Privacy Policy – Easy4Link

Easy4Link Platform (br)

This privacy policy (“Policy”) describes the information we process to enable the operation of our digital platform (“Easy4Link Platform”) and is an integral part of the Terms of Use (“Terms”) that govern access to and use of the Platform. Easy4Link.

We are committed to protecting, under the terms of applicable legislation, in particular the provisions of Law No. 12,965, of April 23, 2014 (“Marco Civil da Internet”) and Law No. ), the privacy of the personal data of its employees, customers, business partners and other identifiable persons. In this context, we have implemented a privacy and data protection program to establish and maintain high standards for collecting, using, disclosing, storing, protecting, accessing, transferring and/or processing personal data from users of the Easy4Link Platform (“User”).

This Policy describes the approach adopted by us to process the personal data that allow the feasibility and development of our operation (“Services”). Its objective is to clarify to interested parties about the data that is collected, the reasons for the collection and the way in which the User can update, manage or delete this information.

For the purposes of this Policy, the expression “data processing” shall mean: any operation carried out with personal data, such as those referring to collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction.

By accessing the Easy4Link Platform and having access to the content and interactivity made available therein, the User also grants his free and express consent for us to collect and process his personal data, in the manner of the purposes, conditions and forms set out here, and guarantees the veracity of the information provided. The User’s acceptance of this Policy will occur expressly, freely and spontaneously.

The Easy4Link Platform is constantly being developed, either to meet the demands of its Users or to comply with applicable legislation. Thus, we may modify this Policy, so that it is essential to consult this document on a regular basis, despite the sending of notification by us every time this Policy is changed.

I. How do we collect the User's personal data?

The User’s personal data is collected by the Easy4Link Platform as follows:

(i) The User must create an account on the Easy4Link Platform, and all personal data provided for this registration, necessary to use our Services, will be stored by us and associated with the respective User account (“Account”). From the creation of the Account, we can identify the User.

(ii) When a User accesses the Easy4Link Platform, interaction and access information is collected by us to ensure a better user and visitor experience. This data can deal with the keywords used in a search, the sharing of a specific document, comments, page views, profiles, the URL where the user and visitor come from, the browser they use and their access IPs, among others. others that can be stored and retained.

(iii) Through a third party: the Easy4Link Platform receives data from third parties when a user logs in with their profile on one of these sites. The use of this data is previously authorized by users with the third party in question.

II. What types of information do we collect?

All information collected receives appropriate treatment, following the strictest data protection standards, and observes the principles outlined below:

(i) The User’s personal data will be processed in a lawful, fair and transparent manner;

(ii) The User’s personal data will only be collected for specific, explicit and legitimate purposes, and cannot be further processed in a way that is incompatible with these purposes;

(iii) The User’s personal data will be collected in an appropriate, relevant and limited way to the needs of the purpose for which they are processed;

(iv) The User’s personal data will be updated whenever necessary, so that inaccurate data are deleted or rectified when possible;

(v) The User’s personal data will be kept in a way that allows the identification of the data subjects only for the period necessary for the purposes for which they are processed.

The information collected is:

● Data provided by the User: We collect the information that the User provides when registering to create an Account (e.g., your Username, password, name, email address, contact information, information about your address, CPF or CNPJ , about your location).

● Data collected automatically by the Easy4Link Platform: Our Services automatically collect certain technical information, including but not limited to, the type of device used to access the Services, your connection IP (with date and time of access), your approximate geographic location, the your device’s unique identification number (such as MAC Address or IMEI), information about your use of the Services, the software or browser used to access the Services, the operating system and your device version used, among others.

● Cookies: We may also use standard technology to collect information from Users, such as cookies, in order to improve your browsing experience. The persistent cookie remains on the user’s and visitor’s hard drive after the browser is closed and will be used by the browser on subsequent visits to the website. Persistent cookies can be removed by following your browser’s instructions. The session cookie is temporary and disappears after the browser is closed. It is possible to reset the User’s web browser to refuse all cookies, however some features of the Easy4Link Platform may not function correctly if the ability to accept cookies is disabled.

In compliance with the strict terms of the LGPD, the User of the Easy4Link Platform Services is entitled to:

● Right of confirmation and access: it is the User’s right to obtain from the Easy4Link Platform confirmation that the personal data concerning him or her are being processed or not and, if that is the case, the right to access their personal data;

● Right of rectification: the User’s right to obtain from the Easy4Link Platform the rectification of inaccurate personal data concerning him;

● Right to data erasure: it is the User’s right to have his/her data erased from the Easy4Link Platform;

● Right to limit the processing of data: it is the User’s right to limit the processing of their personal data, being able to obtain it when they contest the accuracy of the data, when the treatment is illegal, when the Easy4Link Platform no longer needs the data for the proposed purposes and when you have objected to the processing of data in case of processing of unnecessary data;

● Right of data portability: it is the User’s right to receive the data concerning him and which he has provided to the Easy4Link Platform, in a structured, commonly used and machine-readable format, and the right to transmit this data to another application , safeguarding our commercial and industrial secrets; and

● Right to information: this is the right to request that we provide additional information about the use we make of your personal data, as well as to provide us with a copy of the personal data you have provided to us.

