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Last updated date: 23/05/2024
The “Privacy Policy” you are accessing is part of the Terms and Conditions of Use and describes how TRAIN.VC collects, stores, uses, processes, associates, protects, shares and treats your personal data, in connection with the Applications and Services governed by the Terms and Conditions of Use.
This document was written in a simple and accessible way, with several examples of collection and use of Personal Data, precisely so that the User can understand how we use their Personal Data to offer a safe and comfortable experience when using the Services.
With this in mind, we have systematized the definition of some key terms used in this Policy. In this sense, the words below, when used in the singular or plural, will have the following meanings, without prejudice to other definitions attributed in this Policy and in the Terms of Use.
(i) Personal Data: is any information related to an identified or identifiable natural person;
(ii) Sensitive Personal Data: information about racial or ethnic origin, religious belief, political opinion, membership of a trade union or religious, philosophical or political organization, relating to health or sexual life, genetic or biometric data.
(iii) User or Data Holder: is the natural person to whom the Personal Data that are subject to Processing refer.
(iv) Treatment: is any and all operations carried out with Personal Data, including, for example, but not limited to, the collection, storage, alteration, consultation, sharing, transmission, access or elimination thereof.
(v) Legal bases: These are the legal hypotheses that authorize the Processing of Personal Data, such as the consent of the Data Holder, the need to fulfill a contract we have with the User, or compliance with a legal obligation, for example.
In these terms, Personal Data and Sensitive Personal Data will be referred to as “Data” or “Personal Data”.
In order to establish a transparent relationship between TREINE.VC and its users, we will explain in this Privacy Policy how your data is used.
The Personal Data of users of the services and products offered by TREINE.VC are protected and kept secure, therefore, the best efforts are made to ensure that the data is protected and treated in accordance with the General Data Protection Law (LGPD – Law 13,709/18).
This privacy policy establishes the conditions for processing the personal data of the holders that are necessary for the operation of TREINE.VC applications and services for all users of the applications, unless otherwise mentioned.
This Privacy Policy (“Policy") indicates how your information and Personal Data will be collected, used, shared and stored due to the use of the Services provided for in the Terms of Use, without prejudice to other definitions attributed in this Policy. The definitions that are contemplated in the Terms of Use apply to this Policy.
3.1. By using the applications and services provided by TREINE.VC, you agree to the rules established in this Privacy Policy. Therefore, if the user does not agree with the conditions for processing their data under the terms established in this Privacy Policy, it will not be possible to use the services offered by TREINE.VC.
3.2. When browsing our websites and applications, as well as using our services, the user understands that we may collect, store, process, associate, share, use, disclose or treat their personal data, in the ways provided for in the legislation and in this privacy policy.
3.3. If you do not agree with the conditions for processing your data under the terms established in this privacy policy, you will not be able to use the services offered by TREINE.VC.
3.4. In the context of your subscription to the Services and use thereof, the User will have established a direct relationship with TREINE.VC, which will be guided by the Terms of Use and any other documents governing such relationship, as the case may be.
4.1. The Controller of your personal data is ETERNO TECNOLOGIA, SERVIÇOS E PAGAMENTOS LTDA, also known as TREINE.VC. If you still have any questions after reading the Privacy Policy or for any reason you wish to communicate with us regarding issues involving your personal data, you can contact us by email at contato@treine.vc
5.1. This Privacy Policy will apply to:
5.1.1. Administrator User: Refers to anyone who hires or manages TREINE.VC to deliver its content and create its membership platform.
5.1.2. End User: Refers to any natural person who consumes any type of content (regardless of its form) on the platform through TREINE.VC through registration by the Administrator User.
5.2. TREINE.VC does not knowingly collect personal data from minors under the age of 13. If we become aware that we have collected personal data from a minor under the age of 13, we will cancel the account created on the Platform and delete the personal data, keeping only the information necessary to prevent new registration attempts.
5.3. Teenagers between 13 and 18 years old who are users of TREINE.VC will have their personal data processed in accordance with the terms of this policy.
The holders of the personal data used by TREINE.VC have the rights provided for in art. 18 of the General Data Protection Law (LGPD), specified below, which can be exercised via email contato@treine.vc
6.1. Confirmation of the Existence of Processing and Access to Data: The holder has the right to request TREINE.VC to confirm whether his/her personal data is being processed by the Institution. If confirmed, the holder may request access to the information.
