PRIVACY POLICY – ASAS DE SOCORRO

This document aims to establish the rules for data processing that include, for example, data collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, disposal, evaluation or control of information, and/or modification, communication, transfer, dissemination or extraction of data collected from USERS, in addition to the registration of their activities, in accordance with the applicable laws.

By accepting this Privacy Policy, the USER confers his/her free and express agreement with the terms herein stipulated. 

1. Glossary

1.1. For the purposes of this document, the following definitions and descriptions should be considered:

Account: the way the USER is represented when accessing certain restricted areas, exclusive features of the sites, applications and services offered by ASAS DE SOCORRO, generally corresponding to a set of data that represents the USER only, in addition to other relevant data, to ensure a more appropriate and complete relationship between ASAS DE SOCORRO and the USER. 

Cookies: small files or data packages sent by ASAS DE SOCORRO to the USER’s device to identify him/her and collect information that will help our Mission to improve services provided to the USER.

Credentials: is the set of data that the USER uses to authenticate himself in order to access certain restricted areas and / or exclusive features of the site, applications and services offered by ASAS DE SOCORRO, usually represented by login and password, but may also include additional information to assist in the authentication process.

 

Data: the set of Anonymous Data and Personal Data.

 

Anonymous Data: information that, alone or in conjunction with other Anonymous Data, does not allow the identification of a person, considering the use of reasonable and available technical means at the time of its processing. These may include gender, age and generalized geolocation (such as the city the USER is in) and statistical data.  

 

Personal Data: is information related to the identified or identifiable physical person. It may include, for example, name, address, e-mail, telephone, debit / credit card number, IP address and geolocation data. 

 

Data Protection Officer (DPO): entity (personal or organizational/legal) appointed by ASAS DE SOCORRO, responsible for acting as a  channel of communication between the institution, the USER and government authorities in matters related to this Privacy Policy and the use, collection and treatment of Data by ASAS DE SOCORRO.

 

IP address: Internet Protocol address associated with the device used by the USER. Each IP Address corresponds to an alphanumeric set of data that, together with other information, helps to uniquely identify the device that the USER is using to access the internet and, therefore, to access websites, applications and services provided by ASAS DE SOCORRO.

 

Applicable Legislation: means the legislation applicable to the relationship between ASAS DE SOCORRO and the USER, which may vary due to (i) the place where the services are provided; (ii) place of residence or residence of one of the Parties, including the USER himself; (iii) other factors specified in specific legislation. ASAS DE SOCORRO reinforces the fact that it possesses representation in several countries, being subject therefore to various other regulations, in addition to Brazilian legislation,  among them being the General Data Protection Regulation (GDPR) in English.    

 

Logs: records of USERS activities carried out on the websites, applications and services provided by ASAS DE SOCORRO.

 

Privacy Policy: meaning, as a whole, this Global Privacy Policy – Asas de Socorro and its attachments, as well as other documents expressly referenced in this Privacy Policy.

 

USERS: people who access or interact with the features offered by the websites, applications and services provided by ASAS DE SOCORRO. The USER must have the legal capacity to accept and consent to this Privacy Policy and other documents of Asas de Socorro. If the USER does not have this capacity, he/she declares that they have previously obtained all necessary authorizations to accept this Privacy Policy and other documents submitted by ASAS DE SOCORRO.



2. Data Collection

 

SUMMARY

We collect the USER’s Data as he/she provides, directly or indirectly, through access and use of the sites, applications and services provided by ASAS DE SOCORRO or its partners who have been duly authorized by ASAS DE SOCORRO (and who follow the ASAS DE SOCORRO Data privacy guidelines according to this Policy). We also explain what Cookies consist of and how the USER can manage them. 

2.1. Data will be collected:

as inserted or voluntarily submitted by the USERS on the websites, applications and services offered by ASAS DE SOCORRO, such as the creation of an Account, navigation, interaction with content and acquisition of services; when the USER submits Third Party Data to ASAS DE SOCORRO (such as friends’ data). ASAS DE SOCORRO may use the data in accordance with this Privacy Policy, declaring to the USER that he/she has obtained the necessary consent and authorization from the third parties in question to submit the data for knowledge and registration by ASAS DE SOCORRO, keeping ASAS DE SOCORRO secure against any legal liabilities; when the data is submitted in an automated way and without the need of any action by the USERS, such as by means of Cookies; or from partners who have obtained authorization to share them with ASAS DE SOCORRO. 

