LGPDNOW Tratamento e Hospedagem de Dados LTDA, registered with the CNPJ under no. 35.101.516/0001-07, headquartered at Avenida Engenheiro Luiz Carlos Berrini, no. 1140, Conjunto 72, Cidade Monções, São Paulo/SP, CEP: 04.571-930, values and respects the privacy of its users, customers, partners, suppliers, employees and collaborators. Therefore, it created this Privacy Policy to demonstrate its commitment to the protection of personal data, in accordance with Law no. 13.709/2018 – General Data Protection Law.
In this context, this Privacy Policy seeks to explain in a clear and accessible manner how personal data may be processed.
DEFINITIONS
Personal Data: Any information relating to an identified or identifiable natural person, who can be identified, directly or indirectly, by reference to an identifier such as a name, identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
Sensitive Personal Data: Any Personal Data that may give rise to any type of discrimination, such as data on racial or ethnic origin, religious belief, political opinion, membership of a trade union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data;
Data Subject: An identified or identifiable natural person to whom a specific Personal Data refers;
Data Protection Officer (“DPO”): The individual designated as the formal/official data protection officer, as provided for in data protection laws, such as GDPR and LGPD, for a given territory. The DPO may be an employee or an outsourced person;
Processing of Personal Data or Processing: Any operation or set of operations performed on Personal Data or on sets of Personal Data, by automated or non-automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other form of availability, comparison or interconnection, limitation, payment or destruction of data;
Third Parties or “Partner(s)”: Any person, natural or legal, acting on behalf of, in the interest of or for the benefit of LGPDNOW, providing services or supplying other goods, as well as Business Partners who provide services to LGPDNOW, directly related to obtaining, retaining or facilitating business, or for the conduct of LGPDNOW’s affairs, including, without limitation, any distributors, agents, brokers, forwarders, intermediaries, Supply Chain Partners, consultants, resellers, contractors and other professional service providers;
Pseudo-anonymization: This is a process by which Personal Data no longer relates directly to an identifiable person (for example, mentioning their name), but is not anonymous, because it is still possible, with additional information, which is kept separately, to identify a person;
Anonymization: This is the process by which personal information relating to individuals becomes non-identifiable, considering the use of reasonable and available technical means at the time of its processing. Anonymized data is not considered Personal Data;
Information Security: The area responsible for protecting the integrity, availability and confidentiality of IT systems and must implement appropriate measures to achieve this objective, with technical support from the Corporate Privacy Leader and responsible for issues related to technical and administrative measures.
Consent: Free, informed and unequivocal expression by which the Holder agrees to the Processing of his/her Personal Data for a specific purpose.
LGPD: Brazilian legislation No. 13,709/2018, commonly known as the General Personal Data Protection Law, which regulates the processing of personal data and also amends articles 7 and 16 of the Internet Civil Rights Framework;
RECIPIENTS OF THIS POLICY
This Policy applies to any data subject who in any way has a relationship with LGPDNOW, such as users of the website “www.lgpdnow.com.br”, customers, partners, candidates in selection processes, service providers, legal representatives of partner companies, contractors or contracted parties, employees, collaborators, among others.
PERSONAL DATA THAT MAY BE COLLECTED
The amount and type of Personal Data collected by LGPDNOW vary according to the context of the relationship established with the person related to a given Personal Data. Therefore, valuing transparency, we list below the Personal Data that may be requested and/or used by LGPDNOW, according to the different processing contexts, and the purposes for which they are used.
These may be used by LGPDNOW, including, but not limited to:
Recruitment and selection processes and employee information: personal data included in the resume or provided during interviews such as name, surname, telephone number, email, address, gender, education, details of skills, qualifications, professional experience, work history with references from previous employers, current remuneration and benefits;
Contractual information: name, surname, ID, CPF, marital status, address and signature of the legal representative of the Contractor or Contracting Party and name, surname, address, email and telephone number of the person responsible for the commercial relationship, to execute the contract and manage the relationship with service providers and partners;
To request a proposal or schedule a presentation of LGPDNOW services: name, surname, position, telephone number and corporate email;
To receive Newsletters upon prior registration by the data subject: name and email;
For user registration on the platforms provided by LGPDNOW: name, surname, email, department where the user works in the company;
For registration and identification of service providers and representatives of companies providing services to LGPDNOW: name, surname, date of birth, gender, position, education, hierarchical level, department where the user works and email.
Sensitive Data: If you share with us personal information that has special protection under the General Data Protection Law (Law No. 13,709, of August 14, 2018), called “sensitive personal data”, the use of such information will be made in accordance with the applicable law and with your authorization, for specific and necessary purposes, and never for unlawful or abusive discriminatory purposes.
Children’s Data: LGPDNOW does not process Personal Data of children that have not been provided by or with the authorization of their respective parents or legal guardians. Any processing of data relating to minors will only be carried out based on the best interests of the child or adolescent, and in compliance with the need for consent from their father, mother, or legal guardian.
PURPOSE OF PROCESSING
The amount and type of Personal Data collected by LGPDNOW vary according to the context of the relationship established with the person related to a given Personal Data and will be used to achieve certain purposes, namely:
To perform LGPDNOW’s duties and obligations due to negotiations or contracts signed between LGPDNOW and third-party companies in which the data subject appears as the legal representative or as the person responsible for the commercial relationship and execution of the contract with the Personal Data Subject;
To enable LGPDNOW to communicate with the Personal Data Subject, through any of its service channels;
To send communications and alerts (newsletters);
To enable the Personal Data Subject to participate in selection processes promoted by LGPDNOW;
To enable user registration on the platforms made available by LGPDNOW and, consequently, enable the provision of contracted services;
To enable scheduling presentations of LGPDNOW services and products, as well as to forward commercial proposals;
To register and identify service providers and representatives of companies providing services to LGPDNOW;
To authenticate the identity of individuals who contact us by telephone, electronic means or other means.