Your exercise of these rights is subject to certain exceptions aimed at safeguarding the public interest (prevention or detection of crimes) or our interest (maintenance of professional secrecy).

If you exercise any of these rights, we will review them and respond within the deadlines set out in the LGPD.

The User has the right to withdraw his consent at any time, not compromising the lawfulness of the processing of his personal data before the withdrawal. Withdrawal of consent can be done by email: [=].

The Easy4Link Platform will inform you in case of rectification or deletion of a User’s data.

III. What are the purposes of the treatment?

By using the Easy4Link Platform Services, the User is consenting to this Policy. The Easy4Link Platform only processes personal data in situations where it is legally authorized or with the express and unequivocal consent of the User.

The information that the User shares with the Easy4Link Platform is intended for the management, administration, provision, expansion and improvement of the Services.

The legal bases, therefore, include your consent and the legitimate interests of the Easy4Link Platform for the provision, development and improvement of the Services, provided that such processing does not violate the User’s rights and freedoms. In other words, the legitimate interest is the one aimed at the development and improvement of the Easy4Link Platform Services, always observing this Data Protection Policy, in strict terms with the applicable legislation.

We are required by law to retain some basic data to log access to our Services, including, but not limited to, the IP address of the originating connection, with date and time. Such data are kept for a minimum period of 6 (six) months. Eventually, other data may also be stored to comply with legal obligations.

Also, we may use, for example, technical information collected from your device to facilitate the support process and provide technical assistance in the event of a “bug” or malfunction of the Services, adding functionality or improving other aspects of the Services and their navigability.

We may also use the data collected to direct you to offers and advertisements that we think may be of interest to you. Such offers and advertisements will, whenever possible, relate to the Easy4Link Platform or to us.

Finally, we may also use the data collected for secondary purposes that are not conflicting or excessive in relation to the purposes listed above, including for the sale of databases to third parties, always in compliance with Brazilian legislation, based on our legitimate interest. , except in cases where the User’s legal rights and guarantees prevail.

The processing of personal data for purposes not provided for in this Policy will only occur upon prior communication to the User, and acceptance of the User in relation to the new information provided, and, in any case, the rights and obligations provided for in this Policy will remain applicable.

IV. How is this information shared?

We may share the data collected through the Easy4Link Platform with third parties in the situations described below:

(a) To protect our interests in any type of conflict, including legal claims;

(b) In the case of transactions and corporate changes involving us, in which case the transfer of information will be necessary for the continuity of services and delivery of products;

(d) When the data is necessary for the information delivery process, and will be sent to a reseller accredited by us in order to return demand originally requested by the User, such as quotes or other information regarding products, prices, proposals, conditions payment, inventories, among others. The reseller is obliged to use the information provided by us solely and exclusively for the purpose of meeting the request sent by the User, not being able to use the data informed for any other purpose without authorization;

(e) With our partner companies, for promotional, advertising and statistical purposes, as indicated in this Policy.

We may share the data collected through the Easy4Link Platform with service providers, subcontractors or other providers that act, under our direction, in the processing of personal data collected through the Easy4Link Platform, as operators of the treatment in order to allow the correct provision of the Easy4Link Platform to Users.

We may share data with public entities, at their request, for projects of our interest and/or public interest, committing to provide Users with all appropriate information, as provided in the LGPD, whenever such use shared occur.

V. Processing of Personal Data

The processing of the data collected is carried out by us, or by third parties under our guidance, being responsible for the legality of the project as a whole, as Controllers, except in the cases of disclaimer provided for in this Policy or in the Terms of Use.

We undertake to apply technical and organizational measures to protect personal data from unauthorized access and from situations of destruction, loss, alteration, communication and dissemination of such data.

Among others, we have implemented the following measures:
● Restricted personal access to your personal data based on the criterion of “need” and only within the scope of the communicated purposes;

● Transfer of collected data only in encrypted form;

● Protection of information technology systems through firewalls, in order to prevent unauthorized access to your personal data;

● Permanent monitoring of access to information technology systems with a view to preventing, detecting and preventing the misuse of your personal data.

