Brazil's General Data Protection Law (LGPD), Law No. 13,709/2018
This Policy forms part of the Terms of Use of the Cademí Platform. Please read the following terms carefully and attentively, as they contain important information about the privacy and protection of your data. The processing of personal data is a condition for using the Cademí Platform. The Platform's features cannot be provided without access to this data. This Policy and any updates to it shall prevail over all prior policies, proposals, contracts, understandings and agreements, whether oral or written, that may exist between the parties and that relate, directly or indirectly, to privacy.
Introduction
(I) The solutions offered on the Cademí Platform (referred to simply as "Cademí") are made available by CADEMI SOLUCOES DIGITAIS LTDA., a private legal entity registered with the Brazilian National Register of Legal Entities (CNPJ/MF) under No. 42.866.607/0001-07.
(II) The purpose of this Privacy Policy ("Policy") is to set out the rules on (a) how and for what purposes Cademí processes personal data when you use our platform; (b) with whom such data may be shared; and (c) how Users can manage their data.
(III) Please note that Cademí's features cannot be provided without access to this personal data. In other words, the processing of personal data is a condition for using Cademí.
(IV) Cademí reserves the right to amend this Policy at any time, updating its content as required by technological improvements or changes to its features.
(V) Whenever this Policy is amended, Cademí will notify its Users by any of the following means: a notice posted in a prominent area of Cademí, email, or any other means that allows us to reach you. You should likewise review the current version of this Policy each time you visit Cademí.
(VI) If you do not agree with the new terms of the Policy, you must stop using Cademí.
(VII) The official language of this Policy is Portuguese. Any version in another language is a translation provided as a courtesy. In the event of any conflict or discrepancy in interpretation, the Portuguese version shall prevail with respect to the personal data processed by Cademí.
1. General Information
1.1. Types of Users
Cademí is intended for the following types of users:
1.1.1. Customer:
Any person who engages Cademí to deliver their content and build their own membership platform.
1.1.2. User:
Any person who accesses Cademí through a registration made by the means that the Customer chooses to integrate and/or enable on the platform.
1.2. Sharing with third parties
Through this Policy, we want to give you transparency about which of your personal data we process on Cademí. Please note that some of your personal data is shared with third parties so that Cademí can function effectively.
2. Data of children under 13
2.1. Processing of children's data
We do not collect, or knowingly request, personal data from children under the age of 13. If we become aware that we have collected personal data from a child under 13, we will close the account created on the Platform and delete the personal data, retaining only such personal data as is intended to prevent a new registration attempt. Adolescents between 13 and 18 years of age who use Cademí will have their personal data processed in accordance with this policy.
3. Personal data processed
3.1. Provision of data
To use Cademí, you will have an account, and for that purpose you will need to provide certain types of personal data. Among other activities, we collect personal data to enable Cademí to function:
3.1.1. Registration Data:
The information requested from the User to hold an access account on Cademí, which allows the User to be identified, such as: (a) Full name; (b) Email; (c) Password;
3.1.2. Profile Data:
The information that the User provides to Cademí, through Cademí, after creating their account in order to complete their profile, such as: (a) Mobile phone number; (b) Address; (c) Profile picture.
3.1.3. Activity Data:
We collect information relating to your use of Cademí, such as: (a) Frequency of use of Cademí; (b) Information about the User's browser, in the case of web use; (d) Product Usage Data; (f) The User's connection data.
3.1.4. Support Data:
(a) Name; (b) Email; (c) Subject; (d) Department to which the request is addressed; You may, at your discretion, submit other types of documents, information and/or data to support ("Supplementary Documents"). Cademí may also request supplementary documents that will assist in handling your request.
4. Purposes of data collection and processing
Registration Data
- To complete the registration;
- To identify the User with Cademí;
- To enable the User to access Cademí through authentication;
- To contact the User, when necessary;
- To send notices;
- To provide support services;
- To adapt the structure of events to the special needs of each category of User;
Profile Data
- To personalize the User's experience;
- To enable the Customer to ship physical products;
Activity Data
- To enhance the User's experience on Cademí;
- To continuously improve Cademí;
- To keep a record of purchase history;
- To keep a record of access history;
- To keep records of acceptance of terms of use defined by Customers;
- To analyze browsing and usage in order to optimize the Platform;
Support Data
- To provide support to the User in order to address the requests submitted;
- To verify registrations;
- To verify content;
- To verify the User's identity; and
- To update the Customer's registration on the Platform.
5. Cookies
5.1. Use of "Cookies"
When you access Cademí, we may use "Cookies" to recognize the User's profile and personalize their experience on our Platform, as well as the services and other content available on the Platform.
