OBJECTIVE
Inform all Catenaccio customers and employees regarding the application of the General Data Protection Law – LGPD.
SCOPE
It applies to all Catenaccio customers and employees.
PROCESS DESCRIPTION
Catenaccio needs to collect and process personal data from its customers within the scope of the provision of services. In this sense, this Catenaccio Privacy and Personal Data Policy (hereinafter “Privacy Policy”), aims to help our customers understand what personal data we collect, how and why we use it, to whom we disclose it and how we protect their privacy. privacy when using our services.
By using the Catenaccio Platform (or any of the Websites or Applications) and any products, social networks, software services, tools, applications, features or functionality offered on or through the Website (collectively, the “Site” or “Sites”) will be express consent to the collection, use and disclosure of personal information as set out in this Privacy Policy. Please note that if you choose to share your information in an open format, such as through a third-party website such as Facebook, Instagram or other social media, it will be considered public – not personal – information.
WHY?
Catenaccio is committed to protecting the security and privacy of its customers. In this context, it has prepared this Privacy Policy, in order to affirm its commitment and respect for the rules of privacy and protection of personal data.
We want our customers to know the general rules of privacy and the terms of treatment of the data we collect, in strict compliance with the applicable legislation.
Catenaccio seeks to respect best practices in terms of security and protection of personal data, promoting/raising awareness of good practices in this area, and improving systems in order to manage the protection of data made available to it by its customers, in strict compliance with of legal obligations.
Completing the data collection forms and providing data directly or indirectly implies knowledge of the conditions of this Policy, and any other specific terms, policies and conditions regarding the services provided.
WHAT IS PERSONAL DATA?
Personal data is any information related to an identified or identifiable natural person (data subject), of any nature and regardless of the respective support. A person who can be identified directly or indirectly is considered identifiable, namely by reference to an identification number or to more specific elements of their physical, physiological, psychological, economic, cultural or social identity.
Personal data may have a different nature in certain situations, classifying them under the LGPD as “sensitive data”. These may relate to the holder’s racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic information, biometric identifiers, sex life, sexual orientation or health.
OTHER IMPORTANT DEFINITIONS
WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?
This Privacy Policy aims to inform customers about the terms of treatment of personal data by Catenaccio , determining the purposes and means of processing their data in the context of the provision of services and social networks, so it must be considered as Controller. .
Thus, when serviced by an independent third party, on behalf of Catenaccio , this third party will be considered an Operator. Thus, if there is any question regarding the privacy of the customer’s data, we ask that you also indicate who this third party is, when applicable, for the purpose of determining any infringement, intent, negligence, recklessness or malpractice.
Under the terms of this Policy, Catenaccio ‘s customers are aware of the responsibilities regarding the information provided on the personal data of the website users, social networks of other digital channels, who assume the risk in case of incomplete documentation and/or information of the users and Catenaccio customers registered on the platform.
WHAT PERSONAL DATA DO WE COLLECT AND THROUGH WHAT MEANS?
Catenaccio collects personal information provided by the customer, which information is capable of identifying him. This information collected may vary depending on your use of the Catenaccio website, as well as the type of information you choose to provide to us.
We collect your personal information when you use our Site and social media or contact us through other sources, such as when you: (i) visit/browse our Sites; ( ii ) complete forms on our Sites; ( iii ) send us an email; ( iv ) forwards information to a friend.
In particular, we may collect the following categories of personal information such as name, alias, address, email address, telephone number.
Information We Collect Automatically
We collect personal information about you.
We may use some of the information we collect about you and the services you use to help us personalize and improve your experience. In particular, we may collect the following categories of personal information (independently or through marketing service providers):
– Device identifiers: Internet Protocol (IP) address, browser type, operating system, domain name, unique device ID.
– Location data: physical location and inferred country.
– Internet or other similar network activity (through cookies, web beacons and pixel tags ): browsing history, search history, information about your interaction with our Sites, application, marketing emails or advertisements.
WHAT ARE THE PURPOSES OF COLLECTION OF YOUR PERSONAL DATA?
Customers’ personal data are processed to provide better service by Catenaccio . For this to happen, it is often necessary to cross-reference the data we collect, so that marketing actions are directed towards what the customer expects to receive from Catenaccio .
