Last updated April
01, 2021
Thank
you for choosing to be part of our community at Expressia B2S LTDA
("Company", "we", "us",
"our"). We are committed to protecting your personal
information and your right to privacy. If you have any questions or concerns
about this privacy notice, or our practices with regards to your personal
information, please contact us at [email protected].
When
you visit
our website https://expressia.life
(the "Website"), use
our mobile application, as
the case may be (the "App")
and more generally, use any of our services (the "Services",
which include the Website
and App), we appreciate that you are trusting us with
your personal information. We take your privacy very seriously. In this privacy
notice, we seek to explain to you in the clearest way possible what information
we collect, how we use it and what rights you have in relation to it. We hope
you take some time to read through it carefully, as it is important. If there
are any terms in this privacy notice that you do not agree with, please
discontinue use of our Services immediately.
This
privacy notice applies to all information collected through our Services
(which, as described above, includes our Website
and App), as well as, any
related services, sales, marketing or events.
Please read this
privacy notice carefully as it will help you understand what we do with the
information that we collect.
1. WHAT INFORMATION DO WE COLLECT?
Personal information you
disclose to us
In Short: We collect personal information that you
provide to us.
We
collect personal information that you voluntarily provide to us when you register
on the Services,
express an interest in obtaining information
about us or our products and Services, when you participate in activities on
the Services
(such as by posting messages in our online forums or entering competitions, contests or giveaways) or otherwise when you contact us.
The
personal information that we collect depends on the context of your
interactions with us and the Services,
the choices you make and the products and features you use. The personal
information we collect may include the following:
Personal
Information Provided by You. We collect names; phone
numbers; email
addresses; contact
preferences; usernames; passwords; billing
addresses; debit/credit
card numbers; and
other similar information.
Social Media Login
Data. We may provide you with the option to register with us
using your existing social media account details, like your Facebook, Twitter or other social media account. If you choose to
register in this way, we will collect the information described in the section
called "HOW DO WE HANDLE YOUR SOCIAL LOGINS"
below.
All
personal information that you provide to us must be true, complete
and accurate, and you must notify us of any changes to such personal
information.
Information
automatically collected
In Short: Some information — such as your Internet
Protocol (IP) address and/or browser and device characteristics — is collected
automatically when you visit our Services.
We
automatically collect certain information when you visit, use
or navigate the Services.
This information does not reveal your specific identity (like your name or
contact information) but may include device and usage information, such as your
IP address, browser and device characteristics, operating system, language
preferences, referring URLs, device name, country, location, information about
how and when you use our Services
and other technical information. This information is primarily needed to
maintain the security and operation of our Services,
and for our internal analytics and reporting purposes.
Like
many businesses, we also collect information through cookies and similar
technologies.
The
information we collect includes:
- Log
and Usage Data. Log and usage data is
service-related, diagnostic, usage and
performance information our servers automatically collect when you access
or use our Services
and which we record in log files. Depending on how you interact with us,
this log data may include your IP address, device information, browser
type and settings and information about your activity in the Services (such
as the date/time stamps associated with your usage, pages and files
viewed, searches and other actions you take such as which features you
use), device event information (such as system activity, error reports
(sometimes called 'crash dumps') and hardware settings).
- Device
Data. We collect device data such as
information about your computer, phone, tablet or
other device you use to access the Services.
Depending on the device used, this device data may include information
such as your IP address (or proxy server), device and application
identification numbers, location, browser type, hardware model Internet
service provider and/or mobile carrier, operating system
and system configuration information.
- Location
Data. We collect location data such as
information about your device's location, which can be either precise or
imprecise. How much information we collect depends on the type and settings
of the device you use to access the Services.
For example, we may use GPS and other technologies to collect geolocation
data that tells us your current location (based on your IP address). You
can opt out of allowing us to collect this information either by refusing
access to the information or by disabling your Location setting on your
device. Note however, if you choose to opt out, you may not be able to use
certain aspects of the Services.
Information collected through our App
In Short: We collect information regarding your geo-location,
mobile device,
push notifications,
when you use our App.
If you use our App, we also collect the following
information:
- Geo-Location
Information. We may request access or
permission to and track location-based information from your mobile
device, either continuously or while you are using our App, to provide
certain location-based services. If you wish to change our access or
permissions, you may do so in your device's settings.
- Mobile
Device Access. We may request access or
permission to certain features from your mobile device, including your
mobile device's microphone,
storage, social
media accounts, and
other features. If you wish to change our access or permissions, you may
do so in your device's settings.
- Mobile
Device Data. We automatically collect device
information (such as your mobile device ID, model
and manufacturer), operating system, version information and system
configuration information, device and application identification numbers,
browser type and version, hardware model Internet service provider and/or
mobile carrier, and Internet Protocol (IP) address (or proxy server). If
you are using our App, we may also collect information about the phone
network associated with your mobile device, your mobile device’s operating
system or platform, the type of mobile device you use, your mobile
device’s unique device ID and information about the features of our App
you accessed.
