1.1. For the purposes of this document, the following definitions and descriptions should be considered for your better understanding: Platform: Designates the digital platform, made available by ITB360, which enables and makes ITB360 services available to Users. User: Any and all natural or legal persons able to seek and enjoy the services provided by ITB360.
2.1. The information we collect includes, but is not limited to:
b)CNPJ / Company registration number;
d)Telephone for contact;
e)Information about the device's browser and operating system;
g)Web pages / application sessions visited;
h)Clicked links and buttons;
i)Data and information on commercial transactions carried out between Users and Partners.
2.2. We are not responsible for the veracity or lack of it in the information provided by Users, as well as for its outdating when it is your responsibility to provide it accurately or update it.
2.3. The collected data will be used for the following purposes:
a) Properly identify them on the Platform;
b) Manage, provide services and fulfill obligations arising from the use of our services and products;
c) Properly attend to your requests and doubts;
d) Keep your records updated for purposes of contact by phone, instant communication applications, electronic mail, SMS, direct mail or other means of communication;
e) Improve the use and navigation experience of our Platforms;
f) Perform statistics, studies, research, and surveys relevant to the activities of their behavior when using the Platform;
g) Promote our services and products, inform about news, features, content, news and other relevant events;
h) Protect us from rights and obligations related to the use of our Platform;
i) Collaborate and / or comply with a court order or request by an administrative authority;
j) Share the data collected with our partners to maintain and improve our Platform, products, and services;
k) Share the data collected using cookie technology and tools for personalization and recommendation of products and offers, to allow business partners to have access, in addition to offering a more appropriate experience with users;
l) Collect and analyze anonymous data from third-party software including, without limitation, Google Analytics, KISSmetrics, Linkedin, MixPanel, for parameterization and creation of metrics; and
m) Share and transfer the data collected to business partners, provided that for the specific purpose of enriching its database and preventing the occurrence of fraud and associated risks.
n) The use of data may eventually cover purposes other than those provided above, provided that it is duly authorized with the express consent of the User.
2.7. ITB360 uses technological resources in order to guarantee the inviolability of the data. These techniques include (i) encryption techniques; (ii) regular monitoring of the system; (iii) periodic security tests and (iv) installation of barriers against improper access to the database (firewalls).
2.8. ITB360 recommends that Users keep their access data on the Platform in total confidentiality, avoiding its disclosure to third parties. We do not ask for your password outside the website, by phone, email, or any other means of communication.
2.10. We have business partners who can offer services through features or websites accessed from our Platforms. The data provided by the Users to these partners will be their responsibility, being thus subject to their own data collection and use practices, without any burden being placed on ITB360 for the treatment of such information.
2.11. The activities of Users on the Platform, will create, when possible and applicable, logs with the following information:
a) User IP address;
b) Access and actions performed by the User on the Platform;
c) Pages and screens accessed by the User on the ITB360 Platform;
d) Dates and times of each User action on the ITB360 Platform, in addition to the access he makes to the pages and screens of the tools and features he uses;
e) Information about the device used by the User, such as version of the operating system, device location, browser, among other installed applications and software;
f) Session and User ID, when available.
3. Two Rights of Data Subjects
3.1. The User may exercise his rights known as ARCO (Access, Rectification, Cancellation, and Opposition) in relation to the data collected directly by ITB360 and at any time by contacting by e-mail: firstname.lastname@example.org. Only identifiable data is liable to exercise such rights.
3.2. User ARCO rights include the following definitions:
a) Right of access: allows the User to know and obtain information about the personal data subject to processing.
b) Right of rectification or exclusion: allows the correction of errors and the modification of inaccurate and incomplete data.
c) Right of cancellation: allows the exclusion of inappropriate or excessive data.
d) Right of opposition: the User's right to prevent the processing of their personal data or to stop processing in progress.
e) The right to restrict processing: involves marking personal data stored to restrict its future processing.
f) Data portability: providing User data that is subject to processing so that it can be transferred to another controller without hindrance.
g) Right not to be subject to individual automated decisions for which the User has not given his consent (including profile).
h) Right not to be subject to a decision based on automated processing that has legal or similarly significant effects.
i) The right to withdraw the consent given at any time.
3.3. ITB360 reserves the right to use all legal means necessary to verify the identity of those who request the exercise of ARCO rights in order to prove that they are, in fact, the respective data subjects.
4. Retention and Exclusion of Personal Data
4.1. ITB360 will keep the collected data for a minimum of six months to meet the purposes for which ITB360 collects it, including for legal and tax purposes. This deadline is essential to ensure the collection of statistics on access and customer governance. After this period, they will be discarded through data destruction techniques, through the ITB360 server.
4.2. ITB360 follows the security standards commonly used to ensure the safety of Users. However, considering that no security system is infallible, ITB360 disclaims any liability for any damages and / or losses arising from failures, viruses, or invasions of the ITB360 database, except in cases where the sole fault of the ITB360.
4.3. The data obtained from our Users may be stored on our own servers or from a third party hired for this purpose, allocated in Brazil and / or in another country, and may also be stored by means of cloud computing technology and / or others that may arise in the future, always aiming at improving and perfecting our activities. The security of this cloud is achieved, above all, by maintaining its integrity,
confidentiality, authenticity, availability, and privacy. In addition, this data is accessed only by authorized professionals.
4.4. Our Users can request the display, rectification, or ratification of their personal data, through the service tools provided by us.
4.5. Using the same service tools, our User can request the deletion of his personal data collected and recorded by ITB360, provided that the contract between the User and ITB360 has ended and the minimum legal term has elapsed. ITB360 clarifies that in some situations it will not be possible to perform the complete deletion of data.
4.6. We may, for the purposes of auditing and preservation of rights, remain with the history of recording our Users' data for a longer period of time in the event that the law or regulatory rule so establishes or for the preservation of rights. However, we have the option of permanently excluding them at their convenience in a shorter period.
4.7. All of our promotional emails are sent through email@example.com and their links lead directly to the ITB360 website.
4.8. Costumer relationship emails will be sent to Users who choose to receive them. And if at any time, the User wishes to cancel the receipt of these correspondences, his order will be promptly fulfilled.
5. Changes and / or Modifications to this Policy
5.2. The new Policy will come into force 1 (one) day after being published on the Platform. Within 15 (fifteen) days from the publication of the changes, the User must inform, by email, if he does not agree with the amended terms. In this case, the contractual link will cease to exist, as long as there are no open accounts or debts. If there is no manifestation within the stipulated period, it will be understood that the
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