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Privacy and Information Confidentiality Policy, The iFriend

Welcome!

 

We were very glad that you chose THE IFRIEND Platform!

 

THE IFRIEND has privacy and protection of personal data of USERS and IFRIENDS as a priority.

 

At THE IFRIEND you have complete control over the privacy of your data, so you can use the Platform with confidence and certainty that your personal data is well taken care as one of the highest standards of Information Security and Personal Data Protection.

 

Our USERS and IFRIENDS are spread around the world and we know that each country has sovereignty and autonomy to create its own laws, we will treat each one according to our Privacy Policy and specificities of national laws. Therefore, for USERS and IFRIENDS who have a nationality and/or country of residence in Brazil, the United States of America or the European Union, we will proceed with treatment in accordance with the laws of the country of nationality/residence stated in the registration.

 

We are working towards the Privacy and Data Protection of our USERS and IFRIENDS so that we respect and even make available some of the most important applicable privacy laws:

 

  1. Brazil:
  2. The Brazilian Civil Framework of the Internet (Law No. 12.965/2014)[1]
  3. Brazilian Data Protection Law (Law No. 13,709/2018)[2]

 

  1. United States of America:
  2. The California Consumer Privacy Act of 2018 (CCPA). Cal. Civ. Code § 1798.100-§ 1798.198.[3]
  3. Bus. & Prof. Code § 22575[4]
  • Clarifying Lawful Overseas Use of Data Act or the CLOUD Act[5]

 

  • European Union:
  1. General Data Protection Regulation (GDPR). Regulation (EU) No. 2016/679.[6]

 

For all information to be correctly understood, we present our Privacy Policy in a transparent and accessible document, as shown below:

 

Definitions:

  • PRIVACY POLICY: document presenting the measures that the Platform uses to take care of your privacy and your data.
  • TERMS OF USE: document that presents the rules for the operation of the Platform.
  • THE IFRIEND: Platform that mediates business between the traveler and the local guide.
  • IFRIEND: Local guide duly registered with THE IFRIEND
  • USER: Traveler interested in using THE IFRIEND Platform to connect with local guides who may be professional or amateur (called IFRIENDS).

 

 

PURPOSE OF

DATA COLLECT:

 

●        Identify and register the USERS or IFRIENDS in the Platform, as well as make available the resources according to the requested activities;

●        Ensure that the content of the Platform is presented in the most efficient manner;

●        Helping to make improvements to the Platform, such as new features, USER support, new security features, sending updates and administrative messages;

●        Contact and notify the proprietor of modifications to the Platform, services offered by THE IFRIEND or its policies and terms of use as needed; and

●        Perform internal operations, including, for example, verification of the accessed region, operations to prevent service fraud and abuse, troubleshoot operational and software errors, perform data analysis, testing and research, as well as monitoring and analyze data trends.

●        Sending advertisements by email;

●        Allow USERS and IFRIENDS to share sociocultural experiences with each other

 

DATA SUBJECT RIGHTS

 

●        Data subjects could be IFRIENDS or USERS, they both have rights to:

a)      Request to erase personal data;

b)     Request copy and/or rectification of stored personal data;

c)      Request the portability of personal data to another Platform;

d)     Request to unsubscribe advertising;

 

WE HIGHLIGHT THAT THE COMPLETE UNDERSTANDING AND FULL READING OF THIS DOCUMENT IS EXTREMELY IMPORTANT    

   

INDEX

 

CHAPTER I GENERAL TERMS
CHAPTER II STORAGE DATA
CHAPTER III SHARED DATA
CHAPTER IV COOKIES
CHAPTER V ACCESS AND CORRECTION OF PERSONAL DATA
CHAPTER VI NOTIFICATION OF PRIVACY POLICY CHANGES
CHAPTER VII COMMUNICATION
CHAPTER VIII SECURITY
   
 

CHAPTER I

– GENERAL TERMS –

 

1.1. General Terms. This Privacy Policy is designed to communicate our practices regarding the processing (including collection, storage, use, sharing, etc.) of USERS and IFRIENDS personal data for THE IFRIEND (hereinafter referred to as the “Platform”), which encompasses the website and its subdomains, applications, programs and other extensions. The Platform is owned by THE IFRIEND Intermediação de Negócios Ltda., registered under brazilian CNPJ/MF nº 31.675.132/0001-47, and is under their responsibility and management

 

1.2. Personal Data. Personal data are those entered by USERS or IFRIENDS, which can be used to identify them individually.

