Bruno Cassaro Strunz Ltda. (“BCS”), a limited liability company, registered with the CNPJ/MF under no. 42.877.547/0001-10, headquartered in São Paulo/SP, at Rua Igati, 2, Vila Anhanguera, CEP 04673-040, São Paulo/SP, is a company that offers solutions in lectures, workshops and mentoring. BCS is committed to protecting your privacy. This commitment reflects our value of earning and maintaining the trust of our customers, business partners and third parties who share their Personal Data with us.
1. What is the purpose of this Privacy Policy?
This Privacy Policy (“Policy”) aims to disclose the general conditions applicable to the processing of personal data collected by BCS through access to the website www.strunz.com.br, in accordance with the guidelines of the General Data Protection Law (Federal Law No. 13,709/2018 – “LGPD”).
2. Definitions
In order to facilitate the reading and understanding of this Policy, some important definitions are indicated in the table below.
Defined terms
|
meaning
|
| Anonymization |
Process through which data loses the possibility of association, directly or indirectly, with an individual, considering the reasonable technical means available at the time of Processing |
| ANPD |
National Data Protection Authority, the body responsible for monitoring compliance with the LGPD |
| BCS |
The company Bruno Cassaro Strunz Ltda. |
| Personal Data |
Any information relating to a natural person, directly or indirectly, identified or identifiable |
| Sensitive Personal Data |
Special category of Personal Data relating to racial or ethnic origin, religious belief, political opinion, membership of a trade union or organisation of a religious, philosophical or political nature, relating to health or sexual life, genetic or biometric data relating to the natural person |
| Policy |
This Privacy Policy |
| Holder |
Natural person to whom the Personal Data refers, such as former, current or potential customers and their employees, contractors, business partners and third parties |
| Treatment |
Any operation carried out with Personal Data, such as collection, production, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, deletion, modification, transfer, dissemination or extraction |
| User or You |
Website visitor(s) who contact BCS by filling out the available forms, registering or simply browsing the Website |
| Website |
The electronic address www.strunz.com.br is maintained by BCS3. Who is responsible for your information? |
BCS is responsible for the Personal Data (and the Controller, for the purposes of the LGPD) that it originally collects through its Website. This may also be explained in separate privacy notices available when your Personal Data is first collected by BCS.
4. Quick Reading
BCS collects Users’ Personal Data to generate leads, that is, to build relationships with individuals who may show interest in the services provided by BCS, by accessing and sending information via the Website. BCS uses the Personal Data collected through its Website to contact and offer services to Users. BCS, for its own purposes, also uses such information to analyze and improve the way it provides these services, as well as to create products and services to be offered to Data Subjects. The Data Subject of the Personal Data collected by BCS has important rights guaranteed by the LGPD, which may be exercised by You. The main point of contact at BCS in case of questions regarding the Processing of your Personal Data is bruno@strunz.com.br.
5. When and how do we obtain your information?
BCS collects Personal Data in the following ways:
- When you contact us by completing one of the forms available on our Website to request a service or to send us some exclusive material. For example, if you ask us to obtain quotations on your behalf, or if you contact us as a representative of your employer to enquire about a professional service you would like us to provide for your company;
- When You simply browse our Website;
- If you contact us with a request, complaint or question; and/or
- When you interact with us through social media.
6. What data do we collect and for what purposes?
During your experience on the Website, BCS may collect different types of Personal Data, either automatically or provided directly by You. See the table below which Personal Data may be collected, in which situations they are collected and for what purposes:
ORIGIN
|
PERSONAL DATA COLLECTED
|
PURPOSES
|
| Website Navigation |
· IP address · Cookies · Information about the device used for navigation · Information about the device’s operating system · Geolocation · Logs (date and time of access) |
· Protect security · Enable essential Website features · Develop new features and improvements for the Website · Analyze, in an anonymous way, navigation data on the Website |
| Filling in Contact Forms |
· Name · Email · Phone · Name of the company you represent · Message |
· Reply to your message and return your initial contact · Send quotes and/or work proposals · Offer services · Send communications, materials and newsletters that you have consented to receive |
Sensitive Personal Data BCS will not process Sensitive Personal Data. Personal Data of Children and Adolescents BCS does not process Personal Data of Children and Adolescents. Our Website is not directed to children or adolescents, and BCS does not provide services to minors under 18 years of age. Third-Party Data If You share Personal Data relating to other individuals with BCS, You represent that You have the authority to do so and that You have a legitimate legal basis for doing so, such as obtaining the necessary consent to authorize the use of such information under the terms of this Policy. Cookies and other technologies Information about Your use of the Website may be collected through cookies. Cookies are pieces of information stored directly on the computer You are using. Cookies allow the collection of information such as browser type, time spent on websites, pages visited, language preferences, and other anonymous traffic data. We and our service providers use information to protect security, facilitate navigation, display information more efficiently, and personalize your experience when using the Website, as well as for online tracking. We also collect statistical information about the use of the Website to continually improve our design and functionality. If you do not want your information collected through cookies, there is a simple procedure in most browsers that allows you to automatically reject cookies, or to give you the option to accept or decline the transfer of a specific cookie (or cookies) from a particular website to your computer. However, this may make it inconvenient to use the Website. The settings you choose may affect your browsing experience and the operation of some features. In this regard, we decline any liability for the consequences resulting from the limited functioning of our Website caused by the deactivation of cookies on your device (inability to set or read a cookie). Pixel tags (also known as Web beacons and clear GIFs) may be used in connection with the Website to track User actions, measure the success of our marketing campaigns and collect statistical data on Website usage and response rates, and for other unspecified purposes. We may hire behavioral advertising companies to obtain reports on BCS advertisements across the Internet. To do so, these companies use cookies, pixel tags and other technologies to collect information about your use, or the use of other users, of the Website. BCS is not responsible for pixel tags, cookies and other similar technologies used by third parties.
