PRIVACY POLICY – PAULO ROBERTO LEARDI

 

1. LEGAL APPLICATION

All technical and content aspects of PAULO ROBERTO LEARDI's systems and workflows respect Brazilian legislation and in particular the General Data Protection Law (Law 13.709/2018) .

2. DEFINITIONS:

a) User: refers to all natural persons who will use or visit the Site(s) and/or Application(s) , over 18 (eighteen) years of age or emancipated and fully capable of performing the acts of civil life or the absolutely or relatively incapable duly represented or assisted.

b) Personal Data: refers to any information provided and/or collected by any means or format by the user to PAULO ROBERTO LEARDI and/or group company, even if public, that:

(I) identify, or that, when used in conjunction with other data collected by PAULO ROBERTO LEARDI, allow their identification; or

(II) through which identification or personal contact information of an individual may be derived.

c) Purpose: refers to the purpose of PAULO ROBERTO LEARDI from each act of processing personal information.

d) Necessity: refers to the reasons why the collection of personal data is justified, to carry out the purpose.

e) Legal bases:  refers to the legal grounds that make the collection and processing of personal data by PAULO ROBERTO LEARDI legitimate for the purpose.

f) Consent: refers to the express and unequivocal authorization granted by the User holder of the data for PAULO ROBERTO LEARDI to carry out the collection and processing of his personal data, under the terms of this document.

g) Website/Application: Refers to the electronic address of PAULO ROBERTO LEARDI or a platform developed with the objective of bringing together consumers who want to interact with the company over the internet.

We reserve the right to periodically make changes to this Privacy Policy. When we make such changes, we will post the latest version on digital media.

h) Parties: refers to the mention of the user and PAULO ROBERTO LEARDI jointly.

i) Employees of PAULO ROBERTO LEARDI:  are all employees of the Group Companies, including directors, interns, apprentices and any other person who has a direct link with the Group companies.

j) Data Controller: refers to the natural or legal person, public or private, who is responsible for decisions regarding Data Processing User Personal Information.

k) Data Officer or DPO: refers to the person who at PAULO ROBERTO LEARDI is the responsible for coordinating and ensuring compliance with the Data Protection Policy and applicable local legal/regulatory requirements, it will also act as the conduit with data subjects and the National Data Protection Authority.

l) Data Operator:  refers to the natural or legal person, public or private, who processes personal data on behalf of the Data Controller.

m) National Data Protection Authority or ANPD: means the administrative authority in charge of Personal Data Protection is a national public administration body responsible for ensuring, implementing and supervising compliance with the General Data Protection Law throughout the Brazilian territory.

n) Sensitive Data: refers to datapersonal data about racial or ethnic origin, religious conviction, political opinion, union affiliation or organization of a religious, philosophical or political nature, data referring to health or sex life, genetic or biometric data, when linked to a natural person.< /p>

o) LGPD: refers to the General Law for the Protection of Personal Data, Law No. 13,709 of August 14, 2018.

3. APPLICATION CREATION AND DATA CONTROL

The application is owned by the company BDI CENTRAL DE DADOS LTDA, which will be responsible for the control and operation of the data provided, appointing as DPO Germano Leardi Neto.

4. PRIVACY PROTECTION

PAULO ROBERTO LEARDI works respecting the need to protect your personal information. The company will not provide, publish, disclose, commercialize or transmit in any form the information collected about you in violation of this Privacy Policy. ACCESS TO THE APPLICATION AND COLLECTION OF INFORMATION ARE INTENDED TO RESPECT THE PRIVACY AND GUARANTEE THE CONFIDENTIALITY OF AUTOMATED OR MANUAL PERSONAL DATA PROVIDED BY USERS OF THE APPLICATION, IN ACCORDANCE WITH CURRENT LEGISLATION. THUS, THE USER DECLARE TO KNOW AND ACCEPT ALL THE TERMS PRESENTED HERE.

Although PAULO ROBERTO LEARDI uses security measures and system monitoring to check for vulnerabilities and attacks to protect Users against unauthorized disclosure, misuse or alteration, the User understands and agrees that there is no guarantee that the information may not be accessed, disclosed, altered or destroyed by breach of any of the physical, technical or administrative safeguards.

PAULO ROBERTO LEARDI undertakes to immediately inform the User in the event of any type of breach or system vulnerability that may affect the security of the data provided.

5. CONSENT, PURPOSE AND LEGAL BASIS

By agreeing to this and using the website, the User gives his full consent to the use of his data for the proper identification and sale of products and services, under the terms of Article 7 , items I, II and V of the General Data Protection Law.

6. OBLIGATIONS OF PAULO ROBERTO LEARDI

PAULO ROBERTO LEARDI undertakes to maintain the application with the safest possible technical and legal configuration for the User, as provided for in this term.

After user accession, the Personal Data requested will be kept confidential and may be used exclusively for the purpose that motivated the registration and within the terms of this policy.

7. USER INFORMATION

We collect information that you send us, for example, those that are provided when you register an account with PAULO ROBERTO LEARDI, namely, basic user data, such as name , email, address, phone numbers, photograph, date of birth, personal information, contact details and location information.