 

1.3. Consent. By using the Platform, you must accept and authorize, through the “read and agree to the terms” button, the collection, storage, use and other processing of your personal data, in accordance with this privacy policy.

 

1.3.1. You may withdraw your consent to the provisions of this Privacy Policy at any time by notifying THE IFRIEND by e-mail support@theifriend.com within five (05) business days.

 

1.4. Regulation. The Platform operates in accordance with Brazilian law, including, and in particular, complying with the terms of Law No. 12,965 / 2014 (The Brazilian Civil Framework of the Internet) and Law No. 13,709/2018 (Brazilian Data Protection Law) and other applicable laws; European Union, especially Regulation (EU) 2016/679; United States legislation, especially the California Consumer Privacy Act of 2018.

 

1.5. Data Protection Officer. THE IFRIEND has appointed a Data Protection Officer to solve all issues related to data protection, such as contacting national authorities, USERS and IFRIENDS and to provide any information or notifications.

 

1.5.1. Brazil: contact may occur via e-mail support@theifriend.com, mail to address Street Araguaia, 1266, Bloco 6, Flat 108, Zip Code: 22745-271 – Rio de Janeiro – RJ or telephone +55(21)97956-0922 in accordance with Article 41 of the LGPD.

 

1.5.2. United States of America: contact may occur via e-mail support@theifriend.com, mail to address 8 The Green, Suite A, Dover, Delaware, Zip Code: 19901 or telephone +1 305 818 2033, in accordance with the provisions of CCPA Section 1798.130.

 

1.5.3. European Union: contact may occur via email support@theifriend.com or telephone +44 118 328 0971 in accordance with Article 13 of the GDPR.

 

1.6. Contact. In case of questions or suggestions regarding the Platform Privacy Policy or any other information, the USER may contact the administrators by e-mail support@theifriend.com or through the “Menu” on the “Frequently Asked Questions” and “Contact Us” channels available on the Platform, which will be answered during business hours, Monday to Friday, from 9:30 am to 6:00 pm.

 

1.7. Controlling. This Policy describes what personal data may be collected from USER or IFRIEND while using the Platform services, how such information may be used and regular measures taken against unauthorized access or use of this information.

 

CHAPTER II

– STORAGE DATA –

 

2.1. THE IFRIEND may collect, store and use the following information and/or personal data from USERS and IFRIENDS:

 

a)      Full name;

b)     Nickname;

c)      E-mail;

d)     Passport number;

e)      CPF (brazilians) ou ID (another countries);

f)       Address;

g)      Telephone number;

h)     Date of birth;

i)       Gender;

j)       Profile picture;

k)      Introductory text;

l)       Profession;

 

2.2. THE IFRIEND may also collect, store and use the following information:

 

a)      Registration in the database of any files or information uploaded to THE IFRIEND by the data subjects;

 

b)     Details of access to THE IFRIEND and the resources the holder has accessed;

 

c)      Information of the access device used, including, for example, hardware model, operating system and version, file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, movement information device and network information;

 

d)     Server registration information that may include information such as device IP address.

 

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

 
CHAPTER III

– SHARED DATA –

 

3.1. Sharing Personal Data. Exceptions for sharing personal USER data:

 

a)      Cases in which THE IFRIEND is required to disclose or share the data collected in order to comply with court order, or for the purpose of preventing fraud or other crimes, as well as in response to a request by the competent authority, if we believe that the disclosure complies with or is required under applicable laws, regulations or legal procedures;

 

b)     To protect the rights, property or safety of THE IFRIEND and the Platform;

 

c)      With law enforcement and/or government officials, if their actions are deemed inconsistent with the provisions of our terms of use, or to protect the rights, property or safety of THE IFRIEND, its USERS, or others;

 

d)     By your own action;

 

e)      In the event of sale, in whole or in part, of the business or its assets, or as part of any business reorganization or restructuring, merger, spin-off or merger, THE IFRIEND may share USER information with third parties that are part of it. business, taking the necessary steps to ensure that privacy rights continue to be protected in accordance with this Policy..

