Data Controller and Owner: Alianza Global

Owner contact email: caterina.fagundes@gmail.com

Types of Data Collected

Among the types of Personal Data that this website collects, by itself or through third parties, there are: name; phone number; email; «various types of Data; Tracker; Usage Data.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using this website.

Unless specified otherwise, all Data requested by this website is mandatory, and failure to provide this Data may make it impossible for this website to provide its Services. In cases where this website specifically states that some Data is not mandatory, Users are free to not communicate this Data without any consequences to the availability or the functioning of the Service.

Users who have doubts about which Personal Data is mandatory are invited to contact the Owner.

Any use of «Cookies» – or other tracking tools – by this website or by the owners of third-party services used by this website» is for the purpose of providing the Services requested by the User, in addition to the other purposes described in this document and in the Cookie Policy, if available.

Users are responsible for any Personal Data of third parties that are obtained, published, or shared through this Service (this website) and confirm that they have the authorization of the third parties to provide the Data to the Owner.

Mode and place of processing the Data

Method of processing

The Owner will take appropriate security measures to prevent unauthorized access, disclosure, alteration, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and means strictly related to the indicated purposes. In addition to the Owner, in some cases, the Data may be accessed by certain types of persons in charge, involved with the operation of this Service (this website) (administration, sales, marketing, legal administration of the system) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, when necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis for processing

The Owner may process Personal Data related» to Users «if one of the following applies:

• Users have given their consent for one or more specific purposes; Note: According to some legislation, the Owner may be permitted to process Personal Data UNTIL the User objects to it («opt-out»), without having to rely on consent or any other legal basis that follows. This, however, does not apply whenever the processing of Personal Data is subject to the European data protection legislation; the provision of Data is necessary for the fulfillment of a contract with the User and/or any pre-contractual obligations thereof;
• the processing is necessary for compliance with a legal obligation to which the Owner is subject;
• the processing is related to a task that is carried out in the public interest or in the exercise of an official authorization in which the Owner is invested;
• the processing is necessary for the purpose of legitimate interests pursued by the Owner or by a third party;
• In any case, the Owner will gladly cooperate to clarify which legal basis applies to the processing, and in particular» whether the provision of Data is a mandatory requirement by law or contract, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owners’ headquarters of operation and in any other places where the parties involved in the processing are located.

Depending on the location of the User, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users also have the right to be informed about the legal basis of «Data transfers to countries outside the European Union or to any international organizations governed by public international law or formed by two or more countries, such as the UN, and about the security measures taken by the Owner to protect their Data.

If any such transfers occur, Users can find out more about it by checking the relevant sections of this document or by asking the Owner using the information provided in the contact section.

Retention period

Personal Data will be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User will be retained until such contract has been fully performed.
• Personal Data collected for purposes related to the legitimate interests of the Owner will be retained for as long as necessary to fulfill such purposes. Users may obtain specific information about the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given their authorization for such processing, as long as such authorization has not been withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the fulfillment of a legal obligation or in compliance with an order from an authority.

Once the retention period expires, Personal Data will be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as: Contacting the User and Analytics.

For specific information about the Personal Data used for each purpose, the User may consult the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Contacting the User

Contact form (this website)

By filling in the contact form with their Data, the Users authorize this website to use these details to reply to requests for information, quotes, or any other kind of request as indicated by the form’s header.

Personal Data processed: email; name; phone number; various types of Data.

Category of personal information collected according to CCPA: identifiers; internet information.

Mailing list or newsletter (this website)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this website. Your email address might also be added to this list as a result of signing up to this service (this website) or after making a purchase.

Personal Data processed: email; name; phone number.

Category of personal information collected according to CCPA: identifiers.

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google LLC)

Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this service (this website) to prepare reports on activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data processed: Usage Data; Tracker.

Place of processing: USA – Privacy Policy – Opt Out.

Category of personal information collected according to CCPA: internet information.

This processing constitutes a sale based on the CCPA definition. In addition to the information in this clause, the User may find information on how to opt out of the sale in the section describing the California consumers’ rights.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw their consent in cases where they have previously given their consent to the processing of their Personal Data.
• Object to the processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to know if their Data is being processed by the Owner, obtain disclosure on certain aspects of the processing and obtain a copy of the Data being processed.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of, or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to lodge a complaint before their competent data protection authority.

Details about the right to object to processing

In cases where Personal Data is processed for a public interest, in the exercise of an official authorization vested in the Owner, or for the purposes of legitimate interests pursued by the Owner, Users may object to such processing by providing a reason related to their particular situation to justify the objection.

Users must know, however, that should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. Users can refer to the respective sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as promptly as possible and in all cases within one month.

Additional information about Data collection and processing.

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in court or in the stages leading to possible legal action arising from improper use of this Service (this website) or the related Services.

The User declares to be aware that the Owner may be required to reveal Personal Data upon request of governmental authorities.

Additional information about the User’s Personal Data

In addition to the information contained in this privacy policy, this website may provide the User with additional and contextual information about specific services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this website and any third-party services may collect files that record interaction with this website (system logs) or use other Personal Data (such as IP Address) for this purpose.

