us.cluube.com

Cluube Privacy Terms

Last Updated June 3rd, 2022

Using our services as a user implies consent (acceptance) to our Privacy Terms (this document) and Terms of Use (https://www.cluube.com/termsAndConditions.do), either for Personal Accounts (Personal Cluube) or for Professional Account (Professional Cluube).

Cluube.com is a relationship management service and loyalty program on the internet, which acts only as a structure for the account and order of the participants (in Personal Cluubes) and of companies or individuals (in Professional Cluubes), both contracting.

This Privacy Notice describes the information we process to enable the operation of Cluube.com. In order to provide our services to you, to meet your goals and your choices, we need to process information about you. The types of information we collect depend on how you use our Products and your choices.

When reading our Term, please note that the same applies to Cluube.com, a tool owned by FD CORP registered with CNPJ/MF under n° 09.508.481/0001-15 ("Grupo 1a1").

We try to keep our Term as simple as possible, but if you are not familiar with the terms used, please consult the brazilian general data protection law "LGDP" (Law nº 13.709/2018). With regard to the processing of personal data provided in this term, the provisions of the euporean General Data Protection Regulation "GDPR" also apply.

You have the right to object to the processing of your personal data, for this it is sufficient not to register on Cluube.com or if you have already registered at any time, you must enter your account and request the cancellation of your participation. In this way, immediately or within 30 (thirty) days all your personal data will be deleted and, from that moment on, all your participations will be anonymized, being linked to a simple number (anonymous participant) no longer linked to you. , and it is impossible to recover such a link.

When a person or company decides to use Cluube.com, its main objective is so that, from the processing of your personal data and the data of your participation, you can earn points in a gamification dynamic, participate in recreational activities, display your posts, your interactions with other people and/or companies, display your activities and rankings, among other things in the relationship marketing universe, and with that, have different benefits, from pure fun or, eventually, any others, according to what is offered in each Cluube you choose to participate, including the benefits offered by their partners, under the responsibility of each Cluube Professional plan contractor.

Therefore, by making use of Cluube.com you are not only consenting to the use of this data, as this is exactly its purpose: you are contracting the service, based on your personal data, the data of your participation, as well as the use of intelligent mechanisms to process such data, and eventual crossings of data and information, so that you can have the desired and demanded effects that justify your use of Cluube.com, which makes your participation in the Professional Cluubes that you choose if integrate and interact.

Please take a moment to learn about our practices set out in these Privacy Terms and our Terms of Use (https://www.cluube.com/termsAndConditions.do) and, if you have the slightest objection, do not use Cluube.com, neither as a participant (user) in a Personal Account (Personal Cluube), nor in a Professional Account (Professional Cluube) and delete your account if you have already registered.

Personal Cluubes

A Personal Account is called a Personal Cluube and is created when a person (USER) completes his/her registration. It is an online space that can be customized by the creator of the account with their photo, colors and images and is intended for this person (USER) so that they can view, integrate (participate) and interact with other Cluubes, manage their data, profile and centralize the administration of the Cluubes that she wants to participate (or follow), among other available features.

The USER may participate in none, one or more Cluubes (either Personal Cluubes or Professional Cluubes). In their Personal Cluube, the USER will be able to manage their registration data (provide, delete, edit, update), publicly display their posts and activities carried out on Cluubes, centralize the visualization and administration of the Cluubes in which they chose to participate, in addition to searching for others , according to your interest, as well as acknowledge that we may show you paid ads and/or according to relevance based on algorithms that analyze your data and participation history.

In addition, the USER may have access to other functionalities, if available according to the contracted version (contracted plan), for example, functions such as highlighting posts and activities of the Cluubes that participates, and even posting their own content, independent of Cluubes Professionals. .

After your acceptance by clicking on the specific button to start your participation in a Professional Cluube, your registration data will be shared with the people or companies responsible for the Cluubes you choose to participate, and may, eventually, be made available to its partners, in accordance with with the rules established in each particular term and under the responsibility of each Cluube you choose to participate.

Therefore, only provide data that you want to be shared with these people or companies. After all, the main reason for using Cluube.com, participating in Cluubes (relationship programs of other CONTRACTING PARTIES) is that they can use this data to manage their points balances, cashback, among others in the universe of gamification and relationship marketing, create adherent content with your data, profile and usage; in addition to eventually evolving its products, services and offering promotions that are also relevant based on this information. 

