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PRIVACY POLICY

1. GENERAL INFORMATION AND DEFINITIONS

SIN values the privacy of its users and has created this Privacy Policy to demonstrate its commitment to protecting your privacy and your personal data under the Data Protection General Law and other laws on the subject, and to describe so that your privacy is protected by SIN when collecting, processing and storing your personal information.

SIN follows the Code of Conduct SIN (“Code of Conduct”) that represents the mission, vision and values SIN , made in order to guide and portray what the priority values of this office since its inception, always seeking an ethical action of all your employees.

 

1.1 Definitions

User: all individuals who will use or visit the Site (s) and / or Application (s), over 18 (eighteen) years old or emancipated and fully capable of practicing the acts of civil life or absolutely or relatively disabled persons duly represented or assisted.

Personal Data: means any information provided and / or collected by SIN and / or its affiliates, by any means, even if public, which: (I) identifies, or which, when used in combination with other information handled by SIN, identifies an individual ; or (II) through which the identification or contact information of an individual can be derived. Personal Data can be in any medium or format, including electronic or computerized records, as well as paper-based files. Personal Data, however, does not include a business phone, business cell phone number, business address, business email.

Purpose: the objective, the purpose that SIN wishes to achieve from each act of processing personal information.

Necessity: justification for which it is strictly necessary to collect personal data, in order to achieve the purpose, avoiding excessive collection.

Legal basis: legal basis that makes the processing of personal data for a given prior purpose legitimate by SIN.

Consent: express and unequivocal authorization given by the User who holds the personal data so that SIN can treat his personal data for a previously described purpose, in which the legal basis necessary for the act requires the express authorization of the holder.

This policy applies, in general, to all Users and potential Users of the services offered by SIN , including Users of the sites or other media operated by SIN and summarizes how SIN may collect, produce, receive, classify, use, access, reproduce , transmit, distribute, process, archive, store, delete, evaluate or control the information, modify, communicate, transfer, disseminate or extract the collected data, including personally identifiable information, in accordance with applicable legal bases and all laws data protection and privacy policy.

When accessing and / or using this website , the User declares to be at least 18 (eighteen) years old and to have full and express capacity to accept the terms and conditions of this Privacy Policy and the Consent Form for all legal purposes.

If the User does not fit the description above and / or does not agree, even if in part, with the terms and conditions contained in this Privacy Policy, he must not access and / or use the services offered by SIN , as well as the sites and services operated by it.

 

2. COLLECTION AND USES OF PERSONAL INFORMATION

The User is aware that he / she provides information in a conscious and voluntary way through [FORM / ETC], or through the websites operated by SIN.

When the User performs the registration and / or fills in forms offered by SIN , including on the websites operated by it, certain requested Personal Data will be kept confidential and will be used for the purpose that motivated the registration, as well as for commercial purposes.

 

3. SHARING AND TREATMENT OF PERSONAL INFORMATION

SIN will not provide Personal Information collected on their websites to e-mail list brokers without your express consent.

SIN may disclose the Personal Data collected to third parties under the following conditions and within the limits required and authorized by Law:

  1. With its customers and partners when necessary and / or appropriate to provide related services;
  2. With companies and individuals hired to perform certain activities and services on behalf of SIN;
  3. With group companies;
  4. With suppliers and partners to provide services contracted with SIN (such as information technology, accounting, among others);
  5. For administrative purposes such as: research, planning, service development, security and risk management;
  6. When necessary due to legal obligation, determination of competent authority, or judicial decision.

In the event of sharing Personal Data with third parties, all subjects mentioned in items I to VI must use the Personal Data shared consistently and according to the purposes for which they were collected (or with which the User previously consented) and in accordance with what has been determined by this Privacy Policy, other website or country privacy statements, and all applicable privacy and data protection laws.

