PRIVACY NOTICE
Last updated August 28,
2022
This privacy notice for us, describes how and why we might collect, store, use,
and/or share ("process") your information when you use our services ("Services"), such as when
you:
Visit our website at https://leilaosodresantoro.net, or any website of ours that links to
this privacy notice
Engage with us in other related ways, including any sales, marketing, or
events
Questions or concerns? Reading this privacy notice will help you understand your privacy
rights and choices. If you do not agree with our policies and practices, please do not use our Services.
If you still have any questions or concerns, please contact us at
[email protected].
SUMMARY
OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more
details about any of these topics by clicking the link following each key point or by using our table of
contents below to find the section you are looking for. You can also click here to go directly to our
table of contents.
What personal information do we process? When you visit, use, or navigate our
Services, we may process personal information depending on how you interact with us and the Services,
the choices you make, and the products and features you use. Click here to learn more.
Do we
process any sensitive personal information? We do not process sensitive personal information.
Do
we receive any information from third parties? We do not receive any information from third
parties.
How do we process your information? We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud prevention, and to comply with
law. We may also process your information for other purposes with your consent. We process your
information only when we have a valid legal reason to do so. Click here to learn more.
In what
situations and with which parties do we share personal information? We may share information in specific
situations and with specific third parties. Click here to learn more.
How do we keep your
information safe? We have organizational and technical processes and procedures in place to protect your
personal information. However, no electronic transmission over the internet or information storage
technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorized third parties will not be able to defeat our security and
improperly collect, access, steal, or modify your information. Click here to learn more.
What are
your rights? Depending on where you are located geographically, the applicable privacy law may mean you
have certain rights regarding your personal information. Click here to learn more.
How do you
exercise your rights? The easiest way to exercise your rights is by filling out our data subject request
form available here, or by contacting us. We will consider and act upon any request in accordance with
applicable data protection laws.
Want to learn more about what information we collect? Click here
to review the notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE
COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR
PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE
COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE
KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY
RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY
RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT
INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect
personal information that you provide to us.
We collect personal information that you voluntarily
provide to us when you express an interest in obtaining information about us or our products and
Services, when you participate in activities on the Services, or otherwise when you contact
us.
Personal Information Provided by You. The personal information that we collect depends on the
context of your interactions with us and the Services, the choices you make, and the products and
features you use. The personal information we collect may include the following:
names
email
addresses
Sensitive Information. We do not process sensitive information.
All personal
information that you provide to us must be true, complete, and accurate, and you must notify us of any
changes to such personal information.
Information automatically collected
In Short: Some
information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is
collected automatically when you visit our Services.
We automatically collect certain information
when you visit, use, or navigate the Services. This information does not reveal your specific identity
(like your name or contact information) but may include device and usage information, such as your IP
address, browser and device characteristics, operating system, language preferences, referring URLs,
device name, country, location, information about how and when you use our Services, and other technical
information. This information is primarily needed to maintain the security and operation of our
Services, and for our internal analytics and reporting purposes.
Like many businesses, we also
collect information through cookies and similar technologies.
The information we collect
includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and
performance information our servers automatically collect when you access or use our Services and which
we record in log files. Depending on how you interact with us, this log data may include your IP
address, device information, browser type, and settings and information about your activity in the
Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and
other actions you take such as which features you use), device event information (such as system
activity, error reports (sometimes called "crash dumps"), and hardware settings).
2. HOW DO WE
PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud prevention, and to comply with
law. We may also process your information for other purposes with your consent.
We process your
personal information for a variety of reasons, depending on how you interact with our Services,
including:
To request feedback. We may process your information when necessary to
request feedback and to contact you about your use of our Services.
To identify usage trends. We may
process information about how you use our Services to better understand how they are being used so we
can improve them.
To determine the effectiveness of our marketing and promotional campaigns. We may
process your information to better understand how to provide marketing and promotional campaigns that
are most relevant to you.
