Data Privacy Policy

The company CONCILIG TELEMARKETING E COBRANÇA LTDA, with address at Rua Antônio Alves n. 29-16 CEP 17.012-431 registered with CNPJ/ME under number 08.684.859/0001-79 (hereinafter referred to as “CONCILIG” or just “Controller”), understands that it is essential and significant to be transparent to you (“User”) the way we use your electronic records and personal data in the use of the website (“Site”), serving this Privacy Policy (“Policy”) to regulate, in a simple and accessible way, our activities of processing personal data.

Our Policy reaffirms our commitment to security, privacy and transparency in the treatment of your personal information and data, describing how we collect and treat them when you access our Site.

CONCILIG does not record your personal information, unless you voluntarily provide it through registration on the Site, in the Contact tab, for example. To better illustrate how we process personal data, below is a brief summary of our Policy:

This Policy may be updated at any time by CONCILIG, by means of a notice on the website and/or by e-mail, if the User has chosen to receive communications from us.

1. WHAT DATA WE COLLECT

Depending on your relationship with CONCILIG, basic data may be collected for your identification and to allow us to contact you. When there is a need to use sensitive personal data, CONCILIG ensures that all measures required to protect the confidentiality, integrity and availability of such information will be adopted. No data will be collected unnecessarily or applied for a purpose other than the one indicated to you.

When browsing our website, CONCILIG may collect information actively entered by the User at the time of registration, as well as information automatically collected when using the website and related pages, such as, for example, characteristics of the access device, IP with date and time, among others.

In this way, there is the processing of personal data i) provided by the user and ii) collected automatically.

i. Information provided by the User: CONCILIG collects all information actively entered by the User on the Site, such as full name, e-mail, telephone/cell phone number, when filling out forms by the User. CONCILIG will use this information to promote the dissemination of institutional material, newsletters, invitations to lectures and events, among others, if the User consents to this communication.

ii. Data collected automatically: CONCILIG also collects a series of information automatically, such as: characteristics of the access device, browser, IP (with date and time), IP origin, information on clicks, pages accessed, the following pages accessed after leaving the Site, or any search term entered on or in reference to the Site, among others. To this end, CONCILIG will use some technologies such as cookies, pixeltags, beacons and local shared objects, which are used to optimize the user's browsing experience on the website, according to their habits and preferences.

It is possible to disable, through the settings of your internet browser, the automatic collection of information through some technologies, such as cookies and caches, as well as on our own Site, specifically regarding cookies. However, the User must be aware that, if these technologies are disabled, some features offered by the website, which depend on the processing of said data, may not work correctly.

The User may make requests regarding their personal data processed by CONCILIG by sending an email to dpo@concilig.com.br with the subject “My Personal Data”. We try to respond to legitimate requests within a period of 15 (fifteen) calendar days after confirming your identity. Eventually, a longer period may be necessary if the request(s) are complex and/or numerous. In this case, we will inform you and keep you updated about the progress of your request(s) through a service ticket.

2. HOW WE USE COOKIES

Cookies are files or information that may be stored on your devices when you visit applications. Generally, a cookie contains the name of the website that originated it, its lifetime and a value, which is randomly generated.

CONCILIG uses cookies to facilitate use and better adapt the applications to your interests and needs, as well as to compile information about the use of applications, helping to improve their structures and content. Cookies can also be used to speed up your future activities and experiences on the apps.

At any time, you can delete application cookies using your preferred browser settings. For more information on how to manage cookies in browsers:

Internet Explorer:https://support.microsoft.com/pt-br/help/17442/windows-internetexplorer-delete-manage-cookiesMicrosoft Edge: https://support.microsoft.com/pt-br/help/4468242/microsoft-edge-browsing-data-and-privacyMozilla Firefox: https://support.mozilla.org/pt-BR/kb/desative-cookies-terceiros-impedir-rastreamentoGoogle Chrome: https://support.google.com/accounts/answer/61416?co=GENIE.Platform=Desktop&hl=pt-BRSafari: https://support.apple.com/pt-br/guide/safari/sfri11471/mac

In addition to the options highlighted above, on the Concilig Portal (www.concilig.com.br) there is a specific application for managing cookies called AdOpt. Through this application, the user is aware of which cookies are used, how and for what they are used. In addition, it is through the same solution that the visitor will define whether he will consent to the use of cookies not classified as “Necessary or Essential”. The AdOpt solution can be accessed through an icon displayed in the lower left corner of the Portal's home page.

