Privacy Policy

  1. General information

This Privacy Policy contains information about how we treat, in whole or in part, in an automated or non-automated manner, the personal data of users who access our website. Its purpose is to clarify interested parties about the types of data that are collected, the reasons for the collection and how the user can update, manage or delete this information.

This Privacy Policy has been prepared in accordance with Federal Law No. 12,965 of April 23, 2014 (Internet Civil Framework), with Federal Law No. 13,709 of 14 August 2018 (Personal Data Protection Act) and EU Regulation No 2016/679 of April 27, 2016 (European General Regulation on The Protection of Personal Data – RGDP).

This Privacy Policy may be updated due to any regulatory update, which is why the user is invited to periodically consult this section.

  1. User rights

The site undertakes to comply with the standards provided for in the GDPR, in compliance with the following principles:

– The user’s personal data will be processed in a lawful, fair and transparent manner (lawfulness, loyalty and transparency);

– The user’s personal data will be collected only for specific, explicit and legitimate purposes, and may not be processed later in a manner incompatible with these purposes (limitation of purposes);

– The user’s personal data will be collected in an appropriate, pertinent and limited manner to the needs of the objective for which they are processed (minimization of the data);

– The user’s personal data will be accurate and updated whenever necessary, so that inaccurate data is erased or rectified when possible (accuracy);

– The user’s personal data will be kept in a way that allows the identification of the data subjects only for the period necessary for the purposes for which they are processed (limitation of conservation);

– The user’s personal data will be treated securely, protected from unauthorized or unlawful treatment and against its accidental loss, destruction or damage, by adopting appropriate technical or organizational measures (integrity and confidentiality).

The user of the website has the following rights, conferred by the Personal Data Protection Law and the GDPR:

– Right of confirmation and access: it is the right of the user to obtain from the website the confirmation that the personal data concerning him or her are the subject of processing and, if so, the right to access his/her personal data;

– Right of rectification: it is the right of the user to obtain from the site, without undue delay, the rectification of inaccurate personal data concerning him;

– Right to delete the data (right to forgetfulness): is the user’s right to have his/her data deleted from the site;

– Right to limitation of the processing of data: it is the right of the user to limit the processing of his personal data, and can obtain it when he disputes the accuracy of the data, when the processing is unlawful, when the site no longer needs the data for the proposed purposes and when it has opposed the processing of the data and in case of unnecessary data processing;

– Right of opposition: it is the right of the user, at any time, to object for reasons related to his/her particular situation, to the processing of personal data concerning him/ her, and may also object to the use of his/her personal data for profiling;

– Right of data portability: it is the user’s right to receive personal data concerning him/her and that he/she has provided to the website, in a structured format, of current use and automatic reading, and the right to transmit this data to another website;

– Right not to be subject to automated decisions: it is the user’s right not to be subject to any decision taken solely on the basis of automated processing, including profiling, which has effects in its legal sphere or significantly affects it in a similar way.

The user may exercise his rights by means of written communication sent to the site with the subject “RGDP-www.venhapranuvem.com.br”, specifying:

– Full name or corporate name, CPF number (Register of Individuals, Federal Revenue of Brazil) or CNPJ (National Registry of Legal Entities, The Federal Revenue of Brazil) and e-mail address of the user and, if applicable, his representative;

– Right you wish to exercise with the site;

– Order date and user signature;

– Any document that can demonstrate or justify the exercise of its right.

The request must be sent to the e-mail: comercial@venhapranuvem.com.br, or by mail, to the following address:

VPN Solutions in IT Ltda

  1. Teófilo Otoni, 82 / 18º andarCentro – Rio de Janeiro – RJCEP 20090-080

The user will be informed in case of rectification or deletion of his/her data.

  1. Duty not to provide third-party data

During the use of the website,in order to safeguard and protect the rights of third parties, the user of the website must provide only his personal data, not those of third parties.

  1. Information collected

The collection of user data will take place in accordance with the provisions of this Privacy Policy and will depend on the user’s consent, which is dispensable only in the cases provided for in art. 11, item II, of the Personal Data Protection Act.


4.1. Types of data collected

4.1.1. User identification data for registration

The use by the user of certain functionalities of the site will depend on registration, and in these cases, the following user data will be collected and stored:

– name

– email address

– postal address

– social media details

– phone number

– Position and company

4.1.2. Data provided on the contact form

Any data that may be provided by the user using the contact form provided on the website, including the content of the message sent, will be collected and stored.

4.1.3. Data related to the execution of contracts signed with the user

For the execution of a contract for the purchase and sale or provision of services that may be signed between the site and the user, other data related to or necessary for its execution may be collected and stored, including the content of any communications had with the user.

4.1.4. Newsletter

The email address registered by the user who chooses to subscribe to our  Newsletter will be collected and stored until the user requests their registration.

