Privacy and Cookie Policy wewantgreen.co.uk

This Site collects some Personal Data from Users.

This document contains a section dedicated to California consumers and their privacy rights.

This document contains a section dedicated to Brazilian Users and their privacy rights.

This document can be printed for consultation using the print command in your browser settings

Owner and Data Controller

We Wan Green

Church - Sistelo

4970-645 Arcos de Valdevez.

Cx116

Owner's contact e-mail: geral@wewantgreen.pt

Types of data collected

Among the types of Personal Data that this Site collects, by itself or through third parties, there are: Tracker; Usage Data; first name; last name; e-mail; telephone number; All Data that you share while using the service; answers to questions; clicks; key events; motion sensor events; mouse movements; scroll position; touch events; various types of Data.

Full details of each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanatory texts displayed prior to the collection of Data.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Site.

Unless otherwise specified, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its Services. In cases where this Site specifically states that some Data is not mandatory, Users are free to stop communicating this Data without any consequences for the availability or functioning of the Service.

Users who have doubts about which Personal Data is mandatory are invited to contact the Owner.

Any use of cookies - or other tracking tools - by this Website or by the owners of third party services used by this Website will be for the purpose of providing the Services requested by the User, in addition to the other purposes described in this document and in the Cookies Policy, if available.

Users are responsible for any third party Personal Data obtained, published or shared through this Service (this Site) and confirm that they have the third party's authorisation to provide the Data to the Owner.

How and where the data is processed

Processing method

The Owner will take appropriate security measures to prevent unauthorised access, disclosure, alteration or destruction of the Data.

The Data is processed using computers and/or IT-enabled tools, following organisational procedures and means strictly related to the purposes indicated. In addition to the Owner, in some cases the Data may be accessed by certain types of persons in charge, involved with the operation of this Service (this Site) (administration, sales, marketing, legal administration of the system) or external persons (such as third-party providers of technical services, postmen, hosting providers, IT companies, communication agencies) appointed, where necessary, as Data Processors by the Owner. The updated list of these parties can be requested from the Owner at any time.

Legal basis for processing

The Owner may process the Personal Data relating to the User if one of the following hypotheses applies:

the Users have given their consent for one or more specific purposes; Note: Under some legislations the Owner may be allowed to process the Personal Data UNTIL the User objects to this ("opt-out"), without having to rely on consent or any other legal bases thereafter. This, however, does not apply where the processing of Personal Data is subject to European data protection legislation;

the provision of the Data is necessary for the fulfilment of a contract with the User and/or any pre-contractual obligations of the User;

the processing is necessary for the fulfilment of a legal obligation to which the Owner is subject;

the processing is related to a task that is carried out in the public interest or in the exercise of an official authorisation in which the Owner is vested;

the 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 willingly co-operate to clarify which legal basis applies to the processing, and in particular if the provision of Data is a mandatory requirement by law or contract, or a necessary requirement to enter into a contract.

Place

The data is processed at the headquarters of the Owners, and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve the transfer of User Data to a country other than their own. To find out more about where such transferred Data is processed, Users can check the section containing details on the processing of Personal Data.

Users also have the right to be informed about the legal basis of Data transfers to countries outside the European Union or to any international organisations governed by public international law or formed by two or more countries, such as the UN, and about the security measures taken by the Owner to protect their Data.

If any such transfers occur, Users can find out more by checking the relevant sections of this document or by asking the Owner using the information provided in the contact section.

Conservation period

Personal Data will be processed and stored for as long as necessary for the purposes for which it is collected.

So:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be kept until such contract has been fully performed.

Personal Data collected for purposes related to the legitimate interests of the Owner will be kept for as long as necessary to fulfil such purposes. Users may obtain specific information on 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 keep Personal Data for a longer period of time whenever the User has given his/her authorisation for such processing, as long as such authorisation has not been withdrawn. In addition, the Owner may be obliged to keep Personal Data for a longer period of time on all occasions when it is obliged to do so for the fulfilment of a legal obligation or in compliance with a mandate from an authority.

As soon as the retention period expires, the Personal Data will be deleted. This means that the right to access, the right to erasure, the right to correction and the right to data portability cannot be enforced after the expiry of the retention period.

