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Privacy and Information Confidentiality Policy, The iFriend

These Terms for use present Information about the Privacy and Confidentiality Policy, to be complied with by visitors and users of the SITE www.theifriend.com and of the App iFriend. Both the SITE www.theifriend.com and the App IFriend belong to the Holding Company The iFriend Intermediação de Negócios Ltda. (CNPJ: 08974927000134), located at Avenida Presidente Vargas 590 sala 1010 Centro, Rio de Janeiro – RJ.

The SITE www.theifriend.com (“SITE”) and its services, by nature, collect and in some given situations (further described on the Terms for Use and Browsing Conditions) reveal information about the SITE users and iFriends. This Privacy and Confidentiality Policy describes the information that the SITE collects about its users and visitors as well as the rules to be adopted, in order to guarantee to users and visitors, total transparency of the handling of the available data .

According to this policy, the SITE demonstrates that the privacy of the users/visitors/iFriends information is very important to us, therefore we are very cautious when retaining all the information, using the most complete, modern and effective IT safety mechanisms.

This document is an integral part of the Terms of Use and Browsing Conditions of the SITE. By using this SITE, Register and Services, you agree with our Privacy Policy.

When registering and/or browsing the SITE, the user and/or iFriend agrees with the use of her/his personal information, according to the following rules:

a)    Demanded Information:

The first measure to be taken when using the SITE services is to register yourself and provide us with your complete and actual personal data. Data, such as: username, in order to use the SITE, name, valid identification and contact information (phone number, email address, current address, etc),  may be demanded, received and retained,

The SITE might confirm the informed personal data and it is authorized to consult Public Bodies, specialized companies or databank. The information obtained by the site will be considered confidential.

At any time, the registered SITE user, being a Visitor, Client or iFriend, may ask for the deletion and removal of her/his register, as well as the removal of her/his site databank. For further information, read “Rights of access, removal and rectification of personal information” below.

The SITE automatically collects and saves information about its users and visitors activities. This information may include the URL of the user (URL provided by user, from our site, or from another), the URL accessed by the user right after using our SITE (from our site or from another), the web browser used at the moment of the access, the user’s access IPs, the visited sites, the search run, the advertisements, purchases or sales, inserted qualifications and replies, and posts on the discussion forum, among other data, might be saved and restrained.

The SITE may collect and save PERSONAL DATA, including email address, in case users (or third parties) send mail (e mails or letters) concerning the activities or the posts from other users/visitors of the SITE.

b)  Information used by the SITE:

To provide the customer with a quality service so that its users are able to perform operations in a fast and safe way, the SITE requires personal information, including email address. The gathering of this information enables us to offer users services and functionalities that fulfill their needs and personalize our services.

The personal information we demand has the following purposes:

b.1) The SITE makes available an online platform to approximate the USERS (Visitors/Customers/iFriends), so that they share sociocultural experiences. In this case, the SITE will provide personal data (name, phone number, location and email), via email addresses. The information known by the user, must only be used for the expected purposes of the SITE and must not be used by any site with advertising or promotional purposes, or any other purpose not related with the activity expected by the SITE, unless the USER legally authorizes it.

b.2) The SITE Develops internal researches on the interests, behaviors and demography of USERS, in order to understand better their  needs and interests, as well as to offer better services and provide SITE related information.

b.3) The SITE shares the PERSONAL DATA (including email address) with service providers or “outsourcing” companies that foment improvement and easy access of operations performed through the SITE, such as but not limited to: transport services, source of payment, insurance payments management,  intermediaries, call centers or loyalty programs among others. the SITE will take care of the meeting of certain standards, through the agreements or deals, which purpose is the privacy of the USER’S PERSONAL DATA.  Nevertheless, the SITE will not be responsible for the misuse of USER’S PERSONAL DATA performed by third parties. In some cases these services providers will collect information straight from the USER (e.g.if we ask for polls or researches). In such cases the USER will receive a notification concerning the participation of a service provider in these activities, being the USER free to choose and agree with the information shared and additional activities that providers decide to perform.