The data collected and used to enable the use of the Easy4Link Platform and its features, including those voluntarily provided by the User, will be kept as long as the relationship between us and the User exists, and without its conservation, it is not possible to make the Easy4Link Platform available. and its features.

SAW. How long was the personal data stored?

The data collected to allow the improvement of the Easy4Link Platform and to provide technical support will be kept for the time necessary to implement or provide the specific assistance requested by the User, and may be permanently deleted or anonymized to compose an aggregated database for statistical purposes, upon request. of user.

The data collected and maintained for the purpose of complying with legal obligations by us will be kept in accordance with the provisions of item I of article 15 of the LGPD.

Eventually, certain relevant data, always considering the minimum necessary, may be stored beyond the period described above, in order to:

(i) defense of our rights through judicial or extrajudicial means;

(ii) compliance with a legal or regulatory obligation by the controller;

(iii) study by a research body, guaranteeing, whenever possible, the anonymization of personal data;

(iv) transfer to a third party, provided that the data processing requirements set out in the LGPD are complied with;

(v) exclusive use of the controller, its access by a third party being prohibited, and provided that the data is anonymized.

The Easy4Link Platform may contain links (links) to other websites that do not belong to it. We assume no responsibility for the content and/or the privacy policies and practices of such third party websites. We recommend that Users read the privacy statements of linked websites, as their privacy practices may differ from ours.

Finally, we undertake to treat the User’s personal data confidentially, within legal limits.

VII. Security of stored personal data

Access to the Easy4Link Platform can be done through the addresses www.easy4link.com and www.easy4link.com , which have SSL Digital Certification (Secure Socket Layer or Secure Connection Layer), technology that encrypts all data transmitted between your device. and our websites. With this feature, the User sends his data with complete security and privacy. In any case, it is important for the User to be aware that security measures relating to the Internet are not entirely infallible.

However, we exempt ourselves, although we always act with the maximum and best efforts to avoid, through the exclusive fault of third parties, as in the case of an attack by hackers or crackers, or the exclusive fault of the User, as in the case where he himself transfers your data to third parties. We also undertake to notify the User within an adequate period of time in the event of any type of breach of security of their personal data that may pose a high risk to their personal rights and freedoms.

Breach of personal data is a security breach that accidentally or unlawfully causes the destruction, loss, alteration, disclosure or unauthorized access to personal data transmitted, stored or subjected to any other type of treatment.

VIII. How do I control or delete information about myself?

The deletion of the data stored by us may be requested, under the conditions established by the LGPD, through the tools of the Easy4Link Platform or by email [=]. We declare that we are committed to using our best efforts to respond to all deletion requests, when applicable, as soon as possible. Such deletion, when covering data necessary for the operation of the Services, will also result in the termination of the Terms of Use and the deletion of the User’s Account. Even in this case, we may keep the personal data stored, without subjecting it to active treatment, in order to comply with our legal data retention obligations.

IX. How do we operate and transfer data as part of our global services?

We share information globally, both internally and externally with our partners in accordance with this Policy. In the event of communication of personal data to third parties, whether operators or not, or in the case of international transfers, we guarantee that all entities that receive such data will be bound by specific contractual clauses or confidentiality and data security agreements, with the purpose of imposing on such third parties or foreign data recipients the same security, integrity and confidentiality obligations described in this Policy. Additionally, in cases of international data transfer, we will make sure that such transfer takes place within the legal hypotheses acceptable for personal data protection standards to be required from the recipient of such data.

The personal data collected while using the Easy4Link Platform may be processed by us or by affiliates or subcontractors. Our company is established in Brazil, but our affiliates, subcontractors or partners may be based or may process data in other countries. Thus, by agreeing to this Policy and the associated Terms of Use, the User also agrees that their data may be subject to international transfers to affiliates or subcontractors, and declares themselves aware of all guarantees applicable to treatment abroad, as this Policy and related Terms of Use.

X. How will we notify the User of changes to this policy?

We will notify the User of any changes to this Policy, prominently, so that the User is fully aware of the changed content.

XI. General Provisions

Any request that the User is interested in making regarding their data – information, change request, cancellation, among others, as well as if you have questions about this Policy – contact us through our relationship channel, email: [ =].

Any and all requests, complaints, requests for information or exercise of rights by the holder can be made by written message to the aforementioned e-mail address, containing at least the following information and documents:

(a) Full name of applicant;
(b) RG and CPF numbers of the applicant;
(c) E-mail address used to register on the Easy4Link Platform;
(d) Copy of RG and CPF; and
(e) Description of the request.

Eventually, other information or documents may be requested to fulfill the request, if there is any doubt about the veracity of the information provided or about the identity of the requester.