Professional Cluubes

A Professional Account, also called Professional Cluube, is when a person or company hires a special plan so that it can create a relationship program focused on its target audience, according to its objectives, acting as the only controller from the public data, collected from the public's interaction with your Professional Cluube or from the data entries that the contractor of this Professional Account makes.

Each Professional Cluube will be able to create its own commercial name, have its own Policies, Terms of Use and Privacy Conditions. It is essential that you read the specific terms of each Professional Cluube before choosing to participate in each one of them.

By choosing to participate in a Professional Cluube, after clicking on the specific button to start your participation, you are also consenting to the particular terms, rules and processes made available and defined by this Professional Cluube, under the sole responsibility of each person or company responsible for the Cluube. Professional you participate. These particular terms cannot override what is defined in this Privacy Policy or the Cluube.com Terms of Use. In addition, they must process this personal data in accordance with this Privacy Notice and as permitted by applicable data protection laws and regulations. We have no control over these particular terms and over the actions taken by the responsible Cluube Profissional, therefore, be aware of the terms and actions of the Cluubes in which you choose to participate, and if you notice any non-compliance, please contact us.

The company or person responsible for Cluube Profissional will act as data controller of your participation, responses, points balances, medals and cashback, among other actions within the context of the specific relationship program.

Each Professional Cluube will be able to define its rules to authorize the participation of its target audience. You may be asked for additional personal data when contacting each Cluube that decides to participate. You are not obliged to provide the personal data that is requested within Cluube, but if you choose not to do so, Professional Cluubes may choose not to offer you permission to participate, or access to something, or even offer you a service. limited, or of poor quality, or will not be able to answer any questions you may have.

Who provides the data that is collected?

This Privacy Policy applies to personal data collected and processed within Cluube.com, whether made available directly by you, generated from your participation or included by the companies whose Cluubes you choose to participate.

What types of information do we collect?

1. Something you and others make and provide.  See the reasons below, in the item "What and how we use this information".

Information and Content You Provide: We collect your data, content, communications and other information you provide when you use our services, including when you register to create an account, create or share content, send messages or communicate with others or participates in the various activities of the Cluubes that you choose to participate. This may include information present in or about the content you provide (such as metadata), such as the location of a photo or the date a file was created.

Your posts, the activities you carry out, the coupons you issue, points and medals earned and rankings ARE PUBLIC: The information, data and content you choose to post in your Personal Cluube or when you use the posting tool within a Cluube Professional is public on your profile (Personal Cluube) and can be seen by anyone, inside and outside our Services, eventually, even if that person does not have an account on Cluube.com, for example, by integration for display on a wall electronically at an event, or on a company's website or app. This includes your username, your photo; any information and content you share publicly.

By using the post tool within a Professional Cluube, you are making the content public in your Personal Cluube and, in addition, consenting and authorizing the person responsible for the Professional Cluube to make the content public also within the specific Cluube, being able to highlight it . You are solely responsible for the content you post, make sure you comply with legal requirements and that you own the intellectual and copyright over what you post. There is no moderation or censorship in your posts that will be in your Personal Cluube. You will be able to choose to delete them whenever you want, using the administrative tools in your Personal Cluube or in the Professional Cluube that you used to make the publication, and with that they will no longer be publicly available.

When you carry out activities in the Cluubes you participate in, this information, together with the volume of points and eventual medals earned, appears for the other participants within the environment of the Professional Cluube in which you carried out the activity and at the same time it is public on your Profile.

Your position in different types of rankings, for example, but not limited to, the sum of points earned, the number of activities performed, benefits accrued, purchases, in different time windows may appear in the Professional Cluube you chose to participate in and in your Personal Cluube.

Networks and Connections: We collect information about the people, Cluubes, accounts, hashtags and groups you connect with and how you interact with them on our Services, for example the people you communicate with the most or the Cluubes you is part.

Your Use: We collect information about how you use Cluube.com, such as the type of content you view or engage with; the resources you use; the actions and activities you perform; the people or accounts you interact with; and the time, frequency and duration of their activities. For example, we record when you are using and the last time you used Cluube.com, what posts, videos and other content you viewed on our Products.

