Privacy
Policy

1. GOAL

As privacy is everyone’s duty, WITTEL COMUNICAÇÕES undertakes to respect your privacy and the holder’s personal data.

This privacy statement applies to everyone, employees, suppliers, partners and customers and is intended to provide the guidelines defined and applied in the treatment of your personal information.

This Privacy Policy is broad in scope and covers all collection and/or processing of personal information, such as collection through various channels such as websites, applications, social networks, sales and events, or processing of data provided by partners, customers and suppliers for the provision of services.

The Policy was developed based on the ethics and principles established in the General Law for the Protection of Personal Data (LGPD) – Law no. 13.709/2018 and in the Marco Civil da Internet [Internet Bill of Rights] Law no. 12.965/2014.

Learn more about data protection and privacy with the LGPD Glossary:

• ANPD – National Data Protection Authority, a federal government entity responsible for overseeing data processing, receiving complaints from data subjects and applying penalties, such as fines and others.
• Legal Basis for Processing – The processing of personal data is allowed by the LGPD in accordance with the legal bases provided, such as compliance with legal and/or regulatory obligations by WITTEL COMUNICAÇÕES, compliance with established contracts, as well as legitimate interests or through consent of the holder.
• Biometrics – A measurable physical characteristic or a personal behavioral trait used to recognize or verify a person’s identity. Facial images, fingerprints and iris samples are examples of biometrics.
• Consent – It is the free, informed and unambiguous expression by which the holder agrees with the treatment of his personal data for a specific purpose.
• Cookies – Small files downloaded to your computer to improve your experience. WITTEL COMUNICAÇÕES websites may contain cookies, and in this case, the user will be asked to consent before downloading.
• Personal Data – Any data related to the identified or identifiable natural person, such as: IP, geolocation, name, RG [ID card], CPF [Individual Taxpayer’s Registry], address, telephone, bank account, vehicle data.
• Sensitive Personal Data – personal data on racial or ethnic origin, religious conviction, political opinion, affiliation to a 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.
• Right of the Holder – Right guaranteed to the holder to access, correct and delete their personal data.
• Purpose – Statement of the purpose or motivation for the collection and processing of each personal data.
• Legitimate Interest – When the collection of a group of personal data is carried out to comply with legislation, to provide services, and to carry out your business.
• Free Access – Right of the holder to access all information relating to the collection and processing of their personal data.
• Opposition – It is the right of the holder not to want their data to be collected or processed. This right can be exercised in certain specific situations, especially if they do not harm the legitimate interest.
• Retention period – Term defined by WITTEL COMUNICAÇÕES for the period of storage of personal data and subsequent deletion.
• Security – Defines the use of actions to protect personal data from unauthorized access and from accidental and/or illegal situations related to destruction, loss, alteration, unauthorized communication or dissemination.
• Holder – natural person to whom the personal data that are the object of processing refer.
• Treatment – It is any operation performed with personal data, such as: collection, processing, use, access, distribution, storage and disposal.

2. COLLECTION OF PERSONAL DATA:

Depending on the type of holder (employees, suppliers, partners and customers) and how this holder interacts with WITTEL COMUNICAÇÕES, several categories of information are collected:

• Personal Contact Information: Any information provided with intent to contact, such as name, postal address, email address, business address, social networking details and telephone number.
• Account Login Data: any information that is necessary to give access to a specific account profile to access our services. Examples: e-mail address, username, password in irretrievable format and/or security question and answer, among others, to access the platform’s services.
• Computer/Mobile Device Technical Data: any information about the computer system or other device used to access one of our pages, services or applications, IP address used to connect your computer or device to the internet, the type of operating system and the web browser type and version, among other browsing information.
• Financial and Payment Data: to fulfill an order/contract/billing. WITTEL COMUNICAÇÕES guarantees that its payment processing service ensures that financial and payment information complies with applicable laws, regulations and security standards.
• Sensitive Personal Data: whenever necessary to collect and process sensitive personal data for any reason, prior and express consent will be requested (for example, prevention to Covid-19, biometrics for access to facilities or point, etc.). If it is necessary to process sensitive personal data for other purposes, these have a legal basis and WITTEL COMUNICAÇÕES will provide prior knowledge to the holder.
• Children’s Personal Data: whenever necessary to collect and process personal data from children and minors, explicit consent will be requested from the parents or guardians (example: health insurance and other benefits and/or obligations).

