PLEASE READ THIS DOCUMENT CAREFULLY.
(i) V3 EDITORAÇÃO ELETRÔNICA LTDA., Limited Liability Company, headquartered at Rua Miguel Sutil, 370, Vila Cordeiro, Zip Code: 04.583-050, Municipality of São Paulo, State of São Paulo, enrolled with the CNPJ/MF under No. 05.147.282/0001-78, and VISION COMUNICAÇÃO E MARKETING LTDA, a Private Limited Company, headquartered at Rua Miguel Sutil, 370, Vila Cordeiro, Zip Code: 04.583-050, Municipality of São Paulo, State of São Paulo, registered with the CNPJ/MF under No. 03.702. 250/0001-61, jointly or separately “VISION” or “AGÊNCIA VISION COMUNICAÇÃO“; is a legal entity of private law, regularly constituted as a limited company, which is dedicated to the branch of communication regularly constituted, and has developed a commercial business methodology through the VISION brand, in a multidisciplinary and integrated manner in a 360º communication, acting in the market for 17 years;
(ii) the purpose of this document is to establish the rules on the collection, access, use and storage of data collected from individuals (natural persons) who use the services and computer systems of AGÊNCIA VISION COMUNICAÇÃO, including by free registration through social networks, website or other means of contact between AGÊNCIA VISION COMUNICAÇÃO and the holder of the personal data, always in accordance with the laws in force in Brazil;
(iv) for security reasons, we expressly inform – and you hereby agree and are made aware that: (a) we never call you requesting access to areas of the AGENCIA VISION COMUNICAÇÃO website or for security procedures or registration update, asking for data entry or passwords or eventual security codes, tokens or other related measures; (b) you are expressly warned to only access our addresses and official AGENCIA VISION COMMUNICATION sites, entering these addresses, or by clicking on official links freely suggested by search engines (organic or sponsored links); (c) never ask for your confidential and sensitive access data by telephone, and thus never give your passwords or codes of any security devices (tokens or Ids of banks).
– Express consent of the user: In art. 7, IX, of the Marco Civil da Internet (Law No. 12,965, of April 23, 2014), and art. 5, XII, and art. 7, I, of the General Law for the Protection of Personal Data (LGPD) (Law No. 13,709, of August 14, 2018), the user grants express consent to AGÊNCIA VISION COMUNICAÇÃO for the collection, use, storage and processing of his personal data, in the terms specified and discriminated below. The user is aware, and agrees, accepts and gives his express consent for the personal data provided above to be used for sending AGENCY VISION COMMUNICATION informational, analytical and advertising content about products, services and general issues, under the terms of the LGPD.
To register, access and use services and computer systems of AGÊNCIA VISION COMUNICAÇÃO, you must be at least eighteen (18) years of age or be assisted by a legal guardian to perform your registration. Meeting these requirements, you must accept and consent to this Policy, giving acceptance to all the terms and conditions set forth herein.
For the purposes of this document, the following definitions and descriptions should be considered for your better understanding:
Cloud Computing: or cloud computing, is a service virtualization technology built from the interconnection of more than one server through a common information network (e.g. the internet), with the aim of reducing costs and increasing the availability of sustained services;
IP: short for Internet Protocol. It is an alphanumeric string that identifies user devices on the Internet;
Logs: Records of activities of users and users made on the website and systems and social networks of AGÊNCIA VISION COMUNICAÇÃO;
Data Subject: Natural person to whom the personal data that are being processed refer;
Dado Pessoal: informação relacionada a pessoa natural identificada ou identificável;
User: are the individuals who transit and navigate through the website of AGÊNCIA VISION COMUNICAÇÃO and that make use of our solutions and applications for smartphone and/or tablets, or that perform registration or enter data in forms of AGÊNCIA VISION COMUNICAÇÃO or in co-marketing actions, and that submit information in these vehicles;
Database: a structured collection of personal data, established in one or several locations, in electronic or physical media;
Controller: a natural or legal person, governed by public or private law, who is responsible for decisions concerning the processing of personal data;
Operator: a natural or legal person, governed by public or private law, who processes personal data on behalf of the controller;
Officer: person appointed by the controller and operator to act as a communication channel between the controller, the data subjects and the National Data Protection Authority (ANPD);
Treatment agents: the controller and the operator;
Processing: any operation performed with personal data, such as those related to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation or control of the information, modification, communication, transfer, diffusion or extraction;
