collected through cookies or device IDs, including IP address, date and time of access, geographic location, browser type, length of visit, and pages visited.
Website operation: to enable essential features, such as antivirus software, responsiveness of the website/app to desktop/mobile, among other functions.
Analytics: to understand your browsing behavior and how the website/app is being used, in order to improve your experience as a user. The data collected is aggregated and, whenever possible, anonymized.
Marketing: to direct content and advertising, ours and that of our partners, based on your preferences and profile.
Registration Forms
Registration data: e-mail, name, phone number, address, and other information (depending on the service contracted).
Payment Data: credit and debit card information.
Provision of Services: enabling login for the creation of the user's own platform, content processing, among others.
Marketing: to direct content and advertising, ours and that of our partners, based on your preferences and profile.
Provision of Services: purchase processing, installment arrangements, among others.
Customer Service
Registration data: e-mail, name, phone number, and other information (depending on the service contracted).
Handling requests: receiving payments, processing refunds, routing customer requests, among others.
6. How Does Alegry Use the Personal Data Collected?
We process your Personal Data primarily to make our business relationship possible, to comply with certain contractual and legal obligations, and to engage with our brand.
Customer service: We use your Personal Data to provide customer service, including responding to your questions, complaints, and requests. This generally requires the use of your contact and registration Personal Data, as well as information about the service contracted and the reason for your inquiry (for example, the status of a request, a technical issue, a question or complaint about any aspect of the service provided, general inquiries, and the like).
Servicing the contracted service. Alegry uses your Personal Data to process and bill for contracted services, to inform you about the payment status of the service, to correct addresses, to conduct identity verification, and for other fraud-prevention activities.
Targeted communications. Your Personal Data is used to provide information about products or services (for example, marketing communications, campaigns, or promotions). This may be done through channels such as e-mail, advertisements, WhatsApp messages, SMS, phone calls, and postal mail, to the extent permitted by applicable law. Some of our campaigns and promotions are run on third-party websites and/or social media. In addition, your Personal Data may be captured when You interact with third-party social media features, such as “liking” a post, in order to serve you advertisements and create engagement. Since this is not a mandatory use of your Personal Data, You may request the deletion of this Personal Data from our database at any time, and we will accordingly stop processing your data for these purposes.
Personalization of your preferences: Alegry may use your data to: (i) analyze your preferences and habits; (ii) anticipate your needs, based on Our analysis of your profile; (iii) improve and personalize your experience on our website; (iv) ensure that our website's content is optimized for You and for your computer or device; (v) send You targeted advertising and content; and (vi) ensure that You can access our website more quickly the next time You visit it, or easily regain access to your profile.
Legal reasons or merger/acquisition. Should Alegry or its assets be acquired by, or merged with, another company, including due to bankruptcy, we will share your Personal Data with our legal successors. We will also disclose your Personal Data to Third Parties when: (i) required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from a competent legal authority; (iv) to protect our rights, privacy, security, or property; or (v) to enforce the terms of any agreement or the terms of our website. In addition, your Personal Data may be used to comply with obligations set forth in law, regulations issued by government bodies, tax authorities, or the Judiciary, such as judgments and settlements, and/or any other competent authority. This processing may include your identification data and personal documents.
General purposes. Alegry uses your Personal Data for other general business purposes, such as maintaining your account, conducting internal or market research, and measuring the effectiveness of Our advertising campaigns. We also use your Personal Data to manage and operate our communications, IT, and security systems.
You are not required to provide your personal data to us. However, since such data is necessary to fulfill the purposes mentioned above, we will not be able to carry out these operations without it. The same applies to the exercise of your rights under the LGPD. In other words, if You do not provide the personal data necessary to confirm your identity, we will not be able to respond to your request.