 

3.2. Contact. USERS and IFRIENDS authorize THE IFRIEND to contact them using any of the contact information provided on registration with THE IFRIEND.

 

3.3. Improvements. We use Hotjar (www.hotjar.com) in order to better understand our USERS’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our USERS’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual USERS or to match it with further data on an individual user.

 

CHAPTER IV

COOKIES

 

4.1. What are cookies? A cookie is a piece of information that is stored locally on your computer or device and contains information about your activities on the Internet.

 

4.2. Used Cookies. Cookies can be used in different ways and modalities, THE IFRIEND may use:

 

a)      Performance Cookies: This type of cookie collects anonymous information about how the USER or IFRIEND uses the platform so that we can optimize it. The information collected by these cookies never contains personal details from which it can be identified.

 

b)     Functionality Cookies: These cookies are used by THE IFRIEND for some of its features, seeking to offer you a better experience when browsing the platform.

 

c)      Advertising Cookies: These cookies collect information about browsing habits, seeking to make advertising more relevant to the USER.

 

4.3. Cookies Access. Access to cookies ends as soon as the USER or IFRIEND closes the browser. The USER could choose between accept or decline the use of cookies.

 

4.4. Consent to Using Cookies. Acceptance of the USER is required before the section starts for cookies to be used.

 

4.5. Option Without Cookies. The data subject may choose to refuse the use of cookies. If you choose not to accept them, your access to most information available on the Platform will not be compromised. However, the data subject may not be able to make full use of the services offered.

 

 

CHAPTER V

– ACCESS AND CORRECTION OF PERSONAL DATA –

 

5.1. Access and Correction. USERS and IFRIENDS are entitled to access their personal data held by THE IFRIEND by contacting administrators via e-mail. support@theifriend.com which will be answered during business hours, Monday to Friday, from 9:30 am to 6:00 pm.

 

5.1.1. Brazil: Within 15 (fifteen) days, together with a description of the form, purpose and duration of the processing of personal data, which may be sent by email or by letter, in accordance with the provisions of article 9 of the LGPD.

 

5.1.2. United States of America: This should be sent by email or by letter, limited to a maximum of 2 requests every 12 months as provided in Section 1798.100. d) CCPA.

 

5.1.3. European Union: Within 30 (thirty) days, in a concise and transparent manner, which may be exercised by e-mail or by telephone, with storage of the connection, in accordance with article 12 of the GDPR.

 

5.2. Erasure. The USER or IFRIEND has the right to request the deletion of his personal data stored in THE IFRIEND at any time.

 

5.2.1. Brazil: At any time, except where there is a legal obligation or court order to maintain the storage of data, in accordance with the provisions of Articles 18, XVI, and 16 of the LGPD.

 

5.2.2. United States of America: At any time except where there is a legal obligation, court order, exercise of freedom of expression or relevance to identify and resolve platform errors in accordance with Section 1798.105. (a) and (d) of the CCPA.

 

5.2.3. European Union: at any time without undue delay, except in cases where there is a legal obligation, court order, exercise of freedom of expression, in accordance with Article 17 of the GDPR.

 

5.3. Incorrect Information. It is the responsibility of the holder to keep their information up to date, and in the event of inaccuracy, THE IFRIEND may update or delete it, except in cases of need for maintenance for legitimate business or legal purposes.

 

5.4. Protection Measures. THE IFRIEND takes all necessary security measures to protect the personal data of USERS and IFRIENDS and to protect them against unauthorized loss, misuse, access, disclosure, alteration or destruction.

 

5.5. Password Protection. USER and IFRIEND are also responsible for taking reasonable steps to protect your passwords, usernames and other special access features to THE IFRIEND.