In this sense, we use personal data to communicate and manage our customer relationship. In this sense, we can contact you by letter, email, social media, SMS, Whatsapp , Telegram and other channels that we deem appropriate for administrative or operational reasons, for example, in order to send you news that may be of the your interest. We will also use your personal data to respond to your requests, suggestions or contacts, to improve our services and your experience as a Catenaccio customer .
We may use the categories of personal information mentioned above to:
– Process your request for information (eg services, referral of Independent Consultant).
– To allow emails to friends. We may provide functionality to allow you to message a friend about Site-related content through the Site. If you wish to use this feature, you can provide us with your friend’s email address so that we can facilitate your message to them.
– To verify your identity, including account-related questions.
– To send administrative communications relating to the Site, service-related announcements, etc. , which are necessary to serve you, respond to your concerns and provide the high level of customer service that Catenaccio offers. As this information may be important to our use, you may not opt-out of receiving such communications unless you explicitly withdraw your consent to our use of your personal information as described in this Privacy Policy.
– To contact you on any phone number, via a voice call or via text messages (SMS/ Whatsapp / Telegram ) or email, as authorized by our Terms and Conditions.
– To detect, prevent or investigate security breaches, fraud or other suspicious/prohibited/illegal activity; or violations of our Privacy Policy.
– Maintain appropriate records for internal administrative purposes.
– To provide important information about the services provided.
– We use your IP address and the IP addresses of all users for purposes of calculating usage levels, helping diagnose problems with servers, administering the Site, analyzing trends, internal statistics/research, including activity detection and prevention. suspicions, administer the Site, track traffic patterns, and gather demographic information for aggregate use.
– To improve our digital channels and present the content to you.
– For testing, research, analysis and service development.
– We may use these technologies to collect information for a variety of purposes, such as analyzing how our digital channels are used, personalizing your experience with us, or improving our content or offerings. Your browser may provide tools to block or delete cookies. However, if your browser is set to reject cookies or you manually delete them, you may experience problems accessing and using some of the pages and features that are currently on our digital platforms, or that we may place in the future. (Cookies)
ON WHAT BASIS DO WE TREAT YOUR PERSONAL DATA?
Catenaccio will only process your personal data when you are duly authorized. The Law requires, for the processing of personal data to be lawful, that there is an adequate legal basis for each specific processing.
Regarding the processing of your data carried out by Catenaccio to improve our services and fulfill our administrative and quality objectives, the appropriate legal basis will be the pursuit of the Controller’s legitimate interests, as well as Contractual Compliance, when applicable, in addition to the consent itself. of the customer. This implies that data subjects can object to the processing of their data for the aforementioned purposes, in accordance with the Law, if they present valid reasons related to their particular situation. In such an event, the Controller may present legitimate reasons that justify the continuation of such processing, in which case it reserves the right to continue processing its data for these purposes, as in cases where such processing is necessary for the purposes of declaration, exercise or defense of a right in legal proceedings.
Regarding the processing of data carried out by Catenaccio in the context of compliance with legal obligations, the legal basis for carrying out such treatments – mostly data communications to external entities – will be the need for the treatment for the purpose of complying with Controller’s legal obligations, including contractual compliance or legitimate interest.
WHICH CATENACCIO PROFESSIONALS HAVE ACCESS TO YOUR DATA?
Within the scope of the processing of your personal data, Catenaccio observes, at all times, the principles of data protection from conception ( privacy bydesign ). Such a commitment implies, among other things, that your personal data will be of limited access to people who need to know them in the exercise of their functions, to the strictest extent necessary for the pursuit of the processing purposes that we have already listed above.
HOW LONG DOES YOUR PERSONAL DATA BE RETAINED?
The personal data of Catenaccio customers collected are processed in strict compliance with applicable legislation, being stored in specific databases. Such data are kept in a format that allows the identification of data subjects only for the period necessary for the purposes for which they are processed.
The period during which the data is stored and kept varies according to the purpose for which the information is used. There are, however, legal requirements that oblige you to keep the data for a certain period. We take as a reference to determine the appropriate retention period the various deliberations of the data protection control authorities, namely the National Data Protection Authority.
WHAT ARE THE RIGHTS OF DATA OWNERS?
Under the terms of the applicable legislation, the data subject may request, at any time, access to personal data concerning him, as well as its rectification, the portability of his data, directly through the email of Catenaccio , or through face-to-face contact with Catenaccio .