7. Who Does Alegry Share Your Data With
During our relationship, Alegry will share your Personal Data with certain entities:
a. Service Providers. We engage a number of service providers to operate our services. Some of them may Process Personal Data that we collect, such as, for example, companies that provide data hosting services, registration authentication and validation, advertising companies, payment methods, among others. Whenever possible, we always seek to carefully evaluate our vendors and enter into contractual information security and Personal Data protection obligations with them, with the goal of minimizing risks to Data Subjects.
b. Third parties that use your Personal Data for legal reasons or due to a merger/acquisition: we will share your Personal Data with Third Parties for legal reasons or in the context of a merger or acquisition.
8. Data Storage
We will use your Personal Data for as long as necessary to achieve the purposes for which it was collected, or to comply with applicable legal obligations, safeguard our rights, or comply with judicial/extrajudicial settlements.
To determine the retention period for your Personal Data, we rely on the following criteria:
a. To comply with a legal, contractual, or other obligation to retain Personal Data, or where necessary for investigation or litigation purposes. In this case, your data will be kept in our database for a period of 5 (five) years, counted from the termination of the obligation; and
b. To maintain accurate business and financial records. In this case, your data will be kept in our database for up to 5 years after the termination of the contractual obligation.
9. How We Will Keep Your Data Secure
We take a number of measures to keep your Personal Data confidential and secure; however, these protections do not apply to information that You have chosen to share in public areas, such as third-party social media.
People who may access your Personal Data. Your Personal Data will be processed by our staff, service providers, or authorized agents, provided that they need to have access to such information, depending on the specific purposes for which your Personal Data was collected, such as, for example: a provider or staff member responsible for user support, or responsible for billing regularization.
Measures taken in operational environments. We store your Personal Data in operational environments that use reasonable security measures to prevent unauthorized access. We follow reasonable protocols to protect Personal Data. The transmission of information over the internet is unfortunately not completely secure and, although we do Our best to protect your Personal Data, we cannot guarantee the security of data during transmission through our website.
Measures We expect You to take. Your role is essential to keeping your Personal Data secure. When creating an online account, please make sure to choose a password that is difficult for other people to guess. You are responsible for keeping this password confidential for any use of your account. If You use a shared or public computer, never select the option to remember your login ID, e-mail address, or password, and be sure to log out of your account whenever You leave the computer. You should also use any privacy settings or controls that We provide on our website or app.
10. Your Choices About How We Use Your Data
We do our best to give You choices regarding the Personal Data You provide to us. The following mechanisms give You the following control over your Personal Data:
a. Necessary (Always Active) – Necessary cookies are required to enable the basic features of this website, such as providing secure login or adjusting your consent preferences. These cookies do not store any personally identifiable data.
b. Functional – Functional cookies help perform certain functions, such as sharing website content on social media platforms, collecting feedback, and other third-party features.
c. Analytics – Analytics cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics such as number of visitors, bounce rate, traffic source, etc.
d. Advertising – Advertising cookies are used to provide visitors with personalized advertisements based on the pages you have previously visited, and to analyze the effectiveness of advertising campaigns.
11. Your Rights as a Data Subject
You, as a Data Subject and our customer, have the following rights with respect to your personal information:
a. to access, review, know whether we have carried out any processing of your Personal Data, and request an electronic copy of the information we hold about You;
b. to correct, or request the correction of, incomplete, inaccurate, or outdated Personal Data;
c. to request the anonymization, blocking, or deletion of unnecessary or excessive Personal Data;
d. to request the portability of Personal Data to another provider of similar products or services;
e. to request the deletion of Personal Data collected and used based on your consent;
f. to obtain information about the public or private entities with which we share your Personal Data;
g. when the processing activity requires your consent, You may refuse to consent. In such case, we will inform you of the consequences of not carrying out such activity;
h. when the processing activity requires your consent, You may revoke it at any time;
i. to request the review of decisions based solely on automated processing that affect your interests;
j. to object to processing carried out on the basis of any of the grounds for waiving consent set forth in the LGPD.
We highlight that our website has a dedicated feature through which You can review and edit the Personal Data You have provided. In addition, we ask our registered customers to verify their identity (such as login, e-mail address, password) before accessing or changing their accounts, in order to prevent unauthorized access to their account.
