About Us
Our website address is: https://grupos2mkt.com.
Security and Privacy Standards
GLOBAL PRIVACY POLICY – S2 GROUP
The purpose of this document is to establish the rules for data processing, which include, for example, the operations of collection, production, reception, classification, use, access, reproduction, transmission, distribution, processing, archiving, storage, elimination, evaluation or control of information, modification, communication, transfer, dissemination or extraction of data collected from USERS, in addition to recording their activities, in accordance with applicable laws.
| When the USER accepts this Privacy Policy, he/she freely and expressly agrees with the terms stipulated herein.. |
1. Glossary
1.1. For the purposes of this document, the following definitions and descriptions should be considered for better understanding:
Account: is the way in which the USER is represented when accessing certain restricted areas, exclusive features of the websites, applications and services offered by Group S2, usually corresponding to a data set that represents the USER (such as registration data) and other relevant data to ensure a more appropriate and complete relationship of Group S2 to USER (as a record of activities carried out by the USER on websites, applications and services offered by the S2 Group).
Cookies: small files or data packets sent by Group S2 to the device of the USER to identify you and collect information that will help the Group S2 to improve the services provided to USER.
Credentials: is the data set that the USER uses to authenticate when accessing certain restricted areas and/or exclusive features of the websites, applications and services offered by Group S2. Such data is usually a login and password, but may include additional data that assists in the authentication process.
Data: set of Anonymized Data and Personal Data.
Anonymized Data: information that, alone or in conjunction with other Anonymized Data, does not allow the identification of a person, considering the use of reasonable and available technical means at the time of processing. It may include gender, age and geolocation (such as the city in which the person is located) and statistical data.
Personal data: information related to an identified or identifiable natural person. It may include, for example, name, address, email, telephone, debit/credit card number, IP address and geolocation data.
Data Protection Officer (DPO): person (natural or legal) indicated by the Group S2 responsible for acting as a communication channel between the Group S2, USER and government authorities on matters relating to this Privacy Policy and the use, collection and processing of Data by Group S2.
Group S2: all subsidiary companies controlled by the economic group, represented by the legal entity GS2 MARKETING DIGITAL EIRELI (CNPJ 36.322.861/0001-33).
IP adress: address of Internet Protocol associated with the device used by USER. Each IP adress corresponds to an alphanumeric set that, together with other information, helps to uniquely identify the device that USER are using to access the internet and therefore to access websites, applications and services offered by Group S2.
Applicable Legislation: means the legislation applicable to the relationship between the Group S2 and USER, which may vary depending on (i) the place where the services are provided; (ii) the place of residence or housing of one of the Parties, including the Party itself. USER; (iii) other factors indicated in specific legislation. The Group S2 has representation in several countries, being subject, in addition to Brazilian legislation, to several other regulations, including the General Data Protection Regulation (GDPR), in English.
Logs: activity records of USERS made on the websites, applications and services provided by Group S2.
Privacy Policy: means, together, this Global Privacy Policy – S2 Group and its annexes, as well as other documents expressly referenced in this Global Privacy Policy – S2 Group.
USERS: people who access or interact with the functionalities offered by the websites, applications and services offered by Group S2. O USER must have the legal capacity to accept and consent to this Privacy Policy and other documents of the Group S2. If you do not have such capacity, the USER declares to have previously obtained all necessary authorizations to accept this Privacy Policy and other documents presented by the Group S2.
2. Data Collection
| ABSTRACT |
| We collect USER Data as the USER provides it to us, directly or indirectly, when accessing and using the websites, applications and services offered by S2 Group or by partners that have been duly authorized by S2 Group (and that follow S2 Group's Data privacy guidelines in accordance with this policy). We also explain what Cookies consist of and how the USER can manage them. |
2.1. The Data will be collected:
(i) when voluntarily entered or submitted by USERS on the websites, applications and services offered by Group S2, such as the creation of Account, navigation, interaction with content and acquisition of services;
(ii) when the USER submit Data of third parties to the Group S2 (such as friends data). The Group S2 may use them in accordance with this Privacy Policy, declaring the USER which authorizes, under applicable legislation and regulations, to submit these Data for the knowledge and record by the Group S2, keeping the Group S2 unharmed;
(iii) when the Data are submitted automatically and without the need for any action on the part of the USERS, such as by means of Cookies; or
(iv) from partners who have obtained authorization to share them with the Group S2.
