Privacy Policy
Welcome to the Digital Transformation Institute website. Your privacy is extremely important to us.
This Privacy Policy describes how we collect, use, store and protect your personal information when you visit our website and use our services.
We are committed to ensuring the security and confidentiality of the personal data you provide to us. All information collected is used in accordance with applicable laws and regulations, including the General Data Protection Law (LGPD) in force in Brazil.
By accessing and using our website, you agree to the terms of this Privacy Policy.
We encourage you to read this document carefully to understand our privacy practices and how they affect you.
SUMMARY
1. OBJECTIVE, what is the purpose of this document?
2. WHAT INFORMATION DO WE COLLECT?
3. WHY DO WE COLLECT INFORMATION?
4. SENSITIVE DATA
5. NON-SENSITIVE PERSONAL DATA
6. SHARING PERSONAL DATA WITH THIRD PARTIES
7. HOW LONG WILL YOUR PERSONAL DATA BE STORED?
8. LEGAL BASIS FOR PROCESSING PERSONAL DATA
9.1 CONSENT
9.2 COMPLIANCE WITH LEGAL OR REGULATORY OBLIGATIONS BY THE CONTROLLER
9.3 LEGITIMATE INTEREST OF THE HOLDER
9. DATA SUBJECT RIGHTS
10. HOW THE HOLDER CAN EXERCISE HIS RIGHTS
11. SECURITY MEASURES FOR PROCESSING PERSONAL DATA
12. COOKIES
13. COOKIES DEFINED
14. THIRD PARTY COOKIES
15. COOKIE MANAGEMENT
16. CHANGES TO THIS POLICY
17. HOW TO CONTACT US
1. OBJECTIVE, what is the purpose of this document?
This policy aims to communicate to the general public that INSTITUTO DA TRANSFORMACAO DIGITAL - ITD acts in accordance with the General Data Protection Law (LGPD), Law 13,709 of August 14, 2018, and makes this document available in order to resolve any doubts that may arise on this topic.
THE DIGITAL TRANSFORMATION INSTITUTE - ITD , herein referred to as CONTROLLER, is a private association, legal entity, constituted and organized in accordance with the autonomy established in its Articles of Association and by complementary Rules and Regulations.
It is headquartered at Av. Padre Cacique, 320 block A – Porto Alegre – RS, CEP 90810-240, registered with the CNPJ under
number 30.107.695/0001-76.
The Digital Transformation Institute - ITD is the owner of the domain and respective website:
https://www.institutodatransformacao.com.br
In order to comply with the purpose of our Statute, we need to identify you at various stages of the process and, under the law, this is called Data Processing, which occurs whenever there is an exchange of personal data information through actions such as: Collection, Processing, Storage, Sharing and Disposal of data. This Privacy Policy indicates which information is processed by our digital means (application, website, social networks). The digital means are maintained and operated by ITD.
2. WHAT INFORMATION DO WE COLLECT?
We can only respond to your requests if we can identify you or have sufficient data to make contact, with the primary purpose of continuing an interaction initiated by you.
In this way we can collect the following data:
2.1 Data Subject:
Name;
Company;
Email address;
Telephone number/WhatsApp;
2.2 There is also information that can be collected automatically when you access our website https://www.institutodatransformacao.com.br
This information includes:
Date and time of access;
Browsing history;
Website content marked as favorites or even shared;
This information is intended to improve your experience while accessing the ITD website.
3. POR QUE COLETAMOS INFORMAÇÕES?
Os dados poderão ser utilizados pelo ITD para envio de mensagens (novas funcionalidades, conteúdos, novidades, notícias e principalmente responder a uma informação solicitada.
Quando estiver enviando nossos conteúdos, serão fornecidas informações sobre as possibilidade desde suspensão de envio de novas comunicações.
4. SENSITIVE DATA
Sensitive data from users will not be collected through digital means, as defined in articles 11 et seq. of the Personal Data Protection Law.
Therefore, there will be no collection of data on racial or ethnic origin, religious beliefs, political opinions, membership of a trade union or organization of a religious, philosophical or political nature, data relating to health or sexual life, genetic or biometric data, when linked to a natural person.