It is important to note that:
We will not be able to delete your Personal Data without also deleting your user account.
It may be necessary to retain some of your Personal Data after You request its deletion, in order to satisfy our legal or contractual obligations, or to meet business needs.
In order to respond to your requests as a Data Subject, we may request a copy of your identification document. This is necessary to confirm and validate your identity, given the existence of potentially bad-faith individuals, or in situations involving persons with the same name. Accordingly, the greater the sensitivity of the data and/or the purpose of its use, the greater the care that must be taken with the authentication and verification of the data subject/requester.
Requests involving Personal Data and/or documents of other Data Subjects will not be fulfilled, except upon a power of attorney, parental authority, or other circumstance authorizing You to exercise another Data Subject's right.
In situations where You no longer have access to the e-mail address registered on our platforms, we may also request a copy of your identification document to recover your login and password.
In specific circumstances, it is possible that your request will not be fulfilled, but You will always receive a response. In such cases, We will explain the reasons that justified not fulfilling the request.
To exercise your rights, please use the channels provided at the end of this Policy.
12. Changes to Our Policy
This document may be revised at any time, in order to keep it up to date with respect to applicable legislation and the organization of the company itself. We therefore recommend that You review this document periodically and check the date of its last update.
13. Contact
To ask questions, make comments, or file complaints about this Privacy Policy, as well as to request the correction or deletion of any data, please contact us by e-mail ([email protected]), attaching proof of your identity (such as a national ID card, driver's license, or similar document).
If the request is submitted by a person other than You, without providing proof that the request is legitimately made on your behalf, the request will be rejected. Please note that any identifying information provided to Us will only be processed in accordance with applicable law.
We will receive and investigate any complaint regarding the way We manage Personal Data (including complaints regarding the disregard of your rights established under applicable privacy laws and regulations).
At Alegry Tecnologia Ltda., we value you and your personal data, and, more than that, we recognize the importance of your privacy. Accordingly, we have taken certain measures in line with the Brazilian General Data Protection Law (LGPD), and in this document we explain how we handle and protect your data.
This Privacy Policy (“Policy”) has been prepared to explain our practices regarding the processing of your Personal Data and applies to individuals who interact with Alegry's services (“You”). Here we explain how your Personal Data is collected, used, and shared by Alegry (“We” or “Us”), as well as how you can access, update, or delete your Personal Data.
Our data collection activities are carried out online, covering the Personal Data that We collect through our various channels, including websites, apps, third-party social media, our Customer Service, and any events we may hold. If You do not provide us with the necessary Personal Data (We will indicate when this is the case, for example, by clarifying this in our registration forms), We may not be able to provide You with our products and/or services.
This Policy may be amended from time to time, as indicated at the end of the document.
2. Who We Are
We are established at Av. Brig. Faria Lima, 1811 - cj1119 - Jardim Paulistano, São Paulo/SP, Brazil, ZIP Code: 01452-001, and we are a company registered under Brazilian company registration (CNPJ) No. 36.098.662/0001-93, acting as the data controller when processing your personal data.
3. Why Does Alegry Process My Personal Data?
Alegry always aims to offer You the best possible service. When You engage our services, we collect certain personal data to complete your registration and to finalize the engagement, such as credit card data. We also collect certain personal data to better understand your profile and offer you personalized advertisements that are more closely aligned with your preferences.
These are some examples of how we use your data to make your experience with our services possible, through the personal data used, within reasonable expectations and in a legitimate manner.
We are committed to complying with all legal provisions that protect your privacy and, if after reading this Policy you still have questions, feel free to contact us through our service channels.