The purposes of processing

User Data is collected to enable the Owner to provide its Service, fulfil 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: Statistics, Platform and hosting services, Registration and authentication, Contacting the User, Access to third-party service accounts, Interaction with live chat platforms, Anti-spam protection, Tag management, Traffic optimisation and distribution, Payment processing, Viewing content from external platforms and Social features.

For specific information on the Personal Data used for each purpose, the User may consult 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:

Access to third-party service accounts

This type of service allows this Site to access your Account Data with a third party service and carry out actions with it.
These services are not activated automatically, but require explicit authorisation from the User.

Stripe account access (Stripe Technology Europe Ltd)

This service allows this Site to connect with the User's Stripe account, provided by Stripe, Inc.

Personal data processed: e-mail; first name; last name.

Place of processing: Ireland - Privacy Policy.

Category of personal information collected under the CCPA: identifiers.

This processing constitutes a sale, based on the CCPA definition. In addition to the information in this clause, the User can find information on how to opt out of the sale in the section describing California consumer rights.

Contact the User

Mailing list or newsletter (this Site)

By registering for the mailing list or newsletter, the User's e-mail address will be added to the contact list of those who may receive e-mail messages containing information of a commercial or promotional nature about this Site. Your e-mail address may also be added to this list as a result of subscribing to this service (this Site) or after making a purchase.

Personal data processed: e-mail; first name; last name.

Category of personal information collected under the CCPA: identifiers.

Contact telephone number (this site)

Users who have provided their telephone number may be contacted for commercial or promotional purposes related to this Website, as well as to fulfil support requests.

Personal Data processed: telephone number.

Category of personal information collected under the CCPA: identifiers.

Contact form (this Site)

By filling in the contact form with their Data, Users authorise this Website to use these details to respond to requests for information, quotations or any other type of request as indicated by the title of the form.

Personal data processed: e-mail; first name; last name.

Category of personal information collected under the CCPA: identifiers.

Tag management

This type of service helps the Owner to manage the tags or scripts required by this Site in a centralised way. As a result, User Data flows through these services and there is a possibility of retaining this Data.

Google Tag Manager (Google Ireland Limited)

Google Tag Manager is a management service provided by Google Ireland Limited.

Personal Data processed: Usage data; Tracker.

Place of processing: Ireland - Privacy Policy.

Category of personal information collected under the CCPA: information on the Internet.

This processing constitutes a sale, based on the CCPA definition. In addition to the information in this clause, the User can find information on how to opt out of the sale in the section describing California consumer rights.

Traffic optimisation and distribution

These types of services allow this Site to distribute their content using servers located in different countries and to optimise their performance.
Which Personal Data will be processed depends on the characteristics and manner in which these services are implemented. Its function is to filter communications between this Site and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which content that may contain the User's personal information has been transferred.

Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimisation and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all traffic through this service (this Site), i.e. communication between this Site and the User's browser, while at the same time allowing analytical data from this Application to be collected.

Personal Data processed: Tracker; various types of Data as specified in the service's privacy policy.

Place of processing: USA - Privacy Policy.

Category of personal information collected under the CCPA: information on the Internet.

This processing constitutes a sale, based on the CCPA definition. In addition to the information in this clause, the User can find information on how to opt out of the sale in the section describing California consumer rights.

Anti-spam protection

These types of services analyse the traffic of this service (this Site), potentially containing Users' Personal Data, with the aim of filtering it out of the parts of the traffic, messages and content that are recognised as SPAM.

Google reCAPTCHA (Google Ireland Limited)

Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
The use of reCAPTCHA is subject to privacy policy and the terms of use from Google.

Personal Data processed: clicks; Usage Data; keystroke events; touch events; motion sensor events; mouse movements; scroll position; Tracker; answers to questions.

Place of processing: Ireland - Privacy Policy.

Category of personal information collected under the CCPA: information on the Internet; implicit information.

  • Platform and hosting services

These services are intended to host and run key components for this Site, thus enabling this application to be offered within a unified platform. Such platforms offer a wide range of tools to the Owner - such as analyses, User registration, comments, database management, e-commerce, payment processing - which results in the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, which makes it difficult to know where exactly Personal Data is stored.

WordPress.com (Aut O'Mattic A8C Ireland Ltd.)