2.1. WHAT COOKIES DO WE USE ON OUR SITE?

The CONCILIG website is hosted on the Mobsite platform and, as a result, some platform cookies may also be used to optimize your experience with us. Thus, considering all the cookies that can be used for your access, we have:

Necessary or Essential Cookies

Functional Cookies

2.2. AM I OBLIGED TO ACCEPT THE USE OF ALL COOKIES?

You are under no obligation to grant access to cookies. However, it is important to remember that if you do not agree to provide your consent for the installation of some cookies on the CONCILIG website pages, certain services may not function optimally, compromising your navigation on the website. For this reason, the necessary cookies will be enabled and you will be able to decide how to act in relation to functional, marketing and performance cookies, being able to modify your decision at any time. To manage the consent of cookies not classified as “Necessary or Essential”, just use the AdOpt application available on the homepage of the website in the lower left corner.

3. USE OF INFORMATION AND PERSONAL DATA

CONCILIG uses your information and personal data to adapt the Site to your preferences, to provide the services requested by the User and to send you information about products and services. When registering on the CONCILIG website, you can choose to receive certain information by email.

Legal Basis: In these cases, the processing of personal data is legitimized by your consent, pursuant to art. 7th, inc. I, of Federal Law No. 13,709/2018, the General Law for the Protection of Personal Data (“LGPD”).

4. WITH WHOM WE SHARE THE DATA

The User of the Site will always be able to choose not to disclose his personal data to CONCILIG, but some of this data may be necessary to obtain some of the Content and Services that we offer (eg newsletter). Regardless of this, the User of the website will always have rights relating to privacy and the protection of their personal data.

The information collected may be shared by CONCILIG with: i) other partner companies, when necessary for the proper provision of services object of its activity; ii) for the protection of CONCILIG's interests and any type of conflict; iii) by judicial decision or request by the competent authority.

Furthermore, we clarify that your information may be shared with partners, for specific purposes contracted only, such as providers of technological and operational infrastructure necessary for our activities, such as cloud information storage providers. We currently share the data with the following partner(s):

Eventually, CONCILIG may request specific information from the User to help confirm their identity and guarantee their right to access their personal data (or to exercise their other rights). This is a security measure to ensure that the user's personal data is not disclosed to anyone who is not entitled to receive it. We may also contact the user.

In any case, CONCILIG, in order to safeguard itself and protect its rights, may access, read, preserve and provide any data and information about the User, including their interactions, if necessary for: i) Compliance with a legal obligation, court order or request from administrative authorities that have the necessary competence to do so; ii) Comply with or apply other Agreements and/or Contracts; and, iii) Protect the rights, property and safety of CONCILIG, as well as our employees, service providers and/or other Users.

5. HOW LONG WILL DATA BE STORED

CONCILIG will keep the Website User's personal data only for as long as necessary to fulfill the purposes for which we collect them, including for the purposes of complying with any legal, contractual, accountability obligations or requests from competent authorities, as disciplined in our Retention and Disposal Policy.

All data collected will be deleted from our servers when the User so requests or when they are no longer necessary or relevant for us to offer our Services, unless there is any other reason for their maintenance, such as a possible legal obligation to retain data, or need to preserve these to safeguard CONCILIG's rights. Whenever there is deletion or destruction of your personal data, you will be informed via e-mail or another form of contact that you choose among those made available by CONCILIG for this purpose.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm arising from unauthorized use or disclosure of your personal data, the purpose of processing your data personal information and whether we can achieve such purposes through other means, as well as applicable legal requirements.

6. HOW CONCILIG PROTECTS YOUR PERSONAL DATA INFORMATION

CONCILIG employs technical security and organizational measures to protect your information and personal data. Data will be stored in a secure operating environment that is not accessible to the public.