4. Basic Concepts: What Do I Need to Know to Understand This Policy?
To help you understand what we will cover here, these are some important and useful definitions:
a. “Legal Bases” are the legal grounds that authorize Alegry to Process Personal Data. Any and all Processing of Personal Data is considered valid only if based on a legal basis.
b. “Personal Data” is any data relating to an identified or identifiable individual, including identification numbers, location data, electronic identifiers, or any data that, when combined with other information, is capable of identifying someone, rendering them identifiable, or otherwise singling them out. For example, name, national tax ID (CPF), phone number, among others.
c. “Data Protection Officer”, also known as DPO, is the professional responsible for acting as a communication channel between Alegry, Data Subjects, and the Brazilian National Data Protection Authority (ANPD). One of their objectives is to ensure that Alegry complies with the applicable laws and rules relating to privacy and the protection of Personal Data.
d. “Digital Platforms” or “Platforms” are the websites and apps owned by Alegry.
e. “Processing” refers to the uses Alegry makes of Personal Data, including, for example, the following activities: collection, recording, storage, organization, consultation, use, disclosure, sharing, transmission, classification, reproduction, processing, and evaluation.
f. “You” or “Data Subject” is the person to whom the Personal Data relates.
g. International data transfer: the transfer of personal data to a foreign country or to an international organization of which the country is a member.
h. Shared use of data: communication, dissemination, international transfer, interconnection of personal data, or shared processing of personal databases by public bodies and entities in the performance of their legal duties, or between such bodies and private entities, reciprocally, with specific authorization, for one or more forms of processing permitted by such public entities, or between private entities.
i. Consent: a free, informed, and unambiguous manifestation by which the data subject agrees to the processing of their personal data for a specified purpose.
j. National authority (ANPD): the public administration body responsible for overseeing, implementing, and enforcing compliance with this Law throughout the national territory.
5. What Types of Personal Data Does Alegry Collect? How Does Alegry Collect This Data?
The type of Personal Data and the manner in which Alegry collects it depend on how You interact with Alegry. For example, the Personal Data collected will differ depending on whether You are a lead or an existing customer. For this reason, we describe below some of the situations that occur most frequently in the relationship between Alegry and Data Subjects, with a brief explanation of each:
Source
Type of Data Collected
Purpose
Browsing on the Digital Platforms
Browsing data: data collected through cookies or device IDs, including IP address, date and time of access, geographic location, browser type, length of visit, and pages visited.
Website operation: to enable essential features, such as antivirus software, responsiveness of the website/app to desktop/mobile, among other functions.
Analytics: to understand your browsing behavior and how the website/app is being used, in order to improve your experience as a user. The data collected is aggregated and, whenever possible, anonymized.
Marketing: to direct content and advertising, ours and that of our partners, based on your preferences and profile.
Registration Forms
Registration data: e-mail, name, phone number, address, and other information (depending on the service contracted).
Payment Data: credit and debit card information.
Provision of Services: enabling login for the creation of the user's own platform, content processing, among others.
Marketing: to direct content and advertising, ours and that of our partners, based on your preferences and profile.
Provision of Services: purchase processing, installment arrangements, among others.
Customer Service
Registration data: e-mail, name, phone number, and other information (depending on the service contracted).
Handling requests: receiving payments, processing refunds, routing customer requests, among others.
6. How Does Alegry Use the Personal Data Collected?
We process your Personal Data primarily to make our business relationship possible, to comply with certain contractual and legal obligations, and to engage with our brand.
Customer service: We use your Personal Data to provide customer service, including responding to your questions, complaints, and requests. This generally requires the use of your contact and registration Personal Data, as well as information about the service contracted and the reason for your inquiry (for example, the status of a request, a technical issue, a question or complaint about any aspect of the service provided, general inquiries, and the like).
Servicing the contracted service. Alegry uses your Personal Data to process and bill for contracted services, to inform you about the payment status of the service, to correct addresses, to conduct identity verification, and for other fraud-prevention activities.