WordPress.com is a platform offered by Aut O'Mattic A8C Ireland Ltd. that allows the Owner to build, run and host this Site.

Personal data processed: e-mail; first name; last name.

Place of processing: Ireland - Privacy Policy.

Category of personal information collected under the CCPA: identifiers.

Social characteristics

Invite and suggest friends (this Site)

This Site may use the Personal Data provided to allow Users to invite their friends - for example, via the address book, if access has been provided - and to suggest friends or connections within it.

Personal Data processed: various types of Data.

Category of personal information collected under the CCPA: information on the Internet.

Statistics

The services contained in this section enable the Owner to monitor and analyse web traffic and may be used to track User behaviour.

WordPress Stat (Aut O'Mattic A8C Ireland Ltd.)

WordPress is an analysis service provided by Aut O'Mattic A8C Ireland Ltd.

Personal Data processed: Usage data; Tracker.

Place of processing: Ireland - Privacy Policy.

Category of personal information collected under the CCPA: information on the Internet.

This processing constitutes a sale, based on the CCPA definition. In addition to the information in this clause, the User can find information on how to opt out of the sale in the section describing California consumer rights.

Google Analytics with anonymised IP (Google Ireland Limited)

Google Analytics is an Internet analysis service provided by Google Ireland Limited ("Google"). Google uses the data collected to track and analyse the use of this service (this Site) to prepare reports on activities and share them with other Google services.
Google can use the data collected to contextualise and personalise the ads on its own advertising network.
This Google Analytics integration anonymises your IP address. It works by shortening the IP addresses of Users within the Member States of the European Union or other signatory states to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be sent to a Google server and shortened within the USA.

Personal Data processed: Usage data; Tracker.

Place of processing: Ireland - Privacy Policy - Opt Out.

Category of personal information collected under the CCPA: information on the Internet.

This processing constitutes a sale, based on the CCPA definition. In addition to the information in this clause, the User can find information on how to opt out of the sale in the section describing California consumer rights.

Google Analytics (Google Ireland Limited)

Google Analytics is an Internet analysis service provided by Google Ireland Limited ("Google"). Google uses the data collected to track and analyse the use of this service (this Site) to prepare reports on activities and share them with other Google services.
Google can use the data collected to contextualise and personalise the ads on its own advertising network.

Personal Data processed: Usage data; Tracker.

Place of processing: Ireland - Privacy Policy - Opt Out.

Category of personal information collected under the CCPA: information on the Internet.

This processing constitutes a sale, based on the CCPA definition. In addition to the information in this clause, the User can find information on how to opt out of the sale in the section describing California consumer rights.

Interaction with live chat platforms

These types of services allow Users to interact with third-party live chat platforms, directly from the pages of this service (this Site), to contact and receive contact by the support of this service (this Site).
If one of these services is installed, it may collect Usage and Browsing Data on the pages where it is installed, even if Users do not actively use the service. In addition, live chat conversations may be recorded.

Facebook Messenger Customer Chat (Facebook Ireland Ltd)

Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook Ireland Ltd

Personal Data processed: Usage Data; Tracker; All Data you share while using the service.

Place of processing: Ireland - Privacy Policy.

Category of personal information collected under the CCPA: information on the Internet.

This processing constitutes a sale, based on the CCPA definition. In addition to the information in this clause, the User can find information on how to opt out of the sale in the section describing California consumer rights.

Payment processing

Unless otherwise specified, this Site will process any payments via credit card, bank transfer or other means through third party payment service providers. In general and unless otherwise specified, Users will be asked to provide their payment details and personal information to these third party payment service providers. This Site has no involvement in the collection and processing of such information: instead, you will only receive a notification from the respective payment service provider informing you whether the payment has been successfully completed.

Paypal (PayPal Inc.)

PayPal is a payment service provided by PayPal Inc., which allows Users to make payments online.

Personal Data processed: e-mail.

Place of processing: See PayPal's privacy policy - Privacy Policy.

Category of personal information collected under the CCPA: identifiers.

Registration and authentication

By registering or authenticating, Users allow this service (this Site) to identify them and give them access to dedicated services.
Depending on what is described below, registration and authentication services may be provided by third parties. In this case, this Site may access some Data stored by these third-party services for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, see the description of each service.

