Privacy Policy of Piero Astuni - Professional & Personal Development

Data Controller

For more information on the owner, contact the following email address:

Owner e-mail address: [email protected]

Types of data collected

Among the Personal Data collected by this Website, either independently or through third parties, there are: Cookies; Usage data; e-mail; first name; surname; date of birth; address; city; various types of data.

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 when using this Website.
Unless otherwise specified, all data requested by this website are mandatory. If the User refuses to communicate them, it may be impossible for this Website to provide the Service.

In cases where this Website indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation. , are encouraged 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, unless otherwise specified, is intended to provide the Service requested by the User, as well as for the additional purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Website and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties.

Method and place of processing of the collected data

Processing methods

The Owner takes appropriate security measures to prevent 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 subjects involved in the organization of this Website (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers) may have access to the Data. , 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 Owner 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 Data Controller may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, as long as the User does not object ("opt-out") to such treatment. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;

- the processing is necessary for the execution of a contract with the User and/or for 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 with which the Data Controller is invested;

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

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

Place

The Data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, please contact the Data Controller.
The User’s Personal Data may be transferred to a country other than that 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 for the transfer of Data outside the European Union or to an international organization governed by public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.

The User can check if one of the transfers described above takes place by examining the section of this document relating to the details on the processing of Personal Data or request information from the Data Controller by contacting him at the opening details.

Retention period

The Data are processed and stored for the time required by the purposes for which they were 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 related to the legitimate interest of the Data Controller will be retained until this 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 keep the Personal Data longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep 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, at the end of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purpose of processing the collected data

The User Data is collected to allow the Owner to provide the Service, comply with legal obligations, respond to requests or executive actions, protect their rights and interests (or those of Users or third parties), identify any malicious activities. or fraudulent, as well as for the following purposes: Platform and hosting services, Advertising, SPAM protection, Backup saving and management, Traffic optimization and distribution, Statistics, Displaying content from external platforms, Managing contacts and sending messages, Contact the User, Interaction with external social networks and platforms and Data Transfer outside the EU.

To obtain detailed information on the purposes of the processing and on 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:

- Contact the user

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: city; surname; date of birth; e-mail; first name.

Category of personal data collected under the CCPA: identifiers.

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

- Manage contacts and send messages

This type of service allows you to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the User.
These services may also allow the collection of data relating to the date and time the messages are displayed by the User, as well as the User’s interaction with them, such as information on clicks on links inserted in messages.

Mailchimp (The Rocket Science Group LLC)

Mailchimp is an address management and email message sending service provided by The Rocket Science Group LLC.

Personal Data processed: surname; date of birth; e-mail; address; first name.

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

Category of personal data collected under the CCPA: identifiers.

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

- Interaction with social networks and external platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of this Website. The interactions and information acquired from this Website are in any case subject to the User’s privacy settings relating to any 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 make sure that the data processed on this Website is not connected back to the User’s profile.

Like button and Facebook social widgets (Facebook, Inc.)

The “Like” button and Facebook social widgets are interaction services with the Facebook social network, provided by Facebook, Inc.

Personal Data processed: Cookies; Usage data.

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

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

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

"Pin it" button and Pinterest social widgets (Pinterest, Inc.)

The “Pin it” button and Pinterest social widgets are interaction services with the Pinterest platform, provided by Pinterest Inc.

Personal Data processed: Cookies; Usage data.

Place of processing: United States – Privacy Policy.

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

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

Tweet button and Twitter social widgets (Twitter, Inc.)

The Tweet button and Twitter social widgets are interaction services with the Twitter social network, provided by Twitter, Inc.

Personal Data processed: Cookies; Usage data.

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

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

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

Linkedin button and social widgets (LinkedIn Corporation)

The LinkedIn button and social widgets are interaction services with the Linkedin social network, provided by LinkedIn Corporation.

Personal Data processed: Cookies; Usage data.

