Privacy Policy

Find out how the digital ALOHA collects and uses your personal data, as well your rights as a user of this website.

last update:

SEPTEMBER 2022

The privacy of visitors of our website is an extremely important matter and we are committed to protecting it.
This Privacy Policy explains how we treat, partially or entirely, in an automated or non-automated way, the personal data of users who access our website. Its purpose is to inform stakeholders about the types of data that are collected, the reasons for the collection and how the user can update, manage or delete this information.

This Privacy Policy was prepared in accordance with the General Data Protection Regulation (GDPR) No. 13,709, of 14 August 2018, and with the Federal Law of the Internet Civil Framework No. 12,965 of April 2014. Changes may apply due to any regulatory update, which is why the user is invited to periodically consult this section

intro.

1. User Rights

This website is committed to complying with the regulations foreseen in the GDPR, respecting the following principles:

a. The user’s personal data will be processed in a lawful, loyal and transparent manner (lawfulness, loyalty and transparency);
b. Users’ personal data will be collected only for specific, explicit and legitimate purposes, and cannot be further processed in a manner incompatible with those purposes (limitations and purposes);
c. The user’s personal data will be collected in an appropriate, relevant and limited way to the needs of the purpose for which they are processed (data minimization);
d. The user’s personal data will be accurate and updated whenever necessary, so that the inaccurate data is deleted or rectified when possible (accuracy);
e. User data will be treated securely, protected from unauthorized or illicit treatment and against accidental loss, destruction or damage, adopting the appropriate technical or organizational measures (integrity and confidentiality).

The user of the site has the following rights, conferred by GDPR:

f. Right of confirmation of access: it is the user’s right to obtain from the website the confirmation that the personal data concerning him are or are not subject to treatment and, if that is the case, the right to access his personal data;
g. Right of rectification: it is the user’s right to obtain from the website, without undue delay, the rectification of inaccurate personal data concerning him;
h. Right to delete data: it is the user’s right to have their data deleted from the website;
i. Right to limit the data processing: it is the user’s right to limit the processing of his personal data, obtaining it when he disputes the accuracy of the data, when the processing is illegal, when the website no longer needs the data for its the purposes, when opposed to data processing and in case of processing unnecessary data;
j. Right to oppose: it is the user’s right to oppose, at any time, for reasons related to his/hers particular situation, to the processing of personal data concerning him/her, and may also oppose the use of his/her personal data for defining marketing profiles;
l. Right to data portability: it is the user’s right to receive personal data concerning him/her and which he/she has provided to the website, in a structured format, in current use and automatic reading, and the right to transmit this data to another website;
m. Right not to be subjected to automated decisions: it is the user’s right not to be subject to any decision taken exclusively on the basis of automated data processing, including the marketing profile definitions,  which has an effect on its legal sphere or which significantly affects it in a similar way.

The user will be able to claim his/her rights through written communication sent to this website with the subject “GDPR – request”, specifying:

  • Name or corporate name, with respective registration numbers, email address and his/her representative, if applicable;
  • The claim to the website;
  • Date and user signature;
  • Any document that can demonstrate or justify the exercise of your right.

The request should be sent to the email [email protected] , or by mail, to the following address:

Travessa Francisco Vinas, 10 – Brooklin
04710-030 São Paulo / SP
Brazil

2. Obligation to not provide third party data

When using this website, in order to safeguard and protect the rights of third parties, the user of the website must provide only his personal data, and not third party data.

3. Tipos de dados coletados

The following types of user’s personal data can be collected, stored and used:

a. Information about the user’s computer, including his IP address, geographic location, operating system, type and version of the browser;
b. Records of user access and use of this website, including traffic source, visit duration, page views and navigation paths on the website. In compliance with the regulations of GDPR, the user’s access records will be collected and stored for at least six months;
c. The data eventually informed by the user using the contact form provided on the website, including the content of the message sent, will be collected and stored;
d. The data eventually informed by the user for registration or message submission, such as name, telephone number, email address and social network details, in order to receive periodic news and other communications from the website;
e. Data related to contracts signed with the user, or any commercial relations of buying, selling or service’s providing between the website and the user, may be collected and stored, as well as other data related or necessary for its execution, including the content of any communications with the user;
f. Sensitive data: NO sensitive data will be collected from users, thus understood those defined in the GDPR. Thus, there will be no collection of the following data:

data that reveals racial or ethnic origin, political opinions, religious or philosophical convictions, or any type of user’s entities membership;
genetic data;
biometric data to uniquely identify a person;
– dados relativos à saúde do usuário;
data related to the user’s health;
– data relating to the user’s sexual life or sexual orientation;
data related to criminal convictions or offenses or related security measures;

g. Data or information published by the user on this website with the intention of publishing it on the internet, including his username, profile pictures and the eventual content of his publications.

