DESHOP is committed to taking care of the privacy of its users, acting in accordance with the terms of current legislation and, specially with respect to privacy, to fully complying with Law 13.709 of August 14, 2018, Brazilian General Data Protection Law ("LGPD").
In this regard, the company created this policy, with a view to informing users about the way of processing their data, respecting the principles of good faith, purpose, adequacy, need, free access, data quality, transparency, security, prevention, non-discrimination and accountability.
USER: all individuals, holders of personal data and information provided to DESHOP through the PLATFORM, as well as those who will visit and/or use said PLATFORM, who are fully capable subject to the law, taht is, over 18 (eighteen) years or emancipated and who can, freely and consciously, manifest their will; and all individuals under eighteen (18) years old or legally incompetent individuals, provided they are properly represented by their parents or legally guardians.
PERSONAL DATA: all information provided by the user and collected by DESHOP, which identifies or may identify the user and, through which, the identification or contact information of an individual can be derived. Personal data may be in any media or format, including electronic or computer records, as well as in paper-based files. However, personal data does not include business phone, business mobile number, business address, business email.
PURPOSE: lawful purposes of processing user data, specific, explicit, informed to users and approved by them.
NEED: limitation of data processing to the minimum necessary to accomplish the purpose, which scope only reaches relevant, proportional and non-excessive data.
LEGAL GROUNDS: legislation that legitimates the processing of personal data, as well as contracts, terms and policies, for a given purpose.
CONSENT: express and unambiguous authorization granted by USER to DESHOP, after reading and fully understanding the terms to be authorized, which will take place through clicks on the respective boxes expressly indicated on the PLATFORM, for the purpose of authorizing the processing of personal data and performance of such purpose.
PLATFORM: DESHOP Website and Application, through which personal data and other information are provided, collected and processed.
3. COLLECTION AND USE OF PERSONAL DATA
The USER is aware that he/she provides personal data in a conscious and voluntary way, by filling out the registration available on the PLATFORM, being agreed that said data will be kept confidential, and solely used for the purpose that gives rise to such registration, such as consulting, mentoring, training, design, operationalization and automation processes, through flows in the PLATFORM, as well as for the purposes of advertising of PLATFORM advertisers.
Personal data collected:
- CPF: it is users' unique identification key related to corporate vacancy /position they hold.
- Name, telephone and email: this information is used for communication in case of issues regarding the requested services, related notices and their delivery.
- Mother’s name: This data is only stored in incentive program services, since it is required by Alelo benefit card as validation.
- Date of birth: this information is used to congratulate the user and in incentive program services, since it is required by Alelo benefit card as validation.
- Address: This information is optional, and it is used for sending samples and kits from the company that the user works or via DESHOP.
4. SECURITY OF PERSONAL DATA
The personal data will be stored in DESHOP's database, being understood that DESHOP uses several procedures aimed at security and integrity of personal data, with a view to protecting them, thus avoiding any damages arising from the processing of such data.
Notwithstanding the use of security and monitoring measures by DESHOP, aimed to verify any vulnerabilities and attacks, protect personal data against unauthorized disclosure, misuse or alteration, USER understands and agrees that there are no guarantees that this information cannot be accessed, disclosed, altered or destroyed upon violation of any of the physical, technical or administrative protections.
5. DATA RETENTION
DESHOP retains all data provided, including personal data, for the period in which the user's registration remains active and as necessary to perform its services.
DESHOP will retain personal data and other information and keep it stored until USER reuqets their removal.
DESHOP may retain personal data after receiving the request for deletion by the USER, if so required to comply with legal obligations, resolve disputes, maintain security, prevent fraud and abuse and ensure compliance with contracts.
6. LEGAL BASIS
DESHOP treats personal data exclusively in situations where it is legally authorized, with USER's express and unequivocal consent.
DESHOP, in accordance with current legislation and user consent, is allowed to collect, produce, receive, classify, use, access, reproduce, transmit, distribute, process, archive, store, delete, evaluate or control the information, modify, communicate, transfer, disseminate or extract data about the USER.
The legal basis also includes contracts and preliminary contract procedures (where processing is necessary to enter into the contract with the USER) and legitimate interests, provided that such processing does not violate their rights and freedoms.
Such interests include protecting USER from threats, complying with applicable law, exercising regular rights in judicial, administrative or arbitration proceedings, understanding and improving business and relationships with USERS, as well as allowing them to find economic opportunities.
The USER has the right to deny or withdraw the consent provided to DESHOP, which may disrupt the performance of its services for the USER in this case.
7. USER'S RIGHT TO ACCESS AND CONTROL PERSONAL DATA
DESHOP provides the USER with options for deleting and/or correcting their personal data. Users may:
- Delete Data: USERS may delete some personal data (for example, if such data are no longer needed for provision of services).
- Change or correct data: USERS may edit some of his/her personal data.
USERS can make the requests listed above through the PLATFORM.
8. DATA POLICY
This policy describes the information processed by DESHOP in order to enable its operation through the PLATFORM, with a view to providing the procured services.
