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Privacy Policy of www.andreasepejeans.com

 

Data Controller:

Pierre Moda Srl, Piazza Emancipazione 7 Gandino (Bg) – Fiscal Code - VAT number 02002170161

 

Owner's email address: info@pr-moda.com

 

Types of Data collected 

Among the Personal Data collected independently or through third parties, there are: Cookies; Usage data; first name; e-mail; surname; telephone number; VAT number; business name; address; device information. 

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during use of the site. Unless otherwise specified, all requested Data is mandatory. If the User refuses to communicate them, it may be impossible to provide the Service. In cases where some Data is indicated as "optional", Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users who have doubts about which Data is mandatory are encouraged to contact the Owner.
Any use of Cookies - or other tracking tools - by the site or the owners of third-party services used, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the additional purposes described herein. document and in the Cookie Policy, if available. The User assumes responsibility for the Personal Data of third parties obtained, published or shared through the site and guarantees that he or she has the right to communicate or disseminate them, freeing the Owner from any liability towards third parties.

 

Treatment methods

The Data Controller adopts appropriate security measures aimed at preventing unauthorized access, disclosure, modification or destruction of Personal Data. The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the organization (administrative, commercial, marketing, legal, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.

 

Legal basis of the processing

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

· the User has given consent for one or more specific purposes; Note: in some jurisdictions the Owner may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, until the User objects ("opt-out") to this treatment. However, this is not applicable if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;

· the processing is necessary for the execution of a contract with the User and/or the execution of pre-contractual measures;

· the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;

· the processing is necessary for the execution of a task of public interest or for the exercise of public powers vested in the Data Controller;

· the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

However, it is always possible to request the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on the law, provided for by a contract or necessary to conclude a contract.

 

Place

The Data is processed at the Owner's operational offices and in any other place where the parties involved in the processing are located. For further information, contact the Owner. The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data. The User has the right to obtain information regarding the legal basis of the transfer of Data outside the European Union or to an international organization governed by public international law or constituted by two or more countries, such as for example the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data. The User can verify whether one of the transfers just described takes place by examining the section of this document relating to details on the processing of Personal Data or request information from the Data Controller by contacting him at the details indicated at the opening.

 

Retention period

The Data is processed and stored for the time required by the purposes for which it was collected.

Therefore:

· Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.

· Personal Data collected for purposes attributable to the legitimate interest of the Owner will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When the processing is based on the User's consent, the Data Controller may retain the Personal Data for longer until such consent is revoked. Furthermore, the Owner may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiry of this deadline the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

 

Purpose of the Processing of Collected Data

The User's Data is collected to allow the Owner to provide the Service, fulfill legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), identify any malicious activities or fraudulent, as well as for the following purposes: Statistics, Contacting the User, Interaction with social networks and external platforms, Commenting on content, Managing contacts and sending messages, Displaying content from external platforms, Optimization and distribution of traffic and Management of tags. 

To obtain detailed information on the purposes of the processing and the Personal Data processed for each purpose, the User can refer to the "Details on the processing of Personal Data" section.

 

Details on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

 

Content commentary

Commenting services allow Users to formulate and make public their comments regarding the content of this site. Users, depending on the settings decided by the Owner, can also leave comments anonymously. If there is an email among the Personal Data released by the User, this could be used to send notifications of comments regarding the same content. Users are responsible for the content of their comments. In the event that a comment service provided by third parties is installed, it is possible that, even if Users do not use the comment service, it collects traffic data relating to the pages in which the comment service is installed. .

 

Facebook Comments (Facebook, Inc.)

Facebook Comments is a service managed by Facebook, Inc. that allows the User to leave comments and share them within the Facebook platform.

Personal Data processed: Cookies; Usage data. 

Place of processing: United States – Privacy Policy. Subject adhering to the Privacy Shield. 

Category of Personal Information Collected Under the CCPA: Internet Information. 

This type of processing constitutes a “sale of data” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section that describes the rights of Californian consumers, for information on how to opt-out from the sale.