6.2. Request correction of incomplete, inaccurate or outdated data: the holder may request the correction or update of his/her data that he/she considers to be incomplete or incorrect.
6.2.1. If the update is not possible in the TREINE.VC application itself, the user will need to send the TREINE.VC team a document that proves the correct and current form of the personal data in question;
6.3. Request the anonymization, blocking or deletion of unnecessary, excessive data or data processed in non-compliance with the Law: the holder may request the anonymization, blocking or deletion of data that he/she considers excessive, unnecessary or processed in non-compliance with the LGPD, provided that the excess, lack of necessity or non-compliance with the law is effectively proven;
6.4. Request data portability: the holder may request the portability of his/her data, in compliance with applicable regulations and commercial and industrial secrets;
6.4.1. The exercise of the right to data portability is subject to regulation by the National Authority, which, to date, has not been standardized;
6.5. Request the deletion of personal data processed with consent: the holder may request the deletion of personal data that is processed by TREINE.VC through the legal basis of consent, set out in article 7, I of the General Data Protection Law;
6.5.1. The holder may not dispose of his/her personal data when they have processing bases other than consent;
6.6. Request information about the public and private entities with which the controller transferred the data: the holder may request information from TREINE.VC about the sharing of their data with third parties, provided that there is no legal impediment to this;
6.7. Request information about the possibility of not providing consent: the data subject may ask TREINE.VC to clarify whether it is possible to provide a certain product or service without consenting to the processing of their personal data, or what the consequences of not providing consent will be;
6.8. Revoke previously granted consent: the holder may revoke the consent previously given for the processing of his/her personal data;
6.8.1. Revocation of consent may make it impossible to use certain features of the application, or even terminate the services provided. However, it will not prevent TREINE.VC from using anonymized data and data whose processing is based on a legal hypothesis other than consent, as provided for in the LGPD;
6.9. Request review of automated decisions: The data subject may request a review of decisions taken solely based on the automated processing of personal data that affect their interests. At TREINE.VC, the technological models used are consistent and based on legal and ethical principles.
7.1. When registering and using the application or services offered by TREINE.VC, the Data Subject provides us with statistical information about their use of the services, aggregated data and personally identifiable data. This happens because providing this information is essential for the provision of the services.
7.2. Personal data will be collected in the following situations:
When participating in surveys or promotions carried out by TREINE.VC.
7.2.1. When browsing our application, the holder may be redirected to other websites or applications, in which case the holder must pay attention to the privacy policies and terms of use of these third parties, since TREINE.VC is not responsible for the practices and content of third parties.
7.3. TREINE.VC collects the personal data provided by the user at the time of creating the account; those created during the use of the services provided by TREINE.VC applications; and through third parties, such as, for example, other users, business partners, suppliers, financial service providers and government authorities.
7.4. In general, the Personal Data that the Data Subject provides is used to use the Services, as well as to improve them. Your Personal Data is used to achieve the purposes presented in the table below, with the respective legal bases, which authorize their Processing:
|
Personal Data |
Holder |
Purposes |
Legal Basis |
|
Full name, CPF, address of email, address residential, telephone number, Number |
User Administrator |
● Check your identity; ● Registration in Services; |
Compliance with Legal Obligation and/or Contract Execution |
|
of the RG, photo for profile1, login access2, data banking and credit card data credit. |
|
● Identify and prevent potential situations of fraud; ● Identify and prevent potential threats security; |
|
|
Full Name, CPF3, number of telephone, email address, residential4 and IP, bank details, gender5 IP, time and date of access, geolocation, data about your device access and cookies. |
End User User Administrator and Final |
● Check your identity; ● Registration in Services; ● Identify and prevent potential situations of fraud; ● Identify and prevent potential threats security; ● Automated collection through the website or Applications for the purpose of identification and prevention of situations of fraud and threats of security; ● Personalization and improvement of Services based on its form of use |
Compliance with Legal Obligation and/or Contract Execution Compliance with Legal Obligation, Contract Execution and Legitimate Interest |
|
General data of navigability, use of |
|
● Analytics – recognition of profiles and habits of |
Consent and Legitimate Interest |
1 Optional
2 If you purchase the Business plan that includes migration, for more information, access the terms of use at the link: https://site.TREINE.VC.com.br/termos
3 Optional
4 Optional
5 Optional
|
Applications, event funnels. |
Users Administrator, Final and Third Parties |
collective consumption of users of the Services, the in order to generate data statisticians who enable better understanding of how interactions occur of users with the Applications |
|
8.1. The data collected by TRAIN.VC will be used to provide an excellent service, respecting the guidelines established by current regulations. Therefore, your data may be used in the following situations:
8.2. Personal data provided by the Holder will be or may be used by TREINE.VC to:
8.2.1. Personal documents provided by the holder may be shared with third parties, including, but not limited to, law enforcement agencies, in the event of suspicion and involvement in illegal activities.
