Privacy Policy of www.innform.io
This Application collects some Personal Data from its Users.
This document contains a section dedicated to Users in Switzerland and their privacy rights.
This document contains a section dedicated to Brazilian Users and their privacy rights.
This document can be printed for reference by using the print command in the settings of any browser.
Owner and Data Controller
Sebazzo Ltd
Unit 1, 18 Charlotte Road
EC2A 3PB London
Owner contact email: hi@innform.io
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Cookies; Usage Data; email address; Universally unique identifier (UUID); Data communicated while using the service; first name; last name; date of birth; phone number; physical address; username; VAT Number; company name; profession; country; state; county; ZIP/Postal code; city; profile picture; workplace; website; number of employees; billing address; field of activity; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; session statistics; User ID.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
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 transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
SPAM protection, Displaying content from external platforms, Heat mapping and session recording, User database management, Handling payments, Infrastructure monitoring, Registration and authentication provided directly by this Application, Hosting and backend infrastructure, Analytics, Advertising, Managing data collection and online surveys, Traffic optimization and distribution, Tag Management, Contacting the User, Communication and Managing web conferencing and online telephony.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)
Hotjar is an analytics service provided by Hotjar Ltd.
Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Trackers; Usage Data.
Place of processing: Malta – Privacy Policy – Opt Out.
MixPanel (MixPanel)
MixPanel is an analytics service provided by Mixpanel Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Google Analytics 4 (Google Ireland Limited)
Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google’s use of Data, consult Google’s partner policy.
Personal Data processed: session statistics; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Contacting the User
Contact form (this Application)
By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: company name; country; email address; first name; last name; number of employees; phone number.
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Maps widget (Google Ireland Limited)
Google Maps is a maps visualization service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: Ireland – Privacy Policy.
Gravatar (Automattic Inc.)
Gravatar is an image visualization service provided by Automattic Inc. or by Aut O’Mattic A8C Ireland Ltd., depending on how the Owner manages the Data processing, that allows this Application to incorporate content of this kind on its pages.
Please note that if Gravatar images are used for comment forms, the commenter’s email address or parts of it may be sent to Gravatar – even if the commenter has not signed up for that service.
Personal Data processed: email address; Usage Data.
Place of processing: US – Privacy Policy.
Adobe Fonts (Adobe Systems Incorporated)
Adobe Fonts is a typeface visualization service provided by Adobe Systems Incorporated that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Handling payments
Payment processing services enable this Application to process payments by credit card, bank transfer or other means. To ensure greater security, this Application shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
Stripe (Stripe Inc)
Stripe is a payment service provided by Stripe, Inc., Stripe Payments Europe, Limited, Stripe Payments UK, Ltd, Stripe Brasil Soluções de Pagamento – Instituição de Pagamento Ltda., Stripe Payments Canada, Ltd., Stripe India Private Ltd., Stripe Japan KK, Stripe Payments Malaysia Sdn. Bhd., Stripe Payments Mexico, S. de R.L. de C.V., Stripe New Zealand Limited, Stripe Payments Singapore Pte. Ltd. or by Stripe Payments (Thailand) Ltd., depending on how the Owner manages the Data processing.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Heat mapping and session recording
Heat Mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User’s data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy; United Kingdom – Privacy Policy.
Infrastructure monitoring
This type of service allows this Application to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.
StatusCake (TrafficCake Limited)
StatusCake is a monitoring service provided by TrafficCake Limited.
Personal Data processed: Cookies; Usage Data.
Place of processing: UK – Privacy Policy.
Sentry (Functional Software, Inc. )
Sentry is a monitoring service provided by Functional Software, Inc. .
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Managing data collection and online surveys
This type of service allows this Application to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.
These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed – e.g. managing contacts, sending messages, analytics, advertising and payment processing.
Typeform (TYPEFORM S.L)
Typeform is a form builder and data collection platform provided by TYPEFORM S.L.
Personal Data processed: Usage Data.
Place of processing: Spain – Privacy Policy.
Managing web conferencing
This type of service allows this Application to manage the deployment, administration, hosting, distribution and analysis of web conferencing in order to communicate with Users.
The Personal Data collected depend on the information provided by the Users while using the respective service.
Google Meet & Calendar API
When you choose to connect your Google account to our platform for meeting and calendar management, we request access to the following Google API scopes:
/auth/calendar.events: This scope allows us to view, create, and manage your Google Calendar events. We use this to synchronize meetings scheduled through our platform with your Google Calendar.