 

 

CHAPTER VI

– NOTIFICATION OF PRIVACY POLICY CHANGES –

 

6.1. Privacy Policy Changes. THE IFRIEND may change the Platform Privacy Policy at any time. The use of collected information is now under current Privacy Policy. If THE IFRIEND makes changes to the way you use personal information, it will notify your USERS and IFRIENDS by sending an email.

 

6.2. Unreported Amendments. Minor amendments to this Privacy Policy may occur without significantly affecting the ways in which THE IFRIEND treats the information collected so that it does not need to be reported.

 

CHAPTER VII

– COMMUNICATION

 

7.1. Sending Communications. USERS and IFRIENDS, by registering, agree that THE IFRIEND will send you email notifications, advertisements, news about services and important information about using the Platform that needs your attention.

 

7.1.1. Opt out. Upon receiving an email on behalf of the Platform, you may opt out of receiving them by using the opt-out option or via email request.

 

7.2. AntiSpam Policy. The Platform takes care to prevent unsolicited email.

 

7.3. Confidentiality. THE IFRIEND guarantees maximum confidentiality in the handling of the telephone and e-mail list during regular administration tasks.

 
 

CAPÍTULO VIII

– SECURITY –

 

8.1. Storage. Personal data from USERS and IFRIENDS accounts are hosted on Google Cloud Platform servers, and only employees authorized by THE IFRIEND may have access to your personal information, and are subject to confidentiality and strict respect for your privacy. of this Policy.

 

8.2. Security. All THE IFRIEND transactions are encrypted via HTTPS and USER and IFRIENDS passwords are encrypted in the database via Hash.

 

8.3. International Transfer. Personal data stored by THE IFRIEND are submitted to international transfer of personal data rules.

 

8.3.1. Brazil: Transfer to countries that provide a protection similar to Brazil, in accordance with the provisions of Article 33 of the LGPD.

 

8.3.2. United States of America: Ensures the protection and integrity of data that may be transferred to other countries in accordance with Section 3 § 2713 of the Cloud Act.

 

8.3.3. European Union: between European citizens or residents of the European Union according to article 44 of the GDPR.

 

8.4. Notification. If THE IFRIEND becomes aware of any breaches of its own security or of its hosting companies, including any hackers or other data breach, we will notify the affected national authorities, USERS or IFRIENDS of such breach and will provide the details regarding the nature, extent of the violation and the compromised data.

 

8.4.1. Brazil: within a reasonable time, in accordance with the provisions of articles 48, paragraph 1, of the LGPD.

 

8.4.2. United States of America: with submission of Notice ’Notice of Data Breach’, website disclosure within 30 (thirty) days and in the media, pursuant to Section 1798.82. from the California Civil Code.

 

8.4.3. European Union: Within seventy-two (72) hours after becoming aware of the violation in accordance with Article 33 of the GDPR.

 

8.5.  Liability. USERS or IFRIENDS will be liable to indemnify THE IFRIEND for all costs and damages it may incur as a result of violating this Privacy Policy.

 

8.6. Cooperation. THE IFRIEND fully cooperates with any authorities or courts who may disclose the identity or location of any person who has posted any material on the Platform that violates the Clauses set forth in this Policy.

 

8.7. Restrictions. This Privacy Policy only addresses the use and disclosure of information collected by THE IFRIEND Platform. If USERS or IFRIENDS disclose your information to third party websites, different rules may apply to your use of the information.

 

Updated: 24/09/2019.

[1] http://www.planalto.gov.br/ccivil_03/_ato2011-2014/2014/lei/l12965.htm

[2] http://www.planalto.gov.br/ccivil_03/_Ato2015-2018/2018/Lei/L13709.htm

[3] https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180AB375

[4]https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=BPC&division=8.&title=&part=&chapter=22.&article=

[5] https://www.congress.gov/115/bills/hr4943/BILLS-115hr4943ih.pdf

[6] https://eur-lex.europa.eu/legal-content/PT/TXT/?uri=CELEX:32016R0679

 

 

 

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