8.3. Personal data collected from third parties will be or may be used by TREINE.VC to: a) Improve the services and products offered by TREINE.VC;
8.4. Personal data collected from the data subject's device will be or may be used by TREINE.VC to:
8.4. Personal data generated by the use of services and products offered by TREINE.VC
8.5. Personal data obtained from public sources:
8.6. Processing of third party data
8.6.1. In the event of sharing third-party personal data in connection with economic activities, the Data Subject must obtain the free, express and informed consent of the data subject, or their legal representative, or base each processing on some legal hypothesis provided for by applicable legislation.
9.1. The database created by TREINE.VC will not be shared, sold, assigned, transferred, informed or rented to third parties, except in the situations provided for in this privacy policy.
9.1.1. Whenever necessary, the sharing of your personal data will be carried out within the limits and purposes of our business and in accordance with what is authorized by applicable legislation.
9.2. TREINE.VC reserves the right to share your Personal Data with third parties in order to receive, analyze and make decisions on requests related to the Services. Such sharing with third parties, whenever possible, will be carried out in a pseudonymized manner, aiming to preserve your privacy as much as possible.
9.4. Therefore, your data may be shared in the following ways and with the companies listed below:
(i) AWS: transfer of information to Amazon Web Services (AWS) services and infrastructure for storage, processing, analysis, or other specific purposes. (ii) Jira Services: Tool used for incident management, report requests, bug resolution, collecting data from affected users to reproduce and resolve the indicated problems, as well as measuring the efficiency of our solutions and application problem resolutions.
(iii) Pipedrive: Sales management software that offers complete monitoring during and after the sales process carried out by the sales team. With this tool, the data of the Administrator Users will be shared to maintain contact and complete the purchasing process efficiently.
(iv) Payment Checkouts: They are payment processors that forward the personal data of infoproduct buyers to TREINE.VC, with the aim of facilitating these customers' access to the products purchased;
(v) API Integrations (External Tools): integrations that enable the execution of external tools for usability and improvement of the user experience for administrators and end users; (vi) Leadster: When contacting TREINE.VC through the ChatBot available on our website or through the forms available on social media, the Holder will share their personal data with Leadster, a qualified lead capture software;
(vii) Make: Tool responsible for integrating software that is not natively integrable and sharing data between them, via webhook.
(viii) Calendly: Tool used by the sales sector to schedule online conversations with those interested in learning more about the services offered by TREINE.VC. (ix) Zendesk: Tool used by the customer service sector to centralize communication with customers and third parties.
9.5. Therefore, your data may be shared:
(i) in case of transfer of ownership of TREINE.VC or its corresponding companies, which may or may not be part of the group of companies that operate together for the sake of the availability of the services provided;
(ii) TREINE.VC may use its users' personal data to extract statistical information about the business, it should be noted that in this case the data disclosed will never be related to a specific individual;
(iii) With service providers, banking and financial institutions, suppliers, consultants, business partners, among others, such as: cloud storage providers; payment companies; marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers; research partners; analytics service providers; and consultants, lawyers, accountants.
(iv) Authorities and regulatory bodies.
9.6. Sharing data of data subjects with third parties (defined above, by way of example) may have the following purposes:
(i) Check the identity of the holder and eligibility to contract the services provided by TREINE.VC;
(ii) Enable the provision of services, since TREINE.VC uses cloud providers to develop and operate the application;
(iii) Enable contact by telephone, email, SMS, WhatsApp, push notification or other means of communication;
(iv) Investigate and adopt measures to prevent and combat illegal activities and fraud;
(v) Regular exercise of TREINE.VC's rights;
(vi) Comply with a court order, competent authority or supervisory body;
(vii) Compliance with legal or regulatory obligations;
(viii) Marketing, prospecting, market and opinion research; and
(ix) Prevent and remedy technical and security problems.