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

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

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

- Traffic optimization and distribution

This type of service allows this Website to distribute its contents through servers located throughout the territory and to optimize its performance.
The Personal Data processed depend on the characteristics and methods of implementation of these services, which by their nature filter communications between this Website and the User’s browser.

Given the distributed nature of this system, it is difficult to determine the places where the contents are transferred, which may contain the User’s Personal Data.

Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The methods of integration of Cloudflare provide that this filters all traffic on this Website, ie the communications between this Website and the User’s browser, also allowing the collection of statistical data on it.

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

Place of processing: United States – Privacy Policy.

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

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

- SPAM protection

This type of service analyzes the traffic of this Website, potentially containing Users’ Personal Data, in order to filter it from parts of traffic, messages and contents recognized as SPAM.

Akismet (Automattic Inc.)

Akismet is a SPAM protection service provided by Automattic Inc.

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

Place of processing: United States – Privacy Policy.

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

- Backup saving and management

This type of service allows the saving and management of backups of this Website on external servers managed by the service provider itself. These backups may include both the source code and its contents and the data provided to this Website by the User.

Backup to Google Drive (Google LLC)

Google Drive is a backup saving and management service provided by Google LLC.

Personal Data processed: 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 data collected under the CCPA: Internet information.

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

- Statistics

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

Google Analytics (Google LLC)

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

Personal Data processed: Cookies; Usage data.

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

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

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

Histats (Wisecode)

Histats is a statistical service provided by Wisecode S.r.l.

Personal Data processed: Cookies; Usage data.

Place of processing: Italy – Privacy PolicyOpt out.

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

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

- Data transfer outside the EU

The Data Controller may transfer Personal Data collected within the EU to third countries (that is, all countries outside the EU) only in accordance with a specific legal basis. Therefore, such data transfers are performed according to one of the legal bases described below.

The User can request information from the Owner regarding the applicable legal basis concretely applicable to each individual service.

Data transfer to countries that guarantee European standards (this Website)

When this is the legal basis, the transfer of Personal Data from the EU to third countries takes place on the basis of an adequacy decision adopted by the European Commission.

The European Commission adopts adequacy decisions with reference to individual third countries which it deems to guarantee a level of protection of Personal Data comparable to that provided for by European legislation on the protection of Personal Data. The User can view the updated list of adequacy decisions on the European Commission’s website.

Personal Data processed: various types of Data.

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

Transfer to third countries based on consent (this Website)

When this is the legal basis, the transfer of Personal Data from the EU to third countries takes place only when the User has expressly consented to this transfer after being informed about the risks due to the absence of an adequacy decision and the adequate guarantees adopted.

In such cases, the Data Controller informs Users and collects their consent through this Website.

Personal Data processed: various types of Data.

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

- Display of content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
This type of service may still collect data on web traffic relating to the pages where the service is installed, even when users do not use it.

Google Fonts (Google LLC)

Google Fonts is a font style visualization service managed by Google LLC that allows this Website 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 data collected under the CCPA: Internet information.

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

Further information on Personal Data

- Transfer of personal information outside of Brazil based on your consent

We may transfer your personal information outside of Brazilian territory if you consent to such a transfer.
In requesting your consent to such a transfer, we will endeavor to provide you with all the information necessary to enable you to make an informed decision and to understand all the implications and consequences of giving or refusing your consent.

This information will be provided in clear and simple language and in such a way as to allow you to distinguish this type of request from any other type of consent request that we may possibly request.
You can withdraw your consent at any time.

- Transfer of personal information outside of Brazil to countries that guarantee the same protection standards as the LGPD

We can transfer your personal information outside the Brazilian territory, if the recipient country or the international organization that receives the personal information guarantees an adequate level of protection of personal information as established by the ANPD.
The ANPD authorizes such transfers when it believes that the country possesses and provides personal information protection standards comparable to those dictated by the LGPD, taking into consideration the following:

- the general and sectoral rules of the legislation in force in the recipient country or in the international organization;

- the nature of the personal information being transferred;

- compliance with the general principles of protection of personal information and individual rights dictated by the LGPD;

- the adoption of adequate security measures;

- the existence of judicial and institutional guarantees for the protection of rights relating to personal information; and

- any other relevant circumstances relating to the transfer.