To save or protect an individual's vital interest. We may process your
information when necessary to save or protect an individual’s vital interest, such as to prevent
harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only
process your personal information when we believe it is necessary and we have a valid legal reason
(i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to
provide you with services to enter into or fulfill our contractual obligations, to protect your rights,
or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section
applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain
the valid legal bases we rely on in order to process your personal information. As such, we may rely on
the following legal bases to process your personal information:
Consent. We may process your
information if you have given us permission (i.e., consent) to use your personal information for a
specific purpose. You can withdraw your consent at any time. Click here to learn more.
Legitimate
Interests. We may process your information when we believe it is reasonably necessary to achieve our
legitimate business interests and those interests do not outweigh your interests and fundamental rights
and freedoms. For example, we may process your personal information for some of the purposes described
in order to:
Analyze how our services are used so we can improve them to engage and retain
users
Support our marketing activities
Understand how our users use our products and services so
we can improve user experience
Legal Obligations. We may process your information where we believe it
is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body
or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in
litigation in which we are involved.
Vital Interests. We may process your information where we
believe it is necessary to protect your vital interests or the vital interests of a third party, such as
situations involving potential threats to the safety of any person.
If you are located in Canada,
this section applies to you.
We may process your information if you have given us specific
permission (i.e., express consent) to use your personal information for a specific purpose, or in
situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent
at any time. Click here to learn more.
In some exceptional cases, we may be legally permitted
under applicable law to process your information without your consent, including, for example:
If
collection is clearly in the interests of an individual and consent cannot be obtained in a timely
way
For investigations and fraud detection and prevention
For business transactions provided
certain conditions are met
If it is contained in a witness statement and the collection is necessary
to assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons
and communicating with next of kin
If we have reasonable grounds to believe an individual has been,
is, or may be victim of financial abuse
If it is reasonable to expect collection and use with consent
would compromise the availability or the accuracy of the information and the collection is reasonable
for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada
or a province
If disclosure is required to comply with a subpoena, warrant, court order, or rules of
the court relating to the production of records
If it was produced by an individual in the course of
their employment, business, or profession and the collection is consistent with the purposes for which
the information was produced
If the collection is solely for journalistic, artistic, or literary
purposes
If the information is publicly available and is specified by the regulations
4. WHEN
AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in
specific situations described in this section and/or with the following third parties.
We may
need to share your personal information in the following situations:
Business Transfers. We may share
or transfer your information in connection with, or during negotiations of, any merger, sale of company
assets, financing, or acquisition of all or a portion of our business to another company.
5. DO
WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking
technologies to collect and store your information.
We may use cookies and similar tracking
technologies (like web beacons and pixels) to access or store information. Specific information about
how we use such technologies and how you can refuse certain cookies is set out in our Cookie
Notice.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as
long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by
law.
We will only keep your personal information for as long as it is necessary for the purposes
set out in this privacy notice, unless a longer retention period is required or permitted by law (such
as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your
personal information for longer than 90 days.
When we have no ongoing legitimate business need to
process your personal information, we will either delete or anonymize such information, or, if this is
not possible (for example, because your personal information has been stored in backup archives), then
we will securely store your personal information and isolate it from any further processing until
deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect
your personal information through a system of organizational and technical security measures.
We
have implemented appropriate and reasonable technical and organizational security measures designed to
protect the security of any personal information we process. However, despite our safeguards and efforts
to secure your information, no electronic transmission over the Internet or information storage
technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorized third parties will not be able to defeat our security and
improperly collect, access, steal, or modify your information. Although we will do our best to protect
your personal information, transmission of personal information to and from our Services is at your own
risk. You should only access the Services within a secure environment.
8. DO WE COLLECT
INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children
under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years
of age. By using the Services, you represent that you are at least 18 or that you are the parent or
guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that
personal information from users less than 18 years of age has been collected, we will deactivate the
account and take reasonable measures to promptly delete such data from our records. If you become aware
of any data we may have collected from children under age 18, please contact us at
[email protected].
9.
WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area
(EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control
over your personal information. You may review, change, or terminate your account at any time.