2.2. The information that the Group S2 collection may include, but are not limited to:
(i) name;
(ii) gender;
(iii) CPF;
(iv) email address;
(v) postal address;
(vi) telephone number and recordings (if there is contact with the USER);
(vii) date of birth;
(viii) payment information;
(ix) information about your device's browser and operating system;
(x) IP address;
(xi) pages visited;
(xii) left-wing and buttons clicked;
(xiii) contact list; and
(xiv) biometric data (such as, but not limited to, face photo).
2.2.1. Other data collected by Group S2 are defined in item 7 of this Politics, separated by companies and, when applicable, product/service groups.
2.3. The Group S2 is not responsible for the accuracy, inaccuracy or outdated information and Data provided by USER, being the responsibility of the USER provide them accurately and update them. The Group S2 may periodically request that the USER update the information provided and the Data provided.
2.4. ABOUT Group S2 uses Cookies and anonymous identifiers for audience control, navigation, security and advertising, and the USER you agree to this use by accepting this Privacy Policy. The Cookies used by Group S2 can be classified in several ways:
(i) Regarding validity:
a) Session cookies: they are temporary and remain until the web page or browser is closed. They can be used in e-commerce (for USER continue browsing and not lose what you put in your cart, for example), to analyze internet traffic patterns and to provide a better experience and contextualized content to USERS.
b) Permanent: persist even if the browser has been closed. They can be used to remember login and password information. USERS, for example, or to ensure a better user experience between different sessions.
(ii) As to ownership:
a) Own: are owned by the Group S2, which has full control over the Cookies.
b) Third Parties: are owned by third parties, but included in the device of the USERS through the websites, applications and services offered by Group S2.
(iii) As to the purpose:
a) strictly necessary: essential to allow the USER use the websites, applications and services offered by Group S2, which could not be properly offered without these Cookies. They are generally Session and Own.
b) performance: collect anonymous information about how the USERS use and interact with the websites, applications and services offered by Group S2, allowing us to recognize your profiles and count visits and interactions. They are generally your own.
c) functionality: they allow the Group S2 remember choices made by USERS (such as login and location) and provide more personal experiences, as well as enabling possible customizations (when available). This information may be anonymized (turned into Anonymized Data) and do not track activities outside of the websites, applications and services offered by Group S2. They are generally Own and Permanent.
d) analytics and advertising: they allow advertisers to Group S2 deliver more relevant ads and information to USERS. They are also used to limit the number of times the USER view certain advertisements and measure the effectiveness of advertising campaigns. They remember certain preferences of USERS and are used to help profile your users in order to improve their experience. USER. They are usually permanent and can be from third parties (such as Google Analytics, mentioned below).
e) social media: they allow the USER connect with social media such as LinkedIn, Twitter, Facebook, Pinterest and Instagram. They are usually permanent and third party.
f) security: they help the Group S2 to monitor fraudulent activities and protect user data from unauthorized access. They are generally permanent and third-party.
2.5. The USER may not accept the Cookies to use the websites, applications and services offered by Group S2, but in these situations the Group S2 cannot guarantee the correct functioning of these websites, applications and services offered. The Cookies can be accepted, deleted or rejected through management tools of the browser itself used by the USER.
