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Privacy, cookies and security terms
Founding attaches great importance to the confidentiality and security of your personal data.
The purpose of this Privacy Policy is to inform you in a clear, simple, and transparent way about the processing of personal data that you entrust to us, or that we may collect when you browse our website https://www.foundingcompany.com/ (hereinafter referred to as the "Site"), its possible transfer to third parties, and the rights and options you have to control your data and protect your privacy.
FOUNDING SISTEMAS E INFORMACOES LTDA (Trade Name: Founding), a private legal entity, with headquarters in São Paulo/SP, at Rua da Independência, Nº 715, Apt 146 Torre B, Bairro Cambuci, CEP 01524-001, registered with the C.N.P.J. under nº 37.969.819/0001-71, is the Controller of personal data collected on the Website within the meaning of the applicable personal data regulations and, in particular, Law 13.709/2018, known as the General Data Protection Law.
I. What is personal data?
Personal data is any information relating to an identified or identifiable natural person, for example, information that identifies you directly, such as your surname, first name, postal address, or e-mail, or indirectly, such as an order number or an IP address, among others.
II. Why does Founding collect my data?
Founding collects and processes your data to:
• Allow you to create an account on our Site;
• Manage access to your account on the Site;
• Manage payment for your order;
• Ensure delivery of contracted services;
• Ensure the security of online communications and transactions, and prevent fraud and payment incidents, in particular through the automated processing of your data;
• Manage member relationships in the context of information requests, complaints or any support request that you can send us through our website, through any functionality and, in particular, through chat.
• Manage and optimize customer experience through better knowledge of our members;
• Offer adapted and personalized services, particularly in the context of the development of our products and services;
• Perform statistical analyses to develop steering, measurement, and reporting tools to adapt and improve our commercial and marketing activities;
• Send communications and advertising or informational messages about our special offers and/or notices that you may be interested in;
• Communicate your data to our and AWS storage platforms, to prepare and send advertising adapted to your centers of interest;
• Send communication about order status or support request return;
• Prevent the occurrence of fraud, focusing on the security of Customers and the transactions or communications they carry out through the Founding website;
• Ensure the exercise of your data holder rights, by item IX below;
Founding informs that you can modify your choices regarding communication on the Site at any time, in a separate area.
III.When can we collect your data?
We may collect your data during:
• The creation of your customer account on our Site, either directly from you when filling out the account creation form on the Site, or, depending on your choice, through the Facebook, Apple ID or Google connection tool. This tool allows any holder of a Facebook, Apple ID or Google account to use their identification data provided to the social network to create an account on another website. When you register using your Facebook, Apple ID or Google account, you must give those platforms your consent to create the account. You can later change the amount of data that can be accessed by Founding, in accordance with the Facebook, Apple ID or Google terms of use.
• Carrying out plan contracting;
• Payment for your order;
• In general, in brand surveys, customer satisfaction surveys or redirection of commercial or marketing strategies, we collect the customer ID, among other data, observing our cookie policy and the necessary purpose of research and customer satisfaction . In some cases, other personal data may be collected at the time of the survey for the purpose of sending personalized promotions;
• An interaction with our company through its official page or via private message on social networks, or in your exchanges of messages with our Support via chat, telephone, WhatsApp, or email;
• Your participation in events we organize;
• Your browsing on our Website through cookies or similar technologies (hereinafter "Cookies" as defined in item XI - information on cookie management) or when you click on advertisements presented on our website;
• Carrying out activities related to our Possible Fraudulent Operations Detection Program.
IV.What personal data can we collect?
As part of our activities, we may collect some data directly from you for the purposes detailed in point II of this policy.
The information we collect is:
• The personal data you provide when creating your member account, such as your full name, email address, password and gender; your contact details, in particular your billing addresses, CNPJ of the credit card holder and their respective details at the time of purchase;
• Your personal preferences in relation to the way you interact with the system through your contracted plan, in particular your navigation and interaction (website, email or media);
• Information regarding your payment methods when you place an order on our Site.
• Important: Your banking data is never transmitted unencrypted on AWS servers and is not even stored on any Founding server, as we do not have one. Payments are made through a secure payment platform, compliant with the PCI-DSS standard, and complemented by control measures to ensure the security of purchases and combat fraud. Your bank card details communicated during your order never pass unencrypted on the network: they are encrypted using the TLS (Transport Layer Security) protocol.
• When you register your bank card details with our company, Founding does not store such data. This data is processed through a secure platform validated by your bank, through our partner Stripe. Founding cannot in any way reconstitute your bank card number. Additionally, we do not keep your bank card CVV (the 3 numbers on the back of your card).