User rights

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

In particular, the User has the right to:

- withdraw consent at any time. The User can revoke the consent to the processing of their Personal Data previously expressed.

- oppose the processing of their data. The user can oppose the processing of their data when it occurs on a legal basis other than consent. Further details on the right to object are indicated 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 ask for rectification. The User can verify the correctness of their Data and request its updating or correction.

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

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

- receive their data or have them transferred to another owner. The User has the right to receive his / her Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain its unhindered transfer 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 to which the User is a party or on contractual measures connected to it.

- propose 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 are processed in the public interest, in the exercise of public authority 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 are processed for direct marketing purposes, they can oppose the processing without providing any reasons. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

- How to exercise 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 soon as possible, in any case within one month.

Further information on the treatment

- Defense in court

The User’s Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of this Website or related Services by the User.

The User declares to be aware that the Owner may be obliged to disclose the Data by order of the public authorities.

- Specific information

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

- System log and maintenance

For needs related to operation and maintenance, this Website and any third party services used by it may collect system logs, which are files that record the 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 Website does not support “Do Not Track” requests.
To find out if 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 Website as well as, if technically and legally feasible, by sending a notification to Users through one of the extremes. contact number of which it is in possession.

Please therefore consult this page frequently, referring to the date of the last modification indicated at the bottom.

If the changes affect treatments whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.

Information for Californian 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 Website 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 below simply as “you “,” Your “,” you “or” your “), and, for them, these provisions prevail over any other divergent or conflicting provision contained in this privacy policy.

This part of the document uses the term “personal information” 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 that we have collected, communicated or “sold” pursuant to the CCPA and the related purposes of the processing. You can find detailed information on these activities in the section entitled “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 and information on the Internet.

We will not collect additional categories of personal information without first communicating a new policy to you.

- 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 Website.

For example, you directly provide us with your personal information when you submit requests through any form on this Website. You also indirectly provide us with personal information when you browse this Website, as personal information about you is automatically observed and collected.

Finally, we may collect your personal information from third parties working with us in connection with the provision of the Service or the operation of this Website and its features.

- How we use the information collected: 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 that third party which obliges the recipient of your personal information to keep such information confidential and not to use it for purposes other than those necessary for the performance of the contract.

We may also disclose your personal information to third parties when you ask us or authorize us to do so in order to provide you with our Service.

For more information on the purposes of the processing, please consult the relevant section of this document.

- Sale of your personal information

For the purposes of this document, the term “sale” means “sell, transfer, 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 a third party, for consideration or for another type of profit “.

This means that, for example, a sale can take place 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 execute 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 from the sale of personal information

If you wish to have further information or to exercise your right to opt-out in relation to all sales made from this Website, both online and 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 allow this Website and its features to function properly (“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 commercial purposes (as indicated in the “Details on the 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 any other, unrelated or incompatible purpose without first communicating a new policy to you.

Your California Privacy Rights and How to Exercise Them

- Right to knowledge 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 the sale or communication of personal information to third parties for operational purposes, we will provide you with two separate lists in which we will notify you;

- for the sale, the categories of personal information communicated to each category of recipients; and

- for communication to third parties for operational purposes, the categories of personal information obtained from each category of recipients;

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

In the event that our response is provided electronically, the information contained therein will be “portable”, ie delivered in a compatible format so that you can transmit the information to other entities without hindrance – provided this is technically feasible.

- Right to request the deletion of your personal information

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

If no exception provided by law applies, following the 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 submit a verifiable request by contacting us using the contact details provided in this document.