2.6. The Group S2 uses partners to collect and process Data, whose information can be accessed by clicking here
2.7. ABOUT Group S2 will also record the activities carried out by the USER on the websites, applications and services provided by Group S2 creating logs which may include, but are not limited to:
(I) IP adress do USER;
(ii) Actions taken by the USER on the websites, applications and services provided by Group S2;
(iii) Addresses of pages and screens accessed by USER on the websites, applications and services provided by Group S2;
(iv) Dates and times of each action of the USER on the websites, applications and services provided by Group S2, in addition to the access you make to the pages and screens and the tools and functionalities you use;
(v) Information about the device used by the USER, operating system version, browser, among other installed applications and software;
(vi) Session e user ID, when available;
(vii) Connection type of USER, such as Wi-Fi or cellular networks (EDGE, 3G and 4G, for example); and
(viii) Geolocation.
2.8. Other technologies may be used to obtain navigation data from the USER. However, they will always respect the terms of this Politics Privacy and the options of the USER regarding its collection and storage, and that the USER will be informed in advance in case of any changes. If other Data other than those listed above are collected, the USER will be informed in advance. The information collected by Group S2 may be combined with information collected from other sources (including third-party partners) or from other technologies.
3. Use of Data
| ABSTRACT |
| Os Data may only be accessed by companies in the Group S2, partners, subcontractors and authorities. However, if the USER access partner sites or features, you will be subject to those partners' own practices and policies. We also list the uses we will make of the Data collected from the USERS. |
3.1. The Data collected from the USERS may be used for the following purposes:
(i) Identification, authentication and authorization;
(ii) Properly respond to requests and queries, as well as provide support to USERS;
(iii) Keep records up to date for contact purposes by telephone, email, SMS, direct mail or other means of communication;
(iv) Improve the use and interactive experience while browsing the websites, applications and services provided by Group S2;
(v) Carry out statistics, studies, research, project planning and surveys relevant to the activities and behaviors of the USER when using the websites, applications and services provided by Group S2, carrying out such operations anonymously with Anonymized Data;
(vi) Promote the services of Group S2 and its partners, in addition to informing about news, features, content, news and other relevant information for maintaining the relationship with the Group S2;
(vii) Protect the Group S2 of rights and obligations related to the use of the websites, applications and services provided by Group S2;
(viii) Collaborate and/or comply with a court order or request by an administrative authority, as well as meet obligations to preventively report certain activities to the competent authorities;
(ix) Proceed with payment requests made by USERS;
(x) Send newsletters and emails that USER expressly agreed to receive;
(xi) Manage risks and detect, prevent and/or remediate fraud or other potentially illegal or prohibited activities, as well as violations of applicable policies or terms of use;
(xii) Sharing payment information between companies Group S2, aiming to facilitate the experience of USERS when using the websites, applications and services offered by Group S2; is
(xiii) Consult the Data em desks private and public to check if they are correct, update them or request additional data.
3.2. The use, access and sharing of the database formed under the terms of this Privacy Policy will be made within the limits and purposes of the activities of the Group S2, and may be provided and made available for access and/or consultation by member companies. Group S2 in addition to business partners, suppliers, service providers, subcontractors, authorities or third parties in general, provided that the provisions of this Agreement are complied with. Privacy Policy, in Applicable Legislation or by court order. Sensitive data of the USER, such as personal data on racial or ethnic origin, religious belief, political opinion, membership of a trade union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a natural person, will be shared exclusively with the consent of the USER.
3.2.1. Sharing of Data of USERS may be made with entities located outside the country of residence of the USER (such as countries in the European Economic Area, South America or North America). In such cases, the processing, handling, use and sharing of the Data will be done in accordance with the Applicable Legislation and this Privacy Policy. In particular, when there is a transfer of Data originating from the European Economic Area to countries that have not been recognized by the competent authorities as offering an adequate level of protection, the Group S2 will ensure the use of appropriate tools and measures (such as the European Commission's Standard Contractual Clauses).
