We emphasize that this Policy does not apply to the treatment, by Criterion Experts, of the Personal Data of its employees, in relation to the functions they perform for Criterion Experts.
THIRD PARTY SERVICES AND APPLICATIONS
PERSONAL DATA COLLECTION
You accept and agree that Criterion Experts may collect your Personal Data in the following circumstances:
• when you visit a Criterion Experts website (each called a “Site”) or use features or resources available on or through a Site. When you visit a Site, your device and browser automatically disclose certain information (such as the type of device, operating system, browser type, browser settings, IP address, language settings, dates and times of connection to a Site and other technical communications information), some or all of which may constitute Personal Data.
• when you download or use a Criterion Experts mobile app (each called an “App”). Criteria Experts Applications may record certain information (including Application usage statistics, device type, operating system, Application settings, IP address, language settings, Application connection times and dates, location data and other information from communications), some or all of which may constitute Personal Data.
• when you register for any service provided by Criterion Experts through a Site or an Application or when you start any session on a Site or an Application, including the following: registration details, username, e- mail.
• when you contact Criterio Experts, either in person, by mail, by phone, online, by electronic communication or by any other means of communication.
RECEIPT OF PERSONAL DATA FROM THIRD PARTIES
You accept and agree that Criterion Experts may receive your Personal Data from third parties in the following circumstances:
• If you choose to make a payment directly to Criteria Experts, it may receive your Personal Data from third parties as information about payment service providers, for the purposes of that payment, including: purchase details, payment details, etc.
• If a credit check is carried out by Criterion Experts on your behalf in connection with a credit application, in accordance with Applicable Laws, Criterion Experts may receive your Personal Data from credit verification agencies and other third parties for the purpose of verification credit, including: confirmation of whether or not the agency was able to verify your reference verification data and results, including your credit rating.
• Within the scope of its obligations and under the terms of the Applicable Laws, Criterion Experts may receive your Personal Data from public bodies.
DATA COLLECTED AUTOMATICALLY – COOKIES
Navigation cookies are text files containing small amounts of data that are transferred to a device, or more precisely, to the browser that is used on the device, when visiting a website. Cookies are used to make websites work in their entirety, to monitor their movements on the website, and to memorize user behavior from the start of the session. The placement of cookies will help the website to recognize your device on a next visit.
We may use both cookies (which expire after closing the browser) and cookies without an expiration date (which remain on your computer, or mobile device until you delete them) to provide you with a more personal and interactive experience on our website. We use two types of cookies: First, cookies inserted by us on your computer or mobile device
, which we use to recognize when you return to visit our website; and third party cookies that are for services provided by third parties on our website, and that can be used to recognize when your computer, or mobile device visits our and other websites.
At any time, you can, through your internet browser (browser) decide to be notified about the receipt of cookies, as well as block the respective entry in your system.
CATEGORIES OF PERSONAL DATA PROCESSED BY OR ON BEHALF OF THE EXPERTS CRITERIA
The categories of Personal Data that can be processed by or on behalf of Criterion Experts, to meet the legal or contractual purposes arising from the relationship established, in accordance with this Policy (to the extent permitted by the General Data Protection Law), include:
• Personal data: name; sex; photography; date of birth; profession; company or employer; sector;
• Contact details: e-mail address; Postal code; phone number; fax number; customer identification number;
• Data related to Sites or Applications: technical data (as described above, including device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connection to a website, statistics of use of the Application, Application definitions, dates and times of connection to the Application, location data and other technical communication information necessary for the operation of the Site or Application in question; username; password; security login details usage data, aggregated statistical information;
• Business data: financial details and payment information (including bank details or credit card details provided in connection with a purchase);
• Marketing data: advertising interests; cookie data; clickstream data; browsing history; responses to direct marketing; and cancellation of direct marketing.
• Criterion Experts may collect or obtain personal data that is manifestly made public by you, including through social networks (for example, we may collect information from your profile (s) on social networks, if you make a public publication about we).
LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
When processing your Personal Data for the purposes set out in this Policy, Criterion Experts may, depending on the circumstances, rely on any of the following legal bases:
• we obtained your express consent prior to treatment, including, but not limited to, when interacting with any third party content or advertising on a website or an Application (including third party plugins and cookies), Criterion Experts receives your personal data from said third parties providing such content or advertising;
• we have a legitimate interest in carrying out the processing (including our legitimate interests in operating our business, providing you with services, alerting you to other services that may be of interest to you and maintaining or improving our services) and there is no undue risk to your rights, freedoms or interests;
• treatment is necessary in the context of any performance of a contract entered into with you or for your benefit or preliminary procedures related to this contract;
• treatment is required by applicable laws;
• treatment is necessary to protect the vital interests of any individual; or
• any other legal basis available under Applicable Law.