 

Commenting system managed directly by the web platform

The web platform has its own content commenting system.

Personal Data processed: email; name. 

Category of Personal Data Collected Under the CCPA: Identifiers.

 

Contact the user

 

Contact form

By filling in the contact form with their Data, the User consents to their use to respond to requests for information, quotes, or any other nature indicated by the form header.

Personal Data processed: surname; e-mail; address; first name; telephone number; VAT number; company name. 

Category of personal data collected under the CCPA: identifiers; commercial information. 

 

Mailing list or newsletter

By registering on the mailing list or newsletter, the User's email address is automatically added to a contact list to which email messages containing information, including commercial and promotional information, relating to this site may be sent. Your email address may also be added to this list as a result of registering on this site or after making a purchase.

Personal Data processed: email; name. 

Category of Personal Data Collected Under the CCPA: Identifiers.

 

Tag management

This type of service is functional for the centralized management of tags or scripts used on the site
The use of these services involves the flow of User Data through them and, if applicable, their retention.

 

Google Tag Manager 

Google Tag Manager is a tag management service provided by Google LLC or Google Ireland Limited, depending on the location from which the website is used.

Personal Data processed: Usage data. 

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy. Subject adhering to the Privacy Shield. 

Category of Personal Information Collected Under the CCPA: Internet Information. 

This type of processing constitutes a “sale of data” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section that describes the rights of Californian consumers, for information on how to opt-out from the sale.

 

Interaction with social networks and external platforms

This type of service allows you to interact with social networks, or other external platforms, directly from the pages of this site. The interactions and information acquired from this site are in any case subject to the User's privacy settings relating to each social network. This type of service may still collect traffic data for the pages where the service is installed, even when Users do not use it. It is recommended to log out of the respective services to ensure that the data processed on this site is not linked to the User's profile.

 

AddThis (Oracle Corporation)

AddThis is a service provided by Oracle Corporation that displays a widget that allows interaction with social networks and external platforms and sharing the contents of this site. Depending on the configuration, this service can show widgets belonging to third parties, for example social network managers on which interactions can be shared. In this case, the third parties that provide the widget will also be aware of the interaction carried out and the Usage Data relating to the pages on which this service is installed.

Personal Data processed: Cookies; Usage data. 

Place of processing: United States – Privacy Policy

Category of Personal Information Collected Under the CCPA: Internet Information. 

This type of processing constitutes “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section that describes the rights of Californian consumers, for information on how to opt-out from the sale.

 

ShareThis (Sharethis Inc.)

ShareThis is a service provided by ShareThis Inc that displays a widget that allows interaction with social networks and external platforms and sharing the contents of this site. Depending on the configuration, this service can show widgets belonging to third parties, for example social network managers on which interactions can be shared. In this case, the third parties that provide the widget will also be aware of the interaction carried out and the Usage Data relating to the pages on which this service is installed.

Personal Data processed: Cookies; Usage data. 

Place of processing: United States – Privacy Policy

Category of Personal Information Collected Under the CCPA: Internet Information. 

This type of processing constitutes “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section that describes the rights of Californian consumers, for information on how to opt-out from the sale.

 

Facebook Like Button and Social Widgets (Facebook Ireland Ltd)

The "Like" button and Facebook social widgets are interaction services with the Facebook social network, provided by Facebook Ireland Ltd

Personal Data processed: Cookies; Usage data. 

Place of processing: Ireland – Privacy Policy. Subject adhering to the Privacy Shield. 

Category of Personal Information Collected Under the CCPA: Internet Information. 

This type of processing constitutes “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section that describes the rights of Californian consumers, for information on how to opt-out from the sale.

 

 

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to keep track of the User's behavior.

 

Google Analytics (Google Inc.)

Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this site, compiling reports and sharing them with other services developed by Google.
Google may use Personal Data to contextualize and personalize the ads of its advertising network.

Personal Data processed: Cookies; Usage data. 

Place of processing: United States – Privacy Policy – Opt Out. Subject adhering to the Privacy Shield. 