Co-marketing: is shared marketing, where, basically, two companies that have the same audience, or acting together, agency and client, target aligning their interests and efforts to create, together, an impact that they could not have alone. They can be given through posts, infographics, ebooks, or other joint modalities;
Form: designates any form in which the user must provide personal identification data or requested information;
Content: are the texts, images, illustrations, photographs, trademarks, videos and other content produced and made available by AGÊNCIA VISION COMUNICAÇÃO on the website or in one of our solutions and applications for smartphone and / or tablets, which constitute intellectual property of AGÊNCIA VISION COMUNICAÇÃO or third parties with whom AGÊNCIA VISION COMUNICAÇÃO maintains legal relationship;
I – Privacy and Security:
1.1. Nós da AGÊNCIA VISION COMUNICAÇÃO nos comprometemos a resguardar a sua privacidade. Trabalhamos com transparência no tratamento de dados e respeito aos usuários de nosso ecossistema e por isso assumimos o compromisso de privacidade e segurança de seus dados durante todo o processo de navegação pelo website e uso de nossas soluções e aplicativos para smartphone e/ou tablets. Estamos em sintonia e respeitamos os princípios e valores instituídos pelo Marco Civil da Internet (Lei nº 12.965, de 23 de abril de 2014), que estabelece princípios, garantias, direitos e deveres para o uso da internet no Brasil, e pela Lei Geral de Proteção de Dados Pessoais (LGPD) (Lei nº 13.709, de 14 de agosto de 2018).
1.1 We at AGÊNCIA VISION COMUNICAÇÃO are committed to safeguarding your privacy. We work with transparency in data processing and respect for users of our ecosystem and therefore we are committed to privacy and security of your data during the entire process of browsing the website and use of our solutions and applications for smartphone and / or tablets. We are in tune with and respect the principles and values instituted by the Marco Civil da Internet (Law No. 12,965 of April 23, 2014), which establishes principles, guarantees, rights and duties for the use of the internet in Brazil, and by the General Law of Personal Data Protection (LGPD) (Law No. 13,709 of August 14, 2018).
1.2 The registration data of users eventually collected are for the internal use of AGENCIA VISION COMUNICAÇÃO and are not sold, exchanged or disclosed to third parties, except in actions of co-marketing, sharing leads with another company, or when this information is necessary for any billing process (cards and means of payment), or for participation in internal promotions of AGENCIA VISION COMUNICAÇÃO, requested in previous registrations made by the customers themselves. We emphasize that we may send links via e-mail and/or SMS to achieve the objectives of our activities.
1.2.1 In this sense, pursuant to paragraph 1.2 above, we at AGÊNCIA VISION COMUNICAÇÃO do not impose any abusive or illegal rule or condition of authorization for sharing user data with other entities, especially financial entities, or with entities that maintain positive and negative lists of consumers, without giving the User the option to disagree with that sharing, by not hiring the payment service. By choosing the payment method through credit or debit cards, the User shall accept its conditions, being expressly aware and giving full authorization to share the minimum data necessary for the financial operationalization, indispensable information for the execution of the contracted service (credit/debit card).
1.5. Our policy may also be updated. It is recommended that the user periodically visit this page to be aware of changes made. If Agência Vision Comunicação needs to use information for purposes other than those defined in this Policy, users will be asked for a new authorization.
II – Your Data – Form and Means of Obtaining:
Concerned with providing quality content and a good experience to the users of its website and its customers, AGÊNCIA VISION COMUNICAÇÃO collects various data. All data security measures are always adopted in order to safeguard the privacy of its users.
AGÊNCIA VISION COMUNICAÇÃO obtains data from users when voluntarily entered or submitted by the holder when using our digital media, which includes, but is not limited to, accessing and browsing the agency’s website, or our landing pages, or its current or future social networks, including when voluntarily providing answers to questionnaires of personas and buying journeys (in this case without identifying the user).
We collect three (3) types of personal information and data:
(i) those voluntarily provided by users (data owner): Personally identifiable information is that provided by users from filling out forms to access free content or from interactions via email. This information, such as name, telephone number, company linked, professional segment, position and hierarchical level, is stored in the outsourced platform RD Station, which, in turn, maintains high standards of security and privacy of stored data. It is primarily through it that we communicate with our customers and leads, through segmented content tracks, sending newsletters and marketing automation. In the case of form filling through social media buttons – Facebook, LinkedIn, Twitter, Instagram -, we will collect all data provided by these networks to AGÊNCIA VISION COMUNICAÇÃO.