TREATMENT OF YOUR SENSITIVE PERSONAL DATA
Criterion Experts does not collect or process your Sensitive Personal Data, except when:
• treatment is required or permitted by Applicable Laws;
• treatment is necessary to establish, exercise or defend legal claims;
• Criterion Experts has obtained your prior explicit consent before processing your Sensitive Personal Data; or
• any other legal basis for the Treatment of Sensitive Personal Data.
PURPOSES FOR WHICH EXPERTS CRITERIA CAN TREAT YOUR PERSONAL DATA
Criterion Experts may process your Personal Data for the following purposes, in particular, to the extent permitted by the General Data Protection Law:
• to display the contents of a Site, Application or Device and any customizations you may select;
• to monitor, adapt, update, protect and improve the services we offer you;
• To fulfill and execute a signed contract or preliminary procedures related to a contract;
• to respond to your requests for assistance and support needs;
• to manage content
, promotions, questionnaires or other features of a Site, Application or Device;
• to send you relevant information for previously contracted services, subject to compliance with Applicable Laws with respect to direct marketing;
• to send you communications about the administration of your accounts and the functionality of a Site, Application or Device;
• to give effect to your legal rights and your rights under this Policy;
• to protect against fraud, identity theft and other illegal activities in the fulfillment of the established relationship, whether in the commercial or contractual scope;
• to establish or exercise the legal rights of Criterion Experts or defend legal claims;
• to comply with Applicable Laws and our other applicable policies.
DISCLOSURE OF YOUR PERSONAL DATA
Criteria Experts will not sell, exchange or rent your Personal Data to third parties without your consent. We may, however, share or disclose your Personal Data to third parties in the following circumstances:
• to Criterio Experts employees, to the extent necessary to provide services and comply with legal obligations;
• with recipients of Criterion Experts for the purpose of managing our business, operating the Sites, Applications or Devices, providing products or services selected by you or for the purposes set out in this Policy;
• with recipients outside the Criterion Experts, for the purpose of managing our business, operating the Sites, Applications or Devices, providing services selected by you or for the purposes set out in this Policy;
• through external service providers to help us operate our business, operate Sites, Applications or Devices, provide products or services selected by you or manage activities on our behalf, such as sending newsletters or surveys. We may share your Personal Data with these third parties for the purposes set out in this Policy;
• only with your consent, to share your Personal Data with our external marketing partners for direct marketing purposes, and you can withdraw your consent at any time or object to the processing of your Personal Data for purposes direct marketing;
• in the event of a sale, merger or transfer of all or part of our business or assets (including in the case of reorganization, dissolution, liquidation or other corporate restructuring), we may disclose your Personal Data to the potential seller or buyer or their representatives , provided that we take appropriate measures to ensure the security and confidentiality of your Personal Data;
• to the extent necessary to establish, exercise or defend legal claims; (ii) if required by applicable laws or regulations; (iii) in response to requests from government agencies and law enforcement authorities; (iv) when disclosure is necessary or appropriate to avoid physical damage or significant financial loss; and (v) for the purpose of investigating illegal activities.
INTERNATIONAL TRANSFER OF PERSONAL DATA
Specifically, the content and resources of a Site, Application or Device may be provided through servers located outside its jurisdiction (including, without limitation, servers located in the United States). Your Personal Data may be transferred and processed using these servers or other Processing Facilities, as part of the operation of a Site, Application or Device or in association with any of the Processing purposes indicated in this Policy, always in accordance with the provisions Applicable Laws. These transfers are necessary to provide you with our services efficiently and effectively.
PROTECTION OF YOUR PERSONAL DATA
Criterion Experts is committed to treating your Personal Data in a safe manner and in accordance with the Personal Data Protection Act. We adopt appropriate data processing practices and adequate technical and organizational security measures to protect Personal Data from unauthorized access, alteration, div
ulgation or destruction. The Internet is not, in itself, a safe environment and we cannot provide an absolute guarantee that your Personal Data transferred over the Internet will always be protected. The transmission of Personal Data over the Internet is your responsibility and you should only use secure systems to access Sites, Applications or Devices.
You are responsible for keeping your access credentials for each Site, Application and Device secure and confidential. You must change your access credentials frequently and you must notify Criterion Experts immediately if you become aware of any misuse of your access credentials and change them immediately.
ADVERTISING AND MARKETING
We may collect, process and use your Personal Data periodically by email, text message or other electronic or communication means for the purposes of advertising or market research and, in particular, to improve the services offered by Criterion Experts, and to provide information about services that may be of interest to you. Alternatively, you can use the cancellation functions provided through our Sites and Applications or, even, through our Supervisor.