9.7. Sharing data subjects’ data with public authorities and regulatory bodies may have the following purposes:
(i) Investigate and adopt measures to prevent and combat illegal activities and fraud;
(ii) Regular exercise of TREINE.VC's rights;
(iii) Comply with a court order, competent authority or supervisory/regulatory body; and (iv) Compliance with a legal or regulatory obligation.
9.8. TREINE.VC may share, with other institutions and regulatory bodies, your data and information related to occurrences, attempts or signs of fraud in order to prevent them and guarantee the security of operations carried out on the platform, in accordance with current legislation and regulations.
10.1. The personal data of the holders will be processed in accordance with the terms set forth in this policy until the termination of the relationship between the holder and TREINE.VC, storing and maintaining them in a safe and controlled environment, while the Institution holds their possession.
10.2. When applicable, and even after the cancellation of the holder's account, TREINE.VC may store your data for an additional period for auditing purposes, compliance with legal and regulatory obligations, for the regular exercise of its rights or for the period necessary in accordance with the legal basis that justifies retention.
10.3. TREINE.VC keeps your Personal Data only for as long as necessary to achieve the purposes for which we collect it, including for the purposes of complying with any legal, contractual, accountability obligations or requests from competent authorities.
10.4. To determine the appropriate retention period for storing Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes of the Processing and whether we can achieve such purposes through other means, in compliance with applicable legal requirements.
10.5. The request for deletion of the data subject's data may be made by email contact@treine.vc. TREINE.VC's privacy area will analyze the request, as well as inform which data can be deleted and which should continue to be stored in the institution's database.
11.1 TREINE.VC may transfer Personal Data collected in Brazil to the USA. This transfer will occur when the company responsible for hosting the Personal Data, which may be contracted by TREINE.VC, is located in international territory.
11.2. Before transferring your Personal Data to another country, it will be ensured that the country provides the level of protection of Personal Data required in this Privacy Policy, or that TREINE.VC guarantees compliance, regardless of foreign legislation, with the principles, rights of the holder and protection of Personal Data set out in this Privacy Policy, in accordance with applicable standards.
TREINE.VC is headquartered in Brazil and the Personal Data collected is governed by Brazilian law. By accessing or using the Services or providing Personal Data to TREINE.VC, The User agrees to the processing and transfer of such Personal Data to the European Union and the USA, if applicable, subject to the conditions set out above.
The data collected by TREINE.VC will be stored in secure databases, in accordance with best practices, with access restricted only to employees with the appropriate credentials, who are obliged to maintain the confidentiality of the information and not use it inappropriately.
TREINE.VC maintains administrative, technical and physical safeguards designed to protect the Information we have about data subjects against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, it is not possible to completely guarantee that interceptions and violations of TREINE.VC's systems and databases will not occur, since the Internet and data protection have their security structure constantly being improved.
For this reason, in addition to technical and administrative measures, we are constantly promoting a culture of personal data protection, staff training, improving our processes and contractual relationships with partners. Our Help Center has support materials to assist our customers with Tips & Tutorials, step-by-step guides on how to use your account and keep it secure.
Access to Information will be restricted to authorized personnel trained in the proper use of such Information. Employees who use Information improperly, in violation of this Privacy Policy, will be subject to legal measures, as well as penalties under TREINE.VC's disciplinary and ethical process.
TREINE.VC is not responsible for sending false emails in your name, with false promises, false offers, fraudulent forms and/or any type of communication sent by third parties.
Therefore, if you have any questions, please contact us through our official channels.
The User believes that personal information has been used in a manner incompatible with this Policy or with his/her choices as Data Subject, or, if he/she has other questions, comments, suggestions or requests related to this Policy, he/she can contact TREINE.VC at the following contact addresses:
Data Protection Officer: Cassiano Gabriel de Oliveira Silva
E-mail: contact@treine.vc
This Privacy Policy may be updated periodically and without prior notice to reflect changes in our practices. For significant changes, we will notify you by posting a prominent notice on our Services.
By continuing to use the products and services offered by TREINE.VC after the change in the privacy policy, the holder will agree to the new conditions, however, our customer service channel is always available to receive questions from users.