You also have the right to:
– Request details about the categories of personal information collected about you and, if permitted and practical, a copy of the personal information (data portability).
– Request the deletion of any personal information we collect from you, subject to certain exceptions. Once your request is verified, we will proceed with it, unless an exception applies. There is a possibility that we may deny your deletion request if retention of information is necessary for us or our service providers to be able to:
– Complete the transaction for which we collect the personal information, provide you with a service you have requested, take actions reasonably foreseen in the context of our ongoing business relationship with you, or otherwise perform our contract with you.
– Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activities or prosecute those responsible for such activities.
– Debug products to identify and repair errors that impair existing intended functionality.
– Exercise freedom of expression, guarantee the right of another consumer to exercise their freedom of expression rights, or exercise another right provided by law.
– Comply with the law and relevant legislation.
– Engage in public interest or peer-reviewed scientific, historical, or statistical research that complies with all other applicable ethics and privacy laws, if deletion of the information is likely to make it impossible or seriously impair the conduct of the research, if you have previously informed consent.
– Allow only internal uses that are reasonably in line with consumer expectations based on their relationship with us.
– Fulfill a legal obligation.
– Make other internal and legal uses of this information that are compatible with the context in which you provided it.
Without prejudice to any other administrative or judicial remedy, the data subject has the right to file a complaint with the authorities if he considers that his data are not being subject to legitimate treatment by Catenaccio , under the terms of the applicable legislation and the present Policy.
WHAT SAFETY MEASURES DOES CATENACCIO TAKE ?
Catenaccio is committed to ensuring the confidentiality, protection and security of its customers’ personal data, through the implementation of appropriate technical and organizational measures to protect their data against any form of improper or illegitimate treatment and against any accidental loss or destruction of this data. . For this purpose, we have systems and teams to guarantee the security of the personal data processed, creating and updating procedures that prevent unauthorized access, accidental loss and/or destruction of personal data, committing to respect the legislation on the protection of personal data. personal data of customers and to process this data only for the purposes for which it was collected, as well as to ensure that this data is treated with adequate levels of security and confidentiality.
THE Catenaccio may, in some cases, transmit your personal data to third parties. Catenaccio has defined clear contractual rules for the processing of personal data with its operators, and requires them to adopt the appropriate technical and organizational measures to protect their personal data. However, in some cases, we may be required by law to disclose your personal data to third parties (such as supervisory authorities) over whom we have limited control regarding the protection of personal data.
The information database formed by Catenaccio can be made available to strategic business partners aiming at the benefit and generation of mutual results, such as the supply or improvement of our products, services and advertising.
Catenaccio is not responsible for the use and treatment given by Catenaccio ‘s business and economic partners to customer data collected and shared, and Catenaccio or the partner who uses them is responsible for giving due treatment and use.
It may be necessary – by law, legal process, litigation and/or requests from public and governmental authorities inside or outside your country of residence – for Catenaccio to disclose your personal information. We may also disclose your information if we determine that, for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
We may also disclose your information if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. In addition, in the event of a reorganization, merger or sale, we may transfer any and all personal information we collect to relevant third parties.
UNDER WHAT CIRCUMSTANCES IS DATA COMMUNICATION TO OTHER ENTITIES?
Catenaccio uses other entities to provide certain services. Eventually, this provision of services may imply access, by these entities, to personal data of their customers. This will be the case for entities that provide support services for Catenaccio ‘s IT systems .
Thus, any entity that characterizes itself as Operator of Catenaccio will process the personal data of our customers, in our name and on our behalf, in the strict obligation to follow our instructions. Catenaccio ensures that such entities that are characterized as Operators offer sufficient guarantees for the execution of appropriate technical and organizational measures so that the treatment meets the requirements of the applicable law and ensures the security and protection of the rights of data subjects, under the terms of the subcontracting agreement entered into with the aforementioned Operators.
Catenaccio may also transmit its customers ‘ personal data to third parties, when it deems such data communications to be necessary or appropriate:
ii . contractual compliance;
iii.legitimate interest;
i.in compliance with legal obligations/court orders, and;
ii.to respond to requests from public or governmental authorities.
