rev 1.1m14-02-21

PRIVACY POLICY


1. General information

This Privacy Policy contains information regarding the way in which we treat, in whole or in part, in an automated or non-automated way, the personal data of users who access our website. Its purpose is to inform stakeholders about the types of data that are collected, the reasons for the collection and how the user will be able to update, manage or delete this information.

This Privacy Policy was prepared in accordance with Federal Law no. 12,965 of April 23, 2014 (Marco Civil da Internet), with Federal Law no. 13,709, of August 14, 2018 (Personal Data Protection Law) and with EU Regulation no. 2016/679 of 27 April 2016 (European General Regulation for the Protection of Personal Data - GDPR).

This Privacy Policy may be updated as a result of any regulatory update, which is why the user is invited to periodically consult this section.

 

2. User rights

The website is committed to complying with the norms foreseen in the LGPD, respecting the following principles:

- The user's personal data will be processed in a lawful, loyal and transparent manner (lawfulness, loyalty and transparency);

- The user's personal data will be collected only for specific, explicit and legitimate purposes, and cannot be further processed in a way incompatible with those purposes (limitation of purposes);

- The user's personal data will be collected in an appropriate, relevant and limited way to the needs of the purpose for which they are processed (data minimization);

- The user's personal data will be accurate and updated whenever necessary, so that the inaccurate data is erased or rectified when possible (accuracy);

- The user's personal data will be kept in a way that allows the identification of the data holders only for the period necessary for the purposes for which they are processed (conservation limitation);

- The user's personal data will be treated securely, protected from unauthorized or illicit treatment and against its accidental loss, destruction or damage, adopting the appropriate technical or organizational measures (integrity and confidentiality).

The user of the website has the following rights, conferred by the Personal Data Protection Law and the GDPR:

- Right of confirmation and access: it is the right of the user to obtain from the website the confirmation that the personal data concerning him are or are not subject to treatment and, if that is the case, the right to access his personal data;

- Right of rectification: it is the user's right to obtain from the website, without undue delay, the rectification of inaccurate personal data concerning him;

- Right to delete data (right to be forgotten): it is the user's right to have their data deleted from the website;

- Right to limit the processing of data: it is the user's right to limit the processing of his personal data, obtaining it when he disputes the accuracy of the data, when the processing is illegal, when the site no longer needs the data for the proposed purposes and when you have opposed the processing of data and in case of processing unnecessary data;

- Right of opposition: it is the user's right to oppose, at any time, for reasons related to their particular situation, to the processing of personal data concerning them, and may also oppose the use of their personal data to define marketing profile (profiling);

- Right to data portability: it is the user's right to receive personal data concerning him / her and which he has provided to the website, in a structured format, in current use and automatic reading, and the right to transmit this data to another website. ;

- Right not to be subjected to automated decisions: it is the user's right not to be subject to any decision taken exclusively on the basis of automated treatment, including the definition of profiles (profiling), which has an effect on its legal sphere or affects it significantly in a similar way.

The user will be able to exercise his rights through written communication sent to the website with the subject “LGPD-", specifying:

- Full name or corporate name, CPF number (Individual Taxpayer Registry, Federal Revenue Service of Brazil) or CNPJ (National Registry of Legal Entities, Federal Revenue Service of Brazil) and email address of the user and, if applicable case, of its representative;

- Right you want to exercise with the website;

- Order date and user signature;

- Any document that can demonstrate or justify the exercise of your right.

The request should be sent to the email: lgpd@sistemasentinela.com.br.


The user will be informed in case of rectification or deletion of his data.

 

3. Duty not to provide data from third parties

During the use of the website, in order to safeguard and protect the rights of third parties, the user of the website must provide only his personal data, and not those of third parties.

 

4. Information collected

The collection of data from users will take place in accordance with the provisions of this Privacy Policy and will depend on the user's consent, this being dispensable only in the cases provided for in art. 11, item II, of the Personal Data Protection Law.


4.1. Types of data collected

4.1.1. User identification data for sending email

The use, by the user, of certain functionalities of the website will depend on filling in information, and in these cases, the following user data will be collected and stored:

- Name

- email address

- phone number

- id number

 

4.1.2. Data entered in the contact form

The data eventually informed by the user using the contact form available on the website, including the content of the message sent, will be collected and stored.

4.1.3. Data related to the execution of contracts signed with the user

For the execution of the purchase and sale contract or the provision of services eventually signed between the website and the user, other data related to or necessary for its execution, including the content of any communications with the user, may be collected and stored.

4.1.4. Access logs

In compliance with the provisions of art. 15, caput and paragraphs, of Federal Law no. 12,965 / 2014 (Marco Civil da Internet), user access records will be collected and stored for at least six months.