- Push
Notifications. We may request to send you push
notifications regarding your account or certain features of the App. If
you wish to opt-out from receiving these types of communications, you may
turn them off in your device's settings.
This
information is primarily needed to maintain the security and operation of our
App, for troubleshooting and for our internal analytics and reporting purposes.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes
based on legitimate business interests, the fulfillment of our contract with
you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Services
for a variety of business purposes described below. We process your personal
information for these purposes in reliance on our legitimate business
interests, in order to enter into or perform a
contract with you, with your consent, and/or for compliance with our legal obligations.
We indicate the specific processing grounds we rely on next to each purpose
listed below.
We use the information we collect or receive:
- To
facilitate account creation and logon process. If you choose to link your account with us to a third-party
account (such as your Google or Facebook account), we use the information
you allowed us to collect from those third parties to facilitate account
creation and logon process for the performance of the contract. See
the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS" for further information.
- To post testimonials. We post testimonials on our Services
that may contain personal information. Prior to posting a testimonial, we
will obtain your consent to use your name and the content of the
testimonial. If you wish to update, or delete your testimonial, please
contact us at [email protected]
and be sure to include your name, testimonial location, and contact
information.
- Request feedback. We may use your information to request feedback and to contact you
about your use of our Services.
- To enable user-to-user communications. We may use your information in order to
enable user-to-user communications with each user's consent.
- To manage user accounts. We may use your information for the purposes of managing our
account and keeping it in working order.
- To
send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information
about changes to our terms, conditions, and policies.
- To
protect our Services. We may use your
information as part of our efforts to keep our Services
safe and secure (for example, for fraud monitoring and prevention).
- To
enforce our terms, conditions and policies for
business purposes, to comply with legal and regulatory requirements or in
connection with our contract.
- To
respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to
inspect the data we hold to determine how to respond.
- Fulfill
and manage your orders. We may use your
information to fulfill and manage your orders, payments, returns, and
exchanges made through the Services.
- Administer
prize draws and competitions. We may use your
information to administer prize draws and competitions when you elect to
participate in our competitions.
- To
deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested
service.
- To
respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve
any potential issues you might have with the use of our Services.
- To
send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal
information you send to us for our marketing purposes,
if this is in accordance with your marketing preferences. For
example, when expressing an interest in obtaining information about us or
our Services,
subscribing to marketing or otherwise contacting us, we will collect
personal information from you. You can opt-out of our marketing emails at
any time (see the "WHAT ARE YOUR
PRIVACY RIGHTS" below).
- Deliver
targeted advertising to you. We may use your information to develop
and display personalized content and advertising (and work with third
parties who do so) tailored to your interests and/or location and to
measure its effectiveness.
3. WILL YOUR INFORMATION BE SHARED WITH
ANYONE?
In
Short: We only share
information with your consent, to comply with laws, to provide you with
services, to protect your rights, or to fulfill business obligations.
We may process or share your data that we hold
based on the following legal basis:
- Consent: We may process your data if you have given us specific consent to
use your personal information for a specific purpose.
- Legitimate Interests: We may process your data when it is reasonably necessary to
achieve our legitimate business interests.
- Performance of a Contract: Where we have entered into a contract
with you, we may process your personal information to fulfill the terms of
our contract.
- Legal Obligations: We may disclose your information where we are legally required to
do so in order to comply with applicable law,
governmental requests, a judicial proceeding, court order, or legal
process, such as in response to a court order or a subpoena (including in
response to public authorities to meet national security or law
enforcement requirements).
- Vital Interests: We may disclose your information where we believe it is necessary
to investigate, prevent, or take action regarding
potential violations of our policies, suspected fraud, situations
involving potential threats to the safety of any person and illegal
activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your
data or share your personal information in the following situations:
- Business
Transfers. We may share or transfer your
information in connection with, or during negotiations of, any merger,
sale of company assets, financing, or acquisition of all or a portion of
our business to another company.
- Vendors, Consultants and Other Third-Party
Service Providers. We may share your data with
third-party vendors, service providers, contractors or agents who perform
services for us or on our behalf and require access to such information to
do that work. Examples include: payment
processing, data analysis, email delivery, hosting services, customer
service and marketing efforts. We may allow selected third parties to use
tracking technology on the Services,
which will enable them to collect data on our behalf about how you
interact with our Services
over time. This information may be used to, among other things, analyze
and track data, determine the popularity of certain content, pages or features, and better understand online
activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third
parties for their promotional purposes. We
have contracts in place with our data processors, which are designed to
help safeguard your personal information. This means that they cannot do
anything with your personal information unless we have instructed them to
do it. They will also not share your personal information with any
organization apart from us. They also commit to protect the data they hold
on our behalf and to retain it for the period we instruct.
