Privacy Policy

provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;

describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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

If you cannot personally submit a verifiable request, you can 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 parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

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

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12 month period.

Should we deny your request, we will explain you the reasons behind our denial.

We do 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 act on the request. In either case, we will communicate our choices and explain the reasons behind it.

== 8. Information for Users residing in Brazil ==

This part of the Policy integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates.

The provisions contained in this section apply to all Users who reside in Brazil, according to the "Lei Geral de Proteção de Dados". For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in this privacy policy.

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

The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

your consent to the relevant processing activities;

compliance with a legal or regulatory obligation that lies with us;

the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;

studies conducted by research entities, preferably carried out on anonymized personal information;

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

the exercising of our rights in judicial, administrative or arbitration procedures;

protection or physical safety of yourself or a third party; the protection of health – in procedures carried out by health entities or professionals;

our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this Policy.

Categories of personal information processed

To find out what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this Policy.

Why we process your personal information

To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this Policy.

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

You have the right to:

obtain confirmation of the existence of processing activities on your personal information;

access to your personal information;

have incomplete, inaccurate or outdated personal information rectified; obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;

obtain information on the possibility to provide or deny your consent and the consequences thereof;

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 for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;

obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;

revoke your consent at any time;

lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;

oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;

request clear and adequate information regarding the criteria and procedures used for an automated decision; and

request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this Policy, or via your legal representative.

How and when we will respond to your request

We will strive to promptly respond to your requests.

In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.

You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead.

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

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.

How and when we will respond to your request

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

when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;

when the transfer is necessary to protect your life or physical security or those of a third party;

when the transfer is authorized by the ANPD;

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

when the transfer is necessary for the execution of a public policy or legal attribution of public service;

when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.