• Information that you may need to provide to our Support in order to manage your requests for information or complaints;
• Your Google, Facebook or Apple ID profile data, such as your name and email address. You have the option of not transferring some of this data. To learn more, click "Modify this" in the Google, Facebook or Apple tool.
• To carry out activities related to our Possible Fraudulent Operations Detection Program, we may collect, by telephone or via SMS (Short Message Service), various proof of your identity or request ratification of your approval.
Finally, we may collect information related to the use of our Website, in particular your navigation (IP address, pages, services visited or searched, most accessed features, links clicked, etc.). Likewise, we may collect data relating to the query of emails we send for statistical and commercial prospecting purposes. Some of this information may be collected through Cookies placed on your terminal when you browse our Website. To find out more about Cookies, see item XI “information on cookie management” in this policy.
V. What are the legal grounds that legitimize the processing of your data
Founding processes your personal data on the following legal grounds:
• Execution of the contract: the processing of your data is necessary for the execution of the contract concluded between you and Founding and/or its partners when you make contact directly with them;
• Legitimate interest: Founding may have a legitimate interest in processing your personal data. This happens, for example, when Founding sends emails, push notifications, SMS or any form of advertising or informational communication, through its own media or paid media, advertising services to its members and other advertising messages related to its products and services, processes data to prevent and combat fraud on its Website or when analyzing its members' browsing to improve its services, carry out statistical studies on products and/or services and ensure the security of its digital media (websites, applications, etc.);
• Compliance with legal obligations: Founding may process personal data as part of compliance with its legal and regulatory obligations. This is the case of accounting treatment of your services;
• Consent: In some cases, Founding may process personal data with your express consent, which may be revoked at any time. In these cases, Founding will always inform you of the determined purposes of processing personal data and will collect your consent in a free, informed and unequivocal manner.
SAW.Who are the recipients of your personal data?
Your personal data is processed by Founding and its team. We ensure that only people authorized by Founding can access your personal data when this is necessary for the purposes of managing our business relationship or our legal obligations.
We may also be required to communicate your personal data to:
• Founding's commercial partners;
Subcontractors such as:
• Our hosting and maintenance service providers and our dematerialized solutions for collecting personal data;
• Our payment service providers and accounting companies, law firms;
• Our fraud prevention and anti-fraud providers;
• Our marketing solution providers;
• Our commercial prospecting and communication management providers via social networks;
• Our customer service providers;
Founding may also be required to communicate your personal data to third parties to comply with legal and regulatory obligations or respond to requests from legally authorized authorities.
VII.Transfer of personal data abroad
Personal data processed, in any way, due to your registration on the Founding website and use of its services, in accordance with the CGU, will be stored in Brazil under the responsibility of the foreign partner FOUNDING SISTEMAS E INFORMACOES LTDA.
Any international transfer of your personal data is subject to appropriate safeguards, including contractual, technical and organizational safeguards, in accordance with applicable personal data protection standards.
VIII.How long will we keep your data?
Until specific regulation by the National Data Protection Authority, in view of internationally recognized good practices, Founding will use the data retention periods previously defined by the company, which comply with the requirements of the General Data Protection Law (LGPD) and the statute of limitations for legal obligations. You will find below the different retention periods for your personal data in the active database:
IX.What are your rights and how do you exercise them?
In accordance with current regulations, in particular the General Data Protection Law (LGPD - Law 13,709/2018), you have the right, upon request to the Data Protection Officer, to request:
• Confirmation of the existence of treatment;
• Access to personal data;
• Correction of incomplete, inaccurate or outdated data;
• Anonymization, blocking or deletion of unnecessary, excessive or processed data that does not comply with the provisions of this Law;
• Data portability to another service or product provider, upon express request, in accordance with ANPD regulations;
• Revocation of consent and consequent deletion of personal data processed, except in the cases provided for in art. 16 of the LGPD;
• Information from public and private entities with which the controller shared data;
• Information about the possibility of not providing consent and the consequences of refusal
To request the exercise of any of the rights listed above, you can contact us through the following means:
The customer must send an email to vitor@founding.com containing the following information:
• Full name
• Telephone
• Email
• CPF
• Inform which of the rights listed above the customer intends to exercise
The data will only be changed or the account(s) deleted in relation to the registration location data provided by the customer.
The National Data Protection Authority has communication channels that can be found at the link: https://www.gov.br/anpd/pt-br/canais_atendimento/.
Founding may continue processing data if it has a legal basis for processing applicable to the specific case, such as, but without limit, compliance with legal obligations, execution of a contract, legitimate interests, among others.
X. Data Protection Officer (DPO) contact details and right to lodge a complaint
For any questions regarding the processing of your personal data by Founding, you can contact our data protection officer by email at the following address: vitor@founding.com
XI.Information about cookie management
This section aims to help you understand how our website uses cookies (or similar technology), the purpose of cookies and the options available to you as a user to manage or reject cookies. This policy may be subject to periodic updates.