Information about transactions performed on our Products or financial transactions recorded by companies: If you use our Products for purchases or other financial transactions (such as when you make a donation), we collect information about the purchase or transaction. This may include payment information, such as your credit or debit card number and other card information; other account and authentication information; billing, delivery and contact details. We also collect information about the purchase or transaction when companies register the financial transaction, for example, to credit cashback to the user.

2. Device Information

As described below, we may collect information from and about computers, phones, connected TVs and other web-connected devices you use that integrate with our Products and Services, and we combine this information from the different devices you use. For example, we use information collected about your use of Cluube.com on your phone to better personalize the content (including advertisements) or features you see when you use our Products on another device, such as your laptop or tablet, or to assess whether you, in response to an ad we displayed on your phone, took an action on a different device. See the reasons below, in the item "What and how we use this information".

The information we may obtain from these devices includes:

Device attributes: information such as operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, file and application, and plugins.

Device Operations: Information about operations and behaviors performed on the device, such as whether a window is in the foreground or background, or cursor movements (which can help distinguish humans from bots).

Identifiers: unique identifiers, device IDs and other identifiers such as from games, apps or accounts you use, and Device Family IDs.

Device Signals: Bluetooth signals and information about nearby Wi-Fi hotspots, beacons, and cell towers.

Device Settings Data: Information you allow us to receive through the device settings you enable, such as access to your GPS location, camera or photos.

Network and connections: Information such as the name of your mobile operator or internet service provider, language, time zone, mobile number, IP address, connection speed.

Cookie Data: Cookie data stored on your device, including cookie settings and IDs, for example to maintain your login and keep referral data among friends.

3. Information from Professional Cluubes

Personal data that you wish to provide and your participation may be collected in administrative interfaces of Cluube.com made available to Cluubes Professional contractors, either in online actions or in offline actions, for example, to register a purchase or participation in an event. Each company may add data from other external sources, and, if they do so, they must make it clear in their particular terms, and they must have your consent to do so.

Those responsible for Professional Cluubes can send us information through the tools available to them, either by manually entering data in an administrative environment, by importing a file or API (integration interface between systems, for example, for integration with your CRM). In these cases, they provide information about your activities outside of Cluube, for example, a company could inform us about a purchase made in their virtual or physical store, or about your activity in an event, or about your participation within their website or applications. , or in an online game, among others.

Such Professional Cluubes receive your data when you access or use their services or through third parties they work with. Again, we emphasize and require that each of these Professional Cluubes contractors have legal authorization to collect, use and share your data before entering this information into Cluube.

See the reasons below, in the item "What and how we use this information".

4. Information from other sources

We collect personal data from other sources, including from third parties with whom we have trusted partnerships or integrations, and from third-party platforms where we operate accounts. For example, when using the "like" functionality on Facebook or Instagram. In addition, we receive information about your interaction, as well as that of other users, with our advertising to assess whether it is relevant and successful. We also collect information about you and your activities from third parties, where we offer services or products together, or from external enriched data providers who may offer a different view of the personal data we hold. See the reasons below, in the item "What and how we use this information".

When and how "special categories of personal data" or "sensitive data" are collected
Certain categories of personal data, such as those revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data to uniquely identify a person, data relating to health or relating to sex life or sexual orientation are classified as "special categories of personal data" or "sensitive data" and benefit from additional protection under legislation of data protection.

We limit as much as possible the general circumstances in which we collect and process these special categories of data. However, it is your free choice to participate in Cluubes that have such categories as their main focus and theme, such as, for example, and not exclusive, Cluubes that promote the meeting of people who have a common interest in religious discussion and learning, and so, therefore, can m directly create a link of your personal data from your free association and participation in this thematic Cluube.

It is your free choice to answer questions in activities within the Cluubes that you choose to participate that deal with these topics.

This data is the sole responsibility of the person responsible for the Professional Cluube that you chose to participate in, who is the data controller.

How do we protect children's privacy?

We understand the importance of taking extra precautions to protect the privacy and safety of children using Cluube.com. 

