We at REPENSE (R COMUNICACAO E MARKETING EIRELI), a private legal entity with TIN No. 08.549.609/0001-26, located at Rua Girassol, number 285, Conjunto 22, Vila Madalena, State of São Paulo, City of São Paulo, Zip Code: 05.433-000, need to process personal data to provide products and services and also to engage with persons who browse through our website.
- how and why we collect and use personal data on our website (https://www.repense.com.br/) and during the period we render our services;
- your rights as the data holder; and
- how you can use your rights.
If you have any questions, please contact us through the channels presented at the end of this Policy (item 6).
During your browsing on our website, we can show links to some of our partners' websites. We always try to carefully assess our providers and partners, and establish contractual duties regarding personal data protection and information safety. However, we strongly recommend that you always consult the privacy policies of these partners before you provide them with your data.
This Policy was last updated in August 2021.
1. WHY WE USE YOUR PERSONAL DATA
REPENSE acts as a provider of several communication services to third parties, such as content creation, CRM, media strategy, inbound marketing, data visualization and data analysis, using digital marketing solutions to perform its activities. In such occasions, REPENSE may process data as requested by its clients, always following their guidelines, in accordance with these companies' specific needs.
We also collect and use some of your personal data when you access our website, among other situations, as well as when you send us an email through our Contact form. Check more details below:
1.1. Data you voluntarily provide by using our website
Type of data collected
Newsletter subscription: if you sign up to receive our newsletter, we will be using the shared data to send articles, news and campaigns to your email and mobile phone.
Full name, phone and company.
Contact you: if you fill up the contact form available on our website, or if you contact us using one of our social media channels, we will be using the data you provide to contact you and inform you about our services or to reply to messages you sent us.
Full name, email, username, phone and some information displayed in the message you sent.
1.2. Data we collect from you during your browsing on our website by using cookies
Type of data collected
Register your IP, data and time of access.
To activate essential functionalities, such as antivirus, presentation of content on the screen, among other functions.
To understand your browsing behavior and how the website is being used, to improve your user experience. Data collected are aggregated and, whenever possible, anonymized.
Browsing data: IP, data and time of access, geographical location, type of browser, duration of visit and pages visited.
Data from device used: model, manufacturer, operating system, telephone service provider, type of browser and connection speed.
- Essential Cookies: are strictly needed cookies to provide our services and to make our website work correctly, ensuring browsing safety, content scaling and REPENSE’s compliance to legal requirements.
- Advertising Cookies: are cookies used to direct advertising content according to your profile and preferences. They are used to make you see the more relevant and more interesting ads during your browsing.
- Analytics: provide information about your browsing behavior and how the website is being used. Data collected are aggregated and our goal is to better understand our users, so we can offer more interesting content, services and products for people accessing our website.
If you would like to have a general view of the cookies installed in your device, or if you want to delete or restrict them, we recommend you use the settings in your browser. You will find more information about how to proceed by clicking on the links below: For information related to other browsers, visit the website of the browser’s developer.
|Firefox||Chrome||Safari||Internet Explorer ou Edge|
Minors: Services offered by REPENSE - including the use of our website - are not directed to persons under 18 (eighteen) years of age. Therefore, we do not collect or consciously request information from minors under 18 (eighteen) years in our operations. Users under 18 (eighteen) must not try to sign up to have access to our services or send us any type of data.
2. WHO WE SHARE YOUR PERSONAL DATA WITH:
REPENSE works in partnership with other businesses to offer its services. Thus, we might share your personal data with these partners, always seeking to ensure your privacy and, whenever possible, in an anonymous form. Below we describe situations within REPENSE’s context in which we might share your personal data:
- Providers: we have providers who can help us with processing the personal data collected; the information is publicized solely for the purpose of rendered services. We always try to carefully assess our providers and partners, and establish contractual obligations regarding personal data protection and information safety, so as to minimize the risks for the users. Among these providers we have, for instance, data hosting services and companies in charge of communication exchange.
- Partners: besides these providers, we also share your personal data with partners to enable the rendering of our services to our clients. The same way we work with our providers, we carefully assess our partners, and establish contractual obligations regarding information safety and personal data protection, so as to minimize the risks for users. As examples of partners, we have partner companies responsible for rendering photo services or renting photo studios.
We reserve the right to share any personal data we believe necessary to comply with legal requirements and also to protect our rights and those of our collaborators. Besides this, we might also be required to share some of your personal data with public entities to comply with legal or regulatory requirements or to comply with orders from legal authorities.