Category of Personal Information Collected Under the CCPA: Internet Information. 

This type of processing constitutes “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section that describes the rights of Californian consumers, for information on how to opt-out from the sale.

 

Viewing content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this site and interact with them. If a service of this type is installed, it is possible that, even if Users do not use the service, it collects traffic data relating to the pages on which it is installed.

 

YouTube Video Widget (Google Inc.)

YouTube is a video content viewing service managed by Google Inc. which allows this site to integrate such content within its pages.

Personal Data processed: Cookies; Usage data. 

Place of processing: United States – Privacy Policy. Subject adhering to the Privacy Shield. 

Category of Personal Information Collected Under the CCPA: Internet Information. 

This type of processing constitutes a “sale of data” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section that describes the rights of Californian consumers, for information on how to opt-out from the sale.

 

Instagram Widgets (Instagram, Inc.)

Instagram is an image viewing service managed by Instagram, Inc. which allows this site to integrate such content within its pages.

Personal Data processed: Cookies; Usage data. 

Place of processing: United States – Privacy Policy

Category of Personal Information Collected Under the CCPA: Internet Information. 

This type of processing constitutes a “sale of data” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section that describes the rights of Californian consumers, for information on how to opt-out from the sale.

 

Google Maps Widget (Google Inc.)

Google Maps is a map viewing service managed by Google Inc. which allows this site to integrate such content within its pages.

Personal Data processed: Cookies; Usage data. 

Place of processing: United States – Privacy Policy. Subject adhering to the Privacy Shield. 

Category of Personal Information Collected Under the CCPA: Internet Information. 

This type of processing constitutes a “sale of data” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section that describes the rights of Californian consumers, for information on how to opt-out from the sale.

 

Google Fonts (Google Inc.)

Google Fonts is a character style visualization service managed by Google Inc. which allows this site to integrate such content within its pages.

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

Place of processing: United States – Privacy Policy. Subject adhering to the Privacy Shield. 

Category of Personal Information Collected Under the CCPA: Internet Information. 

This type of processing constitutes a “sale of data” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section that describes the rights of Californian consumers, for information on how to opt-out from the sale.

 

User Rights

Users can exercise certain rights with reference to the Data processed by the Owner.

In particular, the User has the right to:

· revoke consent at any time. The User may revoke the previously expressed consent to the processing of their Personal Data. 

· object to the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are set out in the section below.

· access their Data. The User has the right to obtain information on the Data processed by the Owner, on certain aspects of the processing and to receive a copy of the Data processed.

· verify and request rectification. The User can verify the correctness of their Data and request its updating or correction. 

· obtain the limitation of treatment. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case the Owner will not process the Data for any purpose other than their conservation.

· obtain the cancellation or removal of your Personal Data. When certain conditions are met, the User can request the deletion of their Data by the Owner.

· receive your Data or have it transferred to another owner. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain its transfer without obstacles to another owner. This provision is applicable when the Data is processed with automated tools and the processing is based on the User's consent, on a contract of which the User is a party or on contractual measures connected to it.

· lodge a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

 

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public powers vested in the Owner or to pursue a legitimate interest of the Owner, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, if their Data is processed for direct marketing purposes, they can object to the processing without providing any reason. To find out whether the Owner processes data for direct marketing purposes, Users can refer to the respective sections of this document.

 

How to exercise your rights

To exercise the User's rights, Users can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as quickly as possible, in any case within one month.

 

Cookie Policy

This site uses Tracking Tools. To find out more, the User can consult theCookie Policy.

 

Learn more about the treatment

 

Defense in court

The User's Personal Data may be used by the Owner in court or in the preparatory stages of its possible establishment for the defense against abuse in the use of this site or related Services by the User.
The User declares to be aware that the Owner may be obliged to reveal the Data by order of public authorities.