Most Cluubes are intended for use by adults. In cases where one of the Professional Cluubes is intended to be used by a younger audience, the person or company responsible for the Cluube must seek the means to guarantee the consent of the person with parental responsibility in cases where this proves necessary, in the strictest sense. compliance with applicable laws and regulations. 

If you are under the age of 18, you should review the terms of this Privacy Notice with the Parents Responsible to ensure that you understand and accept them. If we are aware that we have collected personal data from a child without the consent of the holders of parental responsibilities in cases where it should have been obtained, we will delete this personal data as soon as possible, creating anonymization of the data relating to their participation. Access to certain parts of Cluube and/or eligibility to receive prizes, samples and other rewards is generally limited to users over a certain age. 

We may use your personal data to perform age checks and enforce any age restrictions.

What for and how we use this information

We collect, process and disclose your personal data to fulfill your purposes as a Cluube.com contractor, in line with the choices you make.

This being your objective, and, therefore, having provided your consent for the activities of collection, treatment and disclosure of your personal data, when you choose to register on Cluube.com and when you choose to participate in Cluubes Professionals, you will have the right to withdraw your consent at any time, having to enter your account and request the cancellation of your participation, either for specific cancellation in each Cluube, or in a general and broad way of Cluube.com itself. In this way, within 30 (thirty) days all your personal data will be deleted, and all your participations will be anonymized, being linked to a simple number (anonymous participant) no longer linked to you, and impossible to recover such a link.

We collect and process your personal data only for specific and limited purposes, in line with the choices made by you and in accordance with the objectives of the people or companies contracting the Professional Cluubes you choose to participate.

Only with the processing of this data is it possible to carry out the services for which we exist to manage your points, medals, levels and benefits in the relationship and loyalty programs that are the Professional Cluubes, to eventually process your payments, so that the Professional Cluubes can evaluate and handle any complaints, to develop and improve our products, services, communication methods and the functionality of our websites, so that we and other contractors can offer you personalized products and communications, as well as targeted advertising and product recommendations and promotions.

There are many cases in which there is a legitimate interest to process your personal data, after all, we only exist for that, to meet the demands of USERS and the people and companies contracting Cluube Profissional. This legitimate interest is the premise for your hiring when you subscribe to a loyalty program (Cluube Profissional), to Cluube.com itself and we use the personal data collected to conduct data analysis to improve our products and services and make possible the main end of Cluube.com. 

For the specific purposes listed below, we or Contractors of Professional Cluubes may also automatically or manually create profiles by analyzing information about your online browsing, searches and usage and purchase habits, and your interactions with communications. of brands and Cluubes, through the construction of segments (creation of groups that share common characteristics) and placing your personal data in one or more of these segments. 

In addition, we process your personal data using automated means as well. An automated decision is a decision made exclusively by automatic means, where no human is involved in the decision process involving your personal data.

In a few cases, Cluube.com acts as the controller of the Data because you have hired us to do so. Therefore, you declare knowledge and consent for us, responsible for Cluube.com to collect, process and disclose your personal data on your behalf and in order for the following specific purposes:

So that you can manage (provide, view, delete , edit) your data, manage the content posted by you (provide, view, delete, edit), and gather the Cluubes that you decide to participate in your Personal Cluube, as well as so that we can display your posts, list of activities carried out, points and medals won;

So that we can provide you with recommendations for Cluubes, products, services and personalized communications, as well as targeted advertising and recommendations for products, activities, etc., within your Personal Cluube environment;

For us to use the information we have to develop, test and improve our Products and Services, including conducting polls and research, and testing and troubleshooting new products and features.

For us to use the information we have to help Professional Cluube contractors develop, test and improve their Products, Services and your Cluube. We use the information we have to measure the effectiveness and delivery of communications, activities, engagement, advertisements and services, and to understand the types of people who use such services and how they interact with the respective Cluubes, websites, media, advertisements, applications, products and services.

For us to use the information we have to send you marketing communications, to communicate with you about our Products, and to inform you about our policies and terms. We also use your information to respond when you contact us.

Why We Use Information to Promote Security and Integrity: We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other negative experiences, maintain the integrity of our Products, and promote security on and off the Services from Cluube.com. For example, we use the data we have to investigate suspicious activity or violations of our terms or policies.

In most cases, the controller of the Data is the person or company contracting Cluube Profissional.