5. DADOS PESSOAIS NÃO SENSÍVEIS
Nós também tratamos os dados pessoais não sensíveis das pessoas usuárias de nossos meios digitais nas seguintes hipóteses:
mediante o consentimento do titular dos dados pessoais;
para o atendimento do legitimo interesse do titular dos dados pessoais;
6. SHARING PERSONAL DATA WITH THIRD PARTIES
We do NOT sell, license or share information that can identify you personally.
But exceptions may occur, such as in the following cases:
1. At your request or with your Consent and for an explicit Purpose;
2. With partners or service providers who process such information on ITD’s behalf, for any purposes set out in this Privacy Policy, and such partners and service providers will not have an independent right to use your information except in a manner that is relevant to a specific service requested;
7. HOW LONG WILL YOUR PERSONAL DATA BE STORED?
Personal data collected by our digital media, applications, pages and networks are stored and used for the period necessary to achieve the purposes listed in this document and which considers the rights of their owners, the rights of the controller of the digital media and the applicable legal or regulatory provisions.
8. LEGAL BASIS FOR PROCESSING PERSONAL DATA
A legal basis for the processing of personal data is nothing more than a legal basis, provided for by law, that justifies it. Therefore, each personal data processing operation must have a corresponding legal basis.
According to art. 7 of the General Personal Data Protection Law, the processing of personal data may only be carried out in the following cases:
upon provision of consent by the holder;
for compliance with a legal or regulatory obligation by the controller;
by the public administration, for the processing and shared use of data necessary for the execution of public policies provided for in laws and regulations or supported by contracts, agreements or similar instruments, in compliance with the provisions of Chapter IV of this Law;
for carrying out studies by a research body, ensuring, whenever possible, the anonymization of personal data;
when necessary for the execution of a contract or preliminary procedures related to a contract to which the data subject is a party, at the request of the data subject;
for the regular exercise of rights in judicial, administrative or arbitration proceedings, the latter under the terms of Law No. 9,307, of September 23, 1996 (Arbitration Law);
to protect the life or physical safety of the holder or third parties;
for the protection of health, exclusively, in a procedure carried out by health professionals, health services or health authorities;
when necessary to meet the legitimate interests of the controller or third parties, except where fundamental rights and freedoms of the data subject prevail which require the protection of personal data; or
for credit protection, including as provided for in the relevant legislation.
8.1 CONSENT
Certain personal data processing operations carried out on our digital media will depend on the user's prior consent, which must be expressed freely, in an informed and unequivocal manner.
The user may revoke their consent at any time, and if there is no legal hypothesis that allows or requires the storage of data, the data provided with consent will be deleted.
Furthermore, if desired, the user may not agree to any personal data processing operation based on consent. In these cases, however, it is possible that they will not be able to use some functionality of our digital channels. The consequences of the lack of consent for a specific activity will always be informed prior to the processing.
8.2 COMPLIANCE WITH LEGAL OR REGULATORY OBLIGATIONS BY THE CONTROLLER
Some personal data processing operations, especially data storage, will be carried out so that we can comply with obligations provided for by law or other regulatory provisions applicable to our activities, as well as based on what is already contained in this privacy term.
8.3 LEGITIMO INTERESSE DO TITULAR
Sempre que você preencher nossos formulários, com o objetivo de receber mais informações a respeito dos produtos ou serviços que oferecemos, essa base legal será utilizada para que possamos dar continuidade a sua solicitação.
9. DATA SUBJECT RIGHTS
You, as a user of our digital media, have the following rights, granted by the Personal Data Protection Law:
confirmation of the existence of treatment;
access to data;
correction of incomplete, inaccurate or outdated data;
anonymization, blocking or deletion of unnecessary, excessive data or data processed in non-compliance with the provisions of the law;
portability of data to another service or product provider, upon express request, in accordance with the regulations of the national authority, observing commercial and industrial secrets, as well as, in our case, issues of a religious nature;
deletion of personal data processed with the consent of the holder, except in cases provided for by law;
information on public and private entities with which the controller shared data;
information about the possibility of not providing consent and the consequences of refusal;
revocation of consent.
It is important to highlight that, under the LGPD, there is no right to delete data processed based on legal grounds other than consent, unless the data is unnecessary, excessive or processed in a manner that does not comply with the law.