3. PURPOSE OF USE OF PERSONAL DATA

The table describes the purposes of personal data, and the different types of Personal Data we collect for each purpose.

 4. USE OF COOKIES COOKIES / SIMILAR TECHNOLOGIES, LOG FILES AND WEB BEACONS

Cookies (Browsing Trackers)

• How and why do we use Cookies? We use Cookies to improve the use and functionality of the pages and services and to improve the browsing experience, as well as the tools and services offered there. Cookies help us adapt WITTEL COMUNICAÇÕES’ pages and services to the client.

5. PROCESSING OF PERSONAL DATA

WITTEL COMUNICAÇÕES may process the personal data collected for the following purposes, among others:

• Execution of environmental and social responsibility projects and activities;
• Conducting fraud prevention processes;
• Execution of relationship and customer service activities;
• Sale of products and/or services;
• Granting of benefits;
• Recruitment and admission and training processes, to fulfill our labor obligations with professionals/collaborators;
• Execution of contractual activities with customers and service providers, including financial obligations, related to purchased products and/or services;
• Compliance with legal and regulatory obligations;
• Meet the requests of customers, former customers, prospects;
• Improve the products and services offered;
• Comply with the determinations of competent authorities;
• Juridical processes;
• Notification of the status (status) and any changes to our products and services;
• Perform internal operations (financial, accounting, labor, among others), problem solving, data analysis, data integration and consolidation;
• Manage risks and detect, prevent and/or remedy fraud or other potentially illegal or prohibited activities, and violations of applicable policies, contracts or terms of use;
• Comply with legal or regulatory obligations, or as required in a court proceeding, by any government or law enforcement agency.
• The end of the processing of personal data will occur:
• When the purpose for which the personal data was collected has been achieved or the collected personal data is no longer needed.
• When the Owner requests the deletion of their data.
• When there is a legal determination.
• The storage of data and information will be:
• For the time required by law and/or compliance with legal or regulatory obligations.
• Until the end of the processing of personal data.
• Governed by the Information Security Policy.
• The deletion of data and information, when applicable, will be done in accordance with the LGPD and in order to eliminate all existing evidence and copies, respecting technical procedures for data deletion.

6. DATA SHARING

The sharing of data and information can take place to:

• Service providers, to operate and perform the contracted services.
• Banking units, exclusively for contractual transactions or
• Regulatory bodies, judicial or administrative authorities, upon request.

7. COVID-19 – ITEM APPLICABLE TO EMPLOYEES AND VISITORS

Due to Covid-19’s contagion prevention and control measures, WITTEL COMUNICAÇÕES and/or condominium may also collect personal information from its employees, service providers and visitors such as:

• Covid-19 health status and history;
• Workplace information;
• Body temperature.

This data collection is intended to help reduce the risk of Covid-19 contagion on WITTEL COMUNICAÇÕES and condominium premises. If the temperature is equal to or greater than 37.7 degrees Celsius, entry will be denied.

We do not store thermal measurement data and we follow the health protocols of public authorities for the entry of people into WITTEL COMUNICAÇÕES.

8. HOLDER’S RIGHTS

The holder has the following rights, provided for in the LGPD:

• Confirmation of the existence of personal data processing.
• Confirmation of which personal data of the holders are in WITTEL COMUNICAÇÕES.
• Request for correction of incomplete, inaccurate or outdated data;
• Deletion of data, when these are processed based on the Owner’s consent or when the data are unnecessary, excessive or processed in disagreement with the applicable legislation.
• Request for information about possible shared use of data.

For security reasons, to meet the holder’s request, we will request confirmation of the holder’s identity and authenticity.

To send requests for personal data, please contact [email protected].

9. RIGHTS AND OBLIGATIONS

WITTEL COMUNICAÇÕES is committed to transparency, assures users of its services information about the data processing it performs, providing them with the correction and updating of personal data that is incorrect, inaccurate or out of date.

We also ensure, in accordance with the LGPD, the anonymization, blocking or deletion of personal data that proves to be unnecessary or that are being treated in breach of the law.

The user must also act in a collaborative and transparent manner, committing to provide, whenever requested, exact and correct information, assuming the obligation to keep ALL their data up to date.

10. PRIVACY POLICY CHANGES

Whenever WITTEL COMUNICAÇÕES changes ways and objectives in the collection and processing of personal data, this statement will be updated.
The company reserves the right to make changes to the practices and this Privacy Statement at any time.

Published on 08/17/2021