(iii) those obtained from other lawful sources: Information and data obtained from other sources are those contained on a limited basis in public databases, those shared by social media, or those provided by marketing partners or other external sources. This includes data such as location – city, state, and country – name, e-mail address, birthday, marketing leads, and results of interaction with sponsored links. This data is filtered and added to our information database in the RD Station platform.
Specifically, the information and personal data that AGÊNCIA VISION COMUNICAÇÃO collects from you, the user, includes, but is not limited to:
AGÊNCIA VISION COMUNICAÇÃO is not responsible for the veracity, or lack thereof, in the information provided by you or for its outdating, when it is your responsibility to provide them accurately or update them.
The list above lists some of the data obtained.
Personal data and information are stored in the RD Station platform
III – Your Data and Activity Record – USO:
Who is responsible for processing your data? The companies listed below (“Companies”) are responsible for the processing of your data and have indicated their respective e-mails for contact and any questions or needs regarding data protection:
Your personal data and information will be primarily for marketing and sales actions. The information and personal data will integrate the database of AGÊNCIA VISION COMUNICAÇÃO, and its use, access and sharing, when necessary, will be made within the limits and purposes of the activities of AGÊNCIA VISION COMUNICAÇÃO.
The personal data and information controlled by AGÊNCIA VISION COMUNICAÇÃO may be used for the following purposes:
We may also evaluate statistics, conduct studies, research and surveys related to user behavior when using the services of AGÊNCIA VISION COMUNICAÇÃO, performing such operations always in an anonymous manner.
We may use and disclose the information collected in other ways, with your prior consent or for the fulfillment of legal or regulatory obligation by AGÊNCIA VISION COMUNICAÇÃO, among other cases established in art. 7, of LGPD.
AGÊNCIA VISION COMUNICAÇÃO may also use and disclose the information and data collected passively, for any other purpose, unless there is an express prohibition of legal authority (ANPD) or expressly prohibited by applicable law. In this sense, AGÊNCIA VISION COMUNICAÇÃO may use and disclose any information, except personal data, not formatted as personal identification, for any purpose. In case there is, in the processing of data and information, a combination of information not formatted as personal information with personal data (e.g. combining your name with your geographical location), the combined information will be treated as personal data, and therefore not disclosed.
The list above lists the uses that we might make of the collected data.
The legal basis for the treatment of data is the execution of the contract for the provision of services, as well as the user’s consent and the legitimate interest of the Companies, where applicable, being possible the exclusion of the treatment at the request of the user, at any time, without prejudice to the execution of the contract.
If AGENCIA VISION COMMUNICATION provides space for comments and / or chat tool between its users or any other functionality that allows the contribution of content by users, it is certain that the data, information, opinions and content that may be provided in these tools are the sole responsibility of those who provided them, without any liability to AGENCIA VISION COMMUNICATION for the use of such information between users, subsisting, always, the liberality of AGENCIA VISION COMMUNICATION to remove any content, ex officio, that it deems to be contrary to its standards of conduct, offensive, vulgar, or contrary to good customs and ethics.
The AGÊNCIA VISION COMUNICAÇÃO team may, occasionally, contact users, by telephone, e-mail, WhatsApp, Telegram or other instant messaging applications, to present products and services or conduct research.
The user can request the cancellation of the treatment of his collected data at any time, which will immediately prevent the sending of new promotional e-mails, as well as eliminate from our contacts and database any use of the same, always within the terms and limits of the Law.
IV – Your Data – ACCESS AND STORAGE:
Internally, the information and personal data will only be accessed by professionals duly authorized by AGÊNCIA VISION COMUNICAÇÃO, respecting the principles of proportionality, necessity and relevance to the objectives of the activities of AGÊNCIA VISION COMUNICAÇÃO, in addition to the commitment to confidentiality and preservation of privacy under the terms of this Policy.
We only share your data in two situations: in cases of legal obligation; and in comarketing actions, when your information is provided when accessing materials created in partnerships between AGÊNCIA VISION COMUNICAÇÃO and another company, explicitly identified. Your data will not be publicly disclosed.
Your personal data and information obtained may be stored in AGÊNCIA VISION COMUNICAÇÃO’s own server or a third party contracted for this purpose, whether they are allocated in Brazil or abroad, and may also be stored by means of cloud computing technology and/or others that may arise in the future, always seeking the improvement and refinement of the activities of the agency.
