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PRIVACY POLICY

Reviewed 18.08.2021

PRIVACY POLICY - FRIDA

Filterfeed is committed to protecting your privacy.

Filterfeed ensures that personal data will be treated only in accordance with the legitimate purposes of personalizing your experience. We will only use the information strictly necessary to fulfill the purposes of the data treatment, limiting it to the minimum necessary to carry out the intended Services, and always in a lawful, proportionate and transparent manner.

Filterfeed will take a variety of security measures to protect your personal information when you use our software, place an order or enter, submit, or access your personal information. We offer the use of a secure server. All supplied sensitive information is transmitted via secure technologies, encrypted, provided and accessed only by those authorized with special access rights to such systems, who are also required to keep the information confidential.

WHAT INFORMATION DO WE COLLECT?

We collect information from you when you sign up and use Frida, contact us from our site, place an order, subscribe to our notifications, respond to a survey or fill out a form. In these cases, you may provide personal data, such as your name, username, password, e-mail, phone number, photo, location, among others.

In addition to it, it is possible for Filterfeed to collect other personal data from Users, but you will always be informed of what information will be collected before the actual collection and the specific purpose for which the personal data will be used.

HOW DO WE USE THE INFORMATION WE COLLECT?

Filterfeed uses both your personal and non-personal data to evaluate and filter content that is relevant to you or to make recommendations based on your personal data profile. We also use your data to complete your registration, prepare statistics and survey the software.

DO WE SHARE THE INFORMATION WE COLLECT WITH THIRD PARTIES?

We may share the information that we collect with those who provide services for us or whose products we think may interest you. We may also share it with our current and future affiliated companies and business partners, and if we are involved in a merger, asset sale or other business reorganization, we may also share or transfer your personal and non-personal information to our successors-in-interest.

HOW DO WE PROTECT YOUR INFORMATION?

We will take a variety of security measures to protect your personal information when you use our software, place an order or enter, submit, or access your personal information. We offer the use of a secure server. All supplied sensitive information is transmitted via secure technologies, encrypted, provided and accessed only by those authorized with special access rights to such systems, who are also required to keep the information confidential. We cannot, however, ensure or warrant the absolute security of any information you transmit to Filterfeed or guarantee that your information on the Service may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or managerial safeguards.

YOUR CONSENT

This Privacy Policy applies to our website, and its associated subdomains (collectively, our “Service”) alongside our application, Frida. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree with all the terms that follow, we recommend that you do not access or use Frida in any capacity.

​​We ask that you carefully read the terms of this Privacy Policy, since, when using Frida, you demonstrate your express, unambiguous and informed agreement with the conditions set out below.

The language of this Privacy Policy will always be as simple and clear as possible. However, if you are unfamiliar or do not understand any of the terms used here, we recommend that you contact Filterfeed, before using the software application or authorizing the collection of your personal data, through the email falecom@filterfeed.com.br.

Filterfeed may modify this Privacy Policy at any time, in its sole discretion, by publishing the updated version in the web, which will always contain the indication of the date of the last revision for your convenience.

DEFINITIONS AND KEY TERMS

“Frida” means the software and application programming interface developed by Filterfeed that recommends personalized content, products and services and, in order to do that, collects non-personal information and personal data from Users.

“Users” refers to the company, organization or person that signs up to use the software. Whenever the term "you" is mentioned, we will be referring to Filterfeed Users, who are consenting to this Privacy Policy and whose non-personal information and / or personal data are used by Frida.

“Personal Data” means any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person. Examples of personal data are: name (full name or abbreviation), surname, CPF, RG, date of birth, address, among others.

“Non-Personal Data” means any information (i) that is related to a legal entity or (ii) that is not directly related to an identified or identifiable natural person.

“Treatment of Personal Data” means any operation performed with personal data, such as collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, disposal, evaluation or control of information, modification, communication, transfer, dissemination or data extraction.

“Personal Data Violation” means any accidental or illegal destruction, loss, alteration, unauthorized disclosure or access to personal data.