In this sense, Catenaccio may transmit your personal data to any Contracting Public Entity, to the Courts, Solicitors, to the criminal police bodies or to the Public Prosecutor’s Office when notified for this purpose or when this is necessary for the fulfillment of legal obligations, as legally provided.
Catenaccio may also transmit your personal data to service providers under contract with us that support our business operations, billing, sending marketing communications, customer service, IT hosting, maintenance products, order fulfillment, aggregation data and technology services. Our agreements state that these service providers only use your information in connection with the services they provide for us and not for their own benefit.
Please note that our service providers may be located in foreign jurisdictions and your personal information may be subject to the laws of those foreign jurisdictions and accessible to law enforcement and other authorities.
In any of the situations mentioned above, Catenaccio undertakes to take all reasonable measures to ensure the effective protection of the personal data it processes.
CONTACT US
Catenaccio ‘s Data Protection Officer (“DPO”) for more information on the processing of your personal data, as well as any questions related to the exercise of the rights attributed to you by applicable legislation and, in particular, those referred to. in this Privacy Policy, through the following contact: info @ ctnc.ae .
RIGHT TO NON-DISCRIMINATION FOR THE EXERCISE OF YOUR PRIVACY RIGHTS
We will not discriminate against you for exercising any of the rights described above.
SOCIAL MEDIA
We work with social networking sites like Facebook, Twitter, Instagram, Google, LinkedIn, and YouTube . All of these companies operate third-party websites. We provide access to our digital platforms by third parties and business partners so that we can generate interest in our products among members of your social networks and allow you to share interest in products with friends in your network. Use of any features made available to you on our digital platforms by third parties may result in the collection or sharing of information about you by us or third parties. If you do not want us to have access to information about you on third-party websites, you must notify the third-party platforms not to share the information. We cannot control how your data is collected, stored, used or shared by third party websites or to whom it is disclosed. Be sure to review the privacy policies and privacy settings on their social networking sites to make sure you understand the information they are sharing. If you do not want a third party website to share information about you, you should contact that website and determine whether it offers an opportunity to opt out of sharing this information. Catenaccio is not responsible for how these third parties may use information collected from or about you.
USE BY MINORS
We do not intend our digital platforms or online services to be used by anyone under the age of 18. If you are a parent or guardian and you think we may have collected information about your child, please contact us at info@ctnc.ae .
HOW DO I KNOW ABOUT CHANGES TO THE PRIVACY POLICY?
Catenaccio reserves the right, at any time, to make changes or updates to this Privacy Policy, these changes being duly updated on our Platforms. We suggest that you check them regularly to be aware of any changes.
COOKIES POLICY
We use cookies to personalize content and advertisements, provide social media features and analyze our traffic. We also share information about your use of the site with our social media, advertising and analytics partners. Click on “Cookie Settings” to update your personal cookie preferences.
ADVERTISING COOKIES
These cookies may be set through our website by our advertising partners social media partners. They may be used by these companies to build a profile of your interests and show you relevant advertisements on other websites. These cookies may also be used to allow you to share pages and content that you find interesting on our websites via third party social networks and other websites. They do not store personal information directly, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising and may not be able to share pages or content that you find interesting through third-party social networking sites.
FUNCTIONALITY COOKIES
These cookies enable the website to provide advanced functionality and personalization. They may be created by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.
ANALYTICAL COOKIES
These cookies allow us to count visits and traffic sources so that we can measure and improve the performance of our website. They help us know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our website, and we will not be able to monitor your performance.
COOKIES STRICTLY NECESSARY
These cookies are necessary for the website to function and cannot be turned off on our systems. They are generally just a set in response to actions taken by you that amount to a request for services, such as configuring your privacy preferences, logging in or filling out forms. You can set your browser to block or alert you about these cookies, but some parts of the website will not work. These ‘cookies’ do not store any personally identifiable information.
COOKIES AND YOUR PRIVACY
When you visit any website, your browser may store or retrieve information, mainly in the form of cookies. This information may be about you, your preferences or the device and is used primarily to make the website work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Because we respect your right to privacy, you can choose not to allow certain types of cookies. Click on the different headings categories to learn more and change our default settings. However, certain types of cookie blocking may affect your experience on the site and the services we are able to offer.
Put a space to “click” saying “I agree with the terms above” authorizing the handling of data under the terms of the Law.
This acceptance must be in writing, as the law requires, or otherwise that demonstrates the owner’s will.