Services providers will use the additional information according to their own privacy policy. If they decide to reveal or share PERSONAL DATA with third parties which are not services providers affiliated or SITE related, the proper allowance will be required.

b.4) The SITE Provides USER’S PERSONAL DATA to entities that intervene in the solution of USER’S dispute among members, such as: Insurance companies, Arbitration Court or a Competent Jurisdiction to solve such disputes.

c) Confidentiality of information

Once registered in the website, the SITE will not sell, rent or share PERSONALLY IDENTIFIABLE DATA except for the limited instances set out in these terms.

c.1) The SITE commits to perform everything within range to safeguard the privacy of information.

c.2). By virtue of legal provisions or judicial order,  the SITE may be obliged to reveal information to the authorities or third parties. Third parties may unlawfully intercept or access transmissions or stored information, if it happens, the SITE will not be responsible for the revealed information.

d) Username

In order to interact in the SITE, the users may choose a nickname (username) to be identified. The users will not have access to the personal data of other users, unless both users had made a deal in the SITE. In such case, both parties will receive data from each other, with the purpose of closing the deal.

e) Personal password

The access to our services is solely restricted to properly registered USERS, who will choose their password. With this password the USERS can buy, sell, offer, qualify, among other activities. The password is chosen by the own USER and must be maintained with strict confidentiality, and, must not be revealed or shared with other people, under any circumstance.

The USER will be responsible for all actions performed with her/his username and password, including services charge payment or any potential harm they may suffer. Should the USER suspect that anyone is misusing her/his password, the USER shall change the password, accessing her/his profile of the SITE.

f) Other users’ use of information

To facilitate interaction among all the SITE community members, we allow a limited access to certain USERS contact data, such as username, telephone numbers, town and email address.

The USERS shall only use other USERS’ personal data if:

f.1) The SITE communication is not an unrequested commercial communication.

f.2) For any other purpose the USER, may strictly allow it, once the legally required information has been previously notified.

Under no circumstance, the USER shall share other USERS’ personal data or email address without the consent of the SITE or affected USER.

g) Cookies

The SITE USER, Visitor and iFriend must be aware and accept the utilization of a tracking system used by “cookies”. Cookies are small pieces of data stored on the USER’S hard drive for a period of time. We use cookies because they help us customize our services. Some functions offered are only available with the use of cookies. Cookies are used with the purpose of getting to know the interests, the behavior and the demography of SITE Visitors or USERS. Cookies help us understand better your needs and interests and give you a better service or any related information.

Cookies may record information which a USER or visitor access on one webpage, simplifying subsequent interactions with that website by the same USER. Cookies also show advertising or sales promotion, interesting banners, news about the SITE. We also use cookies to promote and enforce the rules and safety of the SITE.

The SITE may add cookies to the emails sent in order to measure promotion effectiveness.   Cookies may also be used so that the USER doesn’t need to write her/his password so frequently during a web browsing section. You are required to account for your the activity log (the activity log of the USER)

The cookies are used for the benefit of the USER, and will not be used for purposes aiming goals that are not part of the SITE’s operation.

The installation, permanence, and existence of cookies in the User’s computer depends on her or his exclusive will and therefore can be deleted from the computer whenever the USER desires it.

Additionally you may find cookies or other similar systems installed by third parties in some pages of the SITE, as, for instance, when navigating on a page created by another USER.

The privacy policy only addresses to the use of cookies by the SITE and not the use of cookies by advertisers.

THE SITE doesn’t control the use of cookies by third parties. Our cookies’ policy follows the most recent legislation guidelines existing on the subject.

h) Web Beacons

A Web Beacon is an electronic image, also called semgle-pixel (1 x 1) or transparent pixel, which is a code inserted on a web page. A Web beacon has the same purposes of the Cookies mentioned above.

Moreover a Web Beacon is used to measure traffic patterns of the USERS from one site to another in order to improve the traffic flow through the web.

The USER and VISITOR acknowledge that the SITE may use a tracking system through web beacons.

i) Competent Authorities – Legal Requirement

The SITE cooperates with the competent authorities and third parties to guarantee the legal compliance, especially, concerning the protection of the industrial and intellectual property rights and the fraud prevention among others.