 

2.2. The information ASAS DE SOCORRO collects may include, but is not limited to:

 

  • name;

  • gender;

  • CPF/ personal identification number;

  • email address;

  • ZIP code;

  • telephone number and recordings (in contact with the USER);

  • date of birth 

  • payment information;

  • information about the device’s browser and operating system;

  • IP address;

  • pages visited;

  • links and buttons clicked;

  • address/contact book;

  • biometric data (such as, but not limited to, a facial photo).

2.2.1. Other data collected by ASAS DE SOCORRO are defined in item 7 of this Policy, separated by companies and, when applicable, service groups.

2.3. ASAS DE SOCORRO is not responsible for the veracity, inaccuracy or outdated information and data provided by the USER, being the responsibility of the USER to provide accurate and up-to-date information. ASAS DE SOCORRO may periodically request that the USER update the information and data provided.

2.4. ASAS DE SOCORRO uses Cookies and anonymous identifiers for audience control, navigation, security and advertising, with the USER agreeing to this use by accepting this Privacy Policy. The cookies used by ASAS DE SOCORRO can be classified in various ways:

 

Regarding validity:

  1. Session: these are temporary and remain until the web page or browser is closed. They can be used in e-commerce (for the USER to continue browsing and not lose what they put in the cart, for example), to analyze traffic patterns on the internet and to provide a better experience and contextualized content to USERS.

  2. Permanent: persist even if the browser has been closed. They can be used to remember USERS login and password information, for example, or to ensure a better user experience between different sessions.

 

Regarding ownership:

  1. Own: they are owned by ASAS DE SOCORRO, which has full control over Cookies.

  2. Third Party: are owned by third parties, but included in the USERS device through the websites, applications and services offered by ASAS DE SOCORRO.

 

As to the purpose:

  1. Strictly necessary: essential to allow the USER to use the websites, applications and services offered by ASAS DE SOCORRO, which could not be correctly offered without these Cookies. They are usually Session and Own.

  2. Performance: collect anonymous information about how USERS use and interact with the sites, applications and services offered by ASAS DE SOCORRO, allowing their profiles to be recognized and their visits and interactions recorded. They are usually Own.

  3. Of functionality: they allow ASAS DE SOCORRO to remember choices made by USERS (such as login and location) and provide more personal experiences, in addition to allowing for possible customizations (when they are available). This information can be anonymized (turned into Anonymous Data) and does not track activities outside the websites, applications and services offered by ASAS DE SOCORRO. They are usually Own and Permanent.

  4. Analytics and advertising: allows ASAS DE SOCORRO advertisers to deliver more relevant ads and information to USERS. They are also used to limit the number of times the USER sees certain ads and to measure the effectiveness of advertising campaigns. They are reminiscent of certain USER preferences and are used to help shape their profiles in order to improve the USER experience. They are generally permanent and can be from third parties (such as Google Analytics, mentioned below).

  5. Social media: allow the USER to connect with social media, such as LinkedIn, Twitter, Facebook, Pinterest and Instagram. They are generally permanent and from third parties.

  6. Security: helps ASAS DE SOCORRO to monitor fraudulent activity and protect user data from unauthorized access. They are generally permanent and from third parties.

 

2.5. The USER may opt not to accept Cookies in using the websites, applications and services provided by ASAS DE SOCORRO, but in these situations ASAS DE SOCORRO cannot guarantee the correct functioning of these websites, applications and services provided. Cookies can be accepted, deleted or rejected using management tools available on the USER’s browser.

2.6. ASAS DE SOCORRO uses Google Analytics and Google ReCaptcha for the collection and processing of Data, according to Google policies, available at https://www.google.com/intl/pt-BR/policies/privacy/partners/, https://policies.google.com/privacy and https://policies.google.com/terms with which the USER fully agrees by accepting this Privacy Policy. Any uses of the USER Data collected through these tools by Google or its partners will be the sole and exclusive responsibility of Google, with ASAS DE SOCORRO being exempt from any liability resulting from such use.

