PLEASE READ THIS DOCUMENT CAREFULLY.
Whereas:
(i) V3 ELECTRONIC PUBLISHING LTD., a Limited Liability Business Corporation, located at Miguel Sutil Street, 370, Vila Cordeiro, ZIP: 04.583-050, City of São Paulo, State of São Paulo, registered under CNPJ/MF No. 05.147.282/0001-78, and VISION COMUNICAÇÃO E MARKETING LTDA., a Limited Liability Business Corporation, located at Miguel Sutil Street, 370, Vila Cordeiro, ZIP: 04.583-050, City of São Paulo, State of São Paulo, registered under CNPJ/MF No. 03.702.250/0001-61, collectively or separately referred to as “VISION” or “VISION COMUNICAÇÃO AGENCY”; is a private legal entity, duly established as a limited liability company, engaged in the communication sector, has developed a commercial business methodology through the VISION brand, in a multidisciplinary and integrated manner in 360-degree communication, and has been operating in the market for 17 years;
(ii) this document aims 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 VISION COMUNICAÇÃO AGENCY, including voluntary registration through social networks, web pages or other means of contact between VISION COMUNICAÇÃO AGENCY and the holder of the personal data, always in accordance with the laws in force in Brazil;
(iii) by using the services and computer systems of VISION COMUNICAÇÃO AGENCY, you accept this Privacy Policy and give your free and express agreement to the terms stipulated herein.
(iv) for security reasons, we expressly inform – and you hereby agree and are notified that: (a) we never call you requesting access to areas of the VISION COMUNICAÇÃO AGENCY website or for security procedures or registration updates, asking for data typing or passwords or possible security codes, tokens or other related measures; (b) you are expressly advised to only access our official addresses and sites of VISION COMUNICAÇÃO AGENCY, by typing these addresses, or clicking on officially suggested links by search engines (organically or through sponsored links); (c) we will never request your confidential and secret access data by phone, and thus never give out your passwords or security device codes (tokens or IDs from banks).
(v) changes to our Privacy Policy will be duly informed in this space;
User’s express consent: Under art. 7th, IX, of the Internet Civil Framework (Law No. 12.965, dated April 23, 2014), and art. 5th, XII, and art. 7th, I, of the General Data Protection Law (LGPD) (Law No. 13.709, dated August 14, 2018), the user grants express consent to VISION COMUNICAÇÃO AGENCY for the collection, use, storage, and processing of their personal data, under the terms specified and detailed below. The user is aware, and agrees, accepts, and gives their express consent for the personal data provided above to be used for sending informative, analytical, and advertising content from VISION COMUNICAÇÃO AGENCY about products, services, and general subjects, under the terms of the LGPD.
To register, access, and use the services and computer systems of VISION COMUNICAÇÃO AGENCY, you must be at least 18 (eighteen) years old or be assisted by a legal guardian to register. Meeting these requirements, you must accept and consent to this Policy, agreeing to all the terms and conditions established herein.