Your registration data is shared with all the Cluubes you choose to participate in. However, by default, membership data in one Cluube is not shared with another. When you choose to participate in any specific Professional Cluube, you contract with us, declare your knowledge and give us your consent to collect, process and disclose your personal data on your behalf and on behalf of those responsible for the Professional Cluubes you choose to participate. for the following specific purposes:

So that you and the Contractors of Professional Cluubes can manage the information of the activities carried out by you in the Professional Cluubes that you decide to participate, as well as manage your points, medals, level, ranking, benefits, as well as all others elements that make up the gamification, relationship and loyalty mechanisms, such as displaying positions in the rankings of the Cluubes you chose to participate in;

In order for Professional Cluubes contractors to create personalized content, products and services for you, we use your connections, preferences, activities and interests based on the data we collect and which we become aware of through you and other sources (including data with special protections you choose to provide); how you use and interact with the specific Cluube;

So that Contractors of Professional Cluubes may eventually process your payments, if you purchase products and services from them, to enable you to receive the product or service of your demand, deal with your questions and requests, and evaluate and deal with any complaints;

So that Contractors of Professional Cluubes can process and respond to your requests or to contact you to respond to your questions and/or requests;

So that Contractors of Professional Cluubes can eventually take their registration data, participations and responses to external systems, for example, for use in private CRMs for the management of the relationship with the public, according to the rules defined in their terms of use private individuals;

So that Contractors of Professional Cluubes develop and improve their products, services, communication and relationship methods and quality assurance;

So that the Contractors of Professional Cluubes can administer contests or promotions in which you have participated;

So that Contractors of Professional Cluubes can communicate information to you and to manage your registration and/or subscription to notifications by email, sms, whatsapp or other communications;

So that Contractors of Professional Cluubes can manage the daily business needs related to their participation in contests, sweepstakes or promotional activities;

So that Contractors of Professional Cluubes can authenticate the identity of individuals who contact us by telephone, electronic means or other means;

So that Professional Cluube contractors can understand and assess the public's changing interests, desires, and needs, to improve their current products and services, and/or develop new products and services; and

So that Professional Cluubes contractors can provide you with personalized products and communications, as well as targeted advertising and recommendations for products, activities, etc.

So that Professional Cluubes contractors can use the information to verify accounts and activities, combat harmful conduct, detect and prevent spam and other negative experiences, maintain the integrity of your products and services, and promote safety inside and outside your Cluubehouse. For example, they use the data to investigate suspicious activity or violations of their particular terms or policies.

Where it is necessary for us to collect and use your personal data for purposes other than those mentioned above or for other purposes, we will inform you in advance or at the time of collection to ask for your consent to process your personal data.

We also process your personal data when necessary to fulfill a legal obligation (for example, a tax or social security obligation) that obliges us to process your data. For example, this will be the case when we are facing a court order that requires the processing of your personal data for a specific purpose, or when we are obliged to process personal data in order to report, for example, suspicious transactions in accordance with the anti-laundering rules. of capital. 

Automated decision-making

In some situations, CLUube processes your personal data using automated means. An automated decision is a decision made exclusively by automatic means, where no human is involved in the decision process involving your personal data. 

We will not make decisions based solely on automated decisions that have a significant impact on you. If we do, we will notify you and provide you with clear information about our decision to rely on automated processing to make our decisions and our legal basis for doing so.

You have the right not to be subject to a decision that is solely based on automated processing and that produces legal or other significant effects that affect you. In particular, you have the right:

to obtain human intervention;

to express their point of view;

to obtain an explanation of the decision reached after an assessment; and

to contest that decision.

With whom will the data be shared?

We do not sell and will not sell your data. As Cluube.com is a tool owned by 1a1, a company that is part of the Grupo 1a1, 1a1 shares your personal data within the Grupo 1a1 and with third parties in the following circumstances:

The data you choose to make available and your participation in general in Professional Cluubes or your Personal Cluube:  We share your data with other Cluube users when you choose to make it publicly available on the Cluube network and choose to participate in activities, for example by showing them your publications when you use the posts tool, displaying your photo and name in rankings and in a list of activities completed, when you issue coupons, when you share your social networks and other contacts, etc.

