PRIVACY POLICY

 

 

Welcome!

 

We are happy you chose the ATLAS GOVERNANCE platform!

 

To make all our information perfectly clear, we present here our PRIVACY POLICY in a transparent and accessible way, as you can see ahead:

 

 

IT IS EXTREMELY IMPORTANT THE COMPLETE READING AND UNDERSTANDING OF THIS DOCUMENT.

 

 

 

 

CHAPTER I

- GENERAL TERMS -

 

1.1. General. This Privacy Policy was created to communicate our practices related to the treatment (which includes collecting, storing, using, sharing , etc.) of personal data of USERS of ATLAS GOVERNANCE (from now on designated as such or as “Platform”), that includes the website and its subdomains, apps, software and other extensions. The Platform is owned by Atlas Governance Tecnologia Ltda. Society that is registered with the CNPJ number 25.462.636/0001-86 located in Rua Pais De Araújo 29, Conj. 144, Itaim Bibi, São Paulo/SP, PC 04531-940, and it’s under its responsibility and management.

 

1.2. What Personal Data is. Personal Data is all information provided by the USERS, which is used to identify them individually.

 

1.3. Authorization to Collect Information. When using the platform, you must accept the collecting of information for the compliance with the hired services, by clicking the option “I have read and agree with the terms”, in the terms of this privacy policy services.

 

1.3.1. You can stop and revert your consent to the terms of this Privacy Policy at any given moment, just by notifying ATLAS GOVERNANCE via e-mail to [email protected], in a timeline of 05 (five) business days.

                        

1.4. Regulation. The Platform operates according to the Brazilian legislation, complying, even and specially, with the terms of the Law number 12.965/2014 (The Internet Civil Framework) and of the Law number 13.709/2018 (General Data Protection Law) e and other laws to be applied.

 

1.5. Contact. In case of question or suggestion related to the Privacy Policy of the Platform or any other information, the USER can get in contact with the administrators via e-mail [email protected], which will be answered in business hours, from Monday to Friday, from 9h to 19h.

 

1.6. Control of Information. This Policy describes which personal data belonging to the USERS can be collected while the use the services of the Platform, how that information can be used, and the precautions taken against unauthorized access or use of this information.

 

 

 

 

CHAPTER II

- COLLECTED PERSONAL DATA -

 

2.1. ATLAS GOVERNANCE can collect, store and use the following information and/or personal data of USERS:

 

a)     Full name;

b)     E-mail;

c)      Phone number;

d)     Profile Picture;

 

2.2. ATLAS GOVERNANCE can also collect, store and use the following information:

 

a)     Registry in data bank related to the personal data provided by the USERS to register in ATLAS GOVERNANCE;

 

b)     The access details to ATLAS GOVERNANCE and the resources that the holder accessed;

 

c)     Information of the device used for access, including, for example, hardware model, operational system and version, names and versions of files, language preference, unique device identifier, ads identifiers, serial number, information related to device movement and network information;

 

d)     Information of the server registry that can include information such as the device IP address.

 

e)     Mapping of clicks in browser, browser data, statistics, demographics, etc.

 

f)      Mapping of clicks in apps and browser data.

 

2.3.  Native Apps. Native apps can store use data, images, videos, texts, password access or biometry system, which are not shared with ATLAS GOVERNANCE.

 

 

CHAPTER III

- SHARING OF COLLECTED PERSONAL DATA -

 

3.1. Exceptions in Sharing Personal Data. ATLAS GOVERNANCE doesn’t disclose to third parties any personal data provided by the USERS through the ATLAS GOVERNANCE platform, except:

 

a)     Cases in which ATLAS GOVERNANCE is obligated to disclose or share collected data, in order to comply with a court order, or to prevent cases of fraud and other crimes, as well as a response to the request if information presented by the competent authority if we understand that the disclosure is in line and required by the law, regulation or procedural procedures applicable;

 

b)     To protect the rights, assets or safety of ATLAS GOVERNANCE and the Platform;

 

c)     With law agents and/or government authorities, if it’s understood that the actions are inconsistent in relation to the dispositions in our terms of use, or to protect the rights, the property and the safety of ATLAS GOVERNANCE, its USERS, or others;

 

d)     Through action of the USER itself;

 

e)     In cases of sale, total or partial, of the business or its assets, or as a part of any reorganization or restructuration of the business, merger, split or incorporation, in a way that ATLAS GOVERNANCE can share the information of  USERS with third parties that are part of the related business, taking the necessary measurements to guarantee that the privacy rights continue to be protected, according to this Policy;

 

f)      In operations that involve conferences via audio and video using the partner platforms integrated in ATLAS GOVERNANCE to allow USERS to make use of safe services to make calls. ATLAS GOVERNANCE and its partner platforms will only share personal data of USER registry to identify and enable access to the partner platforms, and won’t be recorded or shared the conference call made via the partner platforms.

