Policy and Processing of Personal Data
This Privacy Policy and Personal Data Processing is intended to demonstrate FABRICADS’s commitment to privacy and processing of personal data from your USERS.
As a condition of access to the systems offered by FABRICADS, the USER declares that they have read it completely and carefully, being fully aware of this Privacy Policy, expressly granting their free, unequivocal and informed agreement with the terms stipulated herein, authorizing the of the personal data and information mentioned herein, as well as their use for the purposes specified below.
If the USER does not comply with these directives, they must discontinue their access to the systems offered by FABRICADS.
1.Collection and Use of Personal Data and Activity Recording
1.1. Personal data is collected with consent of the USER.
1.2. The list of personal data collected and the respective purposes are set out in Annex I.
1.3. Other personal data that are not described in Annex I may be collected according to the specific nature of the product or service in question, under the terms of a specific document that must be considered in conjunction with this Privacy Policy.
1.4. FABRICADS is not responsible for the accuracy, veracity or timeliness of the information provided by the USER, and the USER is responsible for providing them accurately or updating them whenever necessary.
1.5. FABRICADS can update and enrich the data.
1.6. FABRICADS guarantees the USER the right to correct incomplete, inaccurate or outdated data.
1.7. FABRICADS uses technologies compatible with the market, respecting the reasonable state of the art, with reasonable and constant updates, to record navigation events, clicks, events and non-identifiable data. All technologies used must comply with current legislation and the terms of this Privacy Policy.
1.8. When using FABRICADS’ digital environments, the USER can be led, via a link, to other portals or independent platforms that can collect the USER’s information and have their own Privacy Policy.
1.8.1. It is up to the USER to read the Privacy Policy of such digital environments outside the FABRICADS environment, and the USER is responsible for accepting or rejecting it.
1.8.2. FABRICADS is not responsible for the Privacy Policy or the content of any websites, contents or services outside the FABRICADS systems environment, even if linked to it through links.
1.9. The consent provided by the USER is collected individually, clearly, specifically, legitimately and informed to the holder.
1.10. The USER can change its consent grants, grant new permissions or withdraw its consent to current issues by contacting FABRICADS, being advised of the consequences that the withdrawal of consent may cause.
1.11. The USER can contact directly through the electronic address [email protected]. The data collected and the activities recorded may also be shared:
a) With competent judicial, administrative or governmental authorities, in the event of a request, requisition or court order;
b) With the control bodies that supervise FABRICADS, when requested;
c) In case of corporate transformations, such as merger, acquisition and incorporation, always observing the principle of transparency with the USER.
1.12. The database, formed through the collection of personal data in a manner, is the property and responsibility of FABRICADS. Its use, access and sharing, when necessary, will be done within the limits and purposes of FABRICADS’ business and described in Annex I of this Privacy Policy and in specific Terms of Use, when existing.
1.12.1. The USER is co-responsible for the secrecy and confidentiality of their personal data.
1.12.2. Sharing passwords or access data violates this Privacy Policy and the Terms of Use of FABRICADS systems.
1.13. Internally, USERS’ data are only accessed by professionals duly authorized by FABRICADS, who are employees, service providers and partners.
1.14. FABRICADS respects the principles of lawfulness, purpose, adequacy, proportionality, necessity, free access, data quality, transparency, security, prevention, non-discrimination, accountability, accountability, subsidiarity and storage limitation, in addition to signing the commitment to confidentiality and preservation of privacy in terms of this Privacy Policy with USERS.
2. Data Storage and Logging
2.1. The personal data collected and the activity records must be stored in a safe and controlled environment for the minimum period stipulated, according to the table below:
| PERSONAL DATA | STORAGE TERM | LEGAL GROUNDS |
|---|---|---|
| Registration data | 10 years after the end of the relationship | Arts. 12 and 34 of the Consumer Protection Code (Law nº 8.078/90) |
| Digital identification data | 6 months from the last access | Art. 15 of the Civil Rights Framework for the Internet (Law No. 12,965/14) |
2.2. The data can be deleted before this deadline in case of request by the USER. Data may be kept for a period longer than that provided for in this period, for reasons provided for by law, by court decision, for the purposes of accountability to control bodies or for other legitimate interests of FABRICADS, duly specified and informed to the data subject. At the end of the term and the legal need, the data must be deleted using safe disposal methods, or used anonymously for statistical purposes.
2.3. The data collected must be stored on their own servers or on service providers that comply with applicable personal data protection controls.
3. Compliance with user rights
3.1. The personal data collected and activity records must be stored in a safe and controlled environment for the minimum period stipulated, according to the table below:
3.2. The USER may request confirmation of the existence of treatment; access to your personal data; or the correction of your personal data, through the FABRICADS LGPD Service Channel, available at the email [email protected].