XI.1.WHAT IS A COOKIE?
A cookie is an alphanumeric file that Founding can place on your terminal (computer, cell phone, iPhone, smartphone, tablet), subject to your choices, through your browser when you visit our website and/or our application.
There are different types of cookies, such as flash cookies, SDKs, pixels, the result of your terminal's fingerprint calculation (known as fingerprint), etc., (hereinafter referred to as Cookies).
These Cookies allow Founding, during their validity or registration period, to identify your terminal, fixed or mobile, during your next visits.
Only the issuer of a cookie can read or change the information it contains.
You will find below information regarding the Cookies that may be deposited on your terminal when you visit pages on our Website, whether by Founding or third parties, as well as the means that allow you to delete/refuse the registration of these cookies on your terminal.
XI.2. WHO CAN DEPOSIT COOKIES ON MY TERMINAL?
Cookies may be issued and deposited directly by Founding or its service providers. Others may be issued and/or deposited and/or read by partner companies.
XI.3. WHAT TYPES OF COOKIES DOES FOUNDING USE AND CAN THEY BE DEPOSITED ON MY TERMINAL?
Cookies can be classified according to different aspects. Thus, cookies can be classified based on:
Who sets them up and manages them. They can be:
• Own: those sent to You from a domain or team managed by the Founding;
• Third parties: are those that are sent to You from a computer or domain that is managed by an entity other than Founding.
Its duration. They can be:
• Sections: are those that expire when you leave our website;
• Persistent: are those that remain stored on your computer for a longer period of time, which can be from a few minutes to several years.
Its Purposes. They can be:
• Technical cookies: They are necessary for the correct functioning of our Website and the different services or functionalities that exist on it, such as controlling traffic and data communication, identifying the section, accessing restricted access parts or using security elements during navigation, among others.
• Analytical cookies: These inform us, for example, about the number of pages you visit, the location of access, the frequency and recurrence of visits, the duration of your visit, whether you opened a feature or purchased a product as a result of this communication, the browser or computer from which you are visiting, etc.
The information obtained from analytical cookies is used to:
• Measure the activity of our Website in order to carry out the corresponding internal analyzes that help us to understand the supply needs of our products, calculate the need for storage space and anticipate the management of these, as well as detect failures or unusual activities in our Site.
• Monitor and analyze the behavior of users of our Website in order to create user navigation profiles, with the aim of introducing improvements to our Website.
• Advertising cookies: These allow us to manage the advertising spaces where we publish advertisements for our products or services, both on our Website and, especially, on other web pages. These cookies allow companies like Founding to advertise their products or services on these web pages. web according to certain parameters, such as the content of the web page, the age of the visitors or the geographic area.
The use of advertising cookies also helps us monitor how often we impact our customers, and retargeting cookies helps us ensure that content may be of interest to them. Not accepting or deleting these cookies may result in you seeing content that is less relevant to you.
• Social network cookies: If you enter our Site through a social network, they may identify that you have entered the Site.
Some social networks offer advertisers (such as Founding) the opportunity to generate in their own environments personalized audiences of people using such social networks who visit the Site, in order to directly impact the environment of such third parties, offering them information, promotions , advertisements or advertising content that meet the interests of our users.
Furthermore, if you are logged in to any social network, it may capture information about your browsing on our website to use it in its own services, so we strongly recommend that all users read the privacy and cookie policies of the different social networks. , and especially that they establish appropriate privacy parameters.
You can obtain information on how to reject these types of cookies and/or activities later.
XI.4. WHAT CAN I DO IF I DO NOT AGREE TO THE INSTALLATION OF COOKIES?
You can do three things:
1. Block the installation of new cookies in your browser. Please note that if you block the installation of cookies, your browser will not allow any more cookies to be installed from that point onwards. However, this does not prevent you from continuing to have the cookies you already have installed on your terminal.
2. Delete the cookies you have already downloaded to your terminal: this way you delete the cookies you already have installed.
3. Use third-party cookie management systems or do not track
Please be aware that if you block the installation of cookies in your browser, it is possible that some of the sections or functionalities of our website will not function properly.
Additionally, please note that you will need to set your preferences in each different browser you use (blocking cookies in Google Chrome, for example, will not prevent cookies from being installed when you browse Mozilla Firefox, so we recommend that you set your preferences in every browser you use, even on mobile devices).
When you accepted Founding, you consented to cookies, but if you want to object to their installation or maintenance, there is no problem. You can block the installation and delete already installed cookies at any time through the procedures indicated in this policy
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