PAULO ROBERTO LEARDI may not share or make available the Data collected for any type of marketing or mailing without the User's express consent.

PAULO ROBERTO LEARDI will only be authorized to make the Personal Data collected available to third parties, in the following cases and exclusively within the current legal regulations:

a) When strictly necessary and/or appropriate to fulfill a contractual obligation in the relationship agreed between PAULO ROBERTO LEARDI and the user or between PAULO ROBERTO LEARDI and third parties;

b) With third parties hired to perform certain activities and services, related to the relationship between the Parties on behalf of PAULO ROBERTO LEARDI;

c) With companies of the group of which PAULO ROBERTO LEARDI is part;

d) For use with administrative purposes such as: research, planning, service development, security and risk management.

e) When PAULO ROBERTO LEARDI is required to share due to legal obligation, determination of competent authority, or court decision.

In the aforementioned cases of sharing Personal Data with third parties, all subjects involved undertake to use the Personal Data shared consistently and in accordance with this Privacy Policy and all applicable privacy and data protection laws.

PAULO ROBERTO LEARDI may share or provide Personal Data, within the appropriate or necessary parameters, to government agencies, consultants or third parties in order to comply with applicable legislation, in reason of court order or, even, if it is understood in good faith that such action is necessary to:

f) Comply with current legislation;

g) Investigate, prevent or take measures related to illegal activities, suspected or real, probable or actual violation of rights, to cooperate with public bodies or to protect national security;< /p>

h) Execution of your contracts;

i) Investigate and guard against any third-party claims or allegations;

j) The protection of the security or integrity of the provision of services;

k) Exercise or protection of rights, property or security of PAULO ROBERTO LEARDI;

l) Protection of rights, security or integrity of PAULO ROBERTO LEARDI, its employees, partners or users.

m) In case of sale, purchase, merger, reorganization, liquidation or dissolution of PAULO ROBERTO LEARDI.

PAULO ROBERTO LEARDI undertakes to inform Users about any legal demands that require the disclosure or sharing of Personal Data, under the terms of this document, except when prohibited by law or court order or even if the request is an emergency. PAULO ROBERTO LEARDI may contest these ex officio demands if it deems that the requests are excessive, vague or made by incompetent authorities.

The Personal Data collected must be adequate, relevant and not excessive in relation to the purposes for which it is collected and/or will be processed.

PAULO ROBERTO LEARDI and its suppliers declare that they use all appropriate and necessary security procedures to protect the confidentiality, security and integrity of the Users' Personal Data, doing everything possible to the prevention of possible damages due to the processing of such data.

PAULO ROBERTO LEARDI will retain all data provided or received, including Personal Data, as long as the user's registration is active and as necessary to carry out its services.

PAULO ROBERTO LEARDI will retain the Personal Data of users and keep them stored for up to 48 hours, or up to 30 days from a possible request for deletion by the data subject .

PAULO ROBERTO LEARDI may keep the Users' Personal Data archived after receiving a request for deletion or if necessary to comply with legal obligations, resolve disputes, maintain security, preventing fraud or abuse, and ensuring compliance with contracts or obligations.

The User will be entitled to request the partial deletion, alteration, correction or update of their personal data, upon express request;

The User may request the limitation or restriction of the use of their personal data, upon express request;

The User may access, withdraw or request a copy of the Personal Data and data provided in a readable format in printed form or electronically.

8. INFORMATION COLLECTION

We automatically collect certain information when you use our services, including: Location and Access Information: When you open the app, we receive periodically analytical information about location, date and time, screens accessed, geolocation, IP addresses and any other information that may be used to improve the Services. Devices: We store information related to the device used to access the Services, as well as the operating system version used, serial number, network and interaction flow. Detection of other Software: Our systems may also detect other software running on the device used, although we do not collect information related to these, such as prevention of misuse and anti-fraud devices. Cookies and Web Beacons. We use various technologies to collect information, and this may include sending cookies to your browser. Cookies are files we store on your device that serve, among other features, to store your preferences and identity. We also collect information using web beacons, which are packets of information that can be used in our services. We may use web beacons to count visits, understand and measure the performance of marketing campaigns, and determine whether or not you have opened an email sent.

9. CHANGES AND VALIDITY OF THE DATA PROTECTION POLICY

This Data Protection Policy will come into force on 01/01/2023, for an indefinite period.

This Data Protection Policy may be amended or suspended at any time, upon notification visibly on the Site/Application.

10.MEDIATION AND FORUM OF ELECTION

This policy is subject to the Law of the Federative Republic of Brazil and the Forum of the Comarca of the city of São Paulo, in the state of São Paulo, is competent to resolve any dispute with relation to it.

In the event of an incident with Personal Data, PAULO ROBERTO LEARDI, from now on, reserves the right to nominate the ACSP Business Chamber of Mediation and Arbitration - CEMAAC - as a qualified Mediation Chamber to resolve issues involving Users who hold the data, pursuant to article 52, paragraph 7 of the General Data Protection Law.

Last update: January 6, 2023