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Privacy Policy

PILARX CONSULTORIA DE INOVAÇÃO LTDA., hereinafter referred to as “PILARX”, knows that your privacy is important, which is why it has established its Privacy Policy in accordance with the parameters of the General Law for the Protection of Personal Data (LGPD), observing the principles respect for privacy, informative self-determination, freedom of expression, information, communication and opinion, the inviolability of privacy, honor and image, economic and technological development and innovation, free initiative, free competition and consumer protection, human rights, the free development of personality, dignity and the exercise of citizenship by natural persons, with which it is aligned in the development of its economic activity, so that you know what data is collected, how it is processed and for what purpose. By using PilarX services, you consent to the collection, use and disclosure of data as described in this Privacy Policy. In some cases, a separate notification will be provided and your specific consent will be requested via a digital statement “I have read and agree to the terms of the Privacy Policy”. You may refuse to provide certain information that you do not want to share, in which case the system will notify you of the consequences, and you may not have access to the benefits of the various services offered by PilarX.

 

1. DEFINITIONS

 

1.1. For the purposes of this Privacy Policy, it is important to understand the following concepts:

1.1.1. System: It is the digital environment used by PilarX, or any of its authorized commercial partners, to provide the Client with information, contact data, characteristics, address, among other information necessary for the provision of workshops.

1.1.2. Personal Data: Information related to the identified legal or natural person.

1.1.3. Database: Structured set of personal data, established in one or several places, in electronic or physical support.

1.1.4. Treatment: Any operation carried out with personal data, such as those referring to the collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication , transfer, diffusion or extraction.

1.1.5. Statement of Consent: Free, informed and unequivocal statement by which the Customer agrees with the processing of their personal data for a specific purpose.

1.1.6. Shared Use of Data: Communication, dissemination, transfer, national or international, interconnection of personal data or shared treatment of personal databases between PILARX and any of its commercial partners.

1.1.7. Deletion: Deletion of data or a set of data stored in the database, regardless of the procedure used, by determination of PILARX or at the request of the Client.

2. GUIDING PRINCIPLES IN CUSTOMER DATA PROCESSING

2.1. PILARX will observe the following principles when processing Customer data:

2.1.1. Purpose: carrying out the treatment for legitimate, specific, explicit and informed purposes to the data subject, without the possibility of subsequent treatment in a way that is incompatible with those purposes;

2.1.2. Adequacy: compatibility of the treatment with the purposes informed to the holder, according to the context of the treatment;

2.1.3. Necessity: limitation of treatment to the minimum necessary for the fulfillment of its purposes, with the scope of relevant data, proportional and not excessive in relation to the purposes of data processing;

2.1.4. Free access: guarantee, to holders, of facilitated and free consultation on the form and duration of treatment, as well as on the completeness of their personal data;

2.1.5. Data quality: guarantee, to the holders, of accuracy, clarity, relevance and updating of the data, according to the need and for the fulfillment of the purpose of its treatment;

2.1.6. Transparency: guarantee, to holders, of clear, precise and easily accessible information about the processing and the respective treatment agents, observing commercial and industrial secrets;

2.1.7. Security: use of technical and administrative measures able to protect personal data from unauthorized access and accidental or illegal situations of destruction, loss, alteration, communication or dissemination;

2.1.8. Prevention: adoption of measures to prevent the occurrence of damage due to the processing of personal data;

2.1.9. Non-discrimination: impossibility of processing for illicit or abusive discriminatory purposes;

2.1.10. Responsibility and accountability: demonstration, by the agent, of the adoption of effective measures capable of proving compliance with and compliance with personal data protection rules, and even the effectiveness of these measures.

 

3. WHAT INFORMATION WILL BE COLLECTED

 

3.1. PILARX collects personal data from the Customer to supply and improve its products, data being collected in accordance with the sources below:

3.1.1. Information provided by the Customer: We collect and store any information that the Customer provides related to the products.

3.1.2. Automated information: We automatically collect and store information about how you use the digital environment, including data about your interaction with products and content, most visited and desired items, browsing time, comments, clicks, using the cookie tool, obtaining information when the Customer browses the site or accesses their Account.

3.1.3. Information from Other Sources: We may receive Customer information from other sources of treatment, such as tracking and delivery confirmation by transport companies, own or outsourced, as well as financial and credit protection systems, with the purpose of correcting and improve services and products, prevent fraud and default.

 

4. PURPOSE OF COLLECTED PERSONAL DATA

 

4.1. We use your personal data to operate, provide, develop and improve the products we offer to consumers, and for that we apply the treatment to:

4.1.1. Purchase and delivery of products: personal data will be used to receive and deliver orders placed by the Customer, process payment, communicate steps and conditions.