The information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This website does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Service (this website) and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Information for California consumers

This part of the document integrates with and supplements the information contained in the rest of this privacy policy and is provided by the company operating this website and, as the case may be, its parent companies, subsidiaries and affiliates (for the purposes of this section, hereinafter referred to collectively through the pronouns “we,” “us,” “our” and “ours”).

The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to the “California Consumer Privacy Act of 2018” (CCPA) (Users will hereinafter be referred to through the pronouns “you” and “your”) and, for such consumers, these provisions supersede all other possibly divergent or conflicting provisions contained in this privacy policy.

This part of the document uses the term “personal information” as defined in the California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed, or sold

In this section, we summarize the categories of personal information that we collect, disclose, or sell and the respective purposes. You can read about these activities in more detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We collect the following categories of personal information about you: identifiers and internet information.

We will not collect additional categories of personal information without notifying you.

How we collect information: what are the sources of the personal information we collect?

We collect the above-mentioned categories of personal information, either directly or indirectly, from when you use this website.

For example, you provide your personal information directly when you submit requests through any forms on this service (this website). You also provide personal information indirectly by browsing this service (this website), as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the operation of this service (this website) and its features.

How we use the information we collect: sharing and disclosing your personal information with third parties for a business purpose

We may disclose the information we collect about you to third parties for business purposes. In this case, we enter into a written contract with such third parties, requiring the receiving party to keep the personal information confidential and not use it for any purpose other than those necessary for the performance of the contract.

We may also disclose your personal information to third parties when you expressly ask or authorize us to do so in order to provide the Service to you.

To learn more about the purposes of the processing, please refer to the relevant section of this document.

Sale of your personal information

For our purposes, the word “sale” will mean any “sale, rental, lease, disclosure, dissemination, making available, transfer or other form of oral, written or electronic communication of a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration”.

This means that, for example, a sale may occur whenever a website runs ads or performs statistical analyses of its traffic or views, or simply because it uses tools such as social media plugins and similar.

Your right to opt out of the sale of personal information

You have the right to opt out of the sale of personal information. This means that whenever you ask us to stop selling your data, we will comply with your request.

Such requests may be made freely, at any time, without sending any verifiable request, simply by following the instructions below.

Instructions to opt out of the sale of personal information

If you would like to learn more or exercise your right to opt out in relation to all sales made by this website, both online and offline, you may contact us for further information using the contact details provided in this document.

What are the purposes for which we use your personal information?

We may use your personal information to enable the operational functioning of this service (this website) and its features (“business purposes”). In such cases, your personal information will be processed in a necessary and proportionate manner to the business purposes for which it was collected and strictly within the limits of compatible operational purposes.

We may also use your personal information for other purposes, such as commercial purposes (as indicated in the section “Detailed information on the processing of Personal Data” in this document), and also to comply with the law and defend our rights before the competent authorities when our rights and interests are threatened or we suffer actual damage.

We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

Your California privacy rights and how to exercise them

The right to know and portability

You have the right to request that we disclose to you: your personal information, and with whom such information is shared;in the case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:

• categories of personal information acquired by each category of recipient party; and
• for disclosures for a business purpose, the categories of personal information obtained by each category of recipient party.

The disclosure described above will be limited to the personal information collected or used in the course of the last 12 months.

If we provide our response electronically, the information included will be “portable,” i.e., provided in an easily used format to enable you to transmit the information to another entity without hindrances—provided that it is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete your personal information, subject to exceptions under the law (including, but not limited to, when the information is used for identification and repair of errors in this service (this website), for identification of security incidents and protection against fraudulent or illegal activities, for the exercise of certain rights, etc.).

If there is no legal exception in the exercise of your right, we will delete your personal information and instruct all our service providers to do so.

How to exercise your rights

To exercise the rights described above, you need to send us your verifiable request by contacting us through the details provided in this document.

For us to respond to your request, it is necessary for us to know who you are. Therefore, you may only exercise the rights above by making a verifiable request, which must:

• provide sufficient information to allow us, within reasonable limits, to verify that you are the person about whom we collect information or an authorized representative;
• describe your request in sufficient detail to allow us to understand, evaluate, and respond to it adequately.

Information for Users residing in Brazil

This part of the document integrates with and supplements the information contained in the rest of this privacy policy and is provided by the entity operating this website and, as the case may be, its parent companies, subsidiaries, and affiliates (for the purposes of this section, hereinafter referred to collectively through the pronouns “we,” “us,” “our” and “ours”).

The provisions contained in this section apply to all Users who are residents of Brazil, according to the “General Data Protection Law” (Users will hereinafter be referred to through the pronouns “you” and “your”). For such Users, these provisions supersede all other possibly divergent or conflicting provisions contained in this privacy policy.

This part of the document uses the term “personal information,” as defined in the General Data Protection Law (LGPD).

