THE USER'S RIGHTS AND PREFERENCES
The General Data Protection Law (Law No. 13709/18), also referred to as the LGPD, provides individuals with certain rights in relation to the handling of their personal data. In accordance with the applicable legislation and within the limits set out in that legislation, CFL INC PAR S.A. guarantees that you will have the following rights with respect to the handling of your personal data:
- The right for the existence of any data being handled to be confirmed;
- The right to have access to your data;
- The right to have incomplete, incorrect or out-of-date data amended;
- The right to have any unnecessary or excessive data, or any that is not being handled appropriately according to the law, anonymized, restricted or deleted;
- The right to be able to port your data to another service or product supplier, provided this safeguards commercial or industrial confidentiality;
- The right to ensure that the data is available, authentic, complete and kept confidential;
- The right to be notified if there are any changes in how the data is handled;
- The right for the data not to be used for automated decisions and profiling;
- The right to object to or restrict the handling of data;
- The right to be forgotten;
- The right to limit the handling of data;
- The right for personal data to be deleted, with the consent of the owner, except in situations where it needs to be retained for legal purposes or under any legal provisions.
- The right to be informed of the public and private entities that the data has been shared with;
- The right to be informed about the option not to give consent and what the implications would be;
- The right to revoke consent, in accordance with the law.
Be aware, however, that some of these rights have still to be clarified and set out by the National Data Protection Agency (ANPD), so that they can be covered properly.
Why and how we gather your data.
However we gather your data, you can be sure that it will handled for legitimate purposes only, with respect for the assumptions provided in the law.
Examples of these purposes are: (a) to confirm your identity, (b) improve your experience with our website, (c) to enable analytics and media services provided by specialized and certified companies, such as Google and Facebook, (d) to reply to your requests, (e) book events, (f) to send information about content, news, events and any information that CFL INC PAR SA considers relevant for you and (g) to recruit and select individuals.
You may be wondering what data we collect and for what purposes it will be used. Your contact information can be gathered from the contact form available on the website, which includes (i) name, (ii) email, (iii) telephone number and (iv) full address and will be used (a) to identify you when replying to requests made through our service channels and (b) to send you information about content, news, events and any information that we consider relevant to you.
In addition to the data mentioned above, we may also collect (i) your date of birth, (ii) education, (iii) areas of interest, (iv) work experience and (v) CPF, when you fill out the relevant form to indicate you are interested in working for us. This information, along with the rest, is required so that you can take part in our recruitment and selection exercises.
As with most websites, we may also collect electronically identifiable data such as, (i) cookies, (ii) records of dates and times that you interacted with our online system, (iii) which pages you accessed on our website, (iv) the Internet protocol (IP) address, (v) the region or general location where your computer or device is accessing the internet from, (vi) the type of browser and (vii) the operating system. This data is handled, in order to (a) comply with legal obligations for record keeping (The Civil Footprint of the Internet - Law No. 12965 / 2014), (b) monitor security, identify and authenticate you and (c) optimize our website to better meet the needs of our users.
We guarantee that access to your data will be limited to authorized employees only, who are trained to handle your personal data and treated confidentially and always with respect for the principles of proportionality, need and relevance.
The majority of browsers are configured to accept cookies automatically. You can, however, change these settings to block cookies or warn you when a cookie is being sent to your device. There are various ways to manage cookies: you can block them completely, block cookies for a specific website and even block third-party cookies in relation to a website.
Blocking all cookies will affect your experience of the internet, as it won’t be possible to identify your preferences, suggest content and provide relevant adverts.
Check the instructions for your browser to find out more about adjusting or changing your settings. Remember that whatever setting you prefer, will need to be replicated for all devices used to access services (such as computers, smartphones, tablets). If you like, click on the links below to find out how to change the settings for cookies in the main browsers:
Internet Explorer: https://support.microsoft.com/pt-br/help/17442/windows-internet-explorer-delete-manage-cookies
We also use analytical services, like Google Analytics, to help us to understand how users are using our service. In addition, we also use audience matching services to reach people who have visited our service or are identified in one or more of our databases.
This is done by loading a list of customers into a system or incorporating a Pixel from another service into our own, and the third-party system then combines common factors between our data and their’s. For example, we have incorporated the Facebook Pixel into our service and we can share your email address with Facebook as part of Facebook’s personalized audience use.
Google provides tools that enable you to choose whether to allow certain information collected by Google Analytics to be used, at https://tools.google.com/dlpage/gaoptout and by Google Analytics for Display Advertising or by Google’s Display Network at https://www.google.com/settings/ads/onweb/.
Social Media and External Links
In relation to social media and integrated technology, we provide some of our products through websites, platforms and services operated and controlled by other entities. In addition, we have technology operated and controlled by other entities integrated into our website and service. Some examples include:
Links. Our website includes links to other websites, platforms and other services that we do not operate or control.
Like, share and log in. We may include Pixels or SDKs on our website or service that allow content to be “liked” or “shared” or to log in to your social media account. If you choose to use this connectivity, we can receive information from the social network that you have authorized to share with us. Be aware that the social network can collect information about you independently, using this connectivity.
Sharing Personal Data
The personal data and recorded activity can be shared:
- With the relevant legal, administrative or government authorities in accordance only with legal requests, requirements, or court orders; and
- With the real estate team that is handling a purchase, strictly limited by what is necessary to make communication possible and such partners are always required to comply with the same guidance for protecting and safeguarding personal data that we apply to our services.
Storing, Maintaining or Deleting Data
The personal data handled by CFL INC PAR S.A. will be maintained intact in our databases, which are on our own servers, located in Brazil, as well as part of a cloud computing environment.
The personal data we gather will be kept for the length of time necessary for the purpose for which it was gathered, with respect for the life cycle of personal data, referred to in legislation.
As required by law, the personal data provided will be kept for a minimum period of 5 (five) years, following the end of the relationship between you and CFL INC PAR S.A. – articles 14, 27 and 34 of the Consumer Protection Code. For data collected automatically, they must specifically be kept for a minimum period of 6 (six) months, from the time at which you interacted with the online environment.
To exercise your rights or request more information about the handling of your personal data or the terms of this Policy, send an email to Pedro Nocetti, who is responsible for us for this matter, at the following email address: email@example.com.
Came into effect on: May 10th, 2021.