PRIVACY POLICY
Last update: 10/19/2021
ALEA ELETRO COMERCIAL LTDA, a legal entity governed by private law, headquartered at Rua Júlio de Castilhos, 756 – Sala 3 Veranópolis, Rio Grande Do Sul, registered with the CNPJ/MF under No. 93.720.464/0001-53 (“Alea” ) takes your privacy seriously and takes care of the security and data protection of all its users (“Users” or “You”) of the website “www.aleavivo.com.br” and any other website, Store, application operated by Shopkeeper (hereinafter, simply, “Shop”).
This Privacy Policy (“Privacy Policy”) is intended to inform you about how we collect, use, delete and disclose information collected from your visits to our Institutional Site and in messages we exchange with you (“Communications” ). This Privacy Policy applies only to information collected through the Institutional Site.
Institutional Site and/or use of any integrated services and tools will mean that you have read, understood and consented to this Privacy Policy and to the terms of use of each Service and Institutional Site that You access or use (“Terms of Use”).
This Privacy Policy provides an overview of our privacy practices and the choices you can make, as well as the 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 dpo@aleavivo.com.br.
The privacy policy owned by third parties will regulate the information obtained by these third parties about you in these situations, and it is up to the User to verify such policies before using said Institutional Site.
If you send us Personal Data referring to other individuals, you declare that you have the competence to do so and declare that you have obtained the necessary consent to authorize the use of such information under the terms of this Privacy Policy, being responsible for all relevant obligations of it.
- Definitions
- For the purposes of this Privacy Policy:
- “Personal Data” means any information that, directly or indirectly, identifies or can identify a natural person, such as name, CPF, date of birth, IP address, among others;
- “Sensitive Personal Data” means any information that reveals, in relation to a natural person, racial or ethnic origin, religious conviction, political opinion, membership of an union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data;
- “Processing of Personal Data” means any operation carried out within the scope of Personal Data, through automatic means or not, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or, alternatively, making available, harmonizing or associating, restricting, eliminating or destroying. Any other operation provided for under the applicable legislation is also considered Processing of Personal Data;
- “Data Protection Laws” means all legal provisions that regulate the Processing of Personal Data, including, but not limited to, Law No. 13.709/18, General Law for the Protection of Personal Data (“LGPD”).
- For the purposes of this Privacy Policy:
2. Information We Collect, Receive and Store
- Consent
The use of the Institutional Site implies the user’s consent to the collection, storage and use of the personal information provided and its updates, traffic data, IP addresses, among others. The User hereby authorizes Alea, at its discretion, to preserve and store all advertisements and/or content submitted to the Institutional Site, as well as all personal data and other information provided and/or collected.
In addition, the Personal Data provided will also be used in a necessary or appropriate way, when requested: (a) to comply with the terms of the Data Protection Laws; (b) to meet legal process requirements; (c) to comply with a court decision, regulatory decision or decision of competent authorities, including authorities outside the country of residence; (d) to protect our operations; (e) to protect the rights, privacy, safety of us, yours, or others; (f) to detect and prevent fraud; (g) allow us to use available remedies or limit damages we may suffer; (h) in other ways permitted by law; and (i) to enforce our Terms and Conditions of Use.
Account information
When our customers/users create accounts on Our Institutional Site, we may ask for certain information, such as an email address and password. In addition, Users may be required to create an account that includes information such as their location, first and last name, social security number, gender, phone number, interests and related information, including photos they wish to post. This information is required to enable and improve the Service we provide to Users and to comply with Our Terms of Use.
Availability of information
Any information that Users make available in publicly available profiles is at their own risk. For this reason, you should carefully consider the risks of making certain statements or publishing personal information – especially information such as your precise address or location. A User can copy/photograph their messages and circulate among other Users or outside the Institutional Site. We do not admit any responsibility for messages or acts of third parties that occur as a result of information that you have made publicly available to a third party or that you have shared with any person or with another User.
Authentication services
Whenever a user has decided to log in to our Institutional Site through an unauthorized third-party service, Alea cannot be held responsible for the authorizations made.