4.1.5. Sensitive data

No sensitive data will be collected from users, as defined in the 9th and 10th of the GDPR and in arts. 11 and following of the Personal Data Protection Act. Thus, among others, there will be no  collection of the following data:

– data revealing the racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership of the user;

– genetic data;

– biometric data to identify a person unequivocally;

– data relating to the health of the user;

– data relating to the sexual life or sexual orientation of the user;

– data relating to criminal convictions or offences or related security measures.

4.1.6. Data collection not expressly provided for

Eventually, other types of data not expressly provided in this Privacy Policy may be collected, provided that they are provided with the user’s consent, or that collection is permitted or enforced by law.


4.2. Legal basis for the processing of personal data

By using the services of the website, the user is consenting to this Privacy Policy.

The user has the right to withdraw his consent at any time, not compromising the lawfulness of the processing of his personal data before the withdrawal. The withdrawal of consent may be made by e-mail: comercial@venhapranuvem.com.br, or by mail sent to the following address:

  1. Teófilo Otoni, 82 / 18º andarCentro – Rio de Janeiro – RJCEP 20090-080

The consent of the relatively or absolutely incapacitated, especially of children under the age of sixteen,000, may only be made, respectively, if properly assisted or represented.

Personal data necessary for the execution and fulfillment of the services contracted by the user on the website may also be collected.

The processing of personal data without the user’s consent will only be carried out because of a legitimate interest or for the hypotheses provided for by law, i.e., among others, the following:

– for the fulfillment of a legal or regulatory obligation by the controller;

– for the performance of studies by a research body, guaranteed, whenever possible, the anonymization of personal data;

– where necessary for the performance of a contract or preliminary procedures relating to a contract to which the user is a party, at the request of the data subject;

– for the regular exercise of rights in judicial, administrative or arbitration proceedings, the latter pursuant to Law No. 9,307 of September 23, 1996 (Arbitration Law);

– for the protection of the life or physical safety of the data subject or a third party;

– for the protection of health, in a procedure performed by health professionals or health entities;

– where necessary to take account of the legitimate interests of the controller or a third party, except where the fundamental rights and freedoms of the data subject requiring the protection of personal data prevail;

– for the protection of credit, including the provisions of the relevant legislation.


4.3. Purposes of the processing of personal data

The personal data of the user collected by the site are intended to facilitate, expedite and fulfill the commitments established with the user and to enforce the requests made through the filling out of forms.

Personal data may also be used for a commercial purpose, to personalize the content offered to the user, as well as to give subsidy to the site to improve the quality and operation of its services.

The site collects user data in order to profiling, i.e. automated processing of personal data consisting of using this data to evaluate certain personal aspects of the user, primarily to analyze or predict characteristics related to their professional performance, their economic situation, health, personal preferences, interests, reliability, behavior, location or displacement.

The registration data will be used to allow the user access to certain contents of the site, exclusive to registered users.

The collection of data related or necessary to the execution of a contract for the purchase and sale or provision of services that may be signed with the user will have the purpose of giving the parties legal certainty, in addition to facilitating and enabling the conclusion of the business.

The processing of personal data for purposes not provided for in this Privacy Policy will only occur upon prior communication to the user, and in any case, the rights and obligations provided herein will remain applicable.


4.4. Period of retention of personal data

The user’s personal data will be retained for a period not longer than that required to meet the objectives for which they are processed.

The data retention period is defined according to the following criteria:

The data will be stored for a certain time in law in the period of 1 to 6 months at most.

Users’ personal data may only be retained after the end of their processing in the following cases:

– for the fulfillment of a legal or regulatory obligation by the controller;

– for study by research body, guaranteed, whenever possible, the anonymization of personal data;

– for the transfer to a third party, provided that the data processing requirements laid down in the legislation are respected;

– for the exclusive use of the controller, prohibited its access by a third party, and provided that the data is anonymized.


4.5. Recipients and transfer of personal data

Your personal data will not be shared with third parties. They will therefore be treated only by this site.

  1. The processing of personal data

5.1. The datacontroller)

The controller, responsible for the processing of the user’s personal data, is the natural or legal person, the public authority, the agency or other body that, individually or together with others, determines the purposes and means of processing personal data.

On this site, the person responsible for the processing of the personal data collected is Matheus Amorim, represented by Leonardo Rodrigues and Rodrigo Okubo, who can be contacted by e-mail: leonardo@venhapranuvem.com.br or at:

Rua Teófilo Otoni, 82 / 18º andarCentro – Rio de Janeiro – RJCEP 20090-080

The data controller will be directly responsible for the processing of the user’s personal data.


5.2. DataProtection Officer
  )

Thedata protection officeris the data protection officer is the professional in charge of  informing, advising and controlling the data controller, as well as the data controller, regarding the obligations of the website under the RGDP, the Personal Data Protection Act and other data protection provisions present in national and international law, in cooperation with the competent supervisory authority.

On this site the dataprotection officer  is  Matheus Amorim,who can be contacted by e-mail: matheus.amorim@venhapranuvem.com.br.

  1. Security in the processing of the user’s personal data

The site undertakes to apply technical and organizational measures capable of protecting personal data from unauthorized access and from situations of destruction, loss, alteration, communication or dissemination of such data.

