Hi,

This policy is valid from June 2022.

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ACCEPTANCE AND CONSENT
Please read this policy carefully, because as a user of our systems (websites, virtual stores, apps, social media, email, and other electronic tools of our brand), you recognize, understand, and agree with the terms described here:

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IT IS IMPORTANT TO REMEMBER THAT THE VISIT TO THESE SYSTEMS HAPPENS IN A VOLUNTARY WAY ON YOUR PART, DISPOSING OF YOUR DATA TO OBTAIN SERVICE, INFORMATION, OR FACILITY. THEREFORE, YOU ARE AWARE THAT THE CONVENIENCE OF THE USE OF THE DATA IS STRICTLY PERSONAL, AND BY ACCEPTING AND USING OUR SYSTEMS, YOU EXPRESSLY DECLARE TO BE OVER 18 YEARS OF AGE AND CAPABLE. IF YOU DO NOT AGREE WITH ANY OF THE TERMS AND RULES SET FORTH HEREIN, YOU SHOULD NOT USE OUR SYSTEMS.

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BY VISITING OUR STORE/SITE AND SENDING COMMUNICATIONS OR PROVIDING ANY PERSONAL DATA, YOU DECLARE TO KNOW THE ESTABLISHED TERMS AND COMMIT TO FOLLOWING OUR PRIVACY POLICY. THIS POLICY DESCRIBES THE PURPOSES AND WAYS OF TREATMENT OF THE PERSONAL DATA THAT YOU WILL MAKE AVAILABLE TO OUR BRAND.

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WHY DO WE HAVE THIS DOCUMENT?

1. This policy is the foundation of the information privacy and data protection program and describes our approach to processing personal information and data anywhere in the world. It describes the types of data we collect through our systems. How it may use and/or with whom shared. This policy provides an overview of our privacy practices and choices you can make, as well as rights you can exercise in relation to Personal Data processed by us. If you have any questions about the use of Personal Data, please, contact <inup.atendimento@gmail.com>. 

2. The policy also describes how you can contact us to update your contact information. Access and control the use of the personal data we collect in connection with our communications and marketing activities, or obtain answers to questions you may have about our privacy practices on those systems. It drafted taking into account the following laws and regulations:

3. The policy also describes how you can contact us to update your contact information and access and control the use of personal data. We collect in connection with our communications and marketing activities or obtain answers to questions you may have about our privacy practices on those systems. It was taking into account the following laws and regulations:

• Marco Civil da Internet no Brasil – Law No. 12,965 of April 23, 2014, that describes how organizations must collect, handle and store personal information.

• General Data Protection Law in Brazil (LGPD) – Law No. 13,709 of August 14, 2018, - it provides for data protection, and the Civil Rights Framework for the Internet in Brazil.

• EU Regulation nº 2016/679 of April 27, 2016 – General Data Protection Regulation – GDPR, which regulates the protection of personal information for companies within the European Union (and those who offer products or services to the EU).​

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IMPORTANT DEFINITIONS IN THE CONTEXT OF THIS POLICY

1. “Data Controller”: natural or legal person, public or private, who has control over personal data that will be processed by the services of the systems (GDPR Art. 4, item 7 / LGPD Art 5, item VI).

2. “Data Processor (operator)”: natural or legal person, public or private, who processes personal data on behalf of the controller, to carry out a set of operations, automatic or not, such as collecting information from records, structuring, storage, adaptation, alteration, consultation, transmission, among others. (GDPR Art. 4, items 2 and 8 / LGPD Art 5, VII).

3. “Personal Data”: this is any information related to a person that can identify him directly or indirectly, such as name, location, and online identifier, among others. (GDPR Art. 4, item 1 / LGPD Art. 5, I ).

4. “Sensitive Personal Data”: the LGPD indicates this information as data about racial or ethnic origin, religious conviction, political opinion, union membership or organization of a religious, philosophical or political nature, data referring to health or sexual life, data genetic or biometric, when linked to a natural person. (LGPD Art. 5, II).

5. “Anonymized Data”: data relating to a person that does not directly identify them and which, therefore, is not subject to the law. (LDPD Art. 5, III).

6. “Data Protection Officer (in charge)”: a person appointed by the controller and operator to act as a communication channel between the controller, the data subjects, and the National Data Protection Authority. (GDPR Art. 37/LDPD Art. 5, VIII).

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RESPONSIBILITIES

1. The controller responsible for data processing is our agency inUP.digital. All of us and our partners are training to understand the importance of privacy and protection under the following laws in our country and others.

2. We are committed to complying with data protection legislation and taking all security and management recommendations but are not responsible for acts of force majeure or internet criminals.

3. The user also acknowledges that we cannot be responsible for absolute security against attacks, invasions, viruses, loss of data, or other illicit acts in the internet environment, which will not be the responsibility of the controllers, operators, or agents, who are also not responsible for the damages, as well as for any other type of direct or indirect damages.

4. In addition, the policy does not apply to any third-party applications, products, services, websites, or social networking features that may be offered or accessed through our store or website.