For the purposes of this document, the following definitions and descriptions should be considered for a better understanding:
Cloud Computing: a technology of service virtualization built from the interconnection of more than one server through a common information network (e.g., the internet), aimed at reducing costs and increasing the availability of the services provided;
IP: abbreviation for Internet Protocol. It is an alphanumeric set that identifies users’ devices on the internet;
Logs: Records of activities of users carried out on the website and on social networks and systems of VISION COMUNICAÇÃO AGENCY;
DATA SUBJECT: a natural person to whom the personal data being processed refers;
Personal Data: information related to an identified or identifiable natural person;
User: are the natural persons who transit and navigate through the website of VISION COMUNICAÇÃO AGENCY and who make use of our solutions and applications for smartphones and/or tablets, or who register or enter data in forms of VISION COMUNICAÇÃO AGENCY or in co-marketing actions, and who submit information in these media;
Database: structured set of personal data, established in one or several locations, in electronic or physical support;
Controller: a natural or legal person, of public or private law, to whom decisions regarding the processing of personal data are competent;
Operator: a natural or legal person, of public or private law, that processes personal data on behalf of the controller;
Officer: person designated by the controller and operator to act as a communication channel between the controller, the data subjects, and the National Data Protection Authority (ANPD);
Data Processing Agents: the controller and the operator;
Processing: any operation carried out with personal data, such as those referring to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, elimination, evaluation, or control of information, modification, communication, transfer, diffusion, or extraction;
Co-marketing: is a shared marketing, where, basically, two companies that have the same audience, or acting together, agency and client, with aligned targets, join their interests and efforts to create, together, an impact that they could not achieve alone. It can occur 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, brands, videos, and other content produced and made available by VISION COMUNICAÇÃO AGENCY on the website or in one of our solutions and applications for smartphones and/or tablets, which constitute the intellectual property of VISION COMUNICAÇÃO AGENCY or third parties with whom VISION COMUNICAÇÃO AGENCY maintains a legal relationship;
Privacy Policy: is the policy of VISION COMUNICAÇÃO AGENCY that explains how the collection, treatment, storage, and destination of the data collected will take place under the terms of the legislation and regulation in force, with which the user has already expressly agreed.
I – Privacy and Security:
1.1. We at VISION COMUNICAÇÃO AGENCY are committed to safeguarding your privacy. We work with transparency in data processing and respect the users of our ecosystem and, therefore, we assume the commitment to privacy and security of your data throughout the process of browsing the website and using our solutions and applications for smartphones and/or tablets. We are in tune and respect the principles and values established by the Internet Civil Framework (Law No. 12.965, dated April 23, 2014), which establishes principles, guarantees, rights, and duties for the use of the internet in Brazil, and by the General Data Protection Law (LGPD) (Law No. 13.709, dated August 14, 2018).
1.2. The registration data of users eventually collected have the purpose of internal use by VISION COMUNICAÇÃO AGENCY and are not sold, exchanged, or disclosed to third parties, except in co-marketing actions, sharing leads with another company, or when this information is necessary for eventual billing process (cards and payment methods), or for participation in internal promotions of VISION COMUNICAÇÃO AGENCY, requested in previous registrations made by the customers themselves. We highlight that we can send links through emails and/or SMS to achieve the objectives of our activities.
1.2.1. In this sense, in the terms of paragraph 1.2 above, we at VISION COMUNICAÇÃO AGENCY do not impose any abusive or illegal rule or condition of authorization for sharing users’ data with other entities, especially financial ones, or with entities maintaining positive and negative consumer records, without giving the User the option to disagree with that sharing, through the non-contracting of the payment service. Opting for payment through credit or debit cards, the user must accept its conditions, having express knowledge and giving full authorization for the minimum sharing of the data necessary for the financial operation, information essential to the execution of the contracted service (credit / debit card).
1.3. If you do not agree with our Privacy Policy, please do not use our services that require the assignment of, or that request your information.
1.4. If you agreed with our Privacy Policy, you are aware that you consented to the processing of personal data, especially for: (i) structuring a profile for lead generation by types of markets in which the data subject is inserted; (ii) advertising services, events, courses, trainings, and useful information from VISION COMUNICAÇÃO AGENCY and partners; (iii) sending materials and information from VISION COMUNICAÇÃO AGENCY and partners through email automation, aiming to qualify contacts for sales of services; (iv) if the data subject is interested in an event or service, VISION COMUNICAÇÃO AGENCY uses the data with the aim of speeding up the procedures for registration and contracting; (v) sharing their data among the members of VISION COMUNICAÇÃO AGENCY, for the analysis of registration and personal relationship history with the agency.
1.5. Our policy may also be updated. It is recommended that users periodically visit this page to be aware of any changes. If VISION COMUNICAÇÃO Agency needs to use information for purposes not defined in this Policy, new authorization will be requested from users.
II – Your Data – Method and Means of Collection:
Concerned with providing quality content and a good experience to the users of its site and its clients, VISION COMUNICAÇÃO AGENCY collects various data. All data security measures are adopted to safeguard the privacy of its users.