4.1.2. Recommendations and customizations: the Customer's personal data is used to make recommendations for specific products, as well as to customize navigation and indication of products and offers, with the sending of advertisements.

4.1.3. Compliance with legal obligations: the Customer's personal data may be used to comply with legal obligations or court decisions, within the limits imposed by legislation or by competent judicial bodies.

4.1.4. Communication: Customer's personal data is used to get in touch through different forms of communication (message on the system, telephone, e-mail, instant messaging applications, among others), related to the products.

4.1.5. Advertising: we use your information to indicate specific products based on your preferences extracted from the information sources used in data collection. We do not disclose your personal or identifiable information in advertising materials.

4.1.6. Fraud Prevention and Credit Analysis: we use your personal data to prevent fraud that third parties may try to use using personal data, as well as we use them for credit analysis, in order to provide security to consumers, PILARX and third parties. We may use scoring to analyze and manage default risks.

 

5. USE OF COOKIES AND OTHER IDENTIFIERS

 

5.1. So that our system can identify your browser and/or your device and thus provide the products, the cookie tool or other identifiers will be used to collect automated data, providing more information about interests and personalization, including:

5.1.1. Recognize when you access the system. This allows you to receive personalized product recommendations, view products of interest, use simpler shopping tools and other benefits.

5.1.2. Know your preferences. This allows you, for example, to know whether or not you want to receive personalized advertising, ads, among others.

5.1.3. Conduct research to improve PILARX products or our way of interacting with the customer.

5.1.4. Prevent fraudulent activity and improve site security.

5.1.5. Interaction with other systems and databases.

 

6. DATA SHARING

 

6.1. Information about our consumers is an important tool of our business and that is why we handle it with the highest and most up-to-date levels of confidentiality and security, and we DO NOT sell any personal data. We share data with business partners only for the purposes below:

6.1.1. Transactions involving third parties: data sharing will only be used within the limits and in the interest of supplying PILARX products.

6.1.2. Protection of PILARX or third parties: we may share information and data for the protection of PILARX itself or others, notably in cases of fraud or suspected fraud, as well as credit risk analysis.

6.1.3. Availability in credit protection databases: we may share some of the Customer's information for forwarding to databases of credit protection systems in cases of delay or default, in accordance with specific regulations and legislation.

 

7. DATA SECURITY AND STORAGE

 

7.1. Your security and privacy are extremely important and we take it strictly into account in the development of our system, which is why we adopt security, technical and administrative measures capable of protecting personal data from unauthorized access and accidental or unlawful situations of destruction, loss, alteration, communication or any form of inappropriate or unlawful treatment, including:

7.1.1. Security of your personal information during transmission using encryption protocols and software.

7.1.2. Payment card industry data security standards when handling credit card data.

7.1.3. Physical, electronic and procedural copies related to the collection, storage and disclosure of Customer's personal information.

7.1.4. Request for proof of identity before we disclose your personal information.

7.2. We emphasize that it is important that you protect yourself against unauthorized access to your password and to your computers, devices and applications. Be sure to sign out when you're done using a shared computer.

7.3. All personal information provided to PILARX is kept in a proprietary and reserved database, used in accordance with this Privacy Policy, providing greater security for the information collected.

 

8. CUSTOMER RIGHTS

 

8.1. By consenting to PILARX collecting, storing and processing your personal data, know that ownership will be ensured and the fundamental rights of freedom, confidentiality, intimacy and privacy will be guaranteed, and you will be able to obtain at any time upon request:

8.1.1. Confirmation of the existence of treatment;

8.1.2. Access to data collected and processed;

8.1.3. Correction of incomplete, inaccurate or outdated data;

8.1.4. Anonymization, blocking or deletion of data that is unnecessary, excessive or treated in violation of the LGPD;

8.1.5. Data portability to another service or product provider, upon express request, in accordance with the regulations of the national authority, observing commercial and industrial secrets;

8.1.6. Elimination of personal data processed with the consent of the holder;

8.1.7. Information from public and private entities with which the controller carried out shared use of data;

8.1.8. Information about the possibility of not providing consent and the consequences of the refusal;

8.1.9. Withdrawal of consent.

8.2. The Client may object to treatment carried out on the basis of one of the hypotheses of waiver of consent.

8.3. The above rights will be exercised upon express request from the Client or a legally constituted representative.

8.4. In case of impossibility of immediate adoption of the measure, PILARX will send the holder a reply in which he can:

8.4.1. Communicate that you are not a data processing agent and indicate, whenever possible, the agent; or

8.4.2. Indicate the factual or legal reasons that prevent the immediate adoption of the measure.

8.5. Confirmation of existence or access to personal data will be provided, upon request by the holder:

8.5.1. In simplified form, immediately; or

8.5.2. By means of a clear and complete statement, which indicates the origin of the data, the lack of registration, the criteria used and the purpose of the treatment, observing commercial and industrial secrets, provided within a period of up to 15 (fifteen) days, counted from the date holder's application.

