Full policy

Data Controller

The data controller is the University of Milan, in the person of the Rector pro tempore, Via Festa del Perdono no. 7, 20122 Milan, e-mail infoprivacy@unimi.it

Types of Data Collected

Among the Personal Data collected by this Web Site, either independently or through third parties, are: Tracking Tool; Usage Data; unique device identifiers for advertisements (Google Advertiser ID or IDFA identifier, for example); device information; first name; last name; email; geographic location; Data disclosed while using the service; username; password; answers to questions; clicks; keypress events; motion sensor events; mouse movements; position relative to scrolling; touch events; various types of Data.

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected during the use of this Web Site.
Unless otherwise specified, all Data requested by this Web Site is mandatory. If the User refuses to disclose them, it may be impossible for this Web Site to provide the Service. In cases where this Web Site indicates certain Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users who are in doubt about which Data are mandatory are encouraged to contact the Data Controller.
Any use of Cookies – or other tracking tools – by this Website or the owners of third party services used by this Website, unless otherwise specified, is for the purpose of providing the Service requested by the User, in addition to the additional purposes described herein and in the Cookie Policy, if available.

The User assumes responsibility for third party Personal Data obtained, published or shared through this Web Site and warrants that he or she has the right to communicate or disseminate it, releasing the Owner from any liability to third parties.

Method and place of processing of collected Data

Mode of treatment

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out by means of computer and/or telematic tools, with organizational methods and logic strictly related to the indicated purposes. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Web Site (administrative, sales, marketing, legal, system administrators personnel) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller may have access to the Data. An up-to-date list of Data Processors can always be obtained from the Data Controller.

Legal basis for processing

The Owner processes Personal Data related to the User if one of the following conditions exists:

• the User has given consent for one or more specific purposes; Note: In some jurisdictions, the Data Controller may be authorized to process Personal Data without the need for the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;
• processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures;
• processing is necessary to fulfill a legal obligation to which the Controller is subject;
• the processing is necessary for the performance of a task of public interest or the exercise of public authority vested in the Controller;
• processing is necessary for the pursuit of the legitimate interest of the Owner or third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.

Location

The Data are processed at the operational offices of the Data Controller and at any other place where the parties involved in the processing are located. For more information, contact the Holder.
The User’s Personal Data may be transferred to a country other than the country in which the User is located. To obtain more information about the location of processing, the User may refer to the section on Personal Data Processing Details.

The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or formed by two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data.

The User may verify whether any of the transfers just described takes place by reviewing the section of this document on details of the processing of Personal Data or request information from the Controller by contacting it at the contact details given at the beginning.

Retention period

Data are processed and kept for the time required by the purposes for which they were collected.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of that contract is completed.
• Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until that interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When processing is based on the User’s consent, the Data Controller may keep the Personal Data longer until that consent is revoked. In addition, the Data Controller may be required to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, upon the expiration of this period, the right of access, deletion, rectification and the right to Data portability can no longer be exercised.

Purposes of the Processing of Collected Data

User Data is collected to enable the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), detect any malicious or fraudulent activities, as well as for the following purposes: Statistics, Registration and Authentication provided directly from this Website, Location-Based Interactions, Interaction with social networks and external platforms, Interaction with live chat platforms, Payment Management, Content Commentary, Protection from SPAM, Contacting the User, Registration and Authentication, and Viewing Content from External Platforms.

To obtain detailed information on the purposes of processing and the Personal Data processed for each purpose, the User may refer to the section “Personal Data Processing Details.”

Details of the processing of Personal Data

Personal Data are collected for the following purposes and using the following services:

• Content commentary

  Comment services allow Users to make and publish their own comments regarding the content of this Web Site.
  Users, depending on the settings decided by the Owner, can also leave the comment anonymously. In case among the Personal Data released by the User is email, this could be used to send notifications of comments regarding the same content. Users are responsible for the content of their comments.
  In the event that a commenting service provided by third parties is installed, it is possible that, even if Users do not use the commenting service, it will collect traffic data related to the pages where the commenting service is installed.

  Directly managed comment system (this Web site)

  This Web Site has its own content commenting system.