2.7. Asas de Socorro will also record the activities performed by the USER on the websites, applications and services provided by ASAS DE SOCORRO, creating logs that may include, but are not limited to: USER’s IP address; Actions performed by the USER on the websites, applications and services provided by ASAS DE SOCORRO; Addresses of the pages and screens accessed by the USER on the websites, applications and services provided by ASAS DE SOCORRO; Dates and times of each USER action on the websites, applications and services provided by ASAS DE SOCORRO, in addition to the access he/she makes to the pages and screens and the tools and features that are used; Information about the device used by the USER, version of the operating system, browser, among other installed applications and software; Session and User ID, when available; type of USER connection, such as Wi-Fi or cellular networks (EDGE, 3G and 4G, for example); and geolocation.

2.8. Other technologies may be used to obtain navigational data from the USER. However, they will always respect the terms of this Privacy Policy and the USER’s options regarding its collection and storage, and the USER will be informed in advance in case of any changes. If data other than those previously listed starts to be collected, the USER will be previously informed. The information collected by ASAS DE SOCORRO may be combined with information collected by other sources (including third party partners) or from other technologies.

3. Data Usage

SUMMARY

The Data can only be accessed by ASAS DE SOCORRO, partners, subcontractors and authorities. However, if the USER accesses partner sites or features, he/she will be subject to the practices and policies of those partners. We also list the uses we will make of the Data collected from USERS.

3.1. The data collected from USERS may be used for the following purposes: Identification, authentication and authorization; Properly attend to requests and questions, as well as provide support to USERS; Keep records updated for contact purposes by phone, email, SMS, direct mail or other means of communication; Improve the use and interactive experience while browsing the websites, applications and services provided by ASAS DE SOCORRO; Perform statistics, studies, research, project planning and surveys relevant to the activities and behaviors of the USER when using the websites, applications and services provided by ASAS DE SOCORRO, carrying out such operations in an anonymous way with Anonymous Data; Promote the services of ASAS DE SOCORRO and its partners, in addition to informing about news, features, content, news and other relevant information for maintaining the relationship with ASAS DE SOCORRO; Safeguard ASAS DE SOCORRO from rights and obligations related to the use of the websites, applications and services provided by ASAS DE SOCORRO; Collaborate and / or comply with a court order or requisition by administrative authority, as well as meet obligations to preventively report certain activities to competent authorities; Proceed with payment requests made by USERS; Send newsletters and emails that the USER has expressly agreed to receive; Manage risks and detect, prevent and / or remedy fraud or other potentially illegal or prohibited activities, in addition to violations of applicable policies or terms of use; Sharing of payment information between departments within ASAS DE SOCORRO, with the goal of facilitating the USERS experiences when using the websites, applications and services provided by ASAS DE SOCORRO; and Consultation of Data in private and public bureaus to check for accuracy, update them or request additional data.  

3.2. The use, access and sharing of the database formed under the terms of this Privacy Policy will be made within the limits and purposes of the activities of ASAS DE SOCORRO, and may be provided and made available for access and / or consultation to ASAS DE SOCORRO in addition to partners, suppliers, service providers, subcontractors, authorities or third parties in general, as long as they comply with the provisions of this Privacy Policy, the Applicable Laws or by court order. Sensitive data provided by the USER, as understood to be personal data about racial or ethnic origin, religious beliefs, political opinions, membership in any union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a physical person, will be shared exclusively with the consent of the USER.

 

3.2.1. USERS Data may be shared with entities located outside the USER’s country of residence (such as countries in the European Economic Area, South America or North America). In such cases, the processing, treatment, use and sharing of the Data will be done in accordance with the Applicable Legislation and this Privacy Policy. Specifically, when data originating from the European Economic Area is transferred to countries that have not been recognized by the equivalent qualified authorities as offering an adequate level of protection, ASAS DE SOCORRO will ensure the use of the appropriate tools and measures (such as the European Commission’s Standard Contractual Clauses). 

 

3.2.2. ASAS DE SOCORRO is committed to safeguarding the financial and banking privacy of its customers and USERS by not sharing this information with companies with which the USER has not agreed. The USER acknowledges that ASAS DE SOCORRO is obliged to fulfill a series of legal obligations under the Applicable Legislation related to the identity of its clients and the origin of the funds with which it operates. Thus, ASAS DE SOCORRO is authorized to request, and the USER is obliged to provide, additional documents and information, including those necessary for carrying out “Know-Your-Client” procedures and preventing money laundering. The information obtained by ASAS DE SOCORRO in response to the questions raised will be treated as confidential information. ASAS DE SOCORRO is authorized to share data required by Applicable Law with competent authorities and with third parties that need access to the Data to prepare / validate reports on the activities of ASAS DE SOCORRO under said legislation.  