4.1.5. Newsletter

The email address registered by the user who chooses to subscribe to our Newsletter will be collected and stored until the user requests their cancelation.

4.1.6. Sensitive data

Sensitive data from users will not be collected, thus understood those defined in arts. 9 and 10 of the GDPR and in arts. 11 et seq. Of the Personal Data Protection Law. Thus, among others, there will be no collection of the following data:

- data that reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or the union membership of the user;

- genetic data;

- biometric data to uniquely identify a person;

- data related to the user's health;

- data relating to the user's sexual life or sexual orientation;

- data related to criminal convictions or offenses or related security measures.

4.1.7. Collection of data not expressly provided

Eventually, other types of data not expressly provided for in this Privacy Policy may be collected, provided that they are provided with the user's consent, or that the collection is permitted or imposed by law.


4.2. Legal basis for the processing of personal data

By using the services of the website, the user is consenting to this Privacy Policy.

The user has the right to withdraw his consent at any time, without compromising the lawfulness of the treatment of his personal data before the withdrawal. The withdrawal of consent can be made by e-mail: lgpd@sistemasentinela.com.br.

The consent of the relatively or absolutely incapacitated, especially of children under 16 (sixteen) years old, can only be done, respectively, if properly assisted or represented.

Personal data necessary for the execution and fulfillment of the services contracted by the user on the website may also be collected.

The processing of personal data without the user's consent will only be carried out due to legitimate interest or for the cases provided for by law, that is, among others, the following:

- for the fulfillment of a legal or regulatory obligation by the controller;

- to carry out studies by a research body, guaranteeing, whenever possible, the anonymization of personal data;

- when necessary for the execution of a contract or preliminary procedures related to a contract to which the user is a party, at the request of the data subject;

- for the regular exercise of rights in judicial, administrative or arbitration proceedings, the latter under the terms of Law No. 9,307, of September 23, 1996 (Arbitration Law);

- for the protection of life or physical safety of the data subject or third party;

- for the protection of health, in a procedure carried out by health professionals or by health entities;

- when necessary to serve the legitimate interests of the controller or third party, except where the fundamental rights and freedoms of the data subject prevail that require the protection of personal data;

- for credit protection, including the provisions of the relevant legislation.


4.3. Purposes of the processing of personal data

The personal data of the user collected by the website are intended to facilitate, streamline and fulfill the commitments established with the user and to enforce the requests made by filling out forms.

Personal data may also be used for commercial purposes, to personalize the content offered to the user, as well as to subsidize the website for improving the quality and functioning of its services.

The collection of data related to or necessary for the execution of a purchase and sale contract or the provision of services eventually signed with the user will have the purpose of providing the parties with legal certainty, in addition to facilitating and enabling the conclusion of the deal.

The processing of personal data for purposes not provided for in this Privacy Policy will only occur upon prior notification to the user, and, in any case, the rights and obligations provided herein will remain applicable.


4.4. Period of retention of personal data

The user's personal data will be kept for a maximum period of: 5 years, unless the user requests its deletion before the end of this period.

The personal data of users can only be kept after the end of their treatment in the following cases:

- for the fulfillment of a legal or regulatory obligation by the controller;

- for study by a research body, guaranteeing, whenever possible, the anonymization of personal data;

- for the transfer to a third party, provided that the data processing requirements provided for in the legislation are respected;

- for the exclusive use of the controller, access by a third party is prohibited, and provided the data is anonymized.


4.5. Recipients and transfer of personal data

The user's personal data may be shared with the following persons or companies:

Google Analytics, with address at Av. Brigadeiro Faria Lima, 3477, Itaim Bibi, Sao Paulo / SP

The transfer can only be made to another country if the country or territory in question or the international organization concerned ensures an adequate level of protection of the user's data.

If there is no adequate level of protection, the website is committed to ensuring the protection of your data in accordance with the most stringent rules, through specific contractual clauses for a particular transfer, standard contractual clauses, global corporate standards or stamps, certificates and codes of conduct regularly issued.

 

5. Processing of personal data

5.1. Data controller

The controller, responsible for the processing of the user's personal data, is the natural or legal person, the public authority, the agency or other body that, individually or in conjunction with others, determines the purposes and means of processing personal data.

On this website, the person responsible for processing the personal data collected is BRASIL LGPD, represented by Fabio Vilardo who can be contacted by e-mail: lgpd@sistemasentinela.com.br.


The person responsible for processing the data will be directly responsible for processing the user's personal data.


5.2. Data protection officer

The data protection officer is the professional in charge of informing, advising and controlling the data controller, as well as the workers who process the data, regarding the website's obligations under the terms of the GDPR, the Law Protection of Personal Data and other data protection provisions in national and international law, in cooperation with the competent supervisory authority.

