Presentation

When using this and other Proxy Company websites, we collect data automatically recorded during visitors’ browsing, as well as that voluntarily provided when filling in forms, simulation tools and authentication fields for access to restricted pages.

This Privacy and Usage Policy contains information on what and how we process the data collected, which is used to manage the sites themselves, the respective accounts of participants registered with the Proxy Company, and lead management systems.

This Policy has been drawn up in accordance with the Brazilian Civil Rights Framework for the Internet (Law No. 12.965 of April 23, 2014), the General Law on the Protection of Personal Data (Law No. 13.709 of August 14, 2018) and the European General Data Protection Regulation (GDPR).

Guidelines for data collection and processing

The data collected during user browsing is processed by Proxy Company lawfully, fairly, ethically, transparently and confidentially, respecting the privacy of personal information.

Security procedures are based on information technology infrastructure and appropriate organizational measures capable of protecting the data collected from unauthorized processing, loss, destruction or accidental damage.

The data obtained is used only for legitimate purposes, limited to the purposes for which it is processed, and for the period necessary to fulfill those purposes.

Under no circumstances will the data be altered by Proxy Company, except in the case of inaccuracies verified by the entity or users, in which case rectifications will be made on a reasoned basis.

The automatic collection of data through browsing cookies can also be interrupted, in this case by the user themselves, by means of settings on their device and browser, except in cases where this hinders the performance of essential functions.

Data collected by the website

Browsing data – cookies: These are small text files that are automatically sent to the user’s internet browser when visiting our pages, and which record browsing. Among the information obtained with cookies are: IP address, date and time of browsing, geolocation, page that originated the access to the site, operating system, browser and device used for access.

Data for sending forms: These are those used to fill in contact and sign-up forms. They can be: name, CPF, email, telephone, city, state, company, message content, text and image files.

Data for access authentication: Data entered in fields responsible for directing the user to the restricted information area.

List of cookies and APIs used

Treatment and use of collected data

Improving the site itself: The data obtained by browsing cookies is used to quantify access to the site, identify browsing habits, most visited pages, most used devices, origin of access (whether it was direct or came from another site, in which case which one), sponsoring company of the plan from which the access originated, where appropriate, etc. In short, it’s a mapping process that lets you know how the site is used and, consequently, improve the quality and layout of the content.

Access to the individual area of the site: The data entered in the site’s authentication fields (login and password) is collected in order to identify and enable access to the individual information area, restricted to sellers or administrators.

Legitimate interests and cases provided for by law: in addition to the reasons explained in the previous items, the data collected by the site may be used for situations such as compliance with a legal or regulatory obligation, regular exercise of rights in judicial, administrative or arbitration proceedings (under the terms of the Arbitration Law – No. 9,307 of September 23, 1996), satisfaction surveys of the entity, carrying out actuarial studies.

It is also important to point out what is outside the scope of the use of the data collected. In this sense, we would like to point out that the Proxy Company’s websites do not aim to define profiles (profiling), promoting automated processing of personal data to evaluate, analyze or predict user characteristics related to their professional performance, economic situation, health, reliability, among others.

The processing of personal data for purposes not provided for in this Policy will only take place with prior notice to the user. In any case, the rights and obligations provided for herein shall remain applicable.

Data retention and use period

• Compliance with legal or regulatory obligations;
• Regular exercise of rights in judicial, administrative or arbitration proceedings (under the terms of the Arbitration Law – nº 9.307, of September 23, 1996);
• To carry out actuarial studies and satisfaction surveys;
• To transfer participant funds, in accordance with the plan’s regulations and current legislation.

Data sharing

The data collected may be shared in situations such as those set out below:

• With service providers who are partly or wholly responsible for managing the site, for the execution and/or re-establishment of functionalities;
• With service providers responsible for Proxy Company’s communication channels, for the purpose of disclosure consented to by the user, in the case of personal data, and without the user’s consent, in the case of anonymized, grouped information, cookies or forms that do not personally identify the user;
• With Brazilian regulatory and supervisory bodies, auditors, actuaries, research institutes;
• With legal, judicial, administrative or arbitration authorities;
• In cases of acquisition, merger or other corporate reorganizations, in compliance with general legislation, especially social security legislation.

Rights and duties of site users

Users have the right to access their personal data obtained and processed by the site, and to request rectification in the event of inaccuracy or deletion, provided that the request does not imply legal non-compliance and/or impediment of processes inherent to the management of the entity.

Users have the right to limit the processing of their personal data to the purposes of the organization and the period necessary to fulfill the legitimate objectives for which it is collected.

Users may exercise their rights by sending a request to the Proxy Company’s customer service and communication channels, which have the duty to rectify or delete the data, where appropriate, and inform the user, in an informed manner, of the measures adopted.

It is the user’s duty to handle the personal information entered on the sites responsibly, especially that relating to authentication for access to the individual page. In this sense, it is also the user’s duty to provide only their personal data to the site while participating in the Proxy Company, in order to safeguard and protect the rights of third parties.

The user must ensure that access to and use of the site does not infringe Proxy Company’s intellectual property rights, does not include messages and images that are criminal, defamatory, pornographic, racist, prejudiced or violent in nature.

Users must also answer for their actions and the content transmitted via the site, from the point of view of truthfulness, omission of information and, where appropriate, compensation for damage caused to Proxy Company, third parties and other users.

Conclusion

The Proxy Company has developed this Policy based above all on the principle of transparency, which in this case applies to the lawful, ethical, legitimate, secure, responsible and confidential way in which it handles user data during browsing.

The guidelines explained here are restricted to the company’s websites and do not extend to third-party addresses available on our pages and news via links, which the user can click on to be directed.

By using the Proxy Company website, the user consents to the Privacy and Use Policy. As this is a document that may be updated at any time because of any changes in regulations and/or the company’s processes, we recommend periodically consulting this page, which will always have the most up-to-date version.

Última Atualização: 04/01/2020 – 07:34