VISION COMUNICAÇÃO AGENCY obtains user data when it is entered or submitted voluntarily by the data subject when using our digital media, which includes, but is not limited to, accessing and navigating the agency’s website, our landing pages, or from our current or future social networks, including when voluntarily providing answers to personas and buyer journey questionnaires (in this case without user identification).
We collect three (3) types of personal information and data:
(i) those provided voluntarily by users (data subjects): Personal identification information is provided by users through filling out forms to access free content or through email interactions. This information, such as name, phone number, affiliated company, professional sector, job title, and hierarchical level, is stored on the third-party platform RD Station, which, in turn, maintains a high standard of data security and privacy. It is primarily through it that we communicate with our clients and leads, through segmented content paths, newsletter dispatches, and marketing automation. In the case of filling out forms through social media buttons – Facebook, LinkedIn, Twitter, Instagram – we collect all the data made available by these networks to VISION COMUNICAÇÃO AGENCY.
(ii) those collected automatically from pages or visits: The information and data collected automatically are those gathered when the user visits our pages and social networks, mainly used to maintain the security and operation of our website, as well as specific media actions. Among the methods and means of data and information collection, automatically collected, we use cookies: ‘Cookies’ are data files that are placed on your device when you visit a website. This insertion is done by the Google Analytics software, aiming to obtain information such as IP address, geographical location, type of browser, pages visited, and the time spent on each of them, among other navigation data that allow the construction of reports and strategies for improving user experience. Some ‘cookies’, called ‘essential cookies’, are also necessary for technical reasons, so that the website functions as well as possible. The collection of non-personal data (e.g., type of Internet browser and operating system used, name of the domain from which you came, number of visits, average time spent on the site, pages viewed) happens automatically, that is, without registration. We may use these data and share them with our global affiliates to monitor the attractiveness of our sites and improve their performance or content.
(iii) those obtained from other lawful sources: The information and data obtained from other sources are those contained in a limited manner in public databases, shared by social media, or provided by marketing partners or other external sources. Among them are data such as location – city, state, and country –, name, email, birthday, co-marketing leads, and results of interaction with sponsored links. These data are filtered and added to our information bank on the RD Station platform.
Other technologies may be used to obtain your navigation data, which include, but are not limited to, cookies, such as web beacons and JavaScript resources. Such technologies will always respect the terms of this Policy and your options regarding their collection and storage.
Specifically, the personal information and data that VISION COMUNICAÇÃO AGENCY collects from you, the user, include, but are not limited to:
VISION COMUNICAÇÃO AGENCY is not responsible for the truthfulness, or lack thereof, in the information provided by you or for your data being out-of-date, when it is your responsibility to provide them accurately or to update them.
We obtain your data and information as you provide it, either directly or indirectly, in accessing and using the networks of VISION COMUNICAÇÃO AGENCY, and through the use of cookies.
The list above outlines some of the data obtained.
Personal data and information are stored on the RD Station platform.
III – Your Data and Activity Log – USE:
Who is responsible for processing user data? The companies listed below (“Companies”) are responsible for processing your data, with the respective emails provided for contact and any questions or needs regarding data protection:
V3 ELECTRONIC PUBLISHING LTD., a Limited Liability Business Corporation, located at Miguel Sutil Street, 370, Vila Cordeiro, ZIP: 04.583-050, City of São Paulo, State of São Paulo, registered under CNPJ/MF No. 05.147.282/0001-78 – email: [email protected]
VISION COMUNICAÇÃO E MARKETING LTDA., a Limited Liability Business Corporation, located at Miguel Sutil Street, 370, Vila Cordeiro, ZIP: 04.583-050, City of São Paulo, State of São Paulo, registered under CNPJ/MF No. 03.702.250/0001-61 – email: [email protected]
The above Companies will request, before processing the personal data of their clients, the express consent to this Privacy Policy, whenever applicable, and for any other situation that requires prior authorization.