CONCILIG strives to protect the privacy of personal data and other information that is stored, however, total security cannot be guaranteed. Unauthorized use of accounts, hardware or software failure, as well as other factors may compromise the security of your personal data at any time. In this regard, no transmission over the Internet can be guaranteed to be completely secure.

Consequently, CONCILIG, its partner and related companies, third parties, service providers and their respective offices, directors, employees and agents do not represent, authorize or guarantee that personal information will be protected against invasion by "hackers" or any other unauthorized form or device. in the internet environment.

For this reason, if the User identifies or becomes aware of something that compromises the security of personal data, CONCILIG asks that he/she get in touch via the e-mail dpo@concilig.com.br or another form of contact that you choose among the made available by CONCILIG for this purpose.

7. INTERNATIONAL TRANSFER

CONCILIG at its headquarters in Brazil and the data we collect are governed by Brazilian law. When accessing or using our services, the User understands and agrees with the processing of their data in Brazil and eventually with the transfer to other countries or through third party services. The personal data of Website Users, when transferred to these countries, may be subject to local legislation and relevant rules.

CONCILIG uses third-party services that can carry out transfers to other countries, for example, to store data in cloud services. However, it is important to highlight that we only use services from third parties that seek to adopt adequate standards regarding privacy and protection of personal data.

In this way, we inform you that there may be transmission of your data so that CONCILIG can meet the purpose proposed in the treatment activities, which somehow need to act for the provision of CONCILIG services, including database backup companies, cloud storage and other related and necessary systems for the provision and maintenance of CONCILIG's services, observing the principles and guarantees established by the LGPD.

CONCILIG ensures that, in the event of an international transfer of personal data, all the rules of the LGPD and other applicable legislation on privacy and data protection will be complied with, especially those referring to the requirement of an adequate degree of protection and proof of guarantee of compliance with the principles, rights of the holder and the data protection regime provided for by law.

In the case of international data transfer, therefore, CONCILIG guarantees that the transmission of your personal data is carried out using all the contractual, technical and organizational measures in force, depending on the country to which the personal data is transferred.

CONCILIG informs that at any time you may have access to information about the sharing of your data by requesting via email to dpo@concilig.com.br or another form of contact that you choose within those made available by CONCILIG for this end.

8. YOUR RIGHTS

In compliance with current and applicable regulations, with regard to the protection of personal data, CONCILIG respects and guarantees the User the possibility of submitting requests based on the following rights:

i. confirmation of the existence of treatment;

ii. access to data;

iii. the correction of incomplete, inaccurate or outdated data;

iv. the anonymisation, blocking or deletion of unnecessary, excessive or non-compliant data

v. the portability of your data to another service or product provider, upon express request by the User;

saw. the deletion of data processed with the User's consent;

vii. obtaining information about the public or private entities with which AMLABS shared your data;

viii. information about the possibility of not giving your consent, as well as being informed about the consequences, in case of refusal; It is,

ix. the revocation of consent.

If you need any assistance to exercise your rights, the User may contact CONCILIG in accordance with the guidelines contained in this Policy. CONCILIG will undertake the necessary efforts to respond to such requests in the shortest possible time. However, even in the event of a request for exclusion, the minimum period for keeping information on users of internet applications, determined by Brazilian legislation, will be respected.

9. DATA PROTECTION OFFICER / DATA PROTECTION OFFICER (DPO)

If you need help to better understand the content of this Privacy Policy, or want more information about how we treat yours and exercise your rights, you can contact our Data Protection Officer through the following channel service:

Vilmar de Souza Machado

Email: dpo@concilig.com.br

10. UPDATES TO THIS POLICY

We are constantly improving, so this Policy may be updated, in order to provide the User with more security, convenience and improve the provision of the Site. Therefore, we recommend that Users access our Policy periodically, so that they are aware of any changes, and at the end of this Policy, there is an indication of the date of the last update and, if relevant changes are made that give rise to new authorizations from Users, we will publish such an update and eventually request a new consent.

11. LEGISLATION AND JURISDICTION

This Policy will be governed, interpreted and enforced in accordance with the Laws of the Federative Republic of Brazil, especially Federal Law No. of this document.

12. REVISION HISTORY