Currently, we keep the information and your personal data on a platform called RD Station, external to the servers of AGÊNCIA VISION COMUNICAÇÃO. However, only authorized employees of RD Station and AGÊNCIA VISION may access them. The storage takes place in a secure and controlled environment for a minimum period of 6 (six) months, in accordance with art. 15 of the Marco Civil da Internet (Law 12.965/2014), subject to the state of the art available.
IMPORTANT: Considering that no security system is infallible, AGÊNCIA VISION COMUNICAÇÃO disclaims any liability for any damages and/or losses arising from failures, viruses or invasions of the database of AGÊNCIA VISION COMUNICAÇÃO, except in cases where it is at fault.
Likewise, it is the user’s sole responsibility to keep his equipment protected against intrusions and viruses (malware, worms and others)
Your personal data and collected information is stored in a secure location, which may include its allocation through cloud computing technology and/or others that may arise in the future
You have the right to request the display, rectification or ratification of personal data concerning you, through the service channels of AGENCIA VISION COMUNICATION. By the same channels you may request the deletion of all your personal data collected and recorded by AGENCIA VISION COMUNICATION, after the minimum legal period.
AGÊNCIA VISION COMUNICAÇÃO will exclude the user’s data by internal decisions (database review, end of legal term, among other hypotheses).
Deletion of information and personal data can also come from the users’/users’/holders’ wishes. In this case, in all our e-mails there is an ‘unsubscribe‘ link available in the last line. By clicking on this link, you will be excluded from our mailing lists.
But in case the user/holder fills in any of our forms again, his/her e-mail will return to our list and, if desired, it will be necessary to unsubscribe again
Alternatively, to change or delete your data from our database, please send an e-mail to firstname.lastname@example.org
V – Seus Dados – PRAZO
AGÊNCIA VISION COMUNICAÇÃO keeps the personal data during the period that is understood to be necessary and sufficient for the purposes that motivated the collection and treatment, varying the period of time of data storage according to the purpose for which the information is treated and in accordance with the legal regulations that require their retention, after which they will be eliminated, through appropriate technical and functional guarantees, as documented in each of the relevant processes.
AGÊNCIA VISION COMUNICAÇÃO may, for audit purposes and preservation of rights, remain with its historical data record for a maximum period of 5 (five) years counted (i) from the collection or (ii) from the request for exclusion, and may be extended for a longer period in cases that the Law in force at the time or regulatory standard so establish or for preservation of rights, possessing the AGENCIA VISION COMUNICAÇÃO the faculty to exclude them definitely according to its convenience in a shorter period.
The data preserved in the condition indicated above will have its use limited to the hypotheses of safeguarding AGÊNCIA VISION COMUNICAÇÃO of rights and obligations related to the service provided or the modes of use and verification of the database, as well as to collaborate and/or comply with a court order or request by administrative authority.
VI – Right of Access and Exercise of Rights
Data subjects may exercise the rights granted under the applicable data protection legislation at the following e-mail address: email@example.com, and may also lodge a complaint with the ANPD.
– AGÊNCIA VISION COMUNICAÇÃO’s internal managers and Data Protection Officer: Luiz Lopes – firstname.lastname@example.org
VII. Use by children / minors
The use of tools and campaigns AGÊNCIA VISION COMUNICAÇÃO is intended for individuals aged eighteen (18) years or older. Thus, individuals under eighteen (18) years should not handle, frequent, navigate or take advantage of the features of the website, and/or social networks AGÊNCIA VISION COMUNICAÇÃO.
We do not collect personally identifiable information from children and adolescents through our website and/or social networks, much less recommend or suggest that parents accept that children / minors use them, and their parents or guardians must expressly impose limits on this use.
VIII. FINAL PROVISIONS
The definitions and provisions of this Policy apply to words and expressions in the singular or plural.
We reserve the right to update this document at any time.
Check it often!
We will inform all users of any changes at least 5 days in advance.
If you continue to use the features of AGÊNCIA VISION COMUNICAÇÃO (website, social networks, etc) after the change, it means that you agree with what has been changed!
If third-party companies perform the processing of any data collected by AGÊNCIA VISION COMUNICAÇÃO, they must respect the conditions stipulated here and other rules and contracts and agreements signed with AGÊNCIA VISION COMUNICAÇÃO, obligatorily, being certain that you authorize your data to be treated also by these companies.
Date these Policies were last updated:
Version developed by Cruz & Creuz Advogados – December 2019
Revised and Approved Version by AGÊNCIA VISION COMMUNICATION – December 2019