 

g)     Retention: Subject to the rights of users set forth above, we’ll retain information for as long as we need it to provide you the Services or to comply with applicable law. If you discontinue the service, this information can be deleted upon request. But please note: (1) there might be some latency in deleting this information from our servers and back-up storage; (2) we will not delete Anonymized Data and may continue to use it as describe in this Privacy Policy; and (3) we may retain information if necessary to comply with our legal obligations, resolve disputes, manage security risks, or enforce our agreements.

 

 

3.2. Authorizations for Contact and Disclosure. USERS give authorization to ATLAS GOVERNANCE to contact them through any of the contact channels provided in the registry page in ATLAS GOVERNANCE.

 

 

CHAPTER IV

- COOKIES -

 

4.1. What Cookies are. A cookie is a piece of information stored locally in a USER’s computer or device, and that contains information about the user’s activities on-line.

 

4.2. Use of Cookies. Cookies can be used in different ways and forms. ATLAS GOVERNANCE can use:

 

a)     Functional Cookies: These cookies are used by ATLAS GOVERNANCE due to some of its functions, in order to offer a better experience when browsing the platform.

b)     Access to Cookies. The access to cookies ends when the USER closes the browser. The option is given to the USER to accept or reject the cookies.

 

4.3. Consent for the use of Cookies. It is necessary to be approved by the USER, before the session is initiated, for the Cookies to be used.

 

4.4. Option without Cookies. The holder can choose to reject the use of cookies. If the USER chooses not to accept them, its access to most of the information available in the Platform will not be affected. However, the holder might not be able to use fully the services provided.

    

 

CHAPTER V

- ACCESS AND CORRECTION OF PERSONAL DATA -

 

5.1. Access and Correction of Personal Data. USERS have the right to access their personal data posed by ATLAS GOVERNANCE, contacting administrators through the e-mail [email protected], which will be answered in business hours, from Monday to Friday, from 9h to 19h in the time zone of the requested country, in a term of 15 (fifteen) days, cumulated with a description of the form, end, and duration of the treatment of personal data, that can be sent via e-mail or letter, according to what is contemplated in article 9 of the LGPD.

 

5.2. Exclusion. The USER has the right to request the exclusion of its personal data stored in ATLAS GOVERNANCE, at any given time, except in cases of legal obligation our court order to continue the data storage, according to what is contemplated in articles 18, XVI, and 16 of the LGPD.

 

5.3. Incorrectness of Information. It’s the responsibility of the holder to maintain its information updated, being that, in case of incorrect information, ATLAS GOVERNANCE can update or delete it, except in cases of need to maintain it for legitimate commercial or legal purposes.

 

5.4. Necessary Measures for Protection. ATLAS GOVERNANCE takes all necessary security measures to protect personal data of USERS and to protect them from loss, unwanted use, access, disclosure, alteration or unauthorized use.

 

5.5. Passwords Protection. USERS are equally responsible for taking measures in order to protect the passwords, usernames and other access resources for personal login and registry in ATLAS GOVERNANCE.

    

 

CHAPTER VI

- NOTIFICATION OF CHANGES IN PRIVACY POLICY -

 

6.1. Changes in Privacy Policy. ATLAS GOVERNANCE can change the Privacy Policy of the Platform from time to time. The use of collected information is now subjected to the Privacy Policy in force. If ATLAS GOVERNANCE makes any changes to the way of how it uses personal information, it will notify its USERS via e-mail.

 

6.2. Non-Notified Adjustments. Small changes in this Privacy Policy can happen without significantly affecting the ways in which ATLAS GOVERNANCE treats collected information, which makes it unnecessary to notify them.

 

 

 

CHAPTER VII

- PERSONAL DATA SECURITY-

 

7.1. Storing. Personal data of USER accounts are stored in a safe way and all information within the Platform transits in a safe way and only personnel authorized by ATLAS GOVERNANCE can have access to this personal information, being obligatorily subjected to confidentiality duties and rigorous respect to the privacy in the terms of this Policy.

 

7.2. Security of Information. All transactions in ATLAS GOVERNANCE are encrypted, subjected to data backup, monitoring tools, security policies, employee control access, with updated security software.

 

7.3. Notification. If ATLAS GOVERNANCE takes notice of any security violation by the users or the host company, including any hacker or ‘’data breach’’, we will notify the national authorities and the affected USERS about that violation and we will provide the possible details related to the nature and extent of that violation and the compromised data, in a reasonable time, according the what is contemplated in articles 48, § 1º, of the  LGPD.

 

7.4.  Responsibility. USERS will be responsible to compensate ATLAS GOVERNANCE for all costs and damages that this might incur in, as a result of a violation of this Privacy Policy. 

 

7.5. Cooperation. ATLAS GOVERNANCE fully cooperates with any authorities or courts that require the disclosure of the identity or location of any person that inserts any material in the Platform that violates the Clauses displayed in this Policy.

 

7.6. Limitation of Responsibility. This Privacy Policy only addresses the disclosure of information collected by the ATLAS GOVERNANCE Platform. If the USERS disclose its information to third party websites, different rules can be applied to the use of this information.

 

Created on March 6th, 2020.