WordPress.com Single Sign On (Aut O'Mattic A8C Ireland Ltd.)

WordPress.com Single Sign On is a registration and authentication service provided by Aut O'Mattic A8C Ireland Ltd. and is connected to the WordPress.com network.

Personal Data processed: Tracker; various types of Data as specified in the service's privacy policy.

Place of processing: Ireland - Privacy Policy.

Category of personal information collected under the CCPA: information on the Internet.

This processing constitutes a sale, based on the CCPA definition. In addition to the information in this clause, the User can find information on how to opt out of the sale in the section describing California consumer rights.

Visualising content from external platforms

These types of services allow you to view and interact with content hosted on external platforms directly from the pages of this service (this Site) and interact with them.
This type of service may also collect web traffic data for the pages where the service is installed, even when Users are not using them.

Google Fonts (Google Ireland Limited)

Google Fonts is a typeface visualisation service provided by Google Ireland Limited that allows this Site to incorporate typeface content into its pages.

Personal Data processed: Usage Data; various types of Data as specified in the service's privacy policy.

Place of processing: Ireland - Privacy Policy.

Category of personal information collected under the CCPA: information on the Internet.

This processing constitutes a sale, based on the CCPA definition. In addition to the information in this clause, the User can find information on how to opt out of the sale in the section describing California consumer rights.

YouTube IFrame Player (Google Ireland Limited)

YouTube IFrame Player is a video content visualisation service provided by Google Ireland Limited that allows this Site to incorporate content of this type into its pages.

Through this Service, this Site may collect Data directly or indirectly from Users' devices, including by using Trackers to do so. Users may restrict such access to their Data through the security settings page made available by Google. Users may ask the Owner for more information about these privacy settings at any time, using the contact details provided in this document.

 

The Data collected through the service may also be used to help third parties generate interest-based advertising. Users will be able to opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative cancellation option page.

Personal Data processed: Usage data.

Place of processing: Ireland - Privacy Policy - Opt out.

Category of personal information collected under the CCPA: information on the Internet.

This processing constitutes a sale, based on the CCPA definition. In addition to the information in this clause, the User can find information on how to opt out of the sale in the section describing California consumer rights.

Additional information on Personal Data

Selling products and services online

The personal data collected is used to provide the User with services or to sell products, including payment and possible delivery.
The Personal Data collected to complete the payment may relate to the credit card, the bank account used for the transfer, or any other means of payment envisaged. The type of Data collected depends on the payment system used.

Users' rights

Users may exercise certain rights with regard to their Data processed by the Owner.

In particular, Users have the right to do the following:

  • Withdraw your consent at any time. Users have the right to withdraw their consent in cases where they have previously given their consent to the processing of their Personal Data.
  • Object to the processing of your 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. Further details are provided in the specific section below.
  • Access your data. Users have the right to know whether their Data is being processed by the Owner, to obtain disclosures about certain aspects of the processing and to obtain a copy of the Data that is being processed.
  • Check and ask for rectification. Users have the right to verify the accuracy of their Data and to request that it be updated or corrected.
  • Restrict the processing of your Data. Users have the right, under certain circumstances, to restrict the processing of their Data for any purpose other than storing it.
  • Have your Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to have their Owner Data deleted.
  • Receive your 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. This determination applies provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract to which the User is a party or on the User's pre-contractual obligations.
  • Register a complaint. Users have the right to lodge a complaint with their competent data protection authority.

Details on the right to object to processing

In cases where Personal Data is processed in the public interest, in the exercise of an official authorisation in which the Owner is vested or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a reason relating to their particular situation to justify the objection.

Users should be aware, however, that if their Personal Data is processed for direct marketing purposes, they may object to such processing at any time without providing any justification. Users can consult the relevant sections of this document.

How to exercise these rights

Any requests to exercise Users' rights can be directed to the Owner via the contact details provided in this document. These requests can be exercised free of charge and will be dealt with by the Owner as soon as possible and in all cases within a period of less than one month.

Additional information on Data collection and processing

Legal action

Users' Personal Data may be used for legal purposes by the Owner in court or in the steps leading to possible legal action arising from misuse of this Service (this Site) or related Services.
The User declares to be aware that the Owner may be obliged to disclose Personal Data upon request by government authorities.