Your participation in Professional Cluubes. We share your data with each contractor of a Professional Cluubes that you choose to participate, and this contractor may share your data with their partners and sponsors, in accordance with their particular terms of use, under the sole responsibility of the company whose relationship you chose to participate in, this being the primary focus of your choosing to participate in Cluube.com;

External service providers and partners, limiting themselves to the personal data necessary to perform their functions, but can not use them for other purposes. In addition, they must process this personal data in accordance with this Privacy Term and as permitted by applicable data protection laws and regulations.

Your participation in your Personal Cluube. Your Personal Cluube usage data, when you choose to participate in activities or challenges, may also be shared with our sponsors and advertisers.

Other third parties. Your data may also be used on advertising networks, advertising servers, social networks, software developers for new functionality and improvements, and analytics companies or other third parties related to marketing, promotional, data enrichment and other offers, as well as product information. They must process this personal data in accordance with this Privacy Notice and as permitted by applicable data protection laws and regulations.

Transmissions from businesses. Your personal data will be used by us or shared with Grupo 1a1, mainly for commercial and operational purposes. As the Grupo 1a1 continues to develop the business, it may sell or acquire assets, subsidiaries or business units. In this type of transaction, your personal data is usually one of the transferred business assets, but remains subject to the guarantees provided in any pre-existing Privacy Policy (unless, of course, you have consented otherwise). If another entity acquires us, our business, all or a substantial part of our assets, or assets related to the Cluube.com and other websites, your personal data will be disclosed to that same entity as part of the due diligence process and will be transferred to that entity as one of the transferred assets. In addition, if any insolvency or reorganization process occurs or is imposed on us, all your personal data will be considered as an asset that belongs to us and as such it is possible that they will be sold or transferred to third parties, never separated from the original service, keeping compliance with this Privacy Term and as permitted by applicable data protection laws and regulations.

Legal disclosure. We may transfer and disclose your personal data to third parties:

To comply with a legal obligation;

When we believe in good faith that applicable law requires it;

At the request of government authorities in connection with any investigation;

To verify or enforce our Terms of Use, Privacy Policy or other applicable rules;

To detect and protect against fraud, or any technical or security vulnerabilities;

To respond to an emergency; or in any other way

To protect the rights, property, warranties, or safety of third parties, visitors to Cluube.com or the public.

International data transfers

1a1 collects data from participants who may be in different countries of the world and stores their data on servers also distributed in different countries of the world.

We share information globally, both internally within Grupo 1a1 companies and externally with our partners and with those you connect and share with around the world in accordance with this policy. Your information may, for example, be transferred or transmitted to, or stored and processed in, the United States or other countries outside of where you live, for the purposes described in this policy. These data transfers are necessary to provide the services stipulated in our terms, as well as to operate globally and provide our Products to you.

How do we protect your personal data?

1a1 takes the security of your personal data very seriously. We make every effort to protect your personal data from misuse, interference, loss, unauthorized access, modification or disclosure. 

Our measures include implementing appropriate access controls, investing in and seeking out providers that invest in high Information Security Capability to protect computing environments, and ensuring we encrypt and anonymize personal data whenever possible. 

Access to your personal data is only permitted among our employees and agents on a need-to-know basis and subject to strict contractual confidentiality obligations when processed by third parties.

How long do we keep your personal data?

We will keep your personal data for as long as we need them for the purpose for which they are processed. For example, when you make an online purchase, we will keep the data relating to your purchase so that those involved can assume the specific contract you have entered into, after which we will keep your personal data for a period that allows us to deal with or respond to any complaints. , questions or concerns regarding the purchase, or even for history and future analysis. Another example, when you do an activity, we will keep your data, so that we can fulfill the specific contract you have entered into, in order to have your history for purposes of computing points, and so that its use can enrich your profile. This activity data is recorded even after you choose to cancel your account, but it becomes anonymized, with no possibility of recovering the link in relation to the identifiable data.

Your data may also be stored so that we can continue to improve your experience with us and ensure that you receive any loyalty rewards to which you are entitled. 

We will actively review the personal data we hold and will securely erase, or in some cases anonymize, when the legal, commercial or consumer obligation to retain it ceases. 

What are your rights?

You are entitled to a set of rights in relation to your personal data and the way in which it is treated. You may exercise these rights at any time.