What we rely on to process your personal information

We may process your personal information only if we have a legal basis for such processing. The legal bases are as follows:Studies conducted by research entities, preferablyThe exercise of our rights in judicial, administrative, or arbitration proceedings;Protection or physical safety of you or a third partyCredit protection.To learn more about the legal bases, you can contact us at any time through the contact details provided in this document.

Categories of personal information processed

To know which categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” in this document.

Why we process your personal information

To know why we process your personal information, you can read about it in the sections titled “Detailed information on the processing of Personal Data and The purposes of processing” in this document.

Your privacy rights as a Brazilian, how to send a request, and our responses to your requests

Your privacy rights as a Brazilian

You have the right to:

• Obtain confirmation about the existence of personal information processing activities;
• Access your personal information;
• Have your incomplete, inaccurate, or outdated personal information corrected;
• Obtain the anonymization, blocking, or deletion of your unnecessary or excessive personal information, or of information that is not being processed in accordance with the LGPD;
• Obtain information about the possibility of providing or refusing your consent and the respective consequences;
• Obtain information about the third parties with whom we share your personal information;

Obtain, upon your express request, the portability of your personal information (except anonymous information) to Request clear and adequate information regarding the criteria and procedures used for an automated decision; andRequest the review of decisions taken exclusively based on the automated processing of your personal information, which affect your interests. This includes decisions to define your personal, professional, consumer, and credit profile or aspects of your personality.You will never be discriminated against or suffer any kind of harm if you exercise your rights.

How to register your request

You can register your express request to exercise your rights free of charge, at any time, using the contact details provided in this document or through your legal representative.

How and when we will respond to your request

We will do our best to respond to your requests immediately. In any case, if it is impossible, we will be sure to communicate to you the factual or legal reasons that prevent us from immediately attending to, or otherwise fulfilling, your requests. In cases where we are not processing your personal information, we will indicate the natural or legal person to whom you should forward your requests, if we are in a position to do so.

If you register a request for access or confirmation of personal information processing, be sure to specify whether you want your personal information to be delivered in electronic or printed format.

You will also need to inform us if you want us to respond to your request immediately, in which case we will respond in a simplified manner, or if you need a complete response. In the latter case, we will respond within 15 days from the moment of your request, providing all information about the origin of your personal information, confirmation of the existence or not of records, any criteria used for the processing, and the purposes of the processing, while protecting our trade and industrial secrets.

If you request rectification, deletion, anonymization, or blocking of personal information, we will immediately communicate your request to other parties with whom we share your personal information, in order to allow these third parties to also fulfill your request – except in cases where such communication proves impossible or involves a disproportionate effort on our part.

Transfer of Personal Information Outside Brazil as Permitted by Law

We are permitted to transfer your personal information outside Brazilian territory in the following cases:

• When the transfer is necessary for international legal cooperation between public intelligence, investigation, and prosecution agencies, in accordance with the legal means established in international law;
• When the transfer is necessary to protect your life, physical safety, or that of third parties;
• When the transfer is authorized by the ANPD (National Data Protection Authority);
• When the transfer arises from a commitment made in an international cooperation agreement;
• When the transfer is necessary for the execution of a public policy or legal assignment of a public service;
• When the transfer is necessary for compliance with a legal or regulatory obligation, the execution of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative, or arbitration proceedings.

Definitions and Legal References

Personal Data (or Data)
Any information that, directly, indirectly, or in connection with other information—including a personal identification number—allows the identification of a natural person.

Usage Data
Information collected automatically through this website (or third-party services engaged in this service), which may include: IP addresses or domain names of the computers used by Users of this website, URI (Uniform Resource Identifier) addresses, the date and time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the server response status (successful outcome, error, etc.), the country of origin, browser and operating system characteristics used by the User, various time details per visit (e.g., the time spent on each page within the website), and details about the path followed within the application, with special reference to the sequence of pages visited and other parameters about the User’s device operating system and/or IT environment.

User
The person using this website who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency, or other body that processes Personal Data on behalf of the Data Controller as described in this Privacy Policy.

Data Controller (or Owner)
The natural or legal person, public authority, agency, or other body that, alone or jointly with others, determines the purposes and means of processing Personal Data, including security measures related to the operation and use of this Service (this website). The Data Controller, unless otherwise specified, is the Owner of this Service (this website).

This Website
The means by which the User’s Personal Data is collected and processed.

Service
The service provided by this website as described in the relevant terms (if available) and on this website.

European Union (or EU)
Unless otherwise specified, all references made in this document to the European Union include all current member states of the European Union and the European Economic Area.

Cookie
Cookies are trackers consisting of small sets of data stored in the User’s browser.

Tracker
The term Tracker refers to any technology—such as Cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting—that enables the tracking of Users, for example, by accessing or storing information on the User’s device.

Legal Information

This privacy statement has been prepared based on multiple legislative provisions, including Articles 13/14 of Regulation (EU) 2016/679 (GDPR – General Data Protection Regulation).

This Privacy Policy applies solely to this website, unless otherwise stated in this document.