  Personal Data Processed: last name; Usage Data; first name; Tracking Tool; username.

  Category of personal information collected under the CCPA: identifiers; Internet information.

• Contact User

  Contact Form (this Website)

  By filling out the contact form with their Data, the User consents to their use to respond to requests for information, quotes, or any other nature indicated by the header of the form.

  Personal Data Processed: last name; email; first name; types of Data.

  Category of personal information collected under the CCPA: identifiers; biometric information; Internet information.

• Interaction with live chat platforms

  This type of services allows you to interact with live chat platforms operated by third parties, directly from the pages of this Web Site, in order to be able to contact and be contacted by the support service of this Web Site.
  In the event that a service for interaction with live chat platforms is installed, it is possible that, even if Users do not use the service, it will collect Usage Data related to the pages where it is installed. In addition, live chat conversations could be recorded.

  LiveChat Widget (LiveChat, Inc.)

  The LiveChat Widget is an interaction service with the LiveChat live chat platform, provided by LiveChat, Inc.

  Personal Data Processed: Data disclosed while using the service; Usage Data; Tracking Tool.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected under the CCPA: Internet information.

  This type of processing constitutes a “sale of data” (“sale”) under the CCPA. In addition to the information in this clause, the User may consult the section describing California consumer rights for information regarding how to opt out of the sale.

• Interaction with social networks and external platforms

  This type of service allows for interactions with social networks, or other external platforms, directly from the pages of this Web Site.
  Interactions and information captured by this Web Site are in each case subject to the User’s privacy settings related to each social network.
  This type of service may still collect traffic data for pages where the service is installed, even when Users are not using it.
  It is recommended that you disconnect from the respective services to ensure that the data processed on this Web Site is not linked back to your profile.

   

• Location-based interactions

  Non-Continuous Geolocation (this Web Site)

  This Web Site may collect, use, and share Data related to the User’s geographic location in order to provide location-based services.
  Most browsers and devices provide tools by default to deny geographic tracking. If the User has expressly authorized such a possibility, this Web Site may receive information about his/her actual geographical location.
  Geographical localization of the User occurs non-continuously, upon specific request of the User or when the User does not indicate in the appropriate field the place where it is located and allows the application to automatically detect the location.

  Personal data processed: geographic location.

  Category of personal information collected under the CCPA: geolocation data.

• Protection from SPAM

  This type of services analyzes traffic on this Web Site, potentially containing Users’ Personal Data, in order to filter it from parts of traffic, messages and content recognized as SPAM.

  Google reCAPTCHA

  Google reCAPTCHA is a SPAM protection service provided by Google LLC or Google Ireland Limited, depending on where this Web Site is used.
  Use of the reCAPTCHA system is subject to Google’s privacy policy and terms of use.

  Personal Data Processed: clicks; Usage Data; keypress events; motion sensor events; touch events; mouse movements; scrolling relative position; answers to questions; Tracking Tool.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Category of personal information collected under the CCPA: Internet information; indirect information.

• Registration and authentication

  By registering or authenticating, you allow this Web Site to identify you and give you access to dedicated services.
  Depending on the following, registration and authentication services may be provided with the help of third parties. If this occurs, this Web Site may access some Data stored by the third-party service used for registration or identification.
  Some of the services below may also collect Personal Data for targeting and profiling purposes; please refer to the description of each service to learn more.

   

• Registration and authentication provided directly by this Web Site

  By registering or authenticating, you allow this Web Site to identify you and give you access to dedicated services. Personal Data are collected and stored for registration or identification purposes only. The Data collected are only those necessary to provide the service requested by the User.

  Direct Registration (this Web Site)

  The User registers by filling out the registration form and providing their Personal Data directly to this Web Site.

  Personal Data Processed: last name; email; first name; Tracking Tool.

  Category of personal information collected under the CCPA: identifiers; Internet information.

• Statistics

  The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to track User behavior.

  Facebook Analytics for Apps (Facebook Ireland Ltd)

  Facebook Analytics for Apps is a statistics service provided by Facebook Ireland Ltd.