8.5.3. Information and data may be provided:

8.5.4. By electronic means, safe and suitable for this purpose; or

8.5.5. In printed form.

8.6. Confidential information will only be made available to the holder, upon forwarding the request with a copy of an updated identification document with photo, or to a legally constituted representative by power of attorney with notarized signature.

 

9. COMPLIANCE WITH INFORMATION TECHNOLOGY LEGISLATION AND PRACTICES

 

9.1. PILARX is constantly improving its internal processes and products, and is in compliance with Law n. 13,709/2018 (LGPD), upon its entry into force, adhering to the principles and mechanisms of data processing to achieve the objective and protection that the law confers on holders and controllers.

9.2. PILARX has its own and outsourced Information Technology departments, which have extensive knowledge of the legislation and their legal obligations as controllers or assistants in the treatment of Customers' personal information.

 

10. LIMITATION OF LIABILITY

 

10.1. PILARX is not responsible for malicious practices or misuse of content from other websites, as well as for failures in data security or illegalities committed by third parties, whether these are commercial partners or not, committing to offer the best in terms of security to the services that each Client accesses, acquiring modern and effective assets, applying methodologies designated as best practices and adopting measures available in the state of the art in favor of information security.

10.2. PILARX is not responsible for the stability or security of Internet service providers and the hardware they are connected to.

10.3. Data from your internet package may be consumed when accessing or using services related to the System, which are the responsibility of the Customer.

10.4. By consenting to this, you also agree to grant PILARX an unrestricted, irrevocable and free license, without receiving royalties or indemnities, mentions, descriptions or thanks, in the event that you provide feedback and ideas for the development of improvements or new products, whose copyrights will be the total and exclusive property of PILARX, which will be able to take advantage of them in the best way it sees fit, including derivatives, regardless of any reservation to the contrary made by the Client in the means of communication (verbal, physical or electronic), without is obliged to pay compensation, compensation or reimbursement.

10.5. At its sole discretion, PILARX may grant bonuses, vouchers, mentions, acknowledgments, to Customers who provide information that results in the improvement or creation of a new product, whose decision will be up to the controllership and will be communicated to the Customer.

10.6. Business partners may have their own privacy policies, and it is up to the Customer to consent or not with them, and PILARX is not responsible for the loss, deterioration, misuse, fraud or any other form of harm or illicit caused to the Customer as a result of the business partners.

 

11. TERMINATION OF DATA PROCESSING

 

11.1. There is no term of validity for the processing of personal data collected and stored by PILARX, reserving the right to communicate the termination at any time, regardless of prior notice. Termination, however, may occur in the following circumstances:

11.1.1. Verification that the purpose has been achieved or that the data is no longer necessary or relevant to achieve the specific purpose pursued;

11.1.2. End of treatment period;

11.1.3. Communication from the holder, including the exercise of his right to withdraw consent;

11.1.4. Determination of the national authority.

11.2. Personal data will be deleted after the end of their treatment, within the scope and technical limits of activities, with authorized conservation for the following purposes:

11.2.1. Compliance with a legal or regulatory obligation by the controller;

11.2.2. Study by research body, ensuring, whenever possible, the anonymization of personal data;

11.2.3. Transfer to a third party, provided that the data processing requirements set forth in this Law are respected; or

11.2.4. Exclusive use of the controller, access by a third party is prohibited, and provided that the data is anonymised.

 

12. AMENDMENT TO THE TERMS OF THE PRIVACY POLICY

 

12.1. PILARX reserves the right to change, in whole or in part, any of the terms of its Privacy Policy, regardless of prior notice to the Customer.

12.2. In this case, PILARX will communicate through its various service channels, as well as highlight any changes that may be made on its website.

 

13. CONTROLLERSHIP, OPERATORS AND IN CHARGES

 

13.1. Controllership will be carried out by any of the directors of PILARX, who are responsible for the final decision, on an irrevocable basis, regarding the processing of data.

13.2. The information technology sector will be the operator of PILARX in the processing of personal data, which may request support from subcontractors.

13.3. The PILARX SAC will also be in charge of the Client/Holder's service channel, for the presentation of complaints, requests, complaints and compliments about this Privacy Policy, which can be accessed at contato@pilarx.com.br.

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