Additional information on User Personal Data

In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information about specific services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Site and any third-party services may collect files that record interaction with this Site (system logs) or use other Personal Data (such as IP address) for this purpose.

Information not contained in this policy

Further details on 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.

How "Do Not Track" requests are handled

This site does not support "Do Not Track Me" requests.
To determine whether any of the third-party services you use honour "Do Not Track Me" requests, please read their privacy policies.

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 Service (this Site) and/or - to the extent technically and legally feasible - by sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page regularly, referring to the date of the last modification informed at the bottom.

If the changes affect processing activities carried out on the basis of the User's consent, the Owner will collect new consent from the User, where required.

Information for California consumers

This part of the document integrates and supplements the information contained in the rest of this privacy policy and is provided by the company that operates this Website and, as the case may be, its parent companies, subsidiaries and affiliates (for the purposes of this section, hereinafter referred to jointly by the pronouns "we", "us", "our" and "with us").

The provisions contained in this section shall apply to all Users who are consumers residing in the state of California, United States of America, pursuant to the "California Consumer Privacy Act of 2018" (CCPA) (Users shall hereinafter be referred to by the pronouns "you" and "your") and, for such consumers, these provisions supersede all other possibly divergent or conflicting provisions contained in this privacy policy.

This part of the document uses the term "personal information" as defined in the California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold

In this section, we will summarise the categories of personal information that we collect, disclose or sell and the respective purposes. You can read about these activities in more detail in the section entitled "Detailed information on the processing of Personal Data" in this document.

Information we collect: the categories of personal information we collect

We collect the following categories of personal information about you: identifiers, internet information and implicit information.

We will not collect additional categories of personal information without notifying you.

How we collect information: what are the sources of the personal information we collect?

We collect the above-mentioned categories of personal information, either directly or indirectly, from the moment you use this Site.

For example, you provide your personal information directly when you submit requests via any forms on this service (this Site). You also provide personal information indirectly when you browse this service (this Site), as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties who work with us in connection with the Service or the operation of this service (this Site) and its features.

How we use the information we collect: sharing and disclosing your personal information with third parties for a business purpose

We may disclose the information we collect about you to third parties for business purposes. In this case, we enter into a written contract with such third party, requiring the receiving party to keep the personal information confidential and not to use it for any purpose other than those necessary for the performance of the contract.

We may also disclose your personal information to third parties when you expressly request or authorise us to do so in order to provide the Service to you.

To find out more about the purposes of processing, please refer to the relevant section of this document.

Selling your personal information

For our purposes, the word "sale" shall mean any "sale, rental, lease, disclosure, dissemination, making available, transfer or other form of oral, written or electronic communication of a consumer's personal information by the company to another company or to a third party for monetary or other consideration".

This means that, for example, a sale can occur whenever an application runs adverts or makes statistical analyses of its traffic or views, or simply because it uses tools such as social network plugins and the like.

Your right to opt out of the sale of personal information

You have the right to opt out of the sale of personal information. This means that whenever you ask us to stop selling your data, we will comply with your request.
Such requests can be made freely, at any time, without sending any verifiable request, simply by following the instructions below.

Instructions for opting out of the sale of personal information

If you would like to know more, or exercise your right of option with regard to all sales made through this Site, both online and offline, you can contact us for more information using the contact details provided in this document.

What are the purposes for which we use your personal information?

We may use your personal information to enable the operational functioning of this service (this Site) and its features ("business purposes"). In such cases, your personal information will be processed in a manner necessary and proportionate to the business purposes for which it was collected and strictly within the limits of the compatible operational purposes.

We may also use your personal information for other purposes, such as commercial purposes (as indicated in the section "Detailed information on the processing of Personal Data" in this document), and also to comply with the law and defend our rights before the competent authorities, when our rights and interests are threatened or we suffer actual damage.

We will not use your personal information for different, unrelated or incompatible purposes without notifying you.

Your privacy rights in California and how to exercise them

The right to knowledge and portability

You have the right to request that we disclose it to you:

  • the categories and sources of personal information we collect about you, the purposes for which we use your personal information and with whom such information is shared;
  • in the case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
    • for sales, the categories of personal information acquired by each category of receiving party; and
    • for disclosures for a business purpose, the categories of personal information obtained by each category of receiving party.