Targeted communications. Your Personal Data is used to provide information about products or services (for example, marketing communications, campaigns, or promotions). This may be done through channels such as e-mail, advertisements, WhatsApp messages, SMS, phone calls, and postal mail, to the extent permitted by applicable law. Some of our campaigns and promotions are run on third-party websites and/or social media. In addition, your Personal Data may be captured when You interact with third-party social media features, such as “liking” a post, in order to serve you advertisements and create engagement. Since this is not a mandatory use of your Personal Data, You may request the deletion of this Personal Data from our database at any time, and we will accordingly stop processing your data for these purposes.
Personalization of your preferences: Alegry may use your data to: (i) analyze your preferences and habits; (ii) anticipate your needs, based on Our analysis of your profile; (iii) improve and personalize your experience on our website; (iv) ensure that our website's content is optimized for You and for your computer or device; (v) send You targeted advertising and content; and (vi) ensure that You can access our website more quickly the next time You visit it, or easily regain access to your profile.
Legal reasons or merger/acquisition. Should Alegry or its assets be acquired by, or merged with, another company, including due to bankruptcy, we will share your Personal Data with our legal successors. We will also disclose your Personal Data to Third Parties when: (i) required by applicable law; (ii) in response to legal proceedings; (iii) in response to a request from a competent legal authority; (iv) to protect our rights, privacy, security, or property; or (v) to enforce the terms of any agreement or the terms of our website. In addition, your Personal Data may be used to comply with obligations set forth in law, regulations issued by government bodies, tax authorities, or the Judiciary, such as judgments and settlements, and/or any other competent authority. This processing may include your identification data and personal documents.
General purposes. Alegry uses your Personal Data for other general business purposes, such as maintaining your account, conducting internal or market research, and measuring the effectiveness of Our advertising campaigns. We also use your Personal Data to manage and operate our communications, IT, and security systems.
You are not required to provide your personal data to us. However, since such data is necessary to fulfill the purposes mentioned above, we will not be able to carry out these operations without it. The same applies to the exercise of your rights under the LGPD. In other words, if You do not provide the personal data necessary to confirm your identity, we will not be able to respond to your request.
7. Who Does Alegry Share Your Data With
During our relationship, Alegry will share your Personal Data with certain entities:
a. Service Providers. We engage a number of service providers to operate our services. Some of them may Process Personal Data that we collect, such as, for example, companies that provide data hosting services, registration authentication and validation, advertising companies, payment methods, among others. Whenever possible, we always seek to carefully evaluate our vendors and enter into contractual information security and Personal Data protection obligations with them, with the goal of minimizing risks to Data Subjects.
b. Third parties that use your Personal Data for legal reasons or due to a merger/acquisition: we will share your Personal Data with Third Parties for legal reasons or in the context of a merger or acquisition.
8. Data Storage
We will use your Personal Data for as long as necessary to achieve the purposes for which it was collected, or to comply with applicable legal obligations, safeguard our rights, or comply with judicial/extrajudicial settlements.
To determine the retention period for your Personal Data, we rely on the following criteria:
a. To comply with a legal, contractual, or other obligation to retain Personal Data, or where necessary for investigation or litigation purposes. In this case, your data will be kept in our database for a period of 5 (five) years, counted from the termination of the obligation; and
b. To maintain accurate business and financial records. In this case, your data will be kept in our database for up to 5 years after the termination of the contractual obligation.
9. How We Will Keep Your Data Secure
We take a number of measures to keep your Personal Data confidential and secure; however, these protections do not apply to information that You have chosen to share in public areas, such as third-party social media.
People who may access your Personal Data. Your Personal Data will be processed by our staff, service providers, or authorized agents, provided that they need to have access to such information, depending on the specific purposes for which your Personal Data was collected, such as, for example: a provider or staff member responsible for user support, or responsible for billing regularization.
Measures taken in operational environments. We store your Personal Data in operational environments that use reasonable security measures to prevent unauthorized access. We follow reasonable protocols to protect Personal Data. The transmission of information over the internet is unfortunately not completely secure and, although we do Our best to protect your Personal Data, we cannot guarantee the security of data during transmission through our website.