3.2.2. The Group S2 is committed to protecting the financial and banking confidentiality of its clients and USERS by not sharing this information with companies with which the USER have not agreed. The USER recognizes that the Group S2 is required to comply with a series of legal obligations under Applicable Legislation related to the identity of its clients and the origin of the funds it operates. Thus, the Group S2 is authorized to request, and the USER required to provide additional documents and information, including for carrying out know-your-customer and money laundering prevention procedures. The information obtained by Group S2 in response to the questions raised will be treated as confidential information. The Group S2 is authorized to share data required by Applicable Legislation with the competent authorities and with third parties who need to have access to the Data to prepare/validate reports on the activities of the Group S2 under said legislation.
3.2.3. ABOUT USER is responsible for the confidentiality, use and all acts in the use of Credentials (such as, but not limited to, login, password and authentication token). If the USER identify or suspect that a third party has access to your password, they must change it directly in the systems or services. Sharing Credentials resulting from the action of USER constitutes a violation of this Privacy Policy.
3.3. From now on the USER are you aware that the Group S2 may carry out (i) the anonymization of Personal data, making them Anonymized Data; (ii) the enrichment of its database, adding information from other legitimate sources – including from databases of other companies in the Group S2;and (iii) treatment of Personal data based on the legitimate interest of Group S2, as provided for in the Applicable Legislation. The USER expressly consents to such activities by agreeing to the terms of this Privacy Policy.
3.3.1. ABOUT USER acknowledge and agree that the Group S2 you can use the Data to profile the USER, in order to improve its services or comply with Applicable Legislation, including, but not limited to, know-your-customer obligations. The profile of the USER will be shared exclusively under the terms of this Privacy Policy or Applicable Legislation.
3.4. Internally, the Data will only be accessed by professionals duly authorized by Group S2, respecting the principles of purpose, adequacy and necessity, among others provided for in the Applicable Legislation, for the purposes of Group S2, in addition to the commitment to confidentiality and preservation of privacy under the terms of this Privacy Policy.
3.5. The Anonymized Data may be collected, processed, stored, used, transferred and disclosed for any purpose, regardless of authorization from the USER.
3.6. The Group S2 has business partners that may offer services through features or websites accessed from the websites, applications and services provided by Group S2. The Data provided by USER to these partners will be the responsibility of the partners, thus being subject to their own practices of obtaining and using Data, without any burden being placed on the Group S2 with regard to these Data.
3.7. ABOUT Group S2 values the security and inviolability of Credentials do USER. For this reason, it constantly searches and monitors the internet in its various layers in order to identify, collect and process for validation purposes (authentication tests) logins and passwords potentially belonging to USERS that have been improperly published on the internet by third parties.
3.7.1. If through authentication tests the Group S2 to note that the Credentials do USER have been compromised (made accessible to third parties), the Group S2 – for security and in order to prevent inappropriate access by third parties to the Account e Data do USER – will preventively block the Credentials do USER. If you have any questions – including how to unlock the Credentials - Or USER You can consult the terms of use on the websites, applications and services provided by Group S2, or contact the customer service center Group S2.
4. Data Storage
| ABSTRACT |
| The Data collected is stored in a secure location. At any time, the USER may request the display, correction or deletion of their Data. Except in specific cases, we may keep the Data collected for legal compliance, auditing and preservation of rights, for the period necessary to fulfill these responsibilities. |
4.1. The Data collected will be stored in a secure and controlled environment. However, considering that no security system is infallible, the Group S2 is exempt from any liability for any damages and/or losses resulting from failures, viruses or invasions of the database of the websites, applications and services offered by Group S2, except in cases where there is intent or fault. However, if the Group S2 identifies that any of these situations have occurred, will notify the USERS affected informing that there was a violation of their Data and indicating that they adopt appropriate measures.
4.2. The Data obtained from USER may be stored on the server itself. Group S2 or third parties hired for this purpose, whether located in Brazil or abroad, and may also be stored using technology cloud computing and/or others that may arise in the future, always aiming to improve and perfect the activities of Group S2. O Group S2 will cause third parties who eventually maintain the servers on which the Data are stored maintain security and control standards in accordance with applicable legal standards.