In
some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection
laws. These may include the right (i) to request access and obtain a copy of your personal information,
(ii) to request rectification or erasure; (iii) to restrict the processing of your personal information;
and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to
object to the processing of your personal information. You can make such a request by contacting us by
using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"
below.
We will consider and act upon any request in accordance with applicable data protection
laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your
personal information, you also have the right to complain to your local data protection supervisory
authority. You can find their contact details here:
https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are located
in Switzerland, the contact details for the data protection authorities are available here:
https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing your consent: If we are relying on
your consent to process your personal information, which may be express and/or implied consent depending
on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your
consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU
CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the
lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the
processing of your personal information conducted in reliance on lawful processing grounds other than
consent.
Cookies and similar technologies: Most Web browsers are set to accept cookies by
default. If you prefer, you can usually choose to set your browser to remove cookies and to reject
cookies. If you choose to remove cookies or reject cookies, this could affect certain features or
services of our Services. To opt out of interest-based advertising by advertisers on our Services visit
http://www.aboutads.info/choices/.
If you have questions or comments about your privacy rights,
you may email us at
[email protected].
10.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile
applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy
preference not to have data about your online browsing activities monitored and collected. At this stage
no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such,
we do not currently respond to DNT browser signals or any other mechanism that automatically
communicates your choice not to be tracked online. If a standard for online tracking is adopted that we
must follow in the future, we will inform you about that practice in a revised version of this privacy
notice.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you
are a resident of California, you are granted specific rights regarding access to your personal
information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law,
permits our users who are California residents to request and obtain from us, once a year and free of
charge, information about categories of personal information (if any) we disclosed to third parties for
direct marketing purposes and the names and addresses of all third parties with which we shared personal
information in the immediately preceding calendar year. If you are a California resident and would like
to make such a request, please submit your request in writing to us using the contact information
provided below.
If you are under 18 years of age, reside in California, and have a registered
account with Services, you have the right to request removal of unwanted data that you publicly post on
the Services. To request removal of such data, please contact us using the contact information provided
below and include the email address associated with your account and a statement that you reside in
California. We will make sure the data is not publicly displayed on the Services, but please be aware
that the data may not be completely or comprehensively removed from all our systems (e.g., backups,
etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident"
as:
(1) every individual who is in the State of California for other than a temporary or
transitory purpose and
(2) every individual who is domiciled in the State of California who is
outside the State of California for a temporary or transitory purpose
All other individuals are
defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to
certain rights and obligations regarding your personal information.
What categories of personal
information do we collect?
We have collected the following categories of personal information in
the past twelve (12) months:
Category Examples Collected
A. Identifiers
Contact details,
such as real name, alias, postal address, telephone or mobile contact number, unique personal
identifier, online identifier, Internet Protocol address, email address, and account
name
YES
B. Personal information categories listed in the California Customer Records
statute
Name, contact information, education, employment, employment history, and financial
information
YES
C. Protected classification characteristics under California or federal
law
Gender and date of birth
NO
D. Commercial information
Transaction information,
purchase history, financial details, and payment information
NO
E. Biometric
information
Fingerprints and voiceprints
NO
F. Internet or other similar network
activity
Browsing history, search history, online behavior, interest data, and interactions with our
and other websites, applications, systems, and advertisements
NO
G. Geolocation
data
Device location
NO
H. Audio, electronic, visual, thermal, olfactory, or similar
information
Images and audio, video or call recordings created in connection with our business
activities
NO
I. Professional or employment-related information
Business contact
details in order to provide you our Services at a business level or job title, work history, and
professional qualifications if you apply for a job with us
NO
J. Education
Information
Student records and directory information
NO
K. Inferences drawn from other
personal information
Inferences drawn from any of the collected personal information listed above to
create a profile or summary about, for example, an individual’s preferences and
characteristics
YES
We may also collect other personal information outside of these
categories through instances where you interact with us in person, online, or by phone or mail in the
context of:
Receiving help through our customer support channels;
Participation in customer
surveys or contests; and
Facilitation in the delivery of our Services and to respond to your
inquiries.