“Data Controller” means any natural or legal person, under public or private law, who is responsible for decisions regarding the processing of personal data. In this case, Filterfeed acts as a Data Controller under the terms of the LGPD.

“Data Operator” means any natural or legal person, under public or private law, who performs the processing of personal data on behalf of the data controller. In this case, Data Operator will be any company contracted by Filterfeed to provide auxiliary services, such as cloud storage or in-app payments.

“Filterfeed” means Filterfeed Technologies LTDA., developer of Frida to which this Privacy Policy applies.

“LGPD” means the Brazilian General Personal Data or Law nº 13,709 / 2018, which rules the processing of personal data, including in digital media, by a natural person or a legal person under public or private law, in order to protect the fundamental rights of freedom and privacy and the free development of personality of the natural person.

“GDPR” means the General Data Protection Regulation or General Data Protection Regulation of the European Union (EU Regulation nº 2016/679), which rules the protection of individuals with regard to the processing of personal data and the free movement of such data data in the European Union, repealing the Personal Data Protection Directive nº 95/46/EC.

“ANPD” means the National Data Protection Authority, an agency of the federal public administration of Brazil that has jurisdiction on the protection of personal data and privacy and oversees compliance with the LGPD.

 

PROTECTION OF PERSONAL DATA

Frida will collect personal data from Users and, in some cases, but always in a lawful, proportionate and transparent manner. Therefore, the processing of information will only occur in situations expressly provided for in the General Law for the Protection of Personal Data (Law No. 13,709 / 2018) and in the Civil Framework of the Internet (Law No. 12,965 / 2014), always in a clear, intelligible and easy to access, also observing any other legislation regarding the protection of personal data.

Filterfeed will take several measures to protect the data of Users, including the use of encryption; anonymization and pseudo anonymization; secure servers for the storage and traffic of collected data; appropriate protocols of authorization and authentication; control of access to databases by authorized personnel, contractually linked to Filterfeed and qualified to perform the functions inherent to the purpose of the software.

​​The personal information of Users will be collected and stored in accordance with strict confidentiality and security standards and Filterfeed will periodically evaluate internal security and privacy procedures, which also cover the use of the software application.

Frida will not carry out any type of manipulation of the information provided by Users, in order to alter or distort them. Personal information will always be kept in its original state and can be changed, of course, if the Users request their correction or update.

Filterfeed may also retain personal information for statistical or public interest purposes, limiting it, in this case, to the minimum necessary and also applying reasonable and available technical measures to safeguard the rights and freedoms of Users.

We recommend that you protect yourself against unauthorized access to Users' login, password and credentials in Frida, as it is your sole responsibility.

Filterfeed will adopt, whenever possible, appropriate, reasonable and available technical measures, such as anonymization and pseudonymization, to remove the possibility of associating, directly or indirectly, information to Users.

The personal information of the Users will also be collected and stored in accordance with strict confidentiality and security standards and will not be passed on to third parties, unless expressly authorized or by law, contract or express request from administrative or judicial authority.

If Filterfeed hires other organizations to provide support services, it will always require compliance with the privacy, confidentiality and security standards provided for in this Privacy Policy.

Filterfeed is committed to adopting all technical and administrative measures available and appropriate to protect Users' personal information collected by Frida, preserving the security of its systems in the storage of such data, such as the use of methods encryption and anonymization of the information collected, when possible; the application of data access authentication mechanisms; and the use of state-of-the-art software to protect against unauthorized access to Frida database systems.

RIGHTS OF THE PERSONAL DATA HOLDER

Filterfeed guarantees Users, through the email falecom@filterfeed.com.br with regard to the treatment of their information and personal data, the following rights:

(i) access to personal data collected by Frida;

(ii) confirmation of the existence of personal data processing and, also, information related to the specific purpose, form and duration of that treatment, observing commercial and industrial secrets;

(iii) portability of personal data, for yourself or third parties, upon express request;

(iv) opposition to the processing of personal data in cases permitted by law;

(v) elimination of personal data treated with consent, upon express request, free of charge and at any time;

(vi) correction of incomplete, inaccurate or outdated personal data concerning the User;

(vii) anonymizing, blocking or deleting unnecessary, excessive or personal data treated in breach of applicable law;

(viii) information about the shared use of data and on which public and private entities Filterfeed shares personal data with;

(ix) revocation of the consent eventually provided for the treatment of personal data by Frida; and

(x) information about the responsibilities of the agents who carry out the processing of personal data.