4. Legal basis for the processing of personal data

By using the services on this website, the user is consenting to this Privacy Policy.

The user has the right to withhold his consent at any time, without compromising the lawfulness of the processing of his/her personal data before the claim. The withhold of consent can be made by the email [email protected] or by mail, sent to the following address:

Travessa Francisco Vinas, 10 – Brooklin
04710-030 São Paulo / SP
Brazil

The consent of the relatively or absolutely incapacitated, especially children under 16 (sixteen) years old, can only be done, respectively, if properly assisted and represented.
Personal data necessary for providing services acquired by the user on the website may also be collected.

The processing of personal data without the user’s consent will only be carried out due to legitimate interest or for the cases provided for by law, that is, among others, the following:

a. To fulfill legal or regulatory obligations by the controller;
b. To provide studies for research institutions, guaranteeing, whenever possible, the anonymization of personal data;
c. When necessary for providing contractual terms or preliminary procedures related to a contract to which the user participates, at the request of the data holder;
d. For the regular exercise of rights in judicial, administrative or arbitral proceedings;
e. For the protection of life or physical safety of the data holder or third party;
f. For the protection of health, in a procedure performed by health professionals or by health entities;
g. When necessary to serve the legitimate interests of the controller or third party, except where the prevail of fundamental rights and freedoms of the data holder requires the protection of personal data;
h. For credit protection, including the provisions of the relevant legislation.

5. Purposes of processing personal data

The user’s personal data collected by this website are intended to facilitate, streamline and fulfill the commitments established with the user and to enforce the requests made by filling out forms.
Personal data may also be used for a commercial purpose, to personalize the content offered to the user, as well as to subsidize the website to improve the quality and functioning of its services.

This website collects user data so that profiles can be defined, that is, automated processing of personal data to evaluate certain personal aspects of the user, personal preferences, interests, reliability, behavior or geolocation. The registration data can be used to allow the user access to certain contents of the website, that are exclusively for registered users.

The collection of data related to or necessary for commercial relations of buying, selling or providing services eventually signed with the user will have the purpose of providing the parties with legal certainty, in addition to facilitating and enabling the deal’s conclusion.

The processing of personal data for purposes not provided for in this Privacy Policy will only occur upon prior notification to the user, and in any case, the rights and obligations provided for herein will remain applicable.

6. Retention period of personal data

The user’s personal data will be kept for a period not longer than required, in order to fulfill the purposes for which they are processed. The data will be stored for the time necessary to fulfill the services provided by the website, which can vary between 6 and 24 months.

The user’s personal data can only be kept after the end of their processing in the following cases:

  • Fulfillment of legal or regulatory obligation by the controller;
  • Study by a research institution, guaranteed, whenever possible, the anonymization of personal data;
  • The data transfer to a third party, as long as data processing requirements by legislation are respected;
  • For the exclusive use of the controller, with prohibited access by a third party, and anonymized data provided.
7. Recipients and transfer of personal data

The user’s personal data may be shared with the following persons or companies:

LIST OF COMPANIES WITH LINKS

Automattic e WordPress: https://automattic.com/
Elegant Themes: https://www.elegantthemes.com/
Telegram: https://telegram.org/
Tawk.to: https://www.tawk.to/
Subscribers.com: https://subscribers.com/

The data transfer can only be made to another country if the country or territory in question or the international organization concerned ensures an adequate level of protection of user data.
If there is no adequate level of protection, the website is committed to ensuring the protection of your data in accordance with the most stringent rules, through specific contractual clauses for a particular transfer, standard contractual clauses, global corporate standards or stamps, certificates and codes of conduct regularly issued.

8. Data controllers and data protection officers

a. The Controller, responsible for processing the user’s personal data (Data Controller), is the natural or legal person, the public authority, the agency or other body that, individually or in conjunction with others, determines the purposes and means of processing personal data.
On this website, the responsible for the treatment of the personal data collected is the digital ALOHA, a Brazilian company register under CNPJ 10.822.032/0001-26, represented by Luciana Soldi Bullara, who can be contacted by the email [email protected].
The person determined for the data processing will be directly responsible for processing the user’s personal data.

b. The Data Protection Officer is the professional in charge of informing, advising and controlling the data controller, as well as the workers who process the data, regarding the obligations of the website under the GDPR and other data protection provisions in national and international law, in cooperation with the competent supervisory authority.
On this website, the data protection officer is Luciana Soldi Bullara, who can be contacted by the email [email protected] .