On this website, the data protection officer is Fabio Vilardo, who can be contacted by e-mail: lgpd@sistemasentinela.com.br.

 

6. Security in the treatment of the user's personal data

The website undertakes to apply technical and organizational measures to protect personal data from unauthorized access and situations of destruction, loss, alteration, communication or dissemination of such data.

To guarantee security, solutions will be adopted that take into account: the appropriate techniques; application costs; the nature, scope, context and purposes of the treatment; and the risks to the user's rights and freedoms.

The website uses SSL (Secure Socket Layer) certificate which guarantees that personal data is transmitted in a secure and confidential way, so that the data transmission between the server and the user, and in feedback, occurs in a totally encrypted or encrypted way.

However, the site disclaims liability for the sole fault of a third party, such as in the event of a hacker or cracker attack, or the exclusive fault of the user, such as in the case where he himself transfers his data to the third party. The website also undertakes to notify the user in due time if there is any type of breach of the security of your personal data that could cause you a high risk to your personal rights and freedoms.

The breach of personal data is a breach of security that causes, accidentally or unlawfully, the destruction, loss, alteration, disclosure or unauthorized access to personal data transmitted, stored or subject to any other type of treatment.

Finally, the website undertakes to treat the user's personal data with confidentiality, within the legal limits.

 

7. Browsing data (cookies)

Cookies are small text files sent by the website to the user's computer and which are stored there, with information related to the navigation of the website.

Through cookies, small amounts of information are stored by the user's browser so that our server can read them later. For example, data about the device used by the user, as well as their location and time of access to the website, can be stored.

Cookies do not allow any files or information to be extracted from the user's hard drive, and it is not yet possible to access personal information that has not come from the user or the way he uses the website's resources. .


It is important to note that not all cookies contain information that allows the user to be identified, and certain types of cookies can be used simply for the website to be loaded correctly or for its functionality to work as expected.

The information eventually stored in cookies to identify a user is considered personal data. Accordingly, all rules provided for in this Privacy Policy are also applicable to them.


7.1. Site cookies

Site cookies are those sent to the user's and administrator's computer or device exclusively by the site.

The information collected through these cookies is used to improve and personalize the user experience, and some cookies can, for example, be used to remember the user's preferences and choices, as well as to offer personalized content.


7.2. Third-party cookies

Some of our partners may set cookies on the devices of users who access our website.

These cookies, in general, aim to enable our partners to offer their content and services to the user who accesses our website in a personalized way, by obtaining navigation data extracted from their interaction with the website.

The user will be able to obtain more information about third party cookies and about the way the data obtained from it is treated, in addition to having access to the description of the cookies used and their characteristics, by accessing the following link:

Google Analytics
https://developers.google.com/analytics/devguides/collection/gajs/cookie-usage

The entities in charge of collecting the cookies may transfer the information obtained to third parties.


7.3. Management of cookies and browser settings

The user will be able to oppose the registration of cookies by the website, if he only deactivates this option in his own browser or device.

The deactivation of cookies, however, can affect the availability of some tools and functionalities of the website, compromising its correct and expected functioning. Another possible consequence is the removal of user preferences that may have been saved, damaging their experience.

The following are some links to the help and support pages of the most used browsers, which can be accessed by the user interested in obtaining more information about the management of cookies in their browser:

Internet Explorer:
https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies

Safari:
https://support.apple.com/en-us/guide/safari/sfri11471/mac

Google Chrome:
https://support.google.com/chrome/answer/95647

Mozila Firefox:
https://support.mozilla.org/pt-BR/kb/ative-e-desative-os-cookies-que-os-sites-usam

Opera:
https://www.opera.com/help/tutorials/security/privacy/

 


8. Complaint to a supervisory authority

Without prejudice to any other means of administrative or judicial appeal, all data subjects are entitled to lodge a complaint with a supervisory authority. The complaint may be made to the authority of the website's headquarters, the user's country of habitual residence, his place of work or the place where the infraction was allegedly committed.

 

9. Changes

This version of this Privacy Policy was last updated on: 05/25/2020.

The editor reserves the right to modify the present rules at any time, especially to adapt them to the evolution of the site, either by making new features available, or by suppressing or modifying existing ones.

The user will be explicitly notified if this policy changes.

When using the service after any modifications, the user demonstrates his agreement with the new standards. If you disagree with any of the changes, you must immediately request the cancellation of your account and submit your reservation to the customer service, if you wish.

 

10. Applicable law and jurisdiction

In order to resolve disputes arising from this instrument, Brazilian law will be fully applied.

Any disputes should be presented in the jurisdiction of the district where the site editor is located.