Your Personal Data will be processed in accordance with the LGPD, and, in cases where necessary, we will request the consent of the data subject or legal guardian for its processing.
SHARING PERSONAL DATA
The sharing of Personal Data will serve the purposes set out in this Privacy Policy, including the engagement of third-party service providers or subcontractors, who may act as agents for the processing of your personal information, including for the purposes of processing, hosting and storing data, for the execution of the contract in the most efficient manner, or to comply with specific legal obligations to which we are subject.
Your Personal Data may be shared with:
Our business partners and third-party service providers, in accordance with the law, who are not authorized to share or use such information for any purpose other than the provision of their services; and
Third parties who need to process your Personal Data to protect our rights.
In such cases, we will adopt appropriate measures to ensure the security of personal information and prevent its alteration, loss, processing or unauthorized access. Specific contractual clauses and other legal transfer mechanisms.
generally acceptable are adequate and implemented in our procedures for protecting Personal Data.
LEGAL HYPOTHESES FOR DISCLOSING PERSONAL DATA
In some cases provided for in the LGPD, LGPDNOW may disclose your Personal Data collected in order to comply with applicable legislation or by means of a judicial or administrative order or subpoena.
Legal disclosure may be made to:
Comply with legislation;
Investigate, prevent or take measures related to cooperation with public bodies or to protect national security;
Execution of contracts;
Investigation and defense of third-party claims; and
Protect the security or integrity of services.
RETENTION OF PERSONAL DATA
LGPDNOW stores and maintains your Personal Data for the time necessary to fulfill its purpose or for the time required by law, observing the applicable prescriptive terms.
After the processing of your Personal Data has been completed, it will be duly deleted, which will occur when it is verified:
That the purpose for which the data was collected has been achieved or that the Personal Data collected is no longer necessary or relevant to achieve the specific purpose sought;
That the consent has been revoked by the data subject, when this is the only applicable legal basis; or
By virtue of a legal or judicial determination or order from a competent administrative authority.
RIGHTS OF THE HOLDER
In compliance with the applicable regulations, with regard to the processing of Personal Data, LGPDNOW respects and guarantees the data subject the possibility of submitting requests based on the following rights:
i) confirmation of the existence of processing;
ii) access to the data;
iii) correction of incomplete, inaccurate or outdated data;
iv) anonymization, blocking or deletion of unnecessary, excessive or non-compliant data;
v) the portability of your data to another service or product provider, upon express request by the user;
vi) the deletion of data processed with the user’s consent;
vii) obtaining information about the public or private entities with which LGPDNOW shared your data;
viii) information about the possibility of not providing your consent, as well as being informed about the consequences, in case of refusal; and
ix) revocation of consent.
LGPDNOW is available to comply with the rights of Personal Data holders through our Holder Portal, which can be accessed via the link: https://titular.lgpdnow.com.br/
COOKIES
Cookies are small text files stored in your browser or device. Cookies allow us to recognize your preferences to, for example, adapt the website and your navigation to your specific needs. In other words, some of your information is saved in this text file and, when you visit the website again later, the website recognizes your browser. Cookies also usually have an expiration date. For example, some cookies are automatically deleted when you close your browser (so-called session cookies), while others may be stored on your computer for longer until you manually delete them (so-called persistent cookies).
LGPDNOW uses cookies to make it easier to use and better adapt the pages to your interests and needs, as well as to compile information about the use of our websites and services, helping to improve their structures and content.
Types of cookies
What do they do?
Necessary
These cookies help us understand how visitors interact with LGPDNOW pages, providing information about the areas visited, the time spent on the website and any problems encountered, such as error messages.
Functional
These cookies allow LGPDNOW pages to remember your choices, to provide a more personalized experience.
Marketing
These cookies are used to provide more relevant content that is of interest to users. They can be used to present more targeted advertising to the user. They also allow us to measure the effectiveness of an LGPDNOW advertising campaign.
Furthermore, these cookies can be used to indicate the LGPDNOW pages and the websites that the user has visited.
After the holder consents to the use of cookies, when using the LGPDNOW Pages, the latter will store a cookie on their device to remember this in the next session.
At any time, the user may revoke their consent to cookies, and to do so, they must delete the cookies from the LGPDNOW Pages, using the settings of their preferred browser. For more information on how to proceed with regard to managing cookies in browsers:
Internet Explorer: https://support.microsoft.com/pt-br/help/17442/windows-internetexplorer-delete-manage-cookies
Mozilla Firefox: https://support.mozilla.org/pt-BR/kb/ative-e-desative-os-cookies-queos-sites-usam
Google Chrome: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop& hl=pt-BR
Safari: https://support.apple.com/pt-br/guide/safari/sfri11471/mac
If the holder of Personal Data does not accept some cookies from LGPDNOW pages, some services may not function optimally.
Links to other websites
Our website may contain links to third-party websites or applications. However, once you use these links to leave our website, you should note that we no longer have control over such platforms, and you should check the privacy policies and terms that apply to them.
COMMUNICATION CHANNEL
Data Subject Rights can be exercised through our Data Subject Portal, which can be accessed via the link: https://titular.lgpdnow.com.br/
In the event of requests of another nature, such as complaints, questions, reports, notifications from the ANPD or communication of an incident involving personal data, for example, please contact us via email: dpo@lgpdnow.com.br.
PRIVACY POLICY REVISIONS
If LGPDNOW modifies this policy, such changes will be published visibly on its website.