/auth/meetings.space.created: This scope enables us to create new Google Meet spaces for your meetings.
/auth/meetings.space.readonly: This allows us to access details about existing Google Meet spaces you are associated with in read-only mode. We use this to retrieve and display meeting details.
We adhere strictly to Google’s API Services User Data Policy, including the Limited Use requirements. This means that we:
– Do not use your data for purposes beyond the features offered within the platform.
– Do not sell or share your personal information or meeting data with third parties for marketing or other unrelated purposes.
– Ensure the security and confidentiality of all data accessed via the Google API.
You have full control over the data shared between our platform and Google services. You can view and manage permissions at any time.
Zoom
On this website we integrated Zoom for Online Live Training Sessions. Zoom is operated by the company Zoom Video Communications Inc. a software company with headquarters at 55 Almaden Blvd, Suite 600, San Jose, CA 95113.
Trainers & Admins can connect their Zoom account to Innform and schedule an online meeting. When using a Zoom Pro account, meeting recordings can optionally be retrieved back to Innform so that users who could not attend the meeting can review the recording at a later stage.
The following data can be collected and processed:
– oauth credentials
– Video recordings
The data will be stored for as long as it is necessary for the purpose of the procession. The data will be deleted as soon as it is no longer needed for the processing purposes. Data may be transferred to the USA as part of processing by Zoom. The security of the transmission is ensured by so-called standard contractual clauses, which guarantee that the processing of personal data is subject to a security level that corresponds to that of the GDPR. If the standard contractual clauses are not sufficient to ensure an adequate level of security, we will obtain your consent in accordance with Art. 49 (1)(a) GDPR prior to the data processing.
Registration and authentication provided directly by this Application
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration (this Application)
The User registers by filling out the registration form and providing the Personal Data directly to this Application.
Personal Data processed: billing address; city; company name; country; county; date of birth; email address; field of activity; first name; last name; number of employees; phone number; physical address; profession; profile picture; state; username; VAT Number; website; workplace; ZIP/Postal code.
SPAM protection
This type of service analyzes the traffic of this Application, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Akismet (Automattic Inc.)
Akismet is a SPAM protection service provided by Automattic Inc. or by Aut O’Mattic A8C Ireland Ltd., depending on how the Owner manages the Data processing.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Google reCAPTCHA (Google Ireland Limited)
Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
In order to understand Google’s use of Data, consult Google’s partner policy.
Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion.
This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.
Traffic optimization and distribution
This type of service allows this Application to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Application and the User’s browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
jsDelivr (Prospect One Sp. z o.o. sp. k.)
jsDelivr is a traffic optimization and distribution service provided by Prospect One Sp. z o.o. sp. k.
Personal Data processed: Usage Data.
Place of processing: Poland – Privacy Policy.
User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving this Application.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.
Intercom (Intercom Inc.)
Intercom is a User database management service provided by Intercom Inc., Intercom R&D Unlimited Company, Intercom Software Australia Pty Ltd or by Intercom Software UK Limited, depending on how the Owner manages the Data processing.
Intercom can also be used as a medium for communications, either through email, or through messages within this Application. Intercom Messenger may use Trackers to recognize and track Users behavior.
Personal Data processed: Data communicated while using the service; email address; Trackers; Universally unique identifier (UUID); Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Cookie Policy
This Application uses Trackers. To learn more, Users may consult the Cookie Policy.
Further Information for Users
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding 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 Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to 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 their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Further information for Users
in Switzerland
This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.
Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
The rights of Users according to the Swiss Federal Act on Data Protection
Users may exercise certain rights regarding their Data within the limits of law, including the following:
- right of access to Personal Data;
- right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);
- right to receive their Personal Data and have it transferred to another controller (data portability);
- right to ask for incorrect Personal Data to be corrected.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.
Further information for Users
in Brazil
This section of the document 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 (for the purposes of this section referred to collectively as “we”, “us”, “our”).
This section applies to all Users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the “Lei Geral de Proteção de Dados” (the “LGPD”), and for such Users, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.
This part of the document uses the term “personal information“ as it is defined in the 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 document.
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 document.
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 document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
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 document, 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.
Transfer of personal information outside of Brazil permitted by the law
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.
Additional information about Data collection and processing
Legal action
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about 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 concerning particular 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) or use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning 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.
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 feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., 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 device operating system and/or the User’s IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User’s browser.
Tracker
Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to this Application, if not stated otherwise within this document.
Latest update: September 12, 2024