Criterion Experts may also allow third parties, such as analytics companies, advertisers and ad networks, to automatically collect information about You, through our websites, using cookies, web beacons and device identifiers, including Personal Data about your online activities over time and across different sites, devices, online channels and applications, when You use our sites. Among other things, this may allow targeted advertising from Criterion Experts or third parties to be shown to You when you are visiting other sites, for example, advertising relevant to your location or for services You have looked at, recommended or purchased. However, if you see such advertising, it does not mean that we provide advertisers with Personal Data, such as your name, address and date of birth.
Please be aware that even if you cancel marketing or advertising communications, we can, however, continue to contact you to send instructions, administer your account or as required or permitted by Applicable Laws.
CHILDREN AND ADOLESCENTS DATA
Our website is not intended for children under 18. If a parent or guardian finds that your child has provided personal data on our website without your consent, you should contact us immediately. We will delete all of this data as soon as possible.
We will use your email address only for the purposes for which You authorize.
If You have expressly agreed to receive marketing emails or newsletters, You agree to receive communications from Criterion Experts with content selected or prepared by us or emails with advertising at the email address You have provided to us. Criteria Experts communications may appear at regular or irregular intervals and, in addition to information pertaining to Criterion Experts, may contain offers from Criterion Experts business partners or third parties. You can unsubscribe from Criteria Experts communications at any time, through the link for that purpose, present in the messages themselves.
THE RIGHTS OF PERSONAL DATA HOLDERS
It is your responsibility to ensure that your Personal Data stored by Criterion Experts is complete, correct and up to date. Under applicable laws, you may have the following rights:
• the right to access your Personal Data processed by us;
• the right to correct and / or update your Personal Data;
• the right to anonymize your Personal Data;
• the right to the portability of your Personal Data to any other entity, in a structured manner;
• the right to delete your Personal Data processed by us;
• right to information about public and private entities that the company has shared its Personal Data with;
• the right to object, for legitimate reasons, to the Processing of your Personal Data;
• the right to request, for legitimate reasons:
o the deletion of your Personal Data processed by us; and
o the restriction of the Processing of your Personal Data processed by us;
• if we process your Personal Data with your consent, the right to revoke that consent; and
• the right to file complaints regarding the Processing of your Personal Data before the National Data Protection Authority.
This does not affect your regulatory rights. You can exercise any of these rights using the contact details.
If you want to exercise any of the above rights or have any questions or concerns about how your personal data is being used by us, please
contact email@example.com. Please note that these rights are not absolute and, in some circumstances, we may have the right to refuse your request, in whole or in part.
END OF DATA PROCESSING
Criterion Experts will end the processing of your Personal Data in the following cases:
• when the purpose has been achieved or the data is no longer required under this Policy;
• when the time required for processing is reached;
• when you request the deletion of the Data;
• by determination of the national data protection authority or other legally constituted authority.
You are aware that, even after the completion of the Data Processing, Criterion Experts may keep the Personal Data for the following purposes:
• compliance with legal or regulatory obligation;
• transfer to third parties, when applicable;
• anonymized use by Criterion Experts.
INFORMATION SECURITY AND CONFIDENTIALITY
Criterion Expert takes precautions to protect your Personal Data from loss, misuse, unauthorized access, publication, alteration and distribution. We have implemented technical and organizational measures to protect your Personal Data and we contractually require our suppliers and service providers to protect your Personal Data with the same degree of care.
ACCEPTANCE OF THIS POLICY
When using our services, any Site, Application or Device, it is considered that you have accepted this Policy. If you do not accept the terms set out in this Policy, you must not use our services, Sites, Applications or Devices.
If you contact us, we will try to investigate and resolve each issue or complaint within 15 days or any other period required by Applicable Laws.
Keep in mind that email communications are not always secure. Therefore, do not include sensitive information in your emails to us.
In this Policy, the following terms shall have the meanings indicated below, unless expressly stated otherwise:
“Personal Data (s)”: means any information that, directly or indirectly, alone or accompanied by other data, identifies or can identify an individual. Examples of personal data are: name, CPF, CTPS number, Internet Protocol (IP) number, e-mail address, bank account number, financial profile, taxpayer identification, professional registration, geolocation, among others. This concept includes Sensitive Personal Data, as defined below.
“Sensitive Personal Data (s)”: means any information that reveals, in relation to an individual, racial or ethnic origin, religious belief, political opinion, union membership or religious organization, philosophical or political, health or sexual life data, genetic or biometric data, when linked to an individual, in addition to those Personal Data whose treatment will reveal a Sensitive Personal Data.
“Third Party (ies)”: means any Person, whether physical or legal, other than Criterion Expert C or affiliated companies or of the same economic group as Criterion Expert, and includes subcontractors of Criterion Expert.
“Holder (s)”: means in relation to a given Personal Data, the natural person identified or who can be identified to whom that Personal Data refers.
“Treatment”: means any and all operations carried out on Personal Data or Sensitive Personal Data, including, but not limited to, the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, filing, storage , elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.