Ads and Transactions
We may store and transmit your information to our business partners and affiliates, including personal information and contact information.
Customer service
When You contact our customer service department, we may collect the personal information necessary to complete your order and to contact you if a follow-up is necessary. We may also contact you using the contact information for your account that you have provided. We may also collect other information about our communications with our Users, for example any customer support requests that Our Users make or any feedback that Our Users provide to Us.
Institutional website and mobile device data
We may automatically receive and record information on our servers from your browser or device, including your IP address, software and hardware attributes, mobile device identifiers, application usage information, and other device and system information. This may happen on Our Institutional Site or on third-party services.
Failure to provide Personal Data
You are not obligated to share the Personal Data we request, however, if you choose not to share it, in some cases we may not be able to provide you with full access to the Institutional Site.
Use of Information
To provide our service, we may use the information we collect and store, including User Data, for the following general purposes:
- To provide customer services, including creating and managing User accounts, resolving technical difficulties, and enabling or disabling functionality;
- To customize offers and experiences;
- To track the User’s general and individual activity, such as keyword searches, postings and transactions, and to manage traffic on the Institutional Website;
- To contact our User, including matters about service, customer service, or marketing communications permitted through any available means of communication;
- To undertake research initiatives and perform analysis to improve our services; and
- To enforce our Terms of Use, including combating fraud and any illicit acts.
Alea reserves the right to retain User Data and any communications made via email and telephone contact for the period it deems necessary for the proper fulfillment of its business, even after the User’s account is closed, unless otherwise stated, expressed by the User to the contrary, respecting the minimum data retention period imposed by law.
Subject to the applicable legal provisions, the User authorizes Alea to inform and/or disclose their data provided and/or collected in case of legal requirement or if reasonably necessary to: comply with due legal process, enforce the Terms of Use, respond to allegations of alleged infringement of third-party rights and improper disclosure of third-party contact information and to protect the rights, property or safety of third parties or Alea itself and its Users.
To improve the Services and protect User privacy and Personal Information, we may use User Data to determine whether or not you are complying with this Policy and the applicable Terms of Use.
We may use automated technological methods to identify, among any information that may violate or bring about any suspicion of violation of the Terms of Use or current legislation. The identification referred to in this clause will be made exclusively through automated technological tools, with, as a rule, no human access to sales, except in the strictly necessary cases provided for in the applicable Terms of Use and in current legislation.
However, there may be access to purchases made when it is required by law or court order to intercept purchases.
Information sharing
Alea may share information we collect with our affiliates (companies under the same control and ownership) or groups of entities jointly offering the Service, including Groups located outside Brazil. These companies may only process and use this information to assist us in the purposes described above and are bound by this Privacy Policy.
The User expressly acknowledges and agrees that the database may be fully or partially assigned or transferred to third parties, provided that the purpose of continuing the activity provided by Alea is respected or if there is a legal obligation in this regard.
We may use third party service providers to help us provide functionality of our services but, in that case, they will not have any power to independently use personal information that they process on Our behalf, and shall be subject to the terms of this Policy.
We reserve the right to share information with public or private authorities that allows us to fight fraud and abuse on Our network, investigate suspected violations of law, or combat any other suspected violations of our Terms of Use or the law.
We may share personal information with government authorities when required under applicable law.
We may share information with our business partners in order to better serve our users.
We do not rent or sell User Data to unaffiliated third parties unless we have specific permission from Our Users to do so. In the event that Our business or a division of Our business is reorganized or sold and We transfer all or substantially all of our assets to a new owner, your personal information may be transferred to the purchaser irrespective of your authorization to ensure continuity of the Service.
We may share certain non-personal information (data that does not identify our Users individually) with third-party service providers, trusted partners or approved researchers, in order to better understand which advertisements and services may interest you, to improve quality and effectiveness. of Our Services or their service, or to contribute to academic research.
Personal Data Security
We seek to adopt the technical and organizational measures provided for by the Data Protection Law, aimed at protecting 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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