The SITE might reveal the PERSONAL DATA of its USERS to attend the requirements of legal or competent governmental authorities for investigation purposes conducted by those (legal or competent governmental authorities) even if there isn’t a court order.

The SITE may mention any PERSONAL DATA about its USERS with the purpose of applicable law compliance and also, the SITE may cooperate with the competent authorities to any investigation of an unlawful act, infringement of industrial and intellectual property rights or any other unlawful activity or any activity that may expose the SITE or its USERS, directors, employees and agents to any legal responsibility.

The SITE may also mention the USER’S full name, the USER’S name, address, city, district, zip code, phone number, email address, country, etc, to the participants of the Programme of Protection of Intellectual Property of the SITE, so that the fraud, industrial or intellectual property rights infringement, piracy, or any other unlawful activity is investigated. This right will be administered by the SITE in order to cooperate with the law compliance and enforcement, even if there is no court or administrative order for that.

Besides that, the SITE reserves the right to mention its USERS’ personal data to other USERS, entities or third parties, whenever there are sufficient reasons to consider that the activity of an USER is suspicious because of any damage or offense to other people. This right will be used by the SITE whenever it considers appropriate or necessary to keep the integrity and safety of the Community and its USERS, as well as to enforce the Terms of Use and Sailing Conditions and other policies of the SITE, and to cooperate with the law enforcement and compliance.

j) Safety and Information Storage

The SITE is required to observe all the applicable laws concerning PERSONAL DATA safety measures so that it uses the most advanced industrial standards concerning the protection of personal data confidentiality, such as, firewalls, and  Secure Socket Layers (“SSL”). The SITE takes into account the PERSONAL DATA as a valuable commodity that must be protected of any loss, access or unauthorized disclosure.

The SITE uses several safety measures to protect PERSONAL DATA, not authorizing its use by USERS either inside or outside the company.

It is still necessary to consider that there is no perfect safety in internet. Therefore the SITE will neither be responsible for unlawful interceptions or its systems or database violation by unauthorized personnel nor for misuse of the information obtained by these means.

All USERS’ PERSONAL DATA are stored by an automated file, located in the USA. The USER when enrolling in the site, confirms that she or he is informed of the location of this file and allows its international transference of her o his personal data.

k) Changes of emails preference

The SITE wishes to keep its USERS updated all the time with promotions, news, changes, etc. The USERS may select the emails and promotional data that they would like to receive from the SITE. If the USER does not want to receive emails, she or he may change her or his email preferences in order to be considered in future communication.

L) FAQ data or Forums

The SITE allows its USERS to use the FAQ  (Frequently Asked Questions) in the adds, and besides that it allows the maintenance of public forums that are easy to sail. In these sections the USERS are able to comment, give opinions, start discussions and topics of interest in a friendly environment, always subject to the relevant rules in this POLICY.

The PERSONAL DATA inserted in the FAQ or Forums may be read, collected or used by any person. The SITE will not be responsible for the misuse of this information published by the USER in these website areas..

M) Rights of cancellation and rectification of personal data

The USER when enrolling, acknowledges and may exercise her or his rights of access, cancellation and may update her or his PERSONAL DATA. The USER will guarantee the accuracy and precision of the PERSONAL DATA and commits to keep them properly updated.

Once enrolled in the SITE, the USER may review and change the information provided during the enrollment process, information such as:

m.1) Username and email address; in this case, without damage of the changes made, the SITE will store the original PERSONAL DATA due to safety and fraud control;

m.2) The register data such as phone number;

m.3) The personal password. In some cases, PERSONAL DATA that was asked by the USER to be removed from the SITE may be stored in the files, in order to be used in case of dispute resolutions, treatment of complaints, problem or incident detection and law compliance. In any of these cases the USER”S PERSONAL DATA will not be immediately removed from the files for legal and technical reasons, including the support and safety systems.

The USERS may update their PERSONAL DATA regularly, so that other USERS are able to hire them whenever a deal is made. To modify any data provided when enrolling, the USER must access her or his personal profile in the SITE.