 

3.2.3. The USER is responsible for the confidentiality, use and all acts in the use of Credentials (such as, but not limited to, login, password and authentication token). If the USER identifies or suspects that a third party has access to his password, he must change it immediately in the systems or services. The sharing of Credentials resulting from the action of the USER constitutes a violation of this Privacy Policy.

 

3.3. Henceforth the USER is aware that ASAS DE SOCORRO may perform the anonymization of Personal Data, making it Anonymous Data; the enrichment of its database, adding information from other legitimate sources – including data derived from databases of other departments within ASAS DE SOCORRO; and (iii) treatment of Personal Data based on the legitimate interest of ASAS DE SOCORRO, as provided for in the Applicable Law. The USER manifests express consent to such activities when agreeing to the terms of this Privacy Policy. 

 

3.3.1. The USER acknowledges and agrees that ASAS DE SOCORRO may use the Data to profile the USER, in order to improve its services or comply with the Applicable Legislation, including, but not limited to, “Know-your-Client” obligations. The USER’s profile will be shared exclusively under the terms of this Privacy Policy or Applicable Law.

3.4. Internally, the Data will only be accessed by professionals duly authorized by ASAS DE SOCORRO, respecting the principles of purpose, adequacy, among other necessities foreseen in the Applicable Law for the purposes of ASAS DE SOCORRO, in addition to the commitment of confidentiality and preservation of privacy under the terms of this Privacy Policy.

3.5. Anonymous Data may be collected, processed, stored, used, transferred and disclosed for specific purposes, such as data on region, information that does not expose the user.

 

3.6. ASAS DE SOCORRO has partners that can offer services through certain functions or websites accessed from the websites, applications and services provided by ASAS DE SOCORRO. The Data provided by the USER to these partners will be the responsibility of the partners, thus being subject to their own practices of obtaining and using Data, without any burden being placed on ASAS DE SOCORRO in relation to such Data.

 

3.7. ASAS DE SOCORRO values the security and inviolability of the USER Credentials. For this reason, they constantly search and monitor the internet in its various levels in order to identify, collect and process for validation purposes (authentication tests) logins and passwords potentially belonging to USERS that have been improperly published on the internet by third parties.

 

3.7.1. If, through authentication tests ASAS DE SOCORRO verifies that the USER Credentials have been compromised (made accessible to third parties), ASAS DE SOCORRO – for security purposes and in order to prevent inappropriate third party access to the USER Account and Data – will preventively block the USER Credentials. If there are any doubts – including how to unlock the Credentials – the USER can consult the terms of use on the websites, applications and services provided by ASAS DE SOCORRO, or contact the ASAS DE SOCORRO IT service center.

 

4. Data Storage

SUMMARY

The data which is collected is stored in a secure manner. At any time, the USER may request the display, correction or deletion of his Data. Except in specific cases, we may keep the Data collected for legal compliance, auditing and preservation of rights, for the period necessary to fulfill these responsibilities.

4. Data Storage

4.1. The collected data will be stored in a safe and controlled environment. However, considering that no security system is foolproof, ASAS DE SOCORRO disclaims any responsibility for any possible damages and / or repercussions resulting from failures,  viruses which lead to invasions of the database for the sites, applications and services provided by ASAS DE SOCORRO, which ASAS DE SOCORRO identifies where any of these situations has occurred, it will notify the affected USERS informing them that there was a violation of their Data and indicating that appropriate measures be taken.

4.2. The data obtained from the USER may be stored on an ASAS DE SOCORRO owned server or a third party hired for this purpose, whether they are located in Brazil or abroad, and may also be stored using cloud computing technology and / or others that may arise in the future, always with the aim of improving and enhancing the activities of ASAS DE SOCORRO. ASAS DE SOCORRO will ensure that any third parties which might eventually maintain the servers on which the Data is stored maintain security and control standards in accordance with applicable legal standards.