Your personal data and information will primarily be used for marketing and sales actions. The personal data and information will be integrated into the database of VISION COMUNICAÇÃO AGENCY, and their use, access, and sharing, when necessary, will be conducted within the limits and purposes of the activities of VISION COMUNICAÇÃO AGENCY.
Specifically, the personal data and information controlled by VISION COMUNICAÇÃO AGENCY 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 VISION COMUNICAÇÃO AGENCY, always anonymizing such operations.
We may use and disclose the information collected in other ways, with your prior consent or to fulfill a legal or regulatory obligation by VISION COMUNICAÇÃO AGENCY, among other scenarios established in Article 7 of the LGPD.
VISION COMUNICAÇÃO AGENCY may also use and disclose passively collected information and data for any other purpose unless there is an express prohibition by legal authority (ANPD) or explicit prohibition by applicable legislation. In this sense, VISION COMUNICAÇÃO AGENCY may use and disclose any information, except personal data not formatted as personal identification, for any purpose. If there is, in the processing of data and information, a combination of non-formatted 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 above listing relates to the uses we may make of the collected data.
The legal basis for data processing is the execution of the service contract, as well as user consent and the legitimate interest of the Companies, whenever applicable, allowing for the exclusion of processing at the user’s request, at any time, without detriment to the execution of the contract.
Should VISION COMUNICAÇÃO AGENCY provide a space for comments and/or a chat tool among 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 the provider, with no responsibility for VISION COMUNICAÇÃO AGENCY for the use of such information among users, always maintaining the liberty of VISION COMUNICAÇÃO AGENCY to remove any content, officially, that it deems contrary to its standards of conduct, offensive, vulgar, or contrary to good morals and ethics.
The team of VISION COMUNICAÇÃO AGENCY may occasionally contact users by phone, email, WhatsApp, Telegram, or other instant messaging applications, to present products and services or conduct surveys.
The user may request the cancellation of the processing of their collected data at any time, which will immediately prevent the sending of new promotional emails and will remove any use of them from our contacts and database, 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 VISION COMUNICAÇÃO AGENCY, respecting the principles of proportionality, necessity, and relevance to the objectives of VISION COMUNICAÇÃO AGENCY’s activities, 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 co-marketing actions, when your information is provided when accessing materials created in partnerships between VISION COMUNICAÇÃO AGENCY and another company, explicitly identified. Your data will not be disclosed publicly.
Your personal data and information obtained may be stored on a server owned by VISION COMUNICAÇÃO AGENCY or by a third party contracted for this purpose, whether located 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 aiming at the improvement and enhancement of the agency’s activities.
Currently, we keep the information and your personal data on a platform called RD Station, external to the servers of VISION COMUNICAÇÃO AGENCY. However, only authorized employees of RD Station and VISION COMUNICAÇÃO AGENCY can access them. Storage takes place in a secure and controlled environment for a minimum period of 6 (six) months, under the terms of Article 15 of the Civil Rights Framework for the Internet (Law 12.965/2014), considering the state of the available technology.
IMPORTANT: Considering that no security system is infallible, VISION COMUNICAÇÃO AGENCY disclaims any responsibility for possible damages and/or losses resulting from failures, viruses, or invasions of VISION COMUNICAÇÃO AGENCY’s database, except in cases where there is intentional misconduct or fault.
Similarly, it is the exclusive responsibility of the user to keep their equipment protected against invasions and viruses (malware, worms, and others).
Your personal data and information collected are stored in a secure location, which may include their allocation by means of cloud computing technology and/or others that may arise in the future.
You have the right to request the display, rectification, or ratification of the personal data concerning you, through the channels of VISION COMUNICAÇÃO AGENCY. Through the same channels, you may request the deletion of all your personal data collected and recorded by VISION COMUNICAÇÃO AGENCY, after the minimum legal period.
VISION COMUNICAÇÃO AGENCY will delete user data based on internal decisions (database review, end of legal term, among other scenarios).