The disclosure described above will be limited to personal information collected or used in the course of the last 12 months.

If we provide our response electronically, the information included will be "portable", i.e. provided in an easily used format, in order to allow you to transmit the information to another entity without hindrance - as long as it is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete your personal information, subject to exceptions by law (including, but not limited to, when the information is used to identify and repair errors in this service (this Site), to identify security incidents and protect against fraudulent or illegal activities, to exercise certain rights, etc.).

If there is no legal exception as a result of exercising your right, we will delete your personal information and instruct all our service providers to do so.

How to exercise your rights

To exercise the rights described above, you need to send us your verifiable request by contacting us using the details provided in this document.

In order for us to respond to your request, we need to know who you are. Therefore, you can only exercise the above rights by making a verifiable request, which must:

  • provide sufficient information to enable us, within reasonable limits, to verify that you are the person about whom we collect information or an authorised representative;
  • describe your request in sufficient detail to enable us to understand, evaluate and respond to it appropriately.

We will not respond to any request if we are unable to verify your identity and thus confirm that the personal information we hold really relates to you.

If you are unable to submit a verifiable application in person, you can authorise a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable application on behalf of a minor under your guardianship.

You can submit a maximum of 2 applications in a 12-month period.

How and when we expect to fulfil your request

We will acknowledge receipt of your verifiable request within 10 days and provide you with information on how we will process your request.

We will respond to your request within 45 days of receipt. If we need more time, we will explain to you why and how much more time we need. For this purpose, please note that it can take up to 90 days to fulfil your request.

Our disclosures will cover the previous 12-month period.

If we deny your request, we will explain the reasons for our denial.

We will not charge a fee for processing or responding to your verifiable request, unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee or refuse to fulfil the request. In either case, we will communicate our choices and explain the reasons.

Information for Users living in Brazil

This part of the document integrates and complements the information contained in the rest of this privacy policy and is provided by the entity that operates this Website and, as the case may be, its parent companies, subsidiaries and affiliates (for the purposes of this section, hereinafter jointly referred to by the pronouns "we", "us", "our" and "with us").
The provisions contained in this section shall apply to all Users who are resident in Brazil, in accordance with the "General Data Protection Act" (Users shall hereinafter be referred to by the pronouns "you" and "your"). For such Users, these provisions supersede all other possibly divergent or conflicting provisions contained in this privacy policy.
This part of the document uses the term "personal information" as defined in the General Data Protection Act (LGPD).

On what basis we process your personal information

We may process your personal information only if we have a legal basis for such processing. The legal bases are as follows:

  • their consent to the respective processing activities;
  • compliance with a legal or regulatory obligation imposed on us;
  • the fulfilment of public policies laid down in laws or regulations or on the basis of contracts, agreements and similar legal instruments;
  • studies conducted by research organisations, preferably on anonymous personal information;
  • the execution of a contract and its preliminary procedures, in cases where you are a party to the contract;
  • the exercise of our rights in judicial, administrative or arbitration proceedings;
  • protection or physical safety of you or a third party;
  • the protection of health - in procedures carried out by health organisations or professionals;
  • our legitimate interests, provided that your fundamental rights and freedoms 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 which categories of your personal information are processed, you can read the section entitled "Detailed information on the processing of Personal Data" in this document.

Why we process your personal information

To find out why we process your personal information, you can read about the sections entitled "Detailed information on the processing of Personal Data" and "The purposes of processing" in this document.

Your privacy rights as a Brazilian, how to submit a request and our responses to your requests

Your privacy rights as a Brazilian

You have the right to:

  • obtain confirmation about the existence of processing activities of your personal information;
  • access to your personal information;
  • have your incomplete, inaccurate or outdated personal information corrected;
  • obtain the anonymisation, blocking or deletion of your unnecessary or excessive personal information, or of information that is not being processed in accordance with the LGPD;
  • obtain information on the possibility of giving or withholding your consent and the consequences thereof;
  • obtain information about the third parties with whom we share your personal information;
  • obtain, at your express request, the portability of your personal information (except anonymised information) to another supplier of products or services, provided that our commercial and industrial secrets remain protected;
  • obtain the deletion of your personal information processed, if the processing was based on your consent, unless one or more of the exceptions set out in art. 16 of the LGPD apply;
  • withdraw their consent at any time;
  • register a complaint regarding your personal information with the ANPD (National Data Protection Authority) or consumer protection bodies;
  • object to a processing activity in cases where the processing is not carried out in accordance with the provisions of the law;
  • request clear and adequate information regarding the criteria and procedures used for an automated decision; and
  • request a review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. This includes decisions to define your personal, professional, consumer and credit profile or aspects of your personality.