  Personal Data Processed: Usage Data; Tracking Tool; various types of Data as specified by the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected under the CCPA: Internet information.

  This type of processing constitutes a “sale of data” (“sale”) under the CCPA. In addition to the information in this clause, the User may consult the section describing California consumer rights for information regarding how to opt out of the sale.

  Google Analytics (Google Ireland Limited)

  Google Analytics is a web analytics service provided by Google Ireland Limited (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports, and sharing them with other services developed by Google.
  Google may use Personal Data to contextualize and personalize ads in its ad network.

  Personal Data Processed: Usage Data; Tracking Tool.

  Place of processing: Ireland – Privacy Policy – Opt Out.

  Category of personal information collected under the CCPA: Internet information.

  This type of processing constitutes a “sale of data” (“sale”) under the CCPA. In addition to the information in this clause, the User may consult the section describing California consumer rights for information regarding how to opt out of the sale.

  Directly collected statistics (this Web site)

  This Web Site uses an internal statistics system, which does not involve third parties.

  Personal Data Processed: Usage Data; Tracking Tool.

  Category of personal information collected under the CCPA: Internet information.

  Google Analytics with anonymized IP

  Google Analytics is a web analytics service provided by Google LLC or Google Ireland Limited, depending on where this Web Site is used, (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports, and sharing them with other services developed by Google.
  Google may use Personal Data to contextualize and personalize ads in its ad network.
  This Google Analytics integration anonymizes your IP address. Anonymization works by abbreviating within the borders of member states of the European Union or in other countries that are members of the European Economic Area agreement the IP address of Users. Only in exceptional cases will the IP address be sent to Google’s servers and abbreviated within the United States.

  Personal Data Processed: Usage Data; Tracking Tool.

  Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

  Category of personal information collected under the CCPA: Internet information.

  This type of processing constitutes a “sale of data” (“sale”) under the CCPA. In addition to the information in this clause, the User may consult the section describing California consumer rights for information regarding how to opt out of the sale.

• Viewing content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of this Web Site and interact with them.
  This type of service may still collect data on web traffic related to pages where the service is installed, even when users are not using it.

  Google Fonts (Google Ireland Limited)

  Google Fonts is a font style display service operated by Google Ireland Limited that allows this Web Site to integrate such content within its pages.

  Personal Data Processed: Usage Data; Tracking Tool.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected under the CCPA: Internet information.

  This type of processing constitutes a “sale of data” (“sale”) under the CCPA. In addition to the information in this clause, the User may consult the section describing California consumer rights for information regarding how to opt out of the sale.

Further information on the processing of Personal Data

• Personal Data collected through sources other than the User

  The Owner of this Website may have lawfully collected Personal Data about the User without the User’s involvement, drawing on sources provided by third parties, in accordance with the legal bases described in the section on the legal bases for processing.
  If the Owner has collected Personal Data in such a way, the User can find specific information regarding the sources in the respective sections of this document or by contacting the Owner.

• The service is aimed at adults

  Users declare that they are adults according to applicable law. Use of this Web Site is prohibited for minors.

User Rights

Users may exercise certain rights with respect to the Data processed by the Data Controller.

In particular, the User has the right to:

• Revoke consent at any time. The User may revoke the previously expressed consent to the processing of his or her Personal Data.
• Object to the processing of their Data. Users may object to the processing of their Data when it is done on a legal basis other than consent. Further details on the right to object are given in the section below.
• access their Data. The User has the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing, and to receive a copy of the processed Data.
• Verify and request rectification. The User can check the accuracy of their Data and request that it be updated or corrected.
• Obtain restriction of processing. When certain conditions are met, the User may request the restriction of the processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
• Obtain the deletion or removal of their Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Data Controller.
• receive their Data or have it transferred to another owner. You have the right to receive your Data in a structured, commonly used, machine-readable format and, where technically feasible, to have it transferred unimpeded to another data controller. This provision is applicable when the Data are processed by automated means and the processing is based on the User’s consent, a contract to which the User is a party, or contractual measures related thereto.
• Propose complaint. The User may file a complaint with the relevant data protection supervisory authority or take legal action.