How do we use and share your personal information?
More information about our data
collection and sharing practices can be found in this privacy notice.
You may contact us by email
at
[email protected],
by visiting https://leilaosodresantoro.net, or by referring to the contact details at the bottom of
this document.
If you are using an authorized agent to exercise your right to opt out we may deny
a request if the authorized agent does not submit proof that they have been validly authorized to act on
your behalf.
Will your information be shared with anyone else?
We may disclose your
personal information with our service providers pursuant to a written contract between us and each
service provider. Each service provider is a for-profit entity that processes the information on our
behalf.
We may use your personal information for our own business purposes, such as for
undertaking internal research for technological development and demonstration. This is not considered to
be "selling" of your personal information.
We have not disclosed or sold any personal information
to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not
sell personal information in the future belonging to website visitors, users, and other
consumers.
Your rights with respect to your personal data
Right to request deletion of the
data — Request to delete
You can ask for the deletion of your personal information. If you ask us
to delete your personal information, we will respect your request and delete your personal information,
subject to certain exceptions provided by law, such as (but not limited to) the exercise by another
consumer of his or her right to free speech, our compliance requirements resulting from a legal
obligation, or any processing that may be required to protect against illegal activities.
Right
to be informed — Request to know
Depending on the circumstances, you have a right to
know:
whether we collect and use your personal information;
the categories of personal information
that we collect;
the purposes for which the collected personal information is used;
whether we
sell your personal information to third parties;
the categories of personal information that we sold
or disclosed for a business purpose;
the categories of third parties to whom the personal information
was sold or disclosed for a business purpose; and
the business or commercial purpose for collecting
or selling personal information.
In accordance with applicable law, we are not obligated to provide
or delete consumer information that is de-identified in response to a consumer request or to re-identify
individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a
Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy
rights.
Verification process
Upon receiving your request, we will need to verify your
identity to determine you are the same person about whom we have the information in our system. These
verification efforts require us to ask you to provide information so that we can match it with
information you have previously provided us. For instance, depending on the type of request you submit,
we may ask you to provide certain information so that we can match the information you provide with the
information we already have on file, or we may contact you through a communication method (e.g., phone
or email) that you have previously provided to us. We may also use other verification methods as the
circumstances dictate.
We will only use personal information provided in your request to verify
your identity or authority to make the request. To the extent possible, we will avoid requesting
additional information from you for the purposes of verification. However, if we cannot verify your
identity from the information already maintained by us, we may request that you provide additional
information for the purposes of verifying your identity and for security or fraud-prevention purposes.
We will delete such additionally provided information as soon as we finish verifying you.
Other
privacy rights
You may object to the processing of your personal information.
You may request
correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the
processing of the information.
You can designate an authorized agent to make a request under the CCPA
on your behalf. We may deny a request from an authorized agent that does not submit proof that they have
been validly authorized to act on your behalf in accordance with the CCPA.
You may request to opt out
from future selling of your personal information to third parties. Upon receiving an opt-out request, we
will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the
date of the request submission.
To exercise these rights, you can contact us by email at
[email protected], by visiting
https://leilaosodresantoro.net, or by referring to the contact details at the bottom of this
document. If you have a complaint about how we handle your data, we would like to hear from
you.
Metrics
Our metrics for all CCPA requests received for the previous calendar year can
be found here: https://leilaosodresantoro.net.
12. DO WE MAKE UPDATES TO THIS
NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant
laws.
We may update this privacy notice from time to time. The updated version will be indicated
by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If
we make material changes to this privacy notice, we may notify you either by prominently posting a
notice of such changes or by directly sending you a notification. We encourage you to review this
privacy notice frequently to be informed of how we are protecting your information.
13. HOW CAN
YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may
email us at
[email protected]
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the
applicable laws of your country, you may have the right to request access to the personal information we
collect from you, change that information, or delete it. To request to review, update, or delete your
personal information, please submit a request form by clicking here.