You will never be discriminated against or suffer any kind of prejudice if you exercise your rights.

How to register your request

You may register your express request to exercise your rights free of charge at any time using the contact details provided in this document or through your legal representative.

How and when we will respond to your request

We will endeavour to respond immediately to your requests.
In any case, should this prove impossible, we will make a point of informing you of the reasons in fact or in law that prevent us from immediately attending to or otherwise fulfilling your requests. In cases where we are not processing your personal information, we will indicate the natural or legal person to whom you should forward your requests, if we are in a position to do so.

If you register a access or processing confirmation of personal information, be sure to specify whether you want your personal information to be delivered in electronic or printed form.
You will also need to let us know if you want us to respond to your request immediately, in which case we will respond in a simplified manner, or if you need a full response.
In the latter case, we will respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation of the existence or not of records, any criteria used for processing and the purposes of processing, keeping our commercial and industrial secrets protected.

If you request a rectification, deletion, anonymisation or blocking of personal informationWe will promptly communicate your request to other parties with whom we share your personal information, in order to allow these third parties to also fulfil your request - except in cases where such communication proves impossible or involves a disproportionate effort on our side.

Transfer of personal information outside Brazil permitted by law

We are allowed to transfer your personal information outside Brazilian territory in the following cases:

  • when the transfer is necessary for the purposes of international legal co-operation between public intelligence, investigation and prosecution bodies, in accordance with the legal means provided for in international law;
  • when the transfer is necessary to protect your life or physical safety or that of third parties;
  • when the transfer is authorised by the ANPD;
  • when the transfer is the result of a commitment made in an international cooperation agreement;
  • when the transfer is necessary for the execution of a public policy or legal assignment of a public service;
  • when the transfer is necessary for the fulfilment of a legal or regulatory obligation, the execution of a contract or preliminary proceedings related to a contract or the regular exercise of rights in judicial, administrative or arbitration proceedings.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly or in relation to other information - including a personal identification number - allows the identification or identifiability of a natural person.

Usage Data

The information collected automatically through this Site (or third-party services contracted in this Service (this Site)), which may include: the IP addresses or domain names of the computers used by Users using this Site, the URI addresses (Uniform Resource Identifier), the date and time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the response server (positive result, error, etc.), the country of origin and the various details of the time per visit (e.g. time spent on pages within the application), the characteristics of the User's browser and the time spent within the application.), the country of origin, the characteristics of the browser and operating system used by the User, the various time details per visit (for example, the time spent on each page within the application) and details about the path followed within the application, with particular reference to the sequence of pages visited and other parameters about the operating system of the User's device and/or IT environment.

User

The person using this Site who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public administration, agency or other body that processes the Personal Data on behalf of the Controller as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public administration, agency or other body which alone or jointly with others determines the purposes and means of processing Personal Data, including security measures relating to the operation and use of this Service (this Site). The Data Controller, unless otherwise specified, is the Owner of this Service (this Site).

This Site (or this Application)

The means by which the User's Personal Data is collected and processed.

Service

The service provided by this Site as described in the relative terms (if available) and in this site/application.

European Union (or EU)

Unless otherwise specified, all references in this document to the European Union include all current member states of the European Union and the European Economic Area.

Cookie

Cookies are trackers made up of small sets of data stored in the user's browser.

Tracker

The term Tracker indicates any technology - such as 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 the provisions of multiple legislations, including Articles 13/14 of Regulation (EU) 2016/679 (GDPR - General Data Protection Regulation).

This privacy policy refers only to this Site, unless otherwise stated in this document.

Carlos Afonso

Carlos Afonso

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