Details of the right to object

When Personal Data are processed in the public interest, in the exercise of public powers vested in the Data Controller or in pursuit of a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are advised that if their Data were processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise rights

To exercise the User’s rights, Users may address a request to the contact details of the Owner set out in this document. Requests are filed free of charge and processed by the Holder as quickly as possible, in any case within one month.

Cookie Policy

This Web Site makes use of Tracking Tools. To learn more, the User may consult the Cookie Policy.

More information about the treatment

Litigation defense

The User’s Personal Data may be used by the Owner in legal proceedings or in the preparatory stages to its possible establishment for the defense against abuse in the use of this Web Site or related Services by the User.
The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific disclosures

Upon the User’s request, in addition to the information contained in this privacy policy, this Web Site may provide the User with additional and contextual disclosures regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For operation and maintenance purposes, this Web Site and any third-party services it uses may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to “Do Not Track” requests

This Web Site does not support “Do Not Track” requests.
To find out whether any third-party services used support them, the User is encouraged to consult their respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Website as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details it has. Therefore, please consult this page frequently, referring to the date of last modification indicated at the bottom.

If the changes affect processing whose legal basis is consent, the Owner will re-collect the User’s consent, if necessary.

Information for California consumers

This part of the document supplements and complements the information contained in the rest of the privacy policy and is provided by the company that operates this Web Site and, where applicable, its parent company and its subsidiaries and affiliates (for the purposes of this section referred to collectively as “we,” “our,” or “us”).

The provisions contained in this section apply to all Users who are deemed to be consumers residing in the state of California, United States of America, under the “California Consumer Privacy Act of 2018” (such Users are hereinafter referred to simply as “you,” “your,” “you,” or “your”), and, for them, these provisions prevail over any other possibly divergent or conflicting provisions contained in this privacy policy.

This part of the document uses the term “personal information” as defined by the California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed, or sold

This section summarizes the categories of personal information we have collected, disclosed, or “sold” under the CCPA and the related purposes of processing. You can find detailed information about these activities in the section called “Details of Personal Data Processing” in this document.

Information we collect: the categories of personal information we collect.

We collected the following categories of personal information about you: identifiers, business information, biometric information, Internet information, geolocation data, and indirect information.

We will not collect additional categories of personal information without first notifying you of a new disclosure.

How do we collect information: what are the sources of the personal information we collect?

We collect the above categories of personal information, directly or indirectly, from you when you use this Web Site.

For example, you directly provide us with your personal information when you submit requests through any form on this Web Site. In addition, you indirectly provide us with personal information when you browse this Web Site, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties who work with us in connection with the provision of the Service or the operation of this Web Site and its features.

How we use the information we collect: sharing and communicating your personal information with third parties for operational purposes.

We may disclose your personal information to third parties for operational and service purposes. In this case, we enter into a written contract with that third party that obligates the recipient of your personal information to keep that information confidential and not to use it for any purpose other than what is necessary for the performance of the contract.

We may also disclose your personal information to third parties when you request or authorize us to do so in order to provide you with our Service.

For more information on the purposes of processing, please see the relevant section of this document.

Sale of your personal information

For the purposes of this document, the term “sale” means “selling, assigning, releasing, making public, disclosing, making available, transferring or otherwise communicating orally, in writing or by electronic means, personal information of a consumer by one business to another business or to a third party, for a consideration or by otherwise profiting from it.”

This means that, for example, a sale can occur whenever an application runs advertisements, performs statistical analysis on its traffic or views, or simply uses tools such as social network plug-ins and similar tools.

Your right to opt-out of the sale of your personal information

You have the right to opt-out of the sale of your personal information. This means that whenever you ask us not to sell your data, we will carry out your request.
Such requests can be made freely, at any time, and without submitting any request subject to verification, simply by following the instructions below.

Instructions for opting out of the sale of personal information

If you would like further information or to exercise your right to opt-out in connection with all sales made from this Web Site, both online and offline, you may contact us using the contact information provided herein.

What are the purposes for which we use your personal information?