3.3. Through the LGPD Service Channel, the USER may also: (i) request the blocking of the use of their personal data; (ii) express opposition to the processing of your personal data carried out based on one of the hypotheses of waiver of consent, (iii) request the elimination of your personal data collected and recorded by FABRICADS at the end of its purpose of use or (iv) request reviewing automated decisions (v) requesting portability of personal data, (vi) requesting information about who the personal data was shared with, and (vii) information about the impact of the decision not to consent or to withdraw consent.
3.4. Even if the user does not grant or request the revocation of consent for the purposes related to sending information, FABRICADS may send transactional information related to the provision of services.
For auditing, security, fraud control and rights preservation purposes, FABRICADS may keep the USER’s registration history and data for a longer period in the cases that the law or regulatory rule so establishes, in order to render accounts to the control bodies, or to preserve the rights of FABRICADS or the data subject.
4.General provisions
4.1. FABRICADS reserves the right to change the Privacy Policy at any time, according to the purpose or need, such as for adequacy and compliance with a provision of law or rule that has equivalent legal force, the USER being responsible for checking the updated version whenever access the FABRICADS systems.
4.2. In the event of updates to this document that require a new collection of consent, FABRICADS must notify the USER through its systems capable of performing a new collection of consent or through the means of contact provided by it.
4.3. In case of any doubt regarding the provisions contained in this Privacy Policy, the USER may contact FABRICADS through FABRICADS’ LGPD Service Channel.
4.4. If outsourced companies process any data collected by FABRICADS, they must respect the conditions stipulated herein and the FABRICADS Information Security standards, as well as additional Policies and procedures.
4.5. If any provision of this Privacy Policy is considered illegal or illegitimate by the data protection authority, the other conditions remain in full force and effect.
4.6. The USER recognizes that all communication carried out by e-mail (to the addresses informed in their registration), SMS, instant communication applications or any other physical, virtual and digital form are also valid as documentary evidence, being effective and sufficient for the dissemination of any matter that refers to the services provided by FABRICADS, as well as the conditions of its provision or any other matter addressed therein, except for the expressly different provisions provided for in this Privacy Policy.
4.7. FABRICADS uses cookies and similar technologies to evaluate and understand the profile and behavior of users who visit or access the pages, in order to personalize the user’s browsing experience by promoting and promoting products and services, in addition to carrying out fraud prevention.
5. Applicable law and jurisdiction
5.1. This Privacy Policy shall be governed and interpreted in accordance with Brazilian legislation, in the Portuguese language, and the São Paulo/SP District Court is elected to settle any dispute or controversy involving this document, except for the specific exception of personal, territorial or functional by applicable law.
6.Glossary
6.1. For the purposes of this document, the following definitions should be considered:
Cookies: Small files sent by FABRICADS systems, recorded on USERS’ devices, which store preferences and other information, in order to personalize USERS’ navigation on the SITE, according to your profile.
IP: Abbreviation for Internet Protocol. It is the alphanumeric set that identifies USERS’ devices on the Internet.
Session ID: Credential of a USER required to access FABRICADS systems and use its features.
USER: Natural person who accesses and/or uses the functionalities of FABRICADS systems.
Annex I – List of personal data and purposes of use
| TYPES OF DATA | PERSONAL DATA | PURPOSE OF USE OF REGISTRATION DATA |
|---|---|---|
| Full | name, e-mail, mother’s name, schooling, address, telephone, CNPJ and link to the company, CPF, Gender, Access password, date of birth and photo/image. | – Identify the User; – Provide personalized service; – Provide personalized service; – Inform about news, features, content, news and other events relevant to the maintenance of the relationship as a USER; – Promote and publicize FABRICADS products and services; – Respond to USER requests and requests for information; – Conduct research of interest to FABRICADS; – Allow access to restricted areas of FABRICADS digital environments; – Reporting to supervisory bodies in accordance with the law; – Customize the customers’ environment in their navigation in FABRICADS’ digital environments. |
| Transaction information Purchased | products and services and respective quantities, transaction date and period, invoice number | Credit the purchased products and services. |
| Digital identification data | IP Address and Logical Port of Origin, Records of interactions with digital environments, Screens accessed, device (operating system version, geolocation and other installed applications, if necessary), Session ID and Cookies. | – Identify the User -– Administer, credit and send services acquired through digital environments; -– Fulfill the obligations arising from the use of the services; -– Promote and publicize products and services; -– Carry out fraud prevention, customize the navigation experience in the channels, through georeferencing; |
| Anonymized data Conduct | analysis and statistical studies |