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

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

- describe your request with a degree of detail that is sufficient to make us understand, evaluate and respond correctly to what you ask us.

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

If you cannot personally submit a verifiable request, you can delegate 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 whoever falls under your parental responsibility.

A maximum of 2 requests can be submitted within 12 months.

- How and in how long will we 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 on 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 it may take up to 90 days to fulfill your request.

Our communications will cover the period of the previous 12 months.

Should we deny your request, we will explain the reason for the denial.

We will not charge any fees to process or respond to your verifiable request unless it is manifestly unfounded or excessive. In such cases, we may apply a reasonable fee, or deny the request. In both cases, we will notify you of our decisions and explain the reasons.

Information for Users residing in Brazil

This part of the document integrates and completes the information contained in the rest of the privacy policy and is provided by the entity that manages this Website 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” ours “).

The provisions contained in this section apply to all Users who are resident in Brazil, pursuant to “Lei Geral de Proteção de Dados” (such Users are referred to below simply as “you”, “your”, “you” or “your”). For such Users, these provisions prevail over any other divergent or conflicting provision contained in this privacy policy.

In this part of the document, the term “personal information” is used as defined by Lei Geral de Proteção de Dados (LGPD).

- Legal basis under which we process your personal information

We only process your personal information 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 bodies, preferably carried out on anonymised personal information;

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

- the exercise of our rights in court, in administrative procedures 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 interest, provided that your fundamental rights and freedoms do not override those 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 section “Details on the processing of Personal Data” in this document.

- Why we process your personal information

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

Your privacy rights in Brazil, how to submit a request and how it will be handled by us

- 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 the correction of your incomplete, inaccurate or outdated personal information;

- obtain anonymization, blocking or deletion of unnecessary or excessive personal information, or information that is processed contrary to the provisions of the LGPD;

- obtain information regarding the possibility of giving or refusing your consent and the relative 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 anonymised information) to other suppliers of products or services, provided that our trade and industrial secrets are safeguarded;

- obtain the deletion of 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 are applicable;

- withdraw your consent at any time;

- submit a complaint regarding your personal information to the ANPD (National Data Protection Authority) or to 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 outline your personal, professional, consumer or creditor profile, or other aspects of your personality.

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

- How to submit a request

You can make 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 how long will we 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 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 the natural or legal person to whom to address your requests.

In the event that you decide to submit an access request or a request for confirmation of the existence of the processing of personal information, please make 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 would like an immediate response, in which case you will receive a simplified response, or if you need complete information instead.

In the latter case, we will respond within 15 days from the moment of your request, providing you with all the information regarding the origin of your personal information, the 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 trade and industrial secrets.

In the event that you decide to submit a request for rectification, deletion, anonymization or blocking of personal information, we will make sure to immediately inform the other parties with whom we have shared your personal information of your request so that they can in turn fulfill your request – except in cases where such communication is impossible or excessively burdensome for us.

Your privacy rights in Brazil, how to submit a request and how it will be handled by us

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 procedure bodies, as required by the tools made available by international law;

- when the transfer is necessary to defend your life or physical safety or that of third parties;

- when the transfer is authorized by the ANPD;

- when the transfer derives 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 management, administration or arbitration.

Definitions and legal references

- Personal Data (or Data)

Any information that, 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 Website (including from third-party applications integrated into this Website), including: the IP addresses or domain names of the computers used by the User who connects with this Website, the 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 of the itinerary followed within the Application, with particular reference to the sequence of the pages consulted, to the parameters relating to the operating system and the IT environment of the User.

- User

The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

- Interested

The natural person to whom the Personal Data refers.

- Data Processor (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 Owner)

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

- This Website

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

- Service

The Service provided by this Website as defined in the relative terms (if any) on this site / application.

- European Union (or EU)

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

- Cookie

Small portion of data stored in the User’s device.

- Legal references

This privacy statement 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 Website.

Last modification: September 22nd, 2020