We may use your personal information to enable the proper functioning of this Web Site and its features (“operational purposes”). In such cases, your personal information will be processed in a manner appropriate and proportionate to the purpose for which it was originally collected and strictly within the limits of compatible purposes.

We may also use your personal information for other reasons, such as for business purposes (as outlined in the “Personal Information Processing Details” section within this document), as well as to comply with the law and defend our rights before the relevant authorities when our rights or interests are threatened or when we suffer harm.

We will not use your personal information for different, unrelated, or incompatible purposes without first giving you a new notice.

Your privacy rights in California and how to exercise them

Right to knowledge and portability

You have the right to know the following:

• the categories of personal information we collect about you and the sources of that information, the purposes for which we use your personal information, and with whom we share it;
• in case of sale or disclosure of personal information to third parties for operational purposes, we will provide you with two separate lists in which we will notify you:
  • for sale, the categories of personal information disclosed to each category of recipients; and
  • for communication to third parties for operational purposes, the categories of personal information obtained from each category of recipients;

The above information will be limited to personal information collected or used in the past 12 months.

In the event that our response is delivered electronically, the information it contains will be “portable,” that is, delivered in a compatible format so that you can transmit the information to other entities without hindrance – provided this is technically feasible.

Right to request deletion of one’s personal information

You have the right to request deletion of any of your personal information, subject to exceptions provided by law (such as, but not limited to, if the information is used to identify and repair errors on this Web Site, to detect security incidents, for purposes of protecting against fraudulent or illegal activities, to exercise certain rights etc.).

If no statutory exception applies, following the exercise of your right, we will delete your personal information and ask our suppliers to do the same.

How to exercise your rights

To exercise the rights described above, you must submit a verifiable request by contacting us through the contact information provided herein.

In order to respond to your request, it is necessary for us to be able to identify you. Therefore, you can only exercise the above rights by submitting a verifiable request that must:

• Provide sufficient information to enable us to reasonably verify that you are the person to whom the personal information we have collected relates or an authorized representative of that person;
• describe your request in a degree of detail that is sufficient for us to understand, evaluate, and respond correctly to what you are asking.

We will not respond to any request unless we are able to verify your identity and, therefore, confirm that the information we hold actually relates to you.

If you cannot personally submit a verifiable request, you may delegate a person registered with the “California Secretary of State” to do so on your behalf.

If you are an adult, you can make a verifiable request on behalf of those who fall under your parental authority.

A maximum number of 2 applications can be submitted within 12 months.

How and how quickly we will handle your request

Within 10 days we will confirm that we have received your request and provide you with information on how we will process it.

We will respond on the merits of the request within 45 days of receiving it. In case we need more time, we will explain why and let you know how much time we need. In this regard, please note that it may take us up to 90 days to fulfill your request.

Our communications will cover the previous 12-month period.

Should we deny your request, we will explain the reason for the denial.

We will not charge any fee to process or respond to your verifiable request unless it is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or deny the request. In both cases, we will notify you of our decisions and explain the reasons for them.

Information for Users residing in Brazil

This part of the document supplements and complements the information contained in the rest of the privacy policy and is provided by the entity that operates this Web Site and, where applicable, its parent company and its subsidiaries and affiliates (for the purposes of this section referred to collectively as “we,” “our,” or “us”).
The provisions contained in this section apply to all Users who are residents of Brazil, within the meaning of the “Lei Geral de Proteção de Dados” (such Users are referred to hereafter simply as “you,” “your,” “you,” or “your”). For such Users, these provisions prevail over any other possibly divergent or conflicting provisions contained in this privacy policy.
In this part of the document the term “personal information” as defined by the Lei Geral de Proteção de Dados(LGPD) is used.

Legal basis under which we process your personal information

We process your personal information only where there is a legal basis for such processing. The legal bases are as follows:

• Your consent to the processing activities in question;
• The fulfillment of legal obligations that we are required to meet;
• The execution of rules dictated by laws or regulations or by contracts, agreements or other similar legal instruments;
• Studies conducted by research organizations, preferably conducted on anonymized personal information;
• The performance of a contract and related pre-contractual obligations, if you are a party to that contract;
• The exercise of our rights in court, administrative proceedings or arbitration;
• The defense or physical safety of yourself or a third party;
• health protection-in the context of procedures implemented by health care entities or professionals;
• Our legitimate interest, provided that your fundamental rights and freedoms do not override such interests; and
• credit protection.