Measures We expect You to take. Your role is essential to keeping your Personal Data secure. When creating an online account, please make sure to choose a password that is difficult for other people to guess. You are responsible for keeping this password confidential for any use of your account. If You use a shared or public computer, never select the option to remember your login ID, e-mail address, or password, and be sure to log out of your account whenever You leave the computer. You should also use any privacy settings or controls that We provide on our website or app.
10. Your Choices About How We Use Your Data
We do our best to give You choices regarding the Personal Data You provide to us. The following mechanisms give You the following control over your Personal Data:
a. Necessary (Always Active) – Necessary cookies are required to enable the basic features of this website, such as providing secure login or adjusting your consent preferences. These cookies do not store any personally identifiable data.
b. Functional – Functional cookies help perform certain functions, such as sharing website content on social media platforms, collecting feedback, and other third-party features.
c. Analytics – Analytics cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics such as number of visitors, bounce rate, traffic source, etc.
d. Advertising – Advertising cookies are used to provide visitors with personalized advertisements based on the pages you have previously visited, and to analyze the effectiveness of advertising campaigns.
11. Your Rights as a Data Subject
You, as a Data Subject and our customer, have the following rights with respect to your personal information:
a. to access, review, know whether we have carried out any processing of your Personal Data, and request an electronic copy of the information we hold about You;
b. to correct, or request the correction of, incomplete, inaccurate, or outdated Personal Data;
c. to request the anonymization, blocking, or deletion of unnecessary or excessive Personal Data;
d. to request the portability of Personal Data to another provider of similar products or services;
e. to request the deletion of Personal Data collected and used based on your consent;
f. to obtain information about the public or private entities with which we share your Personal Data;
g. when the processing activity requires your consent, You may refuse to consent. In such case, we will inform you of the consequences of not carrying out such activity;
h. when the processing activity requires your consent, You may revoke it at any time;
i. to request the review of decisions based solely on automated processing that affect your interests;
j. to object to processing carried out on the basis of any of the grounds for waiving consent set forth in the LGPD.
We highlight that our website has a dedicated feature through which You can review and edit the Personal Data You have provided. In addition, we ask our registered customers to verify their identity (such as login, e-mail address, password) before accessing or changing their accounts, in order to prevent unauthorized access to their account.
It is important to note that:
We will not be able to delete your Personal Data without also deleting your user account.
It may be necessary to retain some of your Personal Data after You request its deletion, in order to satisfy our legal or contractual obligations, or to meet business needs.
In order to respond to your requests as a Data Subject, we may request a copy of your identification document. This is necessary to confirm and validate your identity, given the existence of potentially bad-faith individuals, or in situations involving persons with the same name. Accordingly, the greater the sensitivity of the data and/or the purpose of its use, the greater the care that must be taken with the authentication and verification of the data subject/requester.
Requests involving Personal Data and/or documents of other Data Subjects will not be fulfilled, except upon a power of attorney, parental authority, or other circumstance authorizing You to exercise another Data Subject's right.
In situations where You no longer have access to the e-mail address registered on our platforms, we may also request a copy of your identification document to recover your login and password.
In specific circumstances, it is possible that your request will not be fulfilled, but You will always receive a response. In such cases, We will explain the reasons that justified not fulfilling the request.
To exercise your rights, please use the channels provided at the end of this Policy.
12. Changes to Our Policy
This document may be revised at any time, in order to keep it up to date with respect to applicable legislation and the organization of the company itself. We therefore recommend that You review this document periodically and check the date of its last update.
13. Contact
To ask questions, make comments, or file complaints about this Privacy Policy, as well as to request the correction or deletion of any data, please contact us by e-mail ([email protected]), attaching proof of your identity (such as a national ID card, driver's license, or similar document).
If the request is submitted by a person other than You, without providing proof that the request is legitimately made on your behalf, the request will be rejected. Please note that any identifying information provided to Us will only be processed in accordance with applicable law.
We will receive and investigate any complaint regarding the way We manage Personal Data (including complaints regarding the disregard of your rights established under applicable privacy laws and regulations).