5.2. What "Cookies" are
"Cookies" are small text files transferred to the User's device that help identify a User.
5.3. "Cookies" functionality
Certain features are available only through the use of Cookies. If the User disables or refuses this function, the use of Cademí may be limited or impossible.
5.4. "Cookies" Policy
For more detailed information on how personal data is collected and on the use of cookies and similar tools, please see our Cookie Policy
6. Public Information
6.1. Access to Comments and Questions
Comments and questions posted on Cademí are public and may be accessed by any User, as may replies to other Users' comments.
6.2. Responsibility for Information
Please remember that the information you share through Cademí may be accessed by any User. Be careful about what you disclose publicly, especially sensitive personal data.
7. Deletion of Personal Data
7.1. Retention Period:
All personal data processed as set out in this Policy will be retained by Cademí for as long as necessary for the respective purposes. We may also retain information as required by law or regulation or for the regular exercise of rights, or in circumstances where Cademí or third parties have a legitimate purpose.
7.2. Deletion Requests
You may delete your Cademí account at any time through the support channels that the Customer makes available to its Users; any other means used for this purpose will be ineffective. In this case, we may retain information as required by law or regulation or for the regular exercise of rights, or in circumstances where Cademí or third parties have a legitimate purpose.
8. Data Sharing
Customer
Data shared: Registration Data, Profile Data, Activity Data and Support Data.
Purposes:
- Providing Cademí's features;
- Delivering content and other items;
- Improving content;
- User support;
Judicial or governmental authorities, or third parties to whom we are required to disclose data by law, regulation or court order
Data shared: Registration Data, Profile Data and Activity Data.
Purposes:
- To comply with requests made by judicial or governmental authorities, as provided for in applicable law or regulation; and
- To comply with laws or regulations.
Service Providers
Data shared: Registration Data, Profile Data, Activity Data and Support Data.
Purposes:
- To enable Cademí to carry out its activities;
- To enable the improvement of Cademí's services and operations, including, without limitation, data backup services, fraud prevention services, email service providers and database providers, among others;
- To enable support to be provided;
- To process and store personal data; and
- To send communications.
9. Rights regarding your Personal Data
9.1. Rights and Guarantees
Users have rights and guarantees regarding their personal data. We provide the mechanisms described below so that Users can exercise their rights with clarity and transparency. Whenever necessary, our team will be ready to review any requests.
9.2. Rights under the LGPD
Under Brazil's General Data Protection Law (Law No. 13,709/2018) ("LGPD"), you have the right to:
- Confirm that we process your personal data;
- Access your personal data;
- Request the correction of incomplete, inaccurate or outdated personal data;
- Request the anonymization, blocking or deletion of personal data that is unnecessary, excessive or processed in breach of the LGPD;
- Request the portability of your personal data to another provider of services or products, subject to our trade and industrial secrets, once regulated by the National Data Protection Authority (ANPD);
- Request the deletion of personal data processed on the basis of your consent, except in the cases where retention of personal data is permitted under the LGPD;
- Request information about the parties with whom we share your personal data;
- Request information about the possibility of not giving your consent and the consequences of doing so;
- Withdraw your consent to the processing of your personal data, where processing is based on your consent; and
- Object to processing that violates the LGPD.
9.3. Additional information
Before we respond to a request to exercise the rights mentioned above, we may ask you to provide certain information so that we can confirm your identity.
10. SPAM Practices
10.1. Our position
We oppose any and all practices that promote SPAM of any kind, and we are committed to ensuring that the messages sent by Cademí are always of interest or relevance to their recipients. In addition, the User may at any time choose to stop receiving emails from Cademí by adjusting their email preferences or by closing their account.
10.2. Cademí Guidelines
Likewise, we require our Customers not to engage in SPAM and to ensure that the messages they send are always of interest to the recipient. Customers acknowledge that failure to follow good Internet practices may result in the termination of the offending Customer's account on Cademí, as set out in the Terms of Use, as well as in the disclosure of their Registration Data and Profile Data, in accordance with this Privacy Policy.
11. Information Security
11.1. How we protect your data
The data collected by Cademí will be stored in secure databases, in line with best practices, with access restricted to employees holding the appropriate credentials, who are required to keep the information confidential and not to misuse it.
12. Contact information
CADEMÍ SOLUÇÕES DIGITAIS LTDA
Postal code (CEP): 11.035-260
Alameda Armênio Mendes, 66, Sala 1.111
Santos, São Paulo, Brazil
To contact the Data Protection Officer (DPO) of the Cademí companies, Renan Corrêa Pinto, please write to: lgpd@minhacademi.com.br