7. Legal basis
In accordance with the provisions of the LGPD, BCS will process Users’ Personal Data in good faith and in compliance with the legal principles for its use, namely: purpose, adequacy, necessity, free access, data quality, transparency, security, prevention, non-discrimination, accountability and reporting. In most cases, processing is justified based on the fact that:
- is necessary for the performance of obligations under a contract to which You are a party, or to take steps (at Your request) to conclude a contract;
- it is necessary for us to comply with a legal or regulatory obligation or to assist in complying with a court order, competent authority or supervisory body (e.g., when we need to collect certain information for tax or accounting purposes or when we need to make disclosures to courts or regulators);
- is necessary to guarantee our regular exercise of rights in judicial, administrative or arbitration proceedings;
- for the protection of the life or physical safety of the Holder or a third party; or
- is included in our legitimate interests, always within the limits of what is expected by the Data Subject, especially taking into account the existing relationship with BCS, and never to the detriment of their interests, rights and fundamental freedoms.
When consent is necessary for the performance of any Processing activity, BCS will adopt the necessary measures to ensure that this is considered valid under the terms of the LGPD. In such cases, we will inform you in advance about the consequences arising from your failure to provide it.
8. How long do we retain your Personal Data?
The length of time for which we retain your Personal Data depends on the purpose for which it was obtained and its nature. We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is permitted by law. We may store your Personal Data for longer periods in specific circumstances to ensure that we have an accurate record of your dealings with us, in case of any complaints or disputes, or if we reasonably believe that there is potential litigation, so that we can exercise our rights in judicial and administrative proceedings.
9. Do we share your Personal Data?
We do not rent, sell or otherwise disclose Personal Data to third parties unrelated to BCS for their own marketing purposes. We do not share your Personal Data with third parties except in the following circumstances discussed below. We may share Personal Data with business partners who provide certain specialized services to us or who collaborate with us on projects. Examples include advertising agencies that help manage the Website, IT support technicians if there are technical issues involving the Website, and attorneys if legal matters arise. These service providers are contractually prohibited from using or disclosing the information except as necessary to perform services on our behalf or comply with legal requirements. Wherever Personal Data is shared, BCS will limit such sharing to the minimum necessary. BCS ensures that these third parties adequately protect your Personal Data and that their activities are limited to the purposes for which your Personal Data was provided.
10. International transfers
As a general rule, BCS does not share your Personal Data internationally. If it makes an international transfer, BCS will adopt the necessary safeguards so that the Personal Data of its suppliers has the same level of protection that BCS adopts for its own Personal Data, and, whenever necessary, BCS will use the international data transfer mechanism required by data protection laws.
11. We have security measures in place to protect your information
The security of your Personal Data is important to us and BCS has implemented reasonable physical, technical and administrative security measures to protect Personal Data from loss, misuse, alteration or destruction. We protect your Personal Data from unauthorized access, use or disclosure using security technologies and procedures, such as encryption and limited access. Only authorized individuals have access to your Personal Data and they receive training on the importance of protecting such information. Our service providers and agents are contractually obligated to maintain the confidentiality of Personal Data and may not use such information for any unauthorized purpose. The Website is security certified.
12. Your Rights
The LGPD guarantees the Personal Data Holder several rights, which BCS fully respects. These rights are listed below, so that You can exercise them by requesting BCS:
- Right of Confirmation: the right to confirm whether BCS processes your Personal Data
- Right of Access: the right to access your Personal Data held by BCS
- Right to Correction: the right to request the correction of incomplete, inaccurate or outdated data
- Right to Anonymization, Blocking or Deletion: the right to request the anonymization, blocking or deletion of unnecessary, excessive data or data processed in non-compliance with the provisions of the law
- Right to Portability: the right to request the portability of Personal Data to another service provider
- Right to Erasure: the right to erasure of Personal Data processed with your consent, to the extent permitted by law
- Right to Information: the right to receive information from BCS about the public or private entities to which your Personal Data has been shared and about the possibility of not providing consent and the consequences of refusal
- Right to Withdraw Consent: the right to request, through a free and easy procedure, the withdrawal of your consent regarding the Processing of your Personal Data
Users’ requests will be handled with special care so that BCS can ensure the effectiveness of the Data Subjects’ rights. It is important to mention that the User may be asked to provide proof of his/her identity, in order to ensure that Personal Data is only shared with the Data Subject. You should be aware that, in certain cases, your request may not be immediately satisfied, and that BCS may not be able to fulfill such request due to some impediment resulting from the need to comply with legal or contractual obligations.
13. Third-party websites and applications
This Policy applies exclusively to services provided by BCS. If you click on any link on our Website and are redirected away from it, we encourage you to read the terms and policies of that third-party website before continuing to browse. We are not responsible for the privacy practices of other websites.
14. Contact Us
If you have any questions, would like to know more information about our Personal Data processing and privacy practices, would like to discuss deletion options or withdrawal of consent, would like to make a complaint about a violation of the Law or this Policy, or would like to exercise any of your rights provided for in the LGPD, please contact us at the email address: bruno@strunz.com.br.
15. Changes to this Policy
We may update this Policy from time to time. When we do, we will post the current version on this Website and revise the version date located at the bottom of this page. We encourage you to periodically review this Policy so that you are aware of our privacy practices. São Paulo/SP, November 2022. Bruno Cassaro Strunz Ltda. ***
