What your rights are and how to exercise them

Your Basic Rights.

You may request our Personal Data Officer to confirm the existence of Personal Data processing, and to display or rectify your Personal Data, through our Customer Service Channel.

Limitation, opposition and deletion of data.

Through the Customer Service Channel, you can also request:

• The limitation of the use of your Personal Data;
• express your opposition and/or revoke consent to the use of your Personal Data; or
• Request the deletion of your Personal Data that has been collected by Us.

If You withdraw Your consent for purposes essential to the regular operation of Our Environments and services, such environments and services may become unavailable to You.

Should You request the deletion of Your Personal Data, it may occur that the Data needs to be kept for a period longer than the request for deletion, pursuant to article 16 of the General Personal Data Protection Law, for (i) compliance with a legal or regulatory obligation, (ii) study by a research body, and (iii) transfer to a third party (subject to the data processing requirements set out in the same Law). In all cases by anonymizing Personal Data, provided that this is possible.

Upon expiration of the maintenance period and legal necessity, Personal Data will be deleted using secure disposal methods, or used in an anonymized form for statistical purposes.

Information about this policy

Change in content and update.

You acknowledge that We have the right to change the contents of this Policy at any time as necessary or appropriate, such as to conform to a provision of law or regulation having equivalent legal force, and You should check it each time You access Our Environments or use Our services.

If there are updates to this document that require new consent collection, You will be notified through the contact channels that You inform.

Should any part of this Policy be held to be unenforceable by a Data Authority or court, the remaining terms will remain in full force and effect.

Electronic Communication.

You acknowledge that all communication made by e-mail (to the addresses informed in your registration), SMS, instant communication applications or any other digital form, are also valid, effective and sufficient for the disclosure of any matter relating to the services we provide, your Data, as well as the conditions of its provision or any other subject addressed therein, being exception only what this Policy provides as such.

Service Channel.

If you have any questions regarding the provisions contained in this Privacy and Data Treatment Policy, you may contact [email protected].

A ESPM opta pela contratação de serviço gerenciado de Encarregado de Dados (DPO as a Service), contratado através do escritório Peck Advogados situado na Rua Henrique Schaumann, 270, CEP 05413-909, São Paulo, SP.

Applicable law and jurisdiction.

This Policy will be interpreted according to the Brazilian legislation, in the Portuguese language, and the jurisdiction of your domicile will be elected to settle any controversy involving this document, unless specific personal, territorial or functional competence is reserved by the applicable legislation.

Você, caso não possua domicílio no Brasil, e em razão dos serviços oferecidos por Nós apenas em território nacional, se submete à legislação brasileira, concordando, portanto, que em havendo litígio a ser solucionado, a ação deverá ser proposta no Foro da Comarca de São Paulo.

Glossary

For the purposes of this Policy, the following definitions and descriptions should be considered for better understanding:

Data:

Any information entered, processed or transmitted through Our Environments.

Personal Data:

Data related to an identified or identifiable natural person.

Anonymization:

Use of reasonable and available technical means at the time of Processing, whereby a data loses the possibility of association, directly or indirectly, with an individual.

Sensitive Personal Data:

personal data concerning racial or ethnic origin, religious conviction, political opinion, membership of a trade union or of a religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data when linked to a natural person.

Data Protection Officer (DPO):

Person appointed by Us to act as a communication channel between the controller, the data subjects and the National Data Protection Authority (ANPD).

Cloud Computing:

Cloud computing is a service virtualization technology built from the interconnection of more than one server through a common information network (e.g. the Internet), with the aim of reducing costs and increasing the availability of sustained services.

Our Environments:

It designates the electronic address https://www.espm.br/ and its subdomains.

Access Account:

Credential required to use or access the exclusive features of Our Environments.

Cookies:

Small files sent by Our Environments, saved on your devices, that store your preferences and little other information, with the purpose of personalizing your navigation according to your profile.

IP:

Abbreviation for Internet Protocol. It is an alphanumeric set that identifies the USERS ' devices on the Internet;

Logs:

Activity logs of any users who use Our Environments.

Session ID:

User session identification when accessing Our Environments.

Automated decisions only:

These are decisions affecting a user that have been programmed to work automatically, without the need for a human operation, based on automated processing of personal data.

Treatment:

Any operation carried out with Personal Data, such as those related to collection, production, receipt, classification, use, access, reproduction, transmission, distribution, processing, filing, storage, deletion, evaluation or control of the information, modification, communication, transfer, dissemination or extraction.