MINDO PUBLICIDADE LTDA. ("MINDO") is committed to protecting your privacy in compliance with the regulation related to the protection of privacy and personal data.
This Privacy Notice ("Policy") explains how and why we treat your personal data and what we do to ensure that they will be kept safe in compliance with the General Data Protection Regulation ("GDPR") and other data protection and privacy regulations, as applicable ("Data Protection Laws").
This Policy shall be construed jointly and according to any other document, contract, or provision of data treatment attached to it, as appropriate. Additional notifications and information can be sent regarding your personal data treatment activities.
By this Privacy Notice, the Owners are informed (i) about what personal data will be treated by MINDO, (ii) for what purpose and how long they will be used, (iii) with whom they shall be shared, and (iv) what are the Owners rights regarding their personal data treatment.
1. Data collection and storage
MINDO may collect the following personal data of their Owners:
- Full name;
- Telephone number;
- Marital status;
- Full name of the spouse, when applicable;
- Marriage certificate, when applicable;
- Complete address and proof of residence;
- Identity card number (RG)
- Individual Taxpayer Identity Number (CPF/ME);
- Copy or number of governmental identification documents;
- Personal data contained in Articles of Incorporation and Power of Attorney;
- Organization or company of which is a member or is related, and related information;
- Position, title, or job;
- Contract information;
- Information about communication preference;
- Information publicly available in third-parties database, including governmental agencies;
- Communications, oral or in writing, between the User and MINDO;
- Images collected by MINDO's security systems, such as registration photos and recordings obtained from security cameras on MINDO's premises.
Note that in certain situations, as in prospecting relationship with the client or in compliance with the best practices and the anti-corruption regulation, MINDO can also obtain your personal data from other sources like public websites or through providers of personal record verification in strict compliance with the applicable data protection law and regulations.
Data collected through the website. MINDO may collect personal data about owners who access the website, especially when the Owner opts to provide such information when contacting us. In addition, technical information such as the IP address, identification of the device, location data (based on your IP), information about cookies when the user accesses the website or other MINDO's electronic properties can also be collected. MINDO also collects the personal data you voluntarily provide in ads forms published on social media or Internet websites.
Security system. MINDO uses a camera security system (CCTV) in its premises to detect and prevent tort and to protect MINDO and the security of our collaborators and visitors.
This means that MINDO collects and stores, for a limited period, the images of visitors at its premises using CCTV. In the case of any security incident, MINDO is allowed to use these images.
2. Purpose and Duration of the data treatment
MINDO performs the data treatment activities in compliance with the Data Protection Law. Depending on the circumstances and the nature of our relationship with you, your personal data can be used for one or more of the following purposes:
- To learn about your interest in our offers and to be able to offer products that fit your profile and your needs, including targeted advertising;
- With the purpose of registration and other contract preliminary procedures;
- To fulfill contract obligations between MINDO and the Owners;
- To establish contact between MINDO and the Owners and also to ensure the performance of the contract or legal obligations;
- To render assistance and accessory services related to the contracts executed with Owners;
- To fight and prevent fraud or tort of any kind, at any moment, when MINDO is providing products and services;
- To respond to the authorities in case of lawsuits or administrative proceedings, to comply with legal and regulatory obligations or any other legally required to MINDO or in defense of its legitimate rights and interests.
- Identification and registration to access MINDO's premises and, when applicable, of its commercial partners;
- To allow your navigation on MINDO's website and other electronic properties, including the analysis of your behavior on our website, the identification of problems, personalization of features, and the website security monitoring;
- To respond to the requests and contact of the Owners and also to receive complaints, analyze claims or respond to requests;
- To perform satisfaction surveys or of other nature; and
- With the purpose of communication and relationship management with the Owners, contact them, provide information, send communications, including advertisements, direct mail, and promotional actions.
MINDO is committed to keeping the personal data as necessary to perform the purposes mentioned above and dispose of the personal data whenever possible and as reasonably required to comply with the Data Protection Law. If the user has any concerns about the retention and disposal practices concerning their personal data, they can contact MINDO through the email email@example.com.
3. Sharing of personal data
MINDO may share your personal data with third-parties only when necessary to perform the purposes listed in this Privacy Notice and according to one or more hypotheses listed below:
- In the case the third-party in question is the parent company, one of MINDO' subsidiary or affiliated companies;
- In the case the third-part is a service provider or commercial partner performing the treatment of personal data on behalf of MINDO and its interest;
- In the case the third-party in question is an official public agency or entity, regulatory law enforcement or governmental authority requesting information legitimately in the context of an inspection, auditing, legal procedures that constitute legally binding obligations from MINDO, or when reasonably necessary to protect MINDO's rights;
- When MINDO has obtained the free, unquestionable, and expressed consent from the user to share the data.
4. Security and treatment location
MINDO is responsible for adopting and maintaining reasonable technical and administrative security measures to prevent the irregular or illegal treatment of the Owners' personal data, including data on non-authorized access, destruction, loss, alteration of data, or communication.
All MINDO's collaborators are subject to confidentiality obligations. MINDO also updates and tests, following the best practices, its security systems to protect personal data.
USERS' PERSONAL DATA TREATMENT ACTIVITIES CAN BE PERFORMED OUTSIDE THE NATIONAL TERRITORY. ALTHOUGH THESE COUNTRIES MAY HAVE DATA PROTECTION LEVELS DIFFERENT FROM BRAZIL'S, MINDO WILL ADOPT SAFEGUARDS, INCLUDING CONTRACTUAL, TO KEEP THE RIGHTS OF USERS, THE CONFIDENTIALITY, INTEGRITY, AND SECURITY OF THE INFORMATION.
5. Rights of the Owner of the personal data
The following rights of the Owner of the personal data can be exerted at any time according to the applicable legislation by the Owners, upon request:
• confirmation of the existence of personal data treatment;
• access to personal data;
• correction of incomplete, inaccurate, or outdated personal data;
• anonymization, blocking, or elimination of unnecessary, excessive data or treated in disagreement with the GDPR;
• portability of personal data to another service or product provider, subject to the regulation of the national authority;
• request to erase the data or anonymization of personal data treated based on the given consent, except when the law authorizes the maintenance of the data due to any other reason;
• information about public and private entities with whom MINDO has shared your personal data;
• information about the possibility of not give consent for your personal data treatment and the consequences of such action; and
• revocation of the consent when the treatment has been performed based on the Owner's consent.
6. Exercise of the Owner's right
MINDO will facilitate the exercise of the data owners' rights whenever possible and according to the law. Mindo has a specific communication channel to manage the communication with the data owners and facilitate the exercise of their rights.
The Owners can make any complaint, request, or demand for information related to the treatment of their personal data, inclusive of exercising the Owner's right mentioned in this Privacy Notice and ensured by the national legislation using the email <firstname.lastname@example.org> or the following address c/o the personal data protection officer:
Alameda Jaú, 1303, 7º andar, Jardim Paulista – São Paulo – SP - Brazil. Zip Code: 01420-005.
When the user contacts MINDO to exercise its Owner's right, MINDO can request information to confirm the Owner's identity to the extent of its interests and security.
Updates to the Privacy Notice
This Privacy Notice can be updated periodically.
All changes shall be considered for immediate application and effect, except when otherwise communicated by MINDO to the personal data Owners.
MINDO will take all reasonable measures to communicate with the Owners about the updates of the Privacy Notice terms.