We have provided a general summary of these rights below, along with what they imply for you. You can exercise your rights by submitting a request to us via your account. 

The right to information. The data subject has the right to be provided with concise, transparent, understandable and easily accessible information, using clear and simple language, on how we use their personal data and on their rights. 

The right of access and rectification. The data subject has the right to access their personal data, as well as to rectify inaccurate personal data concerning them, or to complete them if they prove to be incomplete. We understand the importance of these rights and if you wish to exercise them, you can do so at any time in your account.  

The right to data portability. The personal data you provide us may be portable. This means that they may be transferred, copied or transmitted electronically in certain circumstances.

The right to erasure of data. Under certain conditions, the data subject has the right to obtain from the controller the erasure of his personal data, without justified delay. If you wish to delete your personal data, please request the deletion of your account through the online environment. If the personal data we collect is no longer necessary for any purpose and we are not required by law to keep it, we will use our best efforts to permanently delete, destroy or anonymize it. 

The right to limit processing Under certain conditions, the data subject has the right to limit the processing of their personal data. If you wish to limit the use of your personal data, please request it through a specific function in your account, and if something that completely meets your demand is not available, request the deletion of your account through the online environment.

The right of opposition. The data subject has the right to object at any time, for reasons related to his particular situation, to the processing of personal data concerning him, including the definition of profiles. In particular, when personal data are processed for the purposes of direct marketing, the data subject has the right to object at any time to the processing of personal data concerning him for the purposes of said marketing (eg receiving notification emails from us or be contacted with varied potential opportunities). If you wish to object to the use of your personal data, please request it through a specific function in your account, and if something that completely meets your demand is not available, request the deletion of your account through the online environment.

The right to file a complaint with a Data Protection Authority. You have the right to file a complaint with any Data Protection Authority about the way in which we process your personal data. 

The right to withdraw consent. If you have given your consent to our use of your personal data (eg, we rely on your consent as a legal basis to process your personal data), you have the right to withdraw your consent at any time (withdrawal of consent does not compromises the lawfulness of the treatment carried out on the basis of the consent previously given), informing us of your intention through the contacts provided below. If you wish to withdraw consent to the use of your personal data, please request it through a specific function in your account, and if something that completely meets your demand is not available, request the deletion of your account through the online environment.

Rights related to automated decision making. The data subject has the right not to be subject to decisions solely based on automated processes that produce legal or other significant effects. In particular, you have the right to: 

obtain human intervention;

express your point of view;

obtain a justification of the decision obtained after an evaluation; and

and contest such decision.

Any additional information or advice on your rights can be obtained from the data protection regulatory authority.

How do we keep this policy up to date?

We will update this Privacy Statement as necessary to reflect feedback from participants and all contractors, and changes to our products and services.

When we make changes to this statement, we will change the "Last Updated" date at the beginning of this Term. If the changes are significant, we will provide a more prominent notice (including, on some services, email notifications of changes to the Privacy Statement). We will also keep previous versions of this Privacy Notice on file for you to review.

We will not reduce your rights under this Privacy Policy without your consent.

Additional Privacy Terms or Policies

In addition to this Privacy Policy, there may be specific campaigns or promotions, as well as the Cluube.com Terms of Use (https://www.cluube.com/termsAndConditions.do), and the particular terms of each Cluube that decides to participate, which will be governed by additional terms or privacy policy. We encourage you to read these terms or additional notices before participating in such Cluubes, campaigns or promotions as you will be required to comply with them if you wish to participate. Any additional privacy terms or policies will be prominently displayed.

How to contact us?

In accordance with the General Law for the Protection of Personal Data of Brazil ("LGPD"), you have the right to access, rectify, request the portability of your data and erase your data, in addition to authorizing the processing of this data by us and the companies whose Professional Cluubes you have chosen to join.

In certain circumstances, you also have the right to object and restrict the processing of your personal data or to withdraw your consent when we process data provided by you on the basis of this consent.

If you have any questions, requests or concerns about the Cluube Privacy Policy or the processing of data or wish to file a complaint about a possible violation of privacy laws, please contact us at data@cluube.com.

If you ask us a question, we will make every effort to provide you with information on the respective avenues of complaint that may apply to your circumstances.