- Affiliates. We may share
your information with our affiliates, in which case we will require those
affiliates to honor this privacy notice. Affiliates include our parent
company and any subsidiaries, joint venture partners or other companies
that we control or that are under common control with us.
- Other Users. When you share personal information (for
example, by posting comments, contributions or
other content to the Services)
or
otherwise interact with public areas of the Services,
such personal information may be viewed by all users and may be publicly
made available outside the Services
in perpetuity. If
you interact with other users of our Services
and register for our Services
through a social network (such as Facebook), your contacts on the social
network will see your name, profile photo, and descriptions of your
activity. Similarly,
other users will be able to view descriptions of your activity,
communicate with you within our Services,
and view your profile.
- Offer Wall. Our App may
display a third-party hosted "offer wall." Such an offer wall
allows third-party advertisers to offer virtual currency, gifts, or other
items to users in return for the acceptance and completion of an
advertisement offer. Such an offer wall may appear in our App and be
displayed to you based on certain data, such as your geographic area or
demographic information. When you click on an offer wall, you will be
brought to an external website belonging to other persons and will leave
our App. A unique identifier, such as your user ID, will be shared with
the offer wall provider in order to prevent fraud
and properly credit your account with the relevant reward. Please note
that we do not control third-party websites and have no responsibility in
relation to the content of such websites. The inclusion of a link towards
a third-party website does not imply an endorsement by us of such website.
Accordingly, we do not make any warranty regarding such third-party
websites and we will not be liable for any loss or damage caused by the use of such websites. In addition, when you
access any third-party website, please understand that your rights while
accessing and using those websites will be governed by the privacy notice
and terms of service relating to the use of those websites.
4. WHO WILL YOUR INFORMATION BE SHARED
WITH?
In
Short: We only share
information with the following third parties.
We only share and disclose your information with
the following third parties. We have categorized each party so that you may be
easily understand the purpose of our data collection and processing practices.
If we have processed your data based on your consent and you wish to revoke
your consent, please contact us using the contact details provided in the
section below titled "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?".
- Advertising,
Direct Marketing, and Lead Generation
Google
AdSense and Facebook
Audience Network
Amazon
Web Services (AWS) and Google
Cloud Platform
Apple
Pay, Google
Pay and Stripe
- User Account Registration and Authentication
Google
OAuth 2.0 and Facebook Login
Google
Analytics and Facebook Analytics
5. DO WE USE COOKIES AND OTHER TRACKING
TECHNOLOGIES?
In
Short: We
may use cookies and other tracking technologies to collect and store your
information.
We may use cookies and similar tracking
technologies (like web beacons and pixels) to access or store information.
Specific information about how we use such technologies and how you can refuse
certain cookies is set out in our Cookie Notice.
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In
Short: If
you choose to register or log in to our services using a social media account,
we may have access to certain information about you.
Our Services
offers you the ability to register and login using your third-party social
media account details (like your Facebook or Twitter logins). Where you choose
to do this, we will receive certain profile information about you from your
social media provider. The profile information we receive may vary depending on
the social media provider concerned, but will often include your name, email
address, friends list, profile picture as well as other information you choose
to make public on such social media platform.
We will use the information we receive only for
the purposes that are described in this privacy notice or that are otherwise
made clear to you on the relevant Services.
Please note that we do not control, and are not responsible for, other uses of
your personal information by your third-party social media provider. We
recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set
your privacy preferences on their sites and apps.
7. IS YOUR INFORMATION TRANSFERRED
INTERNATIONALLY?
In
Short: We
may transfer, store, and process your information in countries other than your
own.
Our servers are located in
United States,
Brazil,
and United Kingdom.
If you are accessing our Services
from outside
United States,
Brazil,
and United Kingdom,
please be aware that your information may be transferred to, stored, and
processed by us in our facilities and by those third parties with whom we may
share your personal information (see "WILL YOUR INFORMATION BE SHARED
WITH ANYONE?" above), in and
other countries.
If you are a resident in the European Economic
Area, then these countries may not necessarily have data protection laws or
other similar laws as comprehensive as those in your country. We will however
take all necessary measures to protect your personal information in accordance
with this privacy notice and applicable law.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In
Short: We
keep your information for as long as necessary to fulfill the purposes outlined
in this privacy notice unless otherwise required by law.
We will only keep your personal information for
as long as it is necessary for the purposes set out in this privacy notice,
unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this
notice will require us keeping your personal information for longer than three
(3) months past the termination of the user's account.