9. Security in the processing of user's personal data

This website is committed to applying technical and organizational measures to protect personal data from unauthorized access and situations of destruction, loss, alteration, communication or dissemination of such data.

To guarantee security, solutions will be adopted that take into account: the appropriate techniques, application costs, scope, context and purposes of data processing, and the risks to the user’s rights and freedoms.
However, this website disclaims liability for the sole fault of a third party, such as in the event of a hacker’s attack or the exclusive fault of the user, such as cases where he himself transfers his data to a third party. This website is also committed to communicating the user in a timely manner, in case of any breach of the security of his/her personal data that may cause him/her a high risk to personal rights and freedoms.

The breach of personal data is a breach of security that causes, accidentally or unlawfully, the destruction, loss, alteration, disclosure and unauthorized access to personal data transmitted, stored or subject to any other type of processing.

Finally, this website is committed to treating the user’s personal data with confidentiality, within the legal limits

10. Browsing data (cookies)

Cookies are small text files sent by the website to the user’s computer to be stored, with information related to the website’s navigation.

Through cookies, small amounts of information are stored by the user’s browser so that our server can read them later. For example, data about the device used by the user, as well as their location and access time to the website, can be stored.

Cookies do not allow any file or information to be extracted from the user’s hard drive, and it is not yet possible, through them, to have access to personal information that has not come from the user or the way he uses the website’s resources.
It is important to point out that not all cookies contain information that allows the identification of a user, and certain types of cookies can be used simply for the website to be loaded correctly or for its functionality to operate in an expected manner.

The information eventually stored in cookies that allows to identify a user is considered personal data. Accordingly, all rules provided for in this Privacy Policy are also applicable to you.

a. Website cookies: these are the ones sent to the user’s computer or device and managed exclusively by the website.
The information collected through these cookies is used to improve and personalize the user experience, and some cookies can, for example, be used to remember the user’s preferences and choices, as well as to offer personalized content. This navigation data may also be shared with any website partners, seeking to improve the products and services offered to the user.

b. Social networks cookies: this website uses social network plugins, which allow you to access them through the website. Thus, in doing so, the cookies used by these networks may be stored in the user’s browser.
Each social network has its own privacy and personal data protection policy, with individuals or companies that hold them responsible for the data collected and the privacy practices adopted. The user can search, along with social networks, information about how their personal data is treated. For information, we provide the following links, from which you can consult the privacy and cookie policies adopted by some of the main social networks:

Facebook: https://www.facebook.com/policies/cookies

Twitter: https://twitter.com/pt/privacy

Instagram: https://help.instagram.com/519522125107875

Youtube: https://policies.google.com/privacy?hl=pt-GB&gl=uk

Pinterest: https://policy.pinterest.com/pt-br/privacy-policy

LinkedIn: https://www.linkedin.com/legal/cookie-policy

c. Cookies management and browser settings: the user can oppose the registration of cookies by our website simply by disabling this option in the user’s own browser. The deactivation of cookies, however, can affect the availability of some tools and functionalities of the website, compromising its correct and expected functioning. Another possible consequence is the removal of user preferences that may have been saved, damaging their experience.
The links to the help and support pages of the most used browsers are listed below, which can be accessed by the user interested in obtaining more information about the management of cookies in their browser:

Mozilla Firefox: https://support.mozilla.org/pt-BR/kb/limpe-cookies-e-dados-de-sites-no

Brave: https://brave.com/privacy/browser/

Google Chrome: https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=pt-BR

Safari: https://support.apple.com/pt-br/guide/safari/sfri11471/mac

Opera: https://help.opera.com/en/latest/security-and-privacy/

Internet Explorer: https://support.microsoft.com/pt-br/help/17442/windows-internet-explorer-delete-manage-cookies

11. Privacy Policy Changes

This version of this Privacy Policy was last updated in 09/22/2022.

The publisher reserves the right to modify, at any time and without any prior notice, these rules, especially to adapt them to the evolution of the digital ALOHA website, either by making new features available, or by suppressing or modifying those already existing.

Thus, the user is invited to periodically consult this page to check for updates.

When using the website’s services after any changes, the user demonstrates his/her agreement with the new standards. If you disagree with any of the changes, you must immediately request the cancellation of your account and submit your reservation to the customer service, if you wish.

12. Applicable law and jurisdiction

In order to resolve disputes arising from this instrument, NAME OF THE COUNTRY law will be fully applied.

Any disputes should be presented in the jurisdiction of the district where the website editor is located.

the digital ALOHA
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