10. HOW THE HOLDER CAN EXERCISE HIS RIGHTS
To ensure that you can exercise your rights, we provide Service Channels set out in this Policy,
11. SECURITY MEASURES FOR PROCESSING PERSONAL DATA
We employ technical and organizational measures capable of protecting personal data from unauthorized access and from situations of destruction, loss, misplacement or alteration of such data. The measures we use take into account the nature of the data, the context and purpose of the processing, the risks that a possible violation would generate for the rights and freedoms of the user and the standards currently used in the market by institutions similar to ours.
Among the security measures adopted by us, we highlight the following:
Storage of encrypted passwords;
HTTPs certificate;
Access protection;
Even if we take everything within our reach to avoid security incidents, it is possible that a problem may occur caused exclusively by a third party – such as in the case of hacker or cracker attacks or, even, in cases of exclusive fault of the user, which occurs, for example, when the user transfers his/her data to a third party.
Therefore, although we are, in general, responsible for the personal data we process, we are exempt from liability if an exceptional situation such as this occurs, over which we have no control whatsoever.
In any case, if any type of security incident occurs that may generate significant risk or damage to any of our users, we will notify those affected and the National Data Protection Authority (ANPD) about the incident, in accordance with the provisions of the General Data Protection Law.
12. COOKIES
In addition to the items discussed above, we also have Cookies, which are internet files that temporarily store some user browsing data. In our digital media, we collect Cookies, which are small text files automatically downloaded to your device when you access and browse a website or application. They are basically used to identify devices, activities, trends, time spent and reading, as well as user preferences, among others.
Cookies do not allow any files or information to be extracted from the user's hard drive or device, nor do they allow access to personal information that does not originate from the user or the way in which the website's resources are used.
We do not recommend that you disable Essential Cookies as doing so will disable some functionality and features that are essential for the website to function properly. It is recommended that you leave on all cookies if you are not sure whether you need them or not. By disabling cookies that are necessary for the website to function properly, you should be aware that some services may not be provided effectively.
13. COOKIES DEFINED
- Form-related cookies
When you submit data to through a form such as those found on contact pages or forms on this site, cookies may be set to remember your details for future correspondence.
14. THIRD PARTY COOKIES
Some of our partners or services used may set Cookies on the devices of users who access our digital media. These cookies, in general, aim to enable our partners to offer their content and services to users who access our digital media in a personalized manner, by obtaining browsing data extracted from their interaction with the channels.
Third party analytics are used to track and measure usage of our digital media so that we can continue to produce engaging content. These cookies may track things such as how long you spend on the site or app and the pages you visit, which helps us understand how we can improve our digital media for you.
From time to time, we test new features and make subtle changes to the way that our digital media is delivered. When we are still testing new features, these cookies may be used to ensure that you receive a consistent experience whilst browsing our website and to help us understand which optimizations our digital media users appreciate the most.
The user may obtain more information about third-party cookies and how the data obtained from them is processed, in addition to having access to the description of the cookies used and their characteristics, by accessing the websites of the tools: Google Analytics. The organizations responsible for collecting cookies may transfer the information obtained to third parties.
15. COOKIE MANAGEMENT
The user may oppose the registration of cookies by the website, simply by not accepting them in the Navigation Preferences.
However, disabling cookies may affect the availability of some tools and features of our digital channels, compromising their correct and expected operation. Another possible consequence is the removal of any saved user preferences, which may negatively affect the user's experience.
It is important to highlight that the simple fact that you access our digital media and content can be legally understood as consent for the extraction of data, as long as they are not sensitive and/or legally protected, or even so that they are processed and not disclosed by the institution that collects them, thus avoiding a phenomenon called consent fatigue.
16. CHANGES TO THIS POLICY
We reserve the right to modify these rules at any time, especially to adapt them to any changes made to our digital media, whether by providing new features, deleting or modifying existing ones, or by changing regulations and/or case law.
Therefore, it is important that you visit this Policy periodically, and thus be updated on possible changes that may be made.
17. HOW TO CONTACT US
To clarify any questions about this Privacy Policy or about the personal data we process, please contact our Personal Data Protection Officer via email: dpo@institutodatransformacao.com.br.
18. PRIVACY AND COOKIE POLICY
The Copyright of this Privacy Policy is owned by Erica Grellert, DPO Information Security Specialist at ITD.
Authorization for exclusive use on this website.
date: 09/07/2024