To learn more about the legal basis, you can contact us at any time using the contact information provided in this document.

Categories of personal information processed

To find out what categories of personal information are processed, you can refer to the “Details of Personal Data Processing” section in this document.

Why we process your personal information

To learn why we process your personal information, please refer to the “Details of the Processing of Personal Data” and “Purposes of the Processing of Data Collected” sections found in this document.

Your privacy rights in Brazil, how to submit a request and how it will be handled by us

Your rights related to privacy in Brazil

You have the right to:

• Obtain confirmation of the existence of processing activities regarding your personal information;
• Access your personal information;
• Obtain rectification of your incomplete, inaccurate, or outdated personal information;
• obtain anonymization, blocking or deletion of unnecessary or excessive personal information, or information that is processed contrary to the provisions of the LGPD;
• Obtain information regarding the possibility of giving or withholding your consent and its consequences;
• Get information about the third parties with whom we share your personal information;
• Obtain, upon your explicit request, portability of your personal information (except anonymized information) to other product or service providers, provided that our trade and industry secrets are safeguarded;
• Obtain the deletion of personal information processed where the processing was carried out on the basis of your consent, unless one or more of the exceptions in Article 16 LGPD apply;
• Revoke your consent at any time;
• File a complaint regarding your personal information with the NPA (National Data Protection Authority) or a consumer protection agency;
• Object to processing activities in cases where such processing is not carried out in accordance with the provisions of the law;
• Require clear and adequate information regarding the criteria and procedures used in automated decision making; and
• Request review of decisions that harm your interests, made solely on the basis of automated decision-making processes of your personal information. These include decisions to outline your personal, professional, consumer or creditor profile, or other facets of your personality.

You will never be discriminated against, or suffer in any way any treatment that is unfavorable to you, as a result of exercising your rights.

How to submit a request

You can submit an explicit request to exercise your rights free of charge, at any time, using the contact information in this document or through your legal representative.

How and how quickly we will handle your request

We will make every effort to respond to your request as soon as possible.
In any case, if it is impossible for us to do so, we will be sure to inform you of the factual or legal reasons why we cannot immediately comply or follow up on your request. In the event that your personal information is not processed by us, if we are able to do so, we will direct you to the natural or legal person to whom your requests should be addressed.

Should you decide to submit a request for access or a request for confirmation of the existence of the processing of personal information, please be sure to specify whether you prefer to receive your personal information in electronic or paper format.
You will also need to let us know if you would like an immediate response, in which case you will receive a simplified response, or if you require a full disclosure.
In the latter case, we will respond within 15 days from the time of your request, providing you with all information regarding the origin of your personal information, confirmation or non-confirmation of the existence of personal information about you, all criteria used for processing and the purposes of such processing, while safeguarding our trade and industry secrets.

In case you decide to submit a request for a rectification, deletion, anonymization, or blocking of personal information, we will ensure that we immediately notify other parties with whom we have shared your personal information of your request so that they can in turn comply with your request – except in cases where such a disclosure is impossible or unduly burdensome for us.

Transfer of personal information outside Brazil in cases permitted by law

We may transfer your personal information outside the Brazilian territory in the following cases:

• when the transfer is necessary for international legal cooperation between intelligence services, investigative and criminal procedure bodies, as provided by the instruments made available by international law;
• when the transfer is necessary to defend your life or physical safety or that of a third party;
• When the transfer is authorized by the ANPD;
• when the transfer results from an obligation undertaken in the context of an international cooperation agreement;
• when the transfer is necessary for the exercise of public policy or the performance of a public service;
• when the transfer is necessary for the fulfillment of a legal obligation, the performance of a contract and related pre-contractual fulfillments, or the normal exercise of rights in guidiatorial, administrative, or arbitration proceedings.