Data transfer to other countries: personal data collected might be transferred to companies located in the United States of America. REPENSE has its headquarters in Brazil and its website is directed to persons located in Brazil. Therefore, the laws ruling personal data protection are the Brazilian ones. This transfer happens due to the fact that some of REPENSE’s providers and commercial partners might be located in foreign countries.
3. DATA HOLDER’S RIGHTS
The Brazilian law ensures you a series of rights about your personal data. Below we provide a summary of such rights and information about how you can use them in relation to REPENSE:
Confirmation and Access
It allows you to verify whether we processed your personal data and, if so, request access to such data.
It allows you to correct your personal data in case they are incomplete, incorrect or outdated.
Anonimization, blocking or deletion
It allows you to request us to (a) anonimize your data, so that they can no longer be associated to you and, thus, cease to be your personal data; (b) block your data, temporarily holding our capacity to process them for specific purposes; and (c) delete your data from our archives. These requests can only be granted if the data we have from you are unnecessary, excessive or not handled in compliance with the law.
You have the right to request access to your personal data to be transferred to a third party, provided such transfer does not violate REPENSE’s copyrights or trade secrets.
When we process your personal data with your consent, we can request to have your data deleted.
Information about sharing
You have the right to receive information about public and private entities with which we have shared use of your data. We will keep a list of partners we share your data with in this Policy.
Information about the possibility of not authorizing
It allows you to have clear and complete information about the possibility and the consequences of not allowing us permission, when requested. Thus, whenever we ask your permission, you can deny it - although, in such cases, we will not be able to ensure access to certain services.
Withdrawal of permission
You have the right to withdraw your permission regarding data processing activities that are based on your consent. However, this will not affect the legality of any previously processed data. If you withdraw your consent, we might not be able to provide certain types of communication or services to you, but we will notify you at the time.
The law authorizes personal data processing even without your consent. In case you don’t agree with any purpose of processing your data, you will be able to present an opposition request to REPENSE, asking for its interruption.
When we receive your request, we might ask you to provide some information or additional documents to verify your identity and analyze your request. We proceed in this manner to ensure everybody’s safety and privacy aiming to avoid the publication of personal data to non-authorized individuals.
Also, some requests might not receive immediate reply, but REPENSE is committed to reply to all requests in a timely manner and always in compliance with the applicable law. At any rate, you will always be properly informed.
To exercise any of these rights you can email us directly at email@example.com.
In some cases, REPENSE might have sound reasons to deny your request to exercise rights. These situations include, for instance, cases in which the disclosing of specific information could violate REPENSE’s or third-parties' copyright or trading secrets, as well as cases in which requests for anonimization, blocking or deletion of data cannot be done due to the existence of REPENSE’s obligation to keep data, either to fulfill its legal and regulatory requirements, or to allow the defense of REPENSE or third-parties, including possible future disputes, within the applicable time frame.
4. HOW LONG PERSONAL DATA ARE KEPT:
Personal data are kept only for the time necessary to fulfill the purposes to which they were collected, except it there is any other reason for its storage, such as complying to any legal, regulatory, contractual and other obligations, provided they have proper legal basis. We always run a technical analysis to determine the retention period adequate for each type of personal data we collect, considering its nature, the need for the collection and the purpose for which it will be processed as well as occasional needs to store data to comply with legal and regulatory requirements, or safeguard rights, in accordance with the law.
5. HOW WE PROTECT YOUR PERSONAL DATA:
Our duty is to care for your personal data and use them for licit activities as described in this Policy. To ensure your privacy and protection of your personal data, we adopt safety practices adequate for our market, using measures and safety control of information appropriate for our activity, such as control of access in our directories, complex passwords, double authentication factor, anti-DDoS services, among other safety tools.
We work to preserve your privacy and protect your personal data, but we cannot guarantee total safety when you use the internet. Non-authorized use of your data, hardware or software failures that are not under REPENSE’s scope of control and other factors may compromise the safety of your personal data. Thus, your actions are key to maintain a safe environment to all. You can help us by adopting good safety practices regarding your data - such as, for instance, not sharing your password with third parties - and, in case you identify or find out something that compromises the safety of your data in your interaction with us, please contact us via one of the channels presented at the end of this Policy.
6. CONTACT AND GENERAL INFORMATION
If you have questions, comments or suggestions related to this Policy, contact us through the channels below:
Person in Charge: Sérgio Costa
Physical Address: Rua Girassol, 285 cj 22, Vila Madalena, São Paulo SP CEP 05433-000