When we have no ongoing legitimate business need
to process your personal information, we will either delete or anonymize such
information, or, if this is not possible (for example, because your personal
information has been stored in backup archives), then we will securely store
your personal information and isolate it from any further processing until
deletion is possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In
Short: We
aim to protect your personal information through a system of organizational and
technical security measures.
We have implemented appropriate technical and
organizational security measures designed to protect the security of any
personal information we process. However, despite our safeguards and efforts to
secure your information, no electronic transmission over the Internet or
information storage technology can be guaranteed to be 100% secure, so we
cannot promise or guarantee that hackers, cybercriminals, or other unauthorized
third parties will not be able to defeat our security, and improperly collect,
access, steal, or modify your information. Although we will do our best to
protect your personal information, transmission of personal information to and
from our Services
is at your own risk. You should only access the Services
within a secure environment.
10. DO WE COLLECT INFORMATION FROM MINORS?
In
Short: We do not
knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market
to children under 18 years of age. By using the Services,
you represent that you are at least 18 or that you are the parent or guardian
of such a minor and consent to such minor dependent’s use of the Services.
If we learn that personal information from users less than 18 years of age has
been collected, we will deactivate the account and take reasonable measures to
promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18,
please contact us at [email protected].
11. WHAT ARE YOUR PRIVACY RIGHTS?
In
Short: In some
regions, such as the European Economic Area, you have rights that allow you
greater access to and control over your personal information. You
may review, change, or terminate your account at any time.
In some regions (like the European Economic
Area), you have certain rights under applicable data protection laws. These may
include the right (i) to request access and obtain a
copy of your personal information, (ii) to request rectification or erasure;
(iii) to restrict the processing of your personal information; and (iv) if
applicable, to data portability. In certain circumstances, you may also have
the right to object to the processing of your personal information. To make
such a request, please use the contact details provided below. We
will consider and act upon any request in accordance with applicable data
protection laws.
If we are relying on your consent to process your
personal information, you have the right to withdraw your consent at any time.
Please note however that this will not affect the lawfulness of the processing
before its withdrawal, nor will it affect the processing of your personal
information conducted in reliance on lawful processing grounds other than
consent.
If
you have questions or comments about your privacy rights, you may email us at [email protected].
If you would
at any time like to review or change the information in your account or
terminate your account, you can:
- Log
in to your account settings and update your user account.
Upon your request to terminate your account, we
will deactivate or delete your account and information from our active
databases. However, we may retain some information in our files to prevent
fraud, troubleshoot problems, assist with any investigations, enforce our Terms
of Use and/or comply with applicable legal requirements.
Cookies
and similar technologies: Most Web browsers are set to accept
cookies by default. If you prefer, you can usually choose to set your browser
to remove cookies and to reject cookies. If you choose to remove cookies or
reject cookies, this could affect certain features or services of our Services.
To opt-out of interest-based advertising by advertisers on our Services
visit http://www.aboutads.info/choices/.
Opting
out of email marketing: You can unsubscribe from our marketing
email list at any time by clicking on the unsubscribe link in the emails that
we send or by contacting us using the details provided below. You will then be
removed from the marketing email list — however, we may still communicate with
you, for example to send you service-related emails that are necessary for the
administration and use of your account, to respond to service requests, or for
other non-marketing purposes. To otherwise
opt-out, you may:
- Access your account settings and update your
preferences.
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating
systems and mobile applications include a Do-Not-Track ("DNT")
feature or setting you can activate to signal your privacy preference not to
have data about your online browsing activities monitored and collected. At
this stage no uniform technology standard for recognizing and implementing DNT signals
has been finalized. As such, we do not currently respond to DNT browser signals
or any other mechanism that automatically communicates your choice not to be
tracked online. If a standard for online tracking is adopted that we must
follow in the future, we will inform you about that practice in a revised
version of this privacy notice.
13. DO WE MAKE UPDATES TO THIS NOTICE?
In
Short:
Yes, we will update this notice as necessary to stay compliant with relevant
laws.
We may update this privacy notice from time to
time. The updated version will be indicated by an updated "Revised"
date and the updated version will be effective as soon as it is accessible. If
we make material changes to this privacy notice, we may notify you either by
prominently posting a notice of such changes or by directly sending you a
notification. We encourage you to review this privacy notice frequently to be
informed of how we are protecting your information.
If you have questions or comments about this
notice, you may contact
our Data Protection Officer (DPO), Henrique Latorre, by email at [email protected], by phone at +55 31
3495 1497, or by post to:
Rua
Bento Mendes Castanheira, 31
Belo
Horizonte
,
MG
31260-270
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE
THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you
may have the right to request access to the personal information we collect
from you, change that information, or delete it in some circumstances. To
request to review, update, or delete your personal information, please visit: https://expressia.life/privacyrequest. We will respond to your request within 30 days.
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?