To provide AMIGO SECRETO Services, we need to process information about the USER. The types of information we collect depend on how the USER uses our Services, and the initial registration requires the following data: full name, email, telephone number, date of birth, address, mother's name and CPF.
9. THINGS USERS AND OTHER PEOPLE DO AND PROVIDE
Information to have access to the system: the email provided in the register is collected and stored in order to locate your personalized information every new access, as well for sending the services.
Information and content provided by USER: We collect contents, communications and other information that the USER provides when using our Services, including when the USER registers to create an account, creates or shares content, opens requests, consults data, sends messages or communicates with others. This may include current information or information regarding contents that USER provides (such as metadata), like the location of a photo or the date when a file was created. This may also include anything USER sees through the features we provide, such as our camera, so that we can perform actions like suggesting masks and filters that the USER may like, or giving tips on using camera formats. Our systems automatically process the contents and communications that USER and others provide in order to analyze the context and content included in these items for the purposes described below.
Data with special protections: it is possible to choose to provide information in PLATFORM profile fields, connected to USER's options, interests and preferences.
Network and connections: We collect information about the people, Pages, accounts, hashtags and groups where the USER is connected and how USER interacts with them on our Services; i.e.: the people with whom USER most talks or the groups he/she is a member. We also collect contact information if USER chooses to upload, sync it or import it from a device (such as a contact book, call log, or SMS records), which we use for actions such as helping USER and others find people they may know and for the other purposes listed below.
Their use We collect information about how USERS interact with our Services, such as the type of content they see or engage with; the features they use; the actions they perform; the people or accounts with whom USERS interact; and the time, frequency and duration of their activities. For example, we record when the USER is using and the last time they used our Services, and what kind of publications, videos and other contents USER viewed on our Services. We also collect information about how the USER uses features such as our camera.
What others do and information they provide about USER: We also receive and analyze content, communications, and information that others provide when you use our Services. This may include information about the USERS, such as when other people interact with them through our PLATFORM.
10. DEVICE INFO
As described below, we collect information from and related to the computers, phones, connected TVs and other web-connected devices that the USER employs and that are integrated with our Services, combining this information from the different devices employed by USER. For example, we use the information collected about your use of our Services on your phone to better personalize the content (including ads) or features that the USER sees when using our Services on another device, such as your laptop or tablet, or to assess whether the USER has taken action on a different device in response to an advertisement we display on their phone.
11. PARTNER INFORMATION
Advertisers, app developers and publishers can send DESHOP information through the Business Tools they use, including our social plugins, Login, our APIs, and SDKs. These partners provide information about USERS activities outside DESHOP, including information about their device, the websites they access, the purchases they make, the ads they see, and their use of partners' services, regardless of whether or not tehy have an account or are connected to DESHOP.
Such partners receive their data when USER accesses or uses their services or through third parties with whom they work. We require that each of these partners have legal authorization to collect, use and share their data before providing it to us.
12. HOW DO WE USE THAT INFORMATION?
We use the information we have (in line with the choices made by the USER) as described below and to provide and enable DESHOP operations.
We use the information we have to offer our Services, including to customize features and contents, making suggestions to the USER (such as training or services that USER may be interested in or topics that the USER may wish to follow) inside and outside our Services. To create Personalized Services that are unique and relevant to the USER, we use your connections, preferences, activities and interests based on the data we collect and that we become aware of through you and others; how the USER uses and interacts with our Services; the people, things or places that the USER is connected to and in which he is interested, inside and outside our Services.
Information on DESHOP Services and devices: We connect information about your activities across different DESHOP Services and devices to provide a more personalized and consistent experience across all services that the USER uses, wherever they are used. We may also provide a more integrated experience, by automatically filling in your registration information from a DESHOP Product when the USER registers to create an account on a different Product.
Location-related information: We'll use location-related information, such as your current location, history, to promote filtered services related to the region or location you're in.
Research and development of services: We use the information we have to develop, test and improve our Services, including conducting surveys and researches, and testing and resolving issues related to new services and features.
Ads and other sponsored content: We use the information we have about the USER, including information regarding your interests, actions and connections, to select and personalize advertisements, offers and other sponsored content that we display to the USER.
13. PROVIDE MEASUREMENT, ANALYSIS AND OTHER BUSINESS SERVICES
We use the information we have to help advertisers and other partners evaluate the effectiveness and distribution of their ads and services, and also to understand the types of people who use those services and how they interact with their websites, apps, and services.
14. PROMOTING SAFETY AND INTEGRITY
We use the information we have to verify accounts and activities, fight against harmful conduct, detect and prevent spam and other negative experiences, maintain the integrity of our Services, and promote security within and outside DESHOP Services.
15. COMMUNICATE WITH USER
We use the information we have to send the USER marketing communications, to give notice to USER about our Services and to inform them about our policies and terms. We also use your information to resply when the USER contacts us.
16. RESEARCHING AND INNOVATING FOR SOCIAL WELL-BEING
We use the information we have (including from research partners we collaborate with) to conduct and support research and innovation on topics related to general social well-being, technological advancement, public interest, health and wellness.