 

4. LEGAL REASONS FOR DISCLOSING YOUR DATA

In certain circumstances, SIN may disclose Personal Data, to the extent necessary or appropriate, to government agencies, consultants and other third parties in order to comply with applicable law or a court order or subpoena, or even if SIN believes that good faith that such action is necessary to:

  1. Comply with legislation that requires such disclosure;
  2. Investigate, prevent or take action related to suspicious or actual illegal activities or to cooperate with public bodies or to protect national security;
  3. Execution of your contracts;
  4. Investigate and defend against any third party claims or allegations;
  5. Protect the security or integrity of services (for example, sharing with companies that are experiencing similar threats);
  6. Exercise or protect the rights, property and security of SIN and its related companies;
  7. Protect the rights and personal safety of its employees, users or the public;do público;
  8. In case of sale, purchase, merger, reorganization, liquidation or dissolution of the SIN.

SIN will inform their users on possible legal claims that result in disclosure of personal information in accordance with what has been stated in item 4, unless such scientification is prohibited by law or prohibited by court order, or even if the request emergency. SIN may challenge these demands if it deems that requests are excessive, vague or made by incompetent authorities.

 

5. SECURITY OF PERSONAL INFORMATION

All Personal Data will be stored in the SIN database or in a database maintained “in the cloud” by the service providers contracted by SIN , which are duly in accordance with current data legislation.

SIN and its suppliers use a variety of safety procedures to protect the confidentiality, security and integrity of their personal data, preventing the occurrence of any damage due to the processing of such data.

Although SIN uses security measures and monitors its system to check for vulnerabilities and attacks to protect its Personal Data against unauthorized disclosure, misuse or alteration, the User understands and agrees that there is no guarantee that the information will not be accessible, disclosed , altered or destroyed for violation of any of the physical, technical or administrative protections.

 

6. DATA RETENTION

SIN retains all data provided, including data Personal, as necessary to achieve their services.

SIN will retain your Personal Information and will keep your data stored until ev entual exclusion request.

SIN is likely to keep your personal data after receiving your request for exclusion or if necessary to comply with legal obligations, resolve disputes, maintain security, prevent fraud and abuse and ensure compliance with contracts.

 

7. LEGAL BASIS FOR PROCESSING

SIN only treats Personal Information in situations where it is authorized legally or by its express and unequivocal consent of the User.

As described in this Policy, SIN has legal bases to collect, produce, receive, classify, use, access, reproduce, transmit, distribute, process, archive, store, eliminate, evaluate or control information, modify, communicate, transfer, disseminate or extract data about the User.

The legal bases include your consent (manifested at the time you finished registering on the site), contracts and preliminary contractual procedures (where processing is necessary to sign the contract with the User) and legitimate interests, as long as such processing does not violate your rights and freedoms.

Such interests include protecting the User and the SIN from threats, complying with applicable legislation, the regular exercise of rights in judicial, administrative or arbitration proceedings, enabling the conduct or administration of business, including quality control, reports and services offered, managing transactions understand and improve business and customer relationships and allow users to find economic opportunities.

The User has the right to deny or withdraw the consent provided to SIN , when this is the legal basis for processing personal data, and SIN may terminate the provision of its services to this user in the event of such request.

 

8. RIGHT TO ACCESS AND CONTROL YOUR PERSONAL DATA

SIN offers the User various options of what to do with your personal data collected, processed and stored, including their exclusion and / or correction. The User can:

  1. Delete data: the User can request the deletion of some of his Personal Data (for example, if they are no longer needed to provide the services to him);
  2. Change or correct data: the User can edit or request the edition of some of his Personal Data. The User may also request updates, changes or corrections to his data in certain cases, especially if they are incorrect;
  3. Put objections, limits or restrictions on the use of data: the User may request to stop using all or some of his Personal Data (for example, if we are not entitled to continue using them), or limit our use of such data (for example, if your Personal Data is incorrect or stored illegally);
  4. The User has the right to access or take his data: the User can request a copy of his Personal Data and the data that the User has provided in a legible format in printed form or by electronic means.

 

9. POLICY REVIEWS

If SIN modifies this Privacy Policy, such changes will be posted visibly on the SIN website. This policy is valid from 01/01/2020.

 

10. MEDIATION AND FORUM OF ELECTION

This policy is subject to the Law of the Federative Republic of Brazil and the São Paulo District Court is competent to settle any dispute in relation to it.

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