4.3. Through the service tools made available on the websites, applications and services offered by Group S2 is provided to the USER (may be subject to proof of identity):
(i) request access to the Data, including its display, rectification with the correction of incomplete, inaccurate or outdated data or elimination/deletion of the Personal data that concern you;
(ii) request the deletion/exclusion of all your Personal data collected and recorded by the Group S2, provided that the contract between the USER and Group S2 have finished, the Account cancelled and the minimum legal term for purposes of legal obligations of the Group S2 has elapsed;
(iii) revoke consent for future collection, treatment, use and processing of the Personal data that concern you or restrict the processing of Personal data. This will not affect the lawfulness of the treatment and processing of the Personal data carried out before revocation, based on your consent or in the legitimate interest of the Group S2. Revocation of consent may prevent the USER to fully utilize or even make it impossible to use the websites, applications and services offered by Group S2;
(iv) request the portability of your Data; is
(v) request that the Group S2 no longer use the Personal data for marketing purposes.
4.3.1. Even though the USER have requested the deletion of your data and revoked your consent, in some specific cases the Group S2 may be subject to Laws and regulations that make it impossible to delete/revoke the Data.
4.3.2. The Personal data do USER They will also be deleted when they are no longer necessary, except in the event of a legal or contractual justification for their maintenance (for example, to comply with any legal obligation to retain data or the need to preserve them to preserve the rights and legitimate interests of one of the parties involved in the contract).
4.4. Privacy settings of USERS and the products and resources that USER uses influence the Data do USER that will be obtained by Group S2.
4.5. ABOUT Group S2 may, for auditing and rights preservation purposes, keep the registration history of Data do USER, possessing the Group S2 the ability to permanently exclude them at your convenience or in cases where the law or regulatory standard requires it. The Group S2 you can also keep the Anonymized Data and anonymized version of the Data for statistical and study purposes, even after the deletion request by the USER or after the end of the legal custody period.
5. General Provisions:
| ABSTRACT |
| We may update this document at any time, so please review it frequently. If we outsource any activity, we will ensure that the contracted companies comply with all provisions of this document. |
5.1. The content of this Privacy Policy may be updated or modified at any time, according to the purpose or convenience of the Group S2, such as for legal adequacy and compliance with the provision of law or norm that has equivalent legal force, being the responsibility of the USER check it whenever you access the websites, applications or services offered by Group S2.
5.1.1. If updates are made to this document, the Group S2 will notify the USER through the tools available on the websites, applications and services provided by Group S2 and/or means of contact provided by USER. O USER will be bound by the new terms of this document from the delivery of notification about the updates.
5.2. The contact address for the Manager/DPO is rodrigo@grupos2mkt.com. The USER You may contact us at this address to clarify any questions regarding the provisions contained in this Privacy Policy.
5.3. If you consider that the Group S2 violated any provision of law or this Privacy Policy, USER has the right to lodge a complaint with the appropriate supervisory authority, in addition to contacting the Group S2 directly.
5.4. If third-party companies carry out the processing of any Data collected by Group S2, must comply with the conditions stipulated herein and the Information Security standards of Group S2, necessarily.
5.5. If any provision of this Privacy Policy is considered illegal or illegitimate by the authority of the locality in which the USER reside or your internet connection, the remaining conditions will remain in full force and effect.
6. Law of Application and Jurisdiction
| ABSTRACT |
| In the event of legal action, Brazilian law and the jurisdiction of the city of São Paulo apply, unless specifically provided for by the Applicable Legislation (such as the domicile of the USER). |
6.1. The present Privacy Policy shall be interpreted in accordance with Brazilian law, in the Portuguese language, and the jurisdiction of the city of São José dos Campos/SP shall be elected to resolve any dispute or controversy involving this document, unless there is a specific reservation of personal, territorial or functional jurisdiction by the Applicable Legislation.