To ensure safety, solutions will be adopted that take into account: the appropriate techniques; implementation costs; the nature, scope, context and purposes of the processing; and the risks to the rights and freedoms of the user.

However, the site disclaims liability for the sole fault of a third party, such as in the event of an attack by hackers or crackers, or the sole fault of the user, as in the case in which he himself transfers his data to a third party. The site also undertakes to communicate the user within an appropriate period in the event of any type of breach of the security of his personal data that may cause him a high risk to his personal rights and freedoms.

The breach of personal data is a security breach that causes, in an accidental or unlawful manner, the destruction, loss, alteration, disclosure or unauthorized access to personal data transmitted, stored or subject to any other type of processing.

Finally, the site undertakes to treat the user’s personal data confidentially, within the legal limits.

  1. Navigation data(cookies))

Cookies are small text files sent by the site to the user’s computer and stored on it, with information related to the navigation of the site.

Through cookies,small amounts of information are stored by the user’s browser so that our server can read them later. Data about the device used by the user, as well as their location and time of access to the site, can be stored, for example.

Cookies  do not allow any file or information to be extracted from the user’s hard drive, and it is not possible, through them, to have access to personal information that has not departed from the user or the way he uses the resources of the site.

It is important to note that not every cookie  contains information that allows the identification of the user, and certain types of  cookies  can be used simply so that the site is loaded correctly or for its functionalities to work as expected.

Information that may be stored in cookies  to identify a user is considered personal data. Accordingly, all the rules set out in this Privacy Policy also apply to them.


7.1. Third-party cookies

Some of our partners may set cookies  on the devices of users who access our website.

These cookies,in general, aim to enable our partners to offer their content and services to the user who accesses our website in a personalized way, by obtaining browsing data extracted from their interaction with the website.

The user can obtain more information about third party cookies  and how the data obtained from it are treated, in addition to having access to the description of the  cookies  used and their characteristics by accessing the following  link::

Microsoft – www.microsoft.com.br

The entities responsible for the collection of cookies  may assign the information obtained to third parties.


7.2. Social media cookies

The site uses social media plugins,  which allow you to access them from the site. Thus, in doing so, the  cookies  used by them may be stored in the user’s browser.

Each social network has its own privacy and personal data protection policy, and individuals or legal entities hold them responsible for the data collected and the privacy practices adopted.

The user can search, with social networks, information about how their personal data is treated. For information, we provide the following links,from which the privacy and cookie policies adopted by some of the main social networkscan be consulted: 

Facebook: https://www.facebook.com/policies/cookies/

Twitter: https://twitter.com/pt/privacy

Instagram: https://help.instagram.com/1896641480634370?ref=ig

Youtube: https://policies.google.com/privacy?hl=pt-BR&gl=pt

Google+: https://policies.google.com/technologies/cookies?hl=pt

Pinterest: https://policy.pinterest.com/pt-br/privacy-policy

LinkedIn: https://www.linkedin.com/legal/cookie-policy?trk=hp-cookies


7.3. Management of cookies and browser settings

The user may object to the registration of cookies  by the website, simply by disabling this option on their own browser or device.

The deactivation of cookies,however, may affect the availability of some tools and functionalities of the website, compromising their correct and expected functioning. Another possible consequence is removing user preferences that have eventually been saved, damaging their experience.

The following are some links to the help and support pages of the most used browsers, which can be accessed by the user interested in more information about the management of cookies  in his browser:

Internet Explorer:https://support.microsoft.com/pt-br/help/17442/windows-internet-explorer-delete-manage-cookies

Safari:https://support.apple.com/pt-br/guide/safari/sfri11471/mac

Google Chrome:https://support.google.com/chrome/answer/95647?hl=pt-BR&hlrm=pt

Mozila Firefox: https://support.mozilla.org/pt-BR/kb/ative-e-desative-os-cookies-que-os-sites-usam

Opera:https://www.opera.com/help/tutorials/security/privacy/

  1. Complaint to a supervisory authority

Without prejudice to any other administrative or judicial remedy, all data subjects have the right to lodge a complaint with a supervisory authority. The complaint may be made to the authority of the site’s headquarters, the user’s country of habitual residence, his place of work or the place where the infringement was allegedly committed.

  1. Of the changes

This version of this Privacy Policy was last updated on: 15/03/2020.

The publisher reserves the right to modify, at any time the site these standards, especially to adapt them to the evolutions of the site Come to the Cloud, either by the availability of newfeatures, or by the suppression or modification of those already existing.

The user will be explicitly notified in case of change of this policy.

By using the service after any modifications, the user demonstrates his/her agreement with the new standards. If you disagree with any of the modifications, you must immediately request the cancellation of your account and submit your reservation to the customer service, if you wish.

  1. Applicable law and the forum

Brazilian law will be fully applied to resolve the disputes arising from this instrument.

Any disputes must be submitted in the forum of the district in which the headquarters of the editor of the site is located.

 

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