4.3. Through various customer service tools available on the websites, applications and services provided by ASAS DE SOCORRO, the following are made available to the USER (with the possibility of first needing to confirm his/her identity): to request access to the Data, including its display, modification involving the correction of incomplete, inaccurate or outdated or deletion / deletion of Personal Data concerning him/her; request the deletion / deletion of all of Personal Data collected and recorded by ASAS DE SOCORRO, provided that the contract between the USER and ASAS DE SOCORRO has ended, the Account has been canceled and the minimum legal period necessary for the purposes of any legal obligations on the part of ASAS DE SOCORRO has elapsed; revoke consent for the future collection, treatment, use and processing of Personal Data concerning him/her or restrict the processing of Personal Data. This will not affect the legality of the treatment and processing of Personal Data carried out prior to the cancellation, based on your consent or on the legitimate interests of ASAS DE SOCORRO. The withdrawal / cancellation of consent may prevent the USER from using to the fullest or possibly even impeding the use of the sites, applications and services provided by ASAS DE SOCORRO; request the portability of your Data; and request that ASAS DE SOCORRO no longer use Personal Data for marketing purposes.

 

4.3.1. Although the USER has requested the deletion of his/her data and revoked his/her consent, in some specific cases ASAS DE SOCORRO may be subject to laws and regulations that make it impossible to delete / revoke the Data.

 

4.3.2. The USER’s Personal Data will also be deleted when they are no longer needed, except in the event of legal or contractual justification for their maintenance (for example, to comply with any legal obligation to retain data or the need to maintain these in order to preserve the legitimate rights and interests one of the parties involved in the contract).

 

4.4. The privacy settings of the USERS and the features and resources that the USER uses influence the USER Data that will be obtained by ASAS DE SOCORRO.

 

4.5. ASAS DE SOCORRO, for the purposes of auditing and preservation of rights, keep the registration history of the USER’s Data, with ASAS DE SOCORRO having the power to permanently exclude them at its convenience or in the cases in which the law or regulatory rule requires. ASAS DE SOCORRO may also maintain the Anonymized Data and anonymized version of the Data for statistical and study purposes, even after the exclusion request by the USER or after the end of the legal custody period.

5. General Provisions:

SUMMARY

We reserve the right to update this document at any time, so please consult it frequently. If we outsource any activity, we will ensure that actions involving ASAS DE SOCORRO comply with all the provisions of this document.

5.1. The content of this Privacy Policy may be updated or modified at any time, according to the purpose or convenience of ASAS DE SOCORRO, such as for conformity to applicable laws and legal compliance of a provision of law or rule that has equivalent legal force, to which it is up to the USER to verify, whenever accessing the sites, applications or services provided by ASAS DE SOCORRO.

5.1.1. In the event of updates to this document, ASAS DE SOCORRO will notify the USER through the tools available on the websites, applications and services provided by ASAS DE SOCORRO and / or through other means of contact provided by the USER. The USER will be bound by the new terms of this document upon delivery of the notification of any updates.

5.2. Contact information for the person responsible / DPO is the email address [email protected] . The USER must contact this address in case of requests for exclusion of mailings, restrictions regarding the processing or transfer of Personal Data or to submit any questions or doubts regarding the provisions contained in this Privacy Policy.

 

5.3. Should the USER believe that ASAS DE SOCORRO has violated any legal provision or this Privacy Policy, the USER must send an email to [email protected] to lodge any complaint.

 

5.4. If outsourced companies process any Data collected by ASAS DE SOCORRO, they must comply with the conditions herein stipulated and the Information Security Standards of ASAS DE SOCORRO, mandatorily.

 

5.5. If any provision of this Privacy Policy is considered illegal or illegitimate by the authority of the location where the USER resides or of his internet connection, the other conditions will remain in full force and effect.



6. Applicable Law and Jurisdiction

 

SUMMARY

In any legal action, Brazilian law and the jurisdiction of the city of Anápolis, Goiás, Brazil apply, except where specifically provided for by the Applicable Law (such as the USER’s domicile).

6.1. This Privacy Policy will be interpreted according to Brazilian law, in the Portuguese language, the Forum of the city of São Paulo having been selected to settle any litigation or controversy involving this document, except for specific proviso of personal, territorial or functional competence by the Applicable Law.

7. Contribution Platform

 

To protect your personal information, we take appropriate precautions and follow the best security practices to make sure it is not lost, misused, accessed, disclosed, altered or destroyed. If you provide us with your credit card information, that information is encrypted using “Secure Socket Layer” (SSL) technology for payment processing purposes only.

 

The security practices on the USER’s device are your own responsibility. Our donation link is only available at https://asasdesocorro.transforme.tech/doeagora .