17. YOUR INFORMATION IS SHARED WITH OTHER PEOPLE IN THE FOLLOWING MANNERS:
People and accounts with whom the USER shares and talks When USERS share and communicate using our Services, USERS choose the audience to anything they share.
Public information may be viewed by anyone, inside and outside our Services, including if that person does not have an account.
18. CONTENT THAT OTHERS SHARE OR RE-SHARE ABOUT THE USER
USERS should take into consideration who they choose to share with, because people who can view their activities on our Services may decide to share these contents with third parties within or outside the scope of our Services, including with people and companies outside the audience with whom the USER has shared them.
19. INFORMATION ABOUT YOUR ACTIVE STATUS OR PRESENCE ON OUR SERVICES
People on their networks may see signs informing them whether the USER is active on our Services, or when the USER last used our Services.
20. THIRD PARTY APPLICATIONS, WEBSITES AND INTEGRATIONS IN OUR SERVICES OR THAT USE OUR SERVICES
When USERS decide to use third-party applications, websites or other services that use or are integrated into our Services, they may receive information about what USERS publish or share. Information collected by these third-party services is subject to its own terms and policies, and not to this Policy.
21. SHARING WITH EXTERNAL PARTNERS
We work with external partners who help us provide and improve our Services to grow our business, enabling the operation of our companies and the provision of free services to people around the world. We do not sell any of your information to anyone and we will never do so. We also impose strong restrictions on how our partners can use and disclose the data we provide.
22. PARTNERS WHO USE OUR ANALYTICS SERVICES
We provide aggregate statistics and insights that help people and businesses understand how users are engaging with their posts, services, and other content within and outside the scope of DESHOP Services.
We provide advertisers with reports on the types of people who viewed their ads and the performance of such ads, but we do not share information that personally identifies the USERS (information such as their name or email address, which can be used by themselves to contact or identify the USERS), unless the USERS give us permission to do so.
24. MEASUREMENT PARTNERS
We share user information with companies that aggregate them to provide measurement analysis and reporting to our partners.
25. PARTNERS WHO OFFER GOODS AND SERVICES IN OUR SERVICES
QWhen the USER signs up to receive premium content, or when he/she purchases something from a seller on our Services, the content creator or seller may receive their public information and other information that the USER shares with them, as well as information required to complete the transaction, such as shipping and contact details.
26. SUPPLIERS AND SERVICE PROVIDERS
We provide information and content to suppliers and service providers that enable the operation of our business, whether providing technical infrastructure services, analyzing how our Services are used, providing customer service, facilitating payments or conducting surveys.
27. LAW ENFORCEMENT OR LEGAL REQUESTS
We share information with law enforcement authorities or in response to legal requests in the circumstances described below.
28. HOW DO I TRACK OR DELETE INFORMATION ABOUT ME?
We confer upon USER the ability to access, rectify, hold and erase their data.
We store data until it is no longer needed to provide DESHOP services, or until your account is deleted, whichever comes first. This is a determination that varies by case and depends on factors such as the nature of data, why it is collected and processed, and relevant operational or legal retention needs.
When USERS delete their account, all data and content that they have published will be deleted and it will not be possible to retrieve this information. Information that others have shared with or about a USER is not part of your account and will not be deleted.
29. WE ACCESS, PRESERVE AND SHARE YOUR INFORMATION WITH REGULATORS, AUTHORITIES OR OTHERS
We share user information in response to a court order (such as a search warrant or subpoena), if we believe in good faith that the law requires us to do so. This may include responding to legal requests from jurisdictions outside Brazil when we believe in good faith that the answer requested by law in the relevant jurisdiction, affects users in said jurisdiction, and is consistent with internationally recognized standards.
When we believe, in good faith, that they are necessary to: detect, prevent and resolve fraud issues, unauthorized use of the Services, violations of our terms or policies, or other illegal or harmful activity; to protect us (and protect our rights, property or Services), the USER or others, including as part of regulatory investigations or inquiries, or to prevent imminent death or bodily harm.
The information we receive about the USER can be accessed and preserved for a longer period when it is the subject of a request or legal obligation, government investigation, inquiries of possible violations of our terms or policies, or to otherwise prevent harm. We also retain information from accounts disabled for violation of our terms for at least one year, in order to prevent repeat abuse or other violations of the terms.
30. HOW DO WE OPERATE AND TRANSFER DATA AS PART OF OUR GLOBAL SERVICES?
We share information globally, both internally in DESHOP services and externally with our partners and with those with whom the USER connects and shares worldwide in accordance with this policy. Your information may, for example, be transferred or transmitted to, or stored and processed in Brazil or other countries outside where the USER lives, for the purposes described in this policy. These data transfers are necessary to provide the services established in DESHOP's General Terms and Conditions of Use, as well as to operate globally and provide our Services to the USER.
If DESHOP makes significant changes to this policy, the USER will be notified here, by email, or by a notice on the PLATFORM before the change takes effect.
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