CORRECTION AND EXCLUSION OF INFORMATION

Users may, at any time, request, through the communication channels provided by Filterfeed, the correction and updating of the information collected through the email falecom@filterfeed.com.br.

​​Filterfeed will delete Users data whenever (i) the purpose for which they were collected is achieved; (ii) when they become unnecessary to achieve its purpose; (iii) if the Users revoke the consent previously provided; (iv) upon determination of administrative or judicial authority; or (v) if the contract relating to the participation of Filterfeed and Frida in the Partner Platforms development program is terminated or expires.

Even if Users request the exclusion of shared information, Filterfeed may store some data for the period and under the terms of the legislation in force only for the purpose of complying with contractual, legal and regulatory obligations, resolving disputes or complaints and detecting problems or incidents.

Filterfeed may also retain personal information for statistical or public interest purposes, limiting it, in this case, to the minimum necessary and also applying reasonable and available technical measures to safeguard the rights and freedoms of Users.

COPYRIGHT

The content of Frida is protected by the laws that regulate copyrights, trademarks and patents, and all texts, images, sounds and / or applications displayed belong to Filterfeed or to third parties who lawfully ceded their right to use. Modifications, reproductions, storage, transmissions, copies, distributions or any other forms of use for commercial purposes are not permitted without Filterfeed's consent, and violators will be subject to the corresponding civil and criminal sanctions, under the terms of the Brazilian Laws nº 9,279 / 96, nº 9.609 / 98 and nº 9,610 / 98.

Attempts to invade or maliciously use the website will be treated according to Brazilian criminal law.

GENERAL PROVISIONS

Filterfeed will take commercially reasonable measures to ensure that (i) the people hired by it and (ii) other people hired to act on its behalf comply with the terms of this Privacy Policy.

Filterfeed will ensure that its employees, authorized agents and any Data Operators are obliged to comply with, recognize and respect the confidentiality of personal data, even after the end of their respective jobs, contracts or assignments.

Filterfeed will maintain appropriate organizational measures and security techniques (including with respect to personnel, facilities, hardware and software, storage and networks, access controls, monitoring and logging, vulnerability and breach detection, incident response, data encryption, while in transit and at rest) to protect personal data from unauthorized access or accidental or illegal destruction, loss, alteration, disclosure or destruction of the data.

​​Filterfeed will notify Users and Partner Platforms of any breach of personal data by the Controller and the Data Operator or any other third parties acting on their behalf without undue delay as soon as it becomes aware of a breach of personal data.

Filterfeed is not responsible for the improper and negligent use of the software application by Users or for failures, technical impossibilities or unavailability of Partner Platforms.

In no case will sensitive personal data be collected from Users.

Filterfeed strives for the security of the information collected by Frida and offers a safe navigation environment in the software. However, it is not responsible, under any circumstances, for any damages and problems arising from the delay, interruption or block in the data transmissions occurring on the Internet, nor if the User's equipment is infected with malware or other threats to navigation security.

Filterfeed is also not responsible for the improper or illicit use of Frida by Users or for failures, technical impossibilities or unavailability of access due to misuse or technical problems on the Users' devices.

As for the processing of personal data, in omitted cases, the provisions of the LGPD will apply, as well as related regulations in force on the subject.

DISPUTE RESOLUTION

Any disputes between Filterfeed and Users regarding this Privacy Policy should be resolved in the Judiciary District of Brasília (Brazil).

CONTACT

If you have any questions or complaints related to this Privacy Policy, we ask that you contact us through the email falecom@filterfeed.com.br.

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