5. Accessing these links will cause you to leave our site and may result in third parties collecting or sharing information about you.

6. We do not control, endorse or make representations about third-party websites or their privacy practices, which may differ from ours.

7. We recommend that you review the privacy policy of any website with which you interact before allowing the collection and use of your Personal Data.

8. If you send us Personal Data regarding other natural persons, you automatically declare yourself competent to do so and that you have obtained the consent necessary to authorize the users of that information.

 

Section 1 - Another important definition:
For this policy:

1. "Processing of Personal Data": means any operation carried out within the scope of Personal Data, by automatic means or not, such as the collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or making available, harmonizing or combining, restricting, deleting or destroying. Any other operation foreseen under terms of the applicable legislation is also considered Personal Data Processing.

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Section 2 - About of Personal Data

1. We capture and use Personal Data to manage your relationship with our agency so that you can buy our products and/ or services, personalizing and improving your experience.

2. Examples of how we use data include: making it possible to sell our products and/ or services; confirming or correcting the information we hold about you; submitting information that we believe may be of interest to you; customizing your store experience; so that we can contact you in person, by voice message, through automatic dialing equipment, by text messages (SMS), by email, or by any other means of communication that your device may receive, following the law and for business purposes. 

3. In addition, the Personal Data provided may also used as we deem necessary or appropriate: (A) under Data Protection Laws; (B) to satisfy the requirements of legal process; (C) to comply with a court decision, regulatory decision or decision of competent authorities, including authorities outside your country of residence; (D) to enforce our Terms and Conditions of Use; (E) protect our operations; (F) to protect our rights, privacy, security, yours or the rights of others; G Detect and prevent fraud; (H) allow us to use available remedies or limit the damages we may suffer; and (I) in other ways permitted by law.

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Section 3 - Non-Provision of Personal Data

1. There is no obligation to provide us with your Personal Data. However, if you choose to do so, in some cases, we will not be able to provide full access to our store/ website, some of the necessary features or assistance, or even activate product delivery or provide the contracted service.

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Section 4 - Data Collected

1. The general public will be able to browse our store/site without the need for any registration and sending Personal Data. However, some of the characteristics of the store/site may depend of personal data. For example: the purchase/contracting of the service and/ or authorization to deliver the product/provision of the service, last name, telephone, address, city, state, e-mail and other data through the form (questions, complaints, suggestions, criticisms, compliments, etc.). 

2. In general when browsing our store/ website we may also store geolocation data and information about your preferences and interests in products/services; information about your visits and activities, including the content (and any advertisements) you see and interact with information about the browser and device you are using, your IP address, your location, the address of the website you came from; data about how the store/ website used. In certain cases, we apply a process of identifying your data in a way that is reasonably unlikely to identify you through the use of this data with the technology available, and this information is provides through automated tools that include cookies, web beacons and embedded web links.​

3. Anonymous or Aggregated Data: Anonymous responses to surveys or anonymous and aggregated information about how the store is used. During our operations, in certain cases, we apply a de-identification or pseudonymization process to your data so that it is reasonably unlikely that you will be able to identify yourself through the use of that data with available technology;

4. Other information we may collect: information that does not specifically reveal your identity or that is not directly related to an individual, such as the browser and device information; store usage data; and information collected through cookies, pixel tags, and other technologies.

5. We do not collect Sensitive Personal Data. To learn more, read how we use Automatic Data Collection Tools in section 7 below;

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Section 5 - Sharing of Personal Data with Third Parties

1. We may share your Personal Data:

2. With the partner company(s) you select or choose to send your data, inquiries, questions, etc., as well as with service providers or partners to manage or support certain aspects of our business operations on our Name. These service providers or partners may located in the United States, Argentina, Brazil or other global locations, including servers for homologation and production, and service providers for hosting and data storage, fraud management, customer support, sales on our behalf, order fulfillment, content personalization, advertising and marketing activities (including digital and personalized advertising) and IT services, for example;

3. With third parties, to help us manage the store;

4. With third parties in the event of any reorganization, merger, sale, joint venture, assignment, assignment, or transfer of all or part of our business, assets, or capital, including those relating to bankruptcy or similar proceedings.

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​Section 6 - International Data Transfers

1. Personal Data and information of other nature collected by us may be transferred or accessed by entities belonging to the corporate group of partner companies worldwide following this Privacy Policy.

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Section 7 - Automatic Collection of Personal Data

1. When you visit a store/ website, it may store or retrieve information in your browser, mainly in the form of cookies, which are text files containing small amounts of data. This information could be about you, your influences, or your device and primarily used to make the store work as you expect. This information usually does not directly identify you, but it may provide you with a more personalized internet experience.

2. Following this policy, we and our third-party services, with your consent, may collect Personal Data in a variety of ways, including but not limited to:

• Through browser or device: Some information was collected by most browsers or automatically through Internet access devices, such as computer type, screen resolution, operating system name and version, device model and manufacturer, language, type, and version of the Internet browser you are using. We may use this information to ensure that the store functions properly.