The deletion of information and personal data may also arise from the desire of the users / data subjects. In this case, in all our emails, there is an ‘unsubscribe’ link, available in the last line. By clicking this link, you will be removed from our mailing lists.
However, if the user/data subject fills out any of our forms again, their email will return to our list, and if desired, it will be necessary to perform a new ‘unsubscribe’.
Alternatively, to change or delete your data from our database, send an email to [email protected].
V – Your Data – DURATION
AGÊNCIA VISION COMUNICAÇÃO retains personal data for the period deemed necessary and sufficient for the purposes that motivated its collection and processing. The data retention period varies depending on the purpose for which the information is treated and in accordance with legal norms that mandate its retention. After this period, the data will be deleted, using appropriate technical and functional guarantees, as documented in each of the relevant processes.
In this sense, the information of all users will remain in our database for the time necessary for the purposes described in this Privacy Policy. Exceptions will be made for legal requirements/judicial orders. From the moment we have no planned marketing actions or business intentions related to your data, we will delete it.
AGÊNCIA VISION COMUNICAÇÃO may, for audit purposes and preservation of rights, retain your data registration history for a maximum period of 5 (five) years counted (i) from the collection or (ii) from the request for deletion. This period may be extended in cases where current law or regulatory norm dictates or for the preservation of rights, with AGÊNCIA VISION COMUNICAÇÃO having the discretion to permanently delete them at a sooner date if deemed appropriate.
The preserved data under the conditions mentioned above will have their use limited to cases necessary to safeguard AGÊNCIA VISION COMUNICAÇÃO from rights and obligations related to the service provided or ways of using and proving the database, as well as to collaborate and/or comply with judicial orders or requests by administrative authorities.
VI – Right of Access and Exercise of Rights
Data subjects can exercise their rights under applicable data protection legislation via the following email address: [email protected], and may also lodge a complaint with the ANPD.
Internal representatives of VISION COMUNICAÇÃO AGENCY and the Data Protection Officer: Luiz Lopes – [email protected]
VII – Use by Children / Minors
The use of AGÊNCIA VISION COMUNICAÇÃO tools and campaigns is directed at individuals aged eighteen (18) years and older. Thus, individuals under eighteen (18) years should not handle, attend, browse, or use the functionalities of the website and/or social networks of AGÊNCIA VISION COMUNICAÇÃO.
We do not collect personally identifiable information from children and adolescents through our website and/or social networks, nor do we recommend or suggest that parents allow their children/minors to use them. Parents or guardians should expressly set limits on this usage.
VIII – FINAL PROVISIONS
The definitions and provisions of this Policy apply to words and expressions in both the singular and plural.
This Privacy Policy will be interpreted according to Brazilian legislation, in the Portuguese language, with the competent court of its domicile to settle any disputes or controversies involving this document, except for specific personal, territorial, or functional jurisdiction exceptions provided by applicable law.
The content of this Privacy Policy may be updated or modified at any time, as deemed necessary or convenient by AGÊNCIA VISION COMUNICAÇÃO, such as for legal compliance or adherence to legal or normative provisions with equivalent legal force.
We reserve the right to update this document at any time.
Please consult it frequently!
We will inform all users of any changes at least 5 days in advance.
If you continue to use the functionalities of AGÊNCIA VISION COMUNICAÇÃO (website, social networks, etc.) after the change, it means you agree with the alterations!
Should third-party companies process any data collected by AGÊNCIA VISION COMUNICAÇÃO, they must respect the conditions stipulated here and other norms and contracts and agreements entered into with AGÊNCIA VISION COMUNICAÇÃO, being certain that you authorize your data to be processed also by these companies.
If any provision of this Privacy Policy is considered illegal or illegitimate by an authority, the remaining conditions will remain in full force and effect.
In case of doubts about our Privacy Policy, please send an email to [email protected].
Last update of these Policies: December 2019 Developed by Cruz & Creuz Advogados – December 2019 Revised and Approved by VISION COMUNICAÇÃO AGENCY – December 2019
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