Specific information

Upon request of the User, in addition to the information contained in this privacy policy, this site may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For needs related to operation and maintenance, this site and any third-party services used by it may collect system logs, i.e. files that record interactions and which may also contain Personal Data, such as the User IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to “Do Not Track” requests

This site does not support “Do Not Track” requests.
To find out whether any third-party services used support them, the User is invited to consult the respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this site as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details contact he has. Please therefore consult this page frequently, referring to the date of last modification indicated at the bottom.

If the changes affect processing whose legal basis is consent, the Owner will collect the User's consent again, if necessary.

 

Information for California consumers

 

This part of the document integrates and completes the information contained in the rest of the privacy policy and is provided by the company that operates this site and, where applicable, by its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as "we" , "our" or "our"). The provisions contained in this section apply to all Users who are considered consumers resident in the state of California, United States of America, pursuant to the “California Consumer Privacy Act of 2018" (such Users are referred to herein simply as “you ", "your", "you" or "your"), and, for them, these provisions prevail over any other possibly divergent or conflicting provisions contained in this privacy policy. In this part of the document the term "personal information" is used ” as defined by the California Consumer Privacy Act (CCPA).

Categories of Personal Information Collected, Disclosed, or Sold

This section summarizes the categories of personal information we have collected, disclosed, or “sold” under the CCPA and the purposes for which we process it. You can find detailed information on these activities in the section called “Details on the processing of Personal Data” in this document.

Information We Collect: The categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, commercial information and Internet information.

We will not collect additional categories of personal information without first providing you with a new notice.

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

We collect the above categories of personal information, directly or indirectly, from you when you use this site.

For example, you directly provide us with your personal information when you submit inquiries via any form on this site.

Furthermore, you indirectly provide us with personal information when you browse 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 provision of the Service or the operation of this site and its features.

How we use the information we collect: Sharing and communicating your personal information with third parties for operational purposes.

We may disclose your personal information to third parties for operational and service purposes. In this case, we enter into a written contract with such third party that obligates the recipient of your personal information to keep such information confidential and not to use it for any purpose other than that necessary for the performance of the contract.

We may also disclose your personal information to third parties when you ask us to do so or authorize us to do so in order to provide you with our Service. For further information on the purposes of the processing, we invite you to consult the relevant section of this document.

Sale of your personal information

For the purposes of this document, the term “sale” means “to sell, assign, release, make public, disclose, disseminate, make available, transfer or otherwise communicate orally, in writing or by electronic means, personal information of a consumer by a company to another company or to third parties, for consideration or for any other type of profit".

This means that, for example, a sale can occur whenever an application publishes advertisements, performs statistical analysis on its traffic or views or, simply, uses tools such as social network plug-ins and similar tools.

Your right to opt-out of the sale of your personal information

You have the right to opt-out of the sale of your personal information. This means that whenever you ask us not to sell your data, we will comply with your request. Such requests can be made freely, at any time, and without submitting any request subject to verification, simply by following the instructions below. 

Instructions for opting out of the sale of your personal information

If you wish to have further information or exercise your right to opt-out in relation to all sales made from this site, whether online or offline, you can contact us 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 proper functioning of this site and its features (“operational purposes”). In such cases, your personal information will be processed in an appropriate and proportionate manner to the purposes for which it was originally collected and strictly within the limits of compatible purposes.

We may also use your personal information for other reasons, such as for business purposes (as set out in the “Details on processing of Personal Data” section of this document), as well as to comply with the law and defend our rights. before the competent authorities when our rights or interests are threatened or when we suffer damage.

We will not use your personal information for different, unrelated, or incompatible purposes without first providing you with a new notice.

Your California privacy rights and how to exercise them

Right to know and portability

You have the right to know the following:

· the categories of personal information we collect about you and the sources of that information, the purposes for which we use your personal information and with whom we share it;

· in the event of sale or disclosure of personal information to third parties for operational purposes, we will provide you with two separate lists in which we will notify you: 

· for sales, the categories of personal information communicated to each category of recipients; and for disclosure to third parties for operational purposes, the categories of personal information obtained from each category of recipients;

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

In the event that our response is provided electronically, the information it contains will be “portable”, that is, delivered in a compatible format so as to allow you to transmit the information to other entities without impediment – provided that this is technically feasible.

Right to request deletion of your personal information

You have the right to request deletion of any of your personal information, subject to the exceptions provided by law (such as, but not limited to, where the information is used to identify and repair errors on this site, to detect incidents security, for protection purposes from fraudulent or illegal activities, to exercise certain rights, etc.).

If no statutory exception applies, following your exercise of your right, we will delete your personal information and ask our suppliers to do the same.

How to exercise your rights

To exercise the rights described above, you must make a verifiable request by contacting us using the contact details provided herein.

In order to respond to your request, it is necessary for us to be able to identify you. For this reason you can exercise the above rights only by submitting a verifiable request which must:

· provide sufficient information that allows us to reasonably verify that you are the person to whom the personal information we have collected relates or an authorized representative of that person;

· describe your request with a level of detail that is sufficient for us to understand, evaluate and respond correctly to what you are asking us.

We will not respond to any request if we are unable to verify your identity and, therefore, confirm that the information in our possession actually refers to you.

If you cannot personally submit a verifiable request, you can designate a person registered with the California Secretary of State to do so on your behalf. If you are an adult, you can make a verifiable request on behalf of anyone under your parental responsibility.

It is possible to submit a maximum of 2 requests within 12 months.

How and in what time we will handle your request

Within 10 days we will confirm that we have received your request and provide you with information on how we will process it.

We will respond to the merits of the request within 45 days of receiving it. If we need more time, we will explain why and let you know how much time we need. In this regard, please note that we may take up to 90 days to process your request. Our communications will cover the previous 12 months. If we deny your request, we will explain the reason for the denial. We will not charge a fee for processing or responding to your verifiable request unless it is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or deny the request. In both cases, we will communicate our decisions to you and explain the reasons.

 

Information for Users residing in Brazil

This part of the document supplements and completes the information contained in the rest of the privacy policy and is provided by the entity that operates this site and, where applicable, its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as "we ", "our" or "ours"). The provisions contained in this section apply to all Users who are residents of Brazil, pursuant to the "Lei Geral de Proteção de Dados" (such Users are referred to hereinafter simply as “you”, “your”, “you” or "your"). For such Users, these provisions prevail over any other possibly divergent or conflicting provisions contained in this privacy policy. 
In this part of the document the term “personal information” is used as defined by the Lei Geral de Proteção de Dados (LGPD).

Legal bases on which we process your personal information

We process your personal information only if one of the legal bases for such processing exists. The legal bases are as follows: 

· your consent to the processing activities in question;

· compliance with legal obligations that we are required to satisfy;

· the execution of rules dictated by laws or regulations or by contracts, agreements or other similar legal instruments; 

· studies conducted by research institutions, preferably carried out on anonymized personal information;

· the execution of a contract and related pre-contractual obligations, if you are a party to such contract;

· the exercise of our rights in court, in administrative proceedings or in arbitration;

· the defense or physical safety of you or a third party; 

· health protection - in the context of procedures implemented by entities or professionals in the health sector;

· our legitimate interests, provided that your fundamental rights and freedoms do not override 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 personal information are processed, you can refer to the “Details on the processing of Personal Data” section in this document. 

Why we process your personal information 

To find out why we process your personal information, please refer to the “Details on the processing of Personal Data” and “Purpose of the Processing of Collected Data” sections in this document. 

Your privacy rights in Brazil, how to make a request and how we will handle it

Your privacy rights in Brazil

You have the right to: 

· obtain confirmation of the existence of processing activities regarding your personal information;

· access your personal information;

· obtain rectification of your incomplete, inaccurate or out-of-date personal information;

· obtain the anonymisation, blocking or deletion of unnecessary or excessive personal information, or that information which is processed in conflict with the provisions of the LGPD;

· obtain information regarding the possibility of giving or refusing your consent and the related consequences; 

· obtain information about the third parties with whom we share your personal information;

· obtain, upon your explicit request, the portability of your personal information (with the exception of anonymized information) to other suppliers of products or services, provided that our commercial and industrial secrets are safeguarded;

·       obtain the deletion of the personal information processed if the processing was carried out on the basis of your consent, unless one or more of the exceptions provided for in Article 16 LGPD apply;

· withdraw your consent at any time;

· lodge a complaint regarding your personal information with the ANPD (National Data Protection Authority) or a consumer protection body;

· oppose processing activities in cases where such processing is not carried out in compliance with the provisions of the law;

· request clear and adequate information regarding the criteria and procedures used in the context of automated decision-making processes; And

· request the review of decisions that harm your interests, made exclusively on the basis of automated decision-making processes of your personal information. These include decisions to shape your personal, professional, consumer or creditor profile, or other aspects of your personality.

You will never be discriminated against, nor will you in any way suffer any treatment that is unfavorable to you, following the exercise of your rights.

How to submit a request

You can send an explicit request to exercise your rights free of charge, at any time, using the contact details in this document or through your legal representative.

How and in what time we will handle your request

We will do our best to respond to your request as soon as possible.  In any case, if it is impossible for us to do so, we will make sure to communicate to you the factual or legal reasons that prevent us from immediately satisfying or following up on your request. If your personal information is not processed by us, if we are able to do so, we will indicate to you the natural or legal person to whom your requests should be addressed. In the event that you decide to submit a request for access or a request for confirmation of the existence of the processing of personal information, please be sure to specify whether you prefer to receive your personal information in electronic or paper format. You will also need to let us know if you want an immediate response, in which case you will receive a simplified response, or if you require full disclosure. In the latter case, we will respond within 15 days from the time of your request, providing you with all the information regarding the origin of your personal information, confirmation or not of the existence of personal information concerning you, all the criteria used for the processing and the purposes of such processing, while safeguarding our commercial and industrial secrets. In the event that you decide to make a request for rectification, deletion, anonymization or blocking of personal information, we will ensure that we immediately inform the other parties with whom we have shared your personal information of your request so that they can also satisfy your request - except in cases where such communication is impossible or excessively burdensome for us. 

Transfer of personal information outside Brazil where permitted by law 

We may transfer your personal information outside of Brazilian territory in the following cases: 

· when the transfer is necessary for international legal cooperation between intelligence services, investigative and criminal procedural bodies, as provided for by the instruments made available by international law; 

· when the transfer is necessary to defend the life or physical integrity of you or third parties;

· when the transfer is authorized by the ANPD;

when the transfer arises from an obligation assumed in the context of an international cooperation agreement;

· when the transfer is necessary for the exercise of public order or for the performance of a public service;

· when the transfer is necessary for the fulfillment of a legal obligation, the execution of a contract and related pre-contractual obligations, or the normal exercise of rights in judicial, administrative or arbitration proceedings.

 

Definitions and legal references

 

Personal Data (or Data)

Any information which, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.

Usage Data

This is the information collected automatically through this site (also by integrated third-party applications), including: IP addresses or domain names of the computers used by the User who connects to this site, addresses in URI (Uniform Resource Identifier) notation ), the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin , the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User's IT environment.

User

The individual who uses this site who, unless otherwise specified, coincides with the interested party.

Interested

The natural person to whom the Personal Data refers.

Data Controller (or Manager)

The natural person, legal person, public administration and any other body that processes personal data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Data Controller)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data and the tools adopted, including security measures relating to the operation and use of this site. The Data Controller, unless otherwise specified, is the owner of this site.

Website (or this Application)

The hardware or software tool through which the Personal Data of Users is collected and processed.

Service

The service provided by this site as defined in the relevant terms (if available) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to include all current member states of the European Union and the European Economic Area.

Cookies

Small portion of data stored within the User's device.

 

Legal references

This privacy information is drawn up on the basis of multiple legislative systems, including articles. 13 and 14 of Regulation (EU) 2016/679. Unless otherwise specified, this privacy policy applies exclusively to this site.

 

Last modified: September 25, 2021

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