• Use of cookies: information about your use of the store may be collected by third parties through cookies. Cookies are data stored directly on the computer you are using. Cookies allow the collection of information such as browser type, time spent in the store, pages visited, language preferences, and other anonymous traffic data. We and our service providers use the information for security protection, to make navigation easier, to display information more efficiently, and to personalize your experience when using the store, than for online tracking. We also collect statistical information about store/ website usage to improve our design and functionality to understand how the store has been used, and to assist you in resolving store-related issues.

• If you do not wish to have your information collected through cookies, there is a simple procedure in most browsers that allows cookies to be automatically rejected, or offers the option to accept or reject the transfer of a specific cookie (or cookies) from a certain website to your computer. However, this can cause inconvenience in the use of the store.

• The settings chosen may affect your browsing experience and the operation that requires used cookies. In this sense, we reject any responsibility for the consequences resulting from the limited functioning of the store caused by deactivating cookies on your device (inability to set or read a cookie).

• Use of Pixel Tags and Other Similar Technologies: Pixel tags (also known as web beacons and invisible GIFs) may be used to track the actions of store users (including email recipients), measure the success of our marketing campaigns, marketing and collect statistical data about store usage and response rates and for other unspecified purposes. We may contract with other companies that use cookies, pixel tags, and other technologies to collect information about users of our store and third-party websites. We are not responsible for pixel tags, cookies, and other similar technologies used by third parties.

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Section 8 - Cookie categories

The cookies used in our store comply with legal requirements and fall into the following categories:

1. Strictly Necessary: ​​​​These cookies allow w safe navigated website and enjoy essential features. One example is security cookies, which authenticate users, protect their data and prevent the creation of fraudulent logins.

2. Performance: cookies in this category collect information in a coded and anonymous way related to our online store, such as, for example, the number of visitors to a specific page, the origin of visits to the site, and which pages the user accesses. All data collected is used only for possible improvements to the website and to measure the effectiveness of our communication.

3. Functionality: these cookies have used to remember user preference settings to improve your visit to our website, such as, for example, settings applied to the website layout or your responses to pop-ups for promotions and registrations -; that way, you won't have to ask countless times.

4. Advertising: we use cookies to create segmented campaigns and deliver ads according to your consumption profile in our virtual store.

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Section 9 - User Rights

1. You may, at any time, request: (I) confirmation that your Personal Data is being processed; (II) access to your Personal Data; (III) corrections to incomplete, inaccurate, or outdated data; (IV) anonymization, blocking or deletion of data that is unnecessary, excessive or processed in violation of the provisions of law; (V) portability of Personal Data to another service provider, as long as this does not affect our industrial and trade secrets; (VI) deletion of Personal Data processed with your consent, to the extent permitted by law; (VII) information about the entities to which your Personal Data has been shared; (VIII) information on the possibility of not providing consent and on the consequences of refusal; and (IX) revocation of consent. Your requests will be treated with special care so that we can ensure the effectiveness of your rights. You may be asked to provide proof of your identity to ensure that Personal Data is only shared with the owner.

2. You should bear in mind that, in certain cases, for example, due to legal requirements, an order may not be immediately fulfilled, and we may not be able to fulfill it due to legal obligations.

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Section 10 - Security of Personal Data

1. We seek to adopt the appropriate technical and organizational measures provided by Data Protection Laws to protect Personal Data in our organization. Unfortunately, no data transmission or storage system is guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you believe that the security of any of your accounts has been compromised), please notify us immediately.

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Section 11 - Hypertext links to other websites and social media

1. The store/website may contain hypertext links that will redirect you to the websites of our partner networks, advertisers, suppliers, etc. If you click on one of these links to any of these sites, remember that each site has its privacy practices, and we are not responsible for those policies. Please consult those policies before submitting any Personal Data to these sites.

2. We are not responsible for the collection, use, and disclosure of policies and practices (including data protection practices) of other organizations such as Facebook, Apple, Google, Microsoft, or any other software developer or app provider, media store social media, operating system, wireless internet service provider, or device manufacturer, including any Personal Data that you disclose to other organizations through the apps, in connection with those apps, or posted on our social media pages. We recommend that you inform yourself about the privacy policy of each website you visit or each service provider you use.

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Section 12 - Updates to this Policy

1. If we change our policy, we will post the new wording in the store with the updated revision date. We may change this Privacy Policy at any time. If there is a significant change to the terms of this Privacy Policy, we may inform you through the contact information we have in our database or through a notification in our store/ website.

2. We remind you that we are committed not to treating your Personal Data in a way, that is incompatible with the purposes described above unless otherwise required by law or court order.

3. Your use of the store following the changes means that accept the revised Privacy Policy. After reading the revised version, if you don't agree with its terms, please, terminate access to this store/ website.

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Section 13 - Person in charge of processing Personal Data

1. If you intend to exercise any of the rights provided, including withdrawing your consent, in this Privacy Policy and/ or in the Data Protection Laws, or resolve any